Ehsani v. McCullough Family Partnership

¶[1 Under RAP 12.8, a trial court judgment debtor who has satisfied the judgment against him may be entitled to restitution following a successful appeal. However, such restitution is warranted only in “appropriate circumstances.”1 In accordance with the common law of restitution, as set forth in the Restatement of Restitution § 74 (1937), such circumstances do not include restitution from nonparties to the judgment, as was sought in this case. An attorney who receives funds into his client trust account, pursuant to a favorable trial court judgment, then disburses those funds as his client…