City of Seattle v. Fuller, 300 P.3d 340

Fuller, charged in Seattle Municipal Court, was found guilty of obstructing a law officer and ordered to pay restitution alongside a suspended sentence and fine.
Fuller challenged municipal court authority to impose restitution, arguing RCW 9.92.060(2) and RCW 9.95.210(2) were amended in 1996 to restrict restitution to superior courts.
Superior Court rejected Fuller’s argument; Court of Appeals agreed that municipal court could impose restitution under RCW 35.20.010 and related statutes.
The 1996 amendments inserted the word 'superior' before 'court' in the restitution statutes, prompting questions about intended scope.
The majority conclude the amendments did not remove municipal courts’ restitution power; the dissent would limit restitution to superior courts under specific statutes.
The majority also relies on RCW 3.66.120/3.66.130 and RCW 9A.20.030 as supporting municipal authority to order restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do 1996 amendments strip municipal courts of restitution authority?	Fuller contends amendments limit to superior court.	Fuller argues legislature narrowed municipal power.	Amendments do not divest municipal courts.
May restitution be imposed by municipal courts in addition to a fine?	Restitution in addition to a fine is beyond municipal authority.	RCW 9A.20.030 allows restitution in lieu of a fine; separate statutory schemes apply.	Restitution in addition to a fine is permissible under appropriate statutes; the majority finds authority for municipal courts to impose restitution alongside fines.
What is the proper interpretive scope of RCW 9A.20.030 versus RCW 9.92.060/9.95.210 for municipal courts?	RCW 9A.20.030 applies to restitution in lieu of a fine for municipal courts post-1984.	RCW 9.92.060/9.95.210 confer restitution only on superior court, not general to limited jurisdictions.	RCW 9A.20.030 is general but separate from the increased specificity that limits RCW 9.92.060/9.95.210 to superior courts; municipal courts may have restitution authority through other statutes.

State v. Barnett, 36 Wn. App. 560 (1984) (restitution authorities and the relationship to fines)
City of Seattle v. Briggs, 109 Wn. App. 484 (2001) (concurrent jurisdiction and restitution powers in municipal courts)
Avlonitis v. Seattle Dist. Court, 97 Wn.2d 131 (1982) (concurrent jurisdiction and restitution authority for limited courts)
State ex rel. Willey v. Graham, 168 Wash. 340 (1932) (statutory application to all courts when language is non-discriminatory)
State v. Wicklund, 96 Wn.2d 798 (1982) (necessary powers and limits under concurrency statutes)
State v. Shannahan, 69 Wn. App. 512 (1993) (restitution in lieu of a fine; public policy considerations)