State v. Cosgaya-Alvarez, 172 Wash. App. 785

Cosgaya-Alvarez pleaded guilty to second-degree murder and agreed to restitution in full to the victims.
The State proposed restitution including $100,200 to Crystal Morgan for child support of two children.
The court also ordered other restitution: $4,743.19 to Lorena Mendez and $13,761.61 to the Crime Victims Compensation Program.
Defense conceded the court had authority to order restitution for the child-support obligation but contested the amount.
The court rejected a defense proposal to discount the child-support amount, ultimately ordering $100,200 for Morgan.
Cosgaya-Alvarez appeals, arguing lack of authority and abuse of discretion in the restitution amount; the court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Authority to order child-support restitution	Cosgaya-Alvarez argues no statutory authority.	State contends authority exists and waiver may apply.	Court has statutory authority to order restitution for court-ordered child support.
Calculation of child-support restitution	Cosgaya-Alvarez contends present-value/annuity should reduce the amount.	State contends amount is properly calculated as easily ascertainable loss; discretionary range.	Court did not abuse discretion; amount supported by easily ascertainable damages and evidence.

State v. Young, 63 Wn. App. 324, 818 P.2d 1375 ((1991)) (child-support restitution authority when reduced to judgment)
State v. Tobin, 161 Wn.2d 517, 166 P.3d 1167 ((2007)) (restitution statutory authority and calculation standards)
State v. Davison, 116 Wn.2d 917, 809 P.2d 1374 ((1991)) (broad interpretation of restitution statute)
State v. Kinneman, 155 Wn.2d 272, 119 P.3d 350 ((2005)) (restitution framework and double damages cap)
State v. Young, 63 Wn. App. 324, 818 P.2d 1375 ((1991)) (restitution for future child support; Barr relied on)
State v. Barr, 99 Wn.2d 75, 658 P.2d 1247 ((1983)) (future child-support restitution for death-related crime)