State v. Gray, 174 Wash. 2d 920

The State sought restitution at sentencing; the VAU calculated an amount after the hearing.
CVCP expenses for Hikila’s funeral were initially ordered reimbursed in 2009 ($6,730.82).
In 2010, Hikila’s family reported additional unreimbursed funeral costs totaling $15,253.32.
The State moved to modify the restitution order under RCW 9.94A.753(4) to include the new costs.
Gray did not dispute the modification amount but challenged timeliness under the 180-day deadline.
Division One affirmed, and the Washington Supreme Court granted review to address interpretive scope of RCW 9.94A.753(4).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does RCW 9.94A.753(4) authorize modification beyond 180 days for prior expenses?	Gray: plain period limits prevail; no beyond-180-day modification.	State: text unambiguously allows modification during jurisdictional period.	Yes; plain text permits modification beyond 180 days.
Do Gray’s broader policy arguments overcome the plain text?	Gray: finality and strict construction limit modification.	State: finality is not absolute; victims’ and accountability goals support modification.	No; policy arguments do not defeat the statutory text.

Gonzalez v. State, 168 Wn.2d 256 (Wash. 2010) (modification of total restitution amount permitted when needed to cover victim costs)
State v. Burns, 159 Wn. App. 74 (Wash. App. 2010) (distinguishes cases where there is no restitution to modify)
State v. Griffith, 164 Wn.2d 960 (Wash. 2008) (remand for new restitution hearing; discussing limits of evidence and restitution orders)
State v. Halsey, 140 Wn. App. 313 (Wash. App. 2007) (modification allowed during the jurisdiction period when necessary)
State v. Krall, 125 Wn.2d 146 (Wash. 1994) (timeliness and discretion in restitution determination and modification)