* State of Washington, Respondent v. Patricia M. Teafatiller, Appellant

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IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON
DIVISION II
STATE OF WASHINGTON, No. 58219-8-II
Respondent,
v.
PATRICIA MINAKO TEAFATILLER, PUBLISHED OPINION
Appellant.
GLASGOW, J.—After she was released from prison, Patricia Teafatiller moved to waive all
remaining interest on her fully paid legal financial obligations and restitution. She also sought a
refund of the interest payments already made while she was incarcerated. The trial court entered
an order finding that Teafatiller had paid the principal balance of legal financial obligations and
restitution in full, and the court waived all remaining interest on both. The trial court also found
that there was no established funding or any mechanism for refunding interest amounts already
paid, and the trial court denied that portion of Teafatiller’s motion.
Teafatiller appeals the portion of the trial court’s order denying her motion for a refund.
She argues that the trial court failed to exercise its discretion. We disagree and affirm.
FACTS
After completing her prison sentence, Teafatiller filed a motion to waive remaining interest
on her fully paid legal financial obligations and restitution that were ordered as part of her 1996
Filed
Washington State
Court of Appeals
Division Two
June 25, 2024
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58219-8-II
2
judgment and sentence. Teafatiller also requested that the court refund the $1,519.11 in interest
she had already paid. The trial court initially granted Teafatiller’s motion in full.
Approximately two weeks later, the trial court, on its own motion, issued an order vacating
the portion of its previous order that granted Teafatiller’s request for a refund of interest already
paid. When Teafatiller inquired as to who requested review of the original order, the trial court
responded, “After entry of the order, the clerk made the court aware that the order, as written, was
unenforceable. This is because the clerk cannot refund already paid interest. Further, the process
developed between the court and the [prosecuting attorney’s] office was not followed.” Clerk’s
Papers (CP) at 76-77.
Teafatiller filed a motion for reconsideration. The trial court held a hearing and heard
argument from Teafatiller’s counsel. After taking the issue under advisement, the trial court
ultimately entered an order waiving the remaining interest, but the trial court denied Teafatiller’s
request for a refund of the interest she had already paid. The trial court explained:
The court finds it has discretion to refund the interest amount already paid. The
court further finds that while it may be consistent with legislative policy to refund
those payments to the Defendant as of this writing, the State has not established a
mechanism for doing so. Local county clerks have no funds to reimburse.
CP at 104-05.
Teafatiller appeals.
ANALYSIS
Teafatiller argues that the trial court’s order denying her request for a refund of already-
paid interest must be reversed because the trial court failed to exercise its discretion. We disagree.
Teafatiller likens this case to State v. Grayson where the Washington Supreme Court held
that the categorical refusal to consider an exceptional sentence is reversible error. 154 Wn.2d 333,
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58219-8-II
3
342, 111 P.3d 1183 (2005). But Grayson is distinguishable. Defendants are entitled to ask the trial
court to consider an exceptional sentence below the standard range and have it actually considered
according to the standards set forth in the Sentencing Reform Act of 1981, ch. 9.94A RCW. State
v. Garcia-Martinez, 88 Wn. App. 322, 329, 944 P.2d 1104 (1997). Unlike an exceptional sentence,
there is currently no statute or law establishing a defendant’s right to request a refund of interest
payments or requiring the trial court to consider such a request. Rather, the law specifically
provides, “Nothing in this act requires the courts to refund or reimburse amounts previously paid
towards legal financial obligations or interest on legal financial obligations.” LAWS OF 2018, ch.
269, § 20; LAWS OF 2022, ch. 260, § 25; LAWS OF 2023, ch. 449, § 22.
Moreover, Teafatiller’s characterization of the trial court’s decision as a failure to exercise
its discretion is misplaced. Teafatiller is correct that nothing in the relevant statutes expressly
prohibits trial courts from granting a request to refund interest already paid on legal financial
obligations or restitution. But the trial court considered her request for a refund, considered the
current legislative policy surrounding legal financial obligations for indigent defendants, and
decided not to grant a refund where no legislative mechanism or funding to do so exists. The
legislature could choose to fund refunds of interest already paid on legal financial obligations
and/or restitution, but until it does, recognition that ordering a refund would place a financial
burden on the county is a legitimate consideration absent a constitutional or statutory entitlement
to a refund. The trial court did not fail to exercise its discretion, and it did not err when it declined
to order a refund in this case.
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CONCLUSION
We affirm.
GLASGOW, J.
We concur:
MAXA, P.J.
PRICE, J.
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