Justia Washington Supreme Court Opinion Summaries

In this case, the petitioner pleaded guilty in 2004 to multiple counts of theft of a firearm and theft in the first and second degree, receiving a sentence of 30 months’ confinement and legal financial obligations. While serving this sentence, the State obtained evidence implicating him in a murder, for which he later also pleaded guilty. He completed his sentence for the theft convictions but remained incarcerated for the murder conviction. In 2022, while still in prison, he moved to vacate his 2004 theft convictions.The Superior Court denied his motion, finding that the requisite period had not elapsed since his release from confinement, as required by RCW 9.94A.640(2)(e). On appeal, the Washington State Court of Appeals held that the statute required only that the necessary number of years had passed since release for the offenses sought to be vacated, not all offenses for which the individual is incarcerated. The Court of Appeals also determined that a court must consider evidence of rehabilitation before granting vacatur. The court affirmed the denial of the motion but without prejudice, allowing the petitioner to refile with evidence of rehabilitation.The Supreme Court of the State of Washington reviewed the case. The court held that RCW 9.94A.640 does not permit individuals to seek vacatur if they have never been released from confinement on all convictions, interpreting “release from full and partial confinement” to mean release from custody on all offenses. The court also held that applicants must present evidence of rehabilitation for a court to consider vacatur, in line with its prior decision in State v. Hawkins. The Supreme Court affirmed in part and reversed in part, remanding for further proceedings consistent with its opinion. View "State v. Abrams" on Justia Law

A patient received medical care at a hospital and was billed for those services. At the time, the patient’s income allegedly qualified her for financial assistance known as charity care under Washington law, which is designed to help low-income patients pay hospital bills. The hospital did not determine the patient’s eligibility for charity care before billing her and subsequently assigned the debt to a collection agency. The agency sued to collect the debt, obtained a judgment, and did not provide any information about the availability of charity care in its communications. The patient only learned about the program after judgment and was later granted a partial reduction by the hospital, but the collection agency refused to honor it, citing its policy against reductions after court judgment.The patient filed a class action against the collection agency in Skagit County Superior Court, alleging violations of the Washington Consumer Protection Act (CPA), the Collection Agency Act (CAA), and the federal Fair Debt Collection Practices Act (FDCPA). The case was removed to the United States District Court for the Western District of Washington. The district court dismissed some claims, including those under the CAA, and divided the remaining claims into “failure-to-screen” and “failure-to-notify” theories. The court dismissed the “failure-to-screen” theory, retained the “failure-to-notify” theory, and certified a question of state law to the Washington Supreme Court regarding whether the charity care notice requirements apply to collection agencies.The Supreme Court of the State of Washington held that the statutory requirement to give notice of charity care under RCW 70.170.060(8)(a) applies to collection agencies collecting hospital debt. The court explained that the policy and plain language of the statute require patients to be notified by all entities engaged in billing or collection, including collection agencies, and that the duty to provide notice passes to assignees of hospital debt. View "Preston v. SB&C, Ltd." on Justia Law

A worker at the Cherry Point oil refinery in Washington was regularly exposed to asbestos-containing insulation during his employment, which began in 1971. The insulation at issue was chosen, supplied, and installed by a subcontractor as part of the refinery’s original construction in the early 1970s. Decades after his exposure, the worker developed mesothelioma and died from the disease. His estate brought claims against numerous defendants, including the subcontractor, based on alleged asbestos exposure at the refinery.The Whatcom County Superior Court first granted summary judgment for the subcontractor, relying on Maxwell v. Atlantic Richfield Co., which held that Washington’s six-year construction statute of repose barred such claims. However, the court reconsidered and denied summary judgment after the Washington Court of Appeals issued Welch v. Brand Insulations, Inc., which found there were factual questions about whether the subcontractor’s activities were covered by the statute of repose. Due to conflicting appellate decisions, the Supreme Court of Washington granted direct review.The Supreme Court of the State of Washington held that claims against the subcontractor arising from its construction activities—specifically, its installation of asbestos insulation as part of constructing an improvement on real property—are barred by the construction statute of repose. However, the court held that claims based on the subcontractor’s independent role as a product seller or supplier, separate from its construction activities, are not barred by the statute of repose. The court affirmed in part, reversed in part, and remanded the case for further proceedings to determine which claims, if any, survive under theories of product seller or supplier liability. The court declined to address the constitutionality of the statute of repose, as that issue was not timely raised. View "Polinder v. Aecom Energy & Constr., Inc." on Justia Law

A homeowner obtained a home equity line of credit (HELOC) secured by a deed of trust, subsequently defaulted, and faced nonjudicial foreclosure initiated by a party claiming to be the beneficiary. The loan servicer, acting on behalf of the claimed beneficiary, executed a declaration asserting that the beneficiary was the “holder” of the HELOC agreement, as required by Washington’s Deed of Trust Act (DTA) for nonjudicial foreclosure. The homeowner challenged the foreclosure in federal court, arguing that a HELOC is not a negotiable instrument and, therefore, the entity seeking foreclosure could not be its “holder” as contemplated by the DTA.In the United States District Court for the Western District of Washington, the homeowner’s quiet title and some statutory claims were dismissed, but other claims were allowed to proceed. Recognizing that state law questions were central and unresolved, the district court certified two questions to the Supreme Court of the State of Washington: (1) whether a typical HELOC is a negotiable instrument under Article 3 of the Uniform Commercial Code, and (2) whether a party claiming to be a beneficiary can satisfy the DTA’s “holder” requirement by declaring it holds a HELOC agreement.The Supreme Court of the State of Washington held that a HELOC agreement, as described, is not a negotiable instrument because it does not contain an unconditional promise to pay a fixed amount of money. The court further held that under the DTA, “holder” means the holder of a negotiable instrument as defined by Article 3 of the UCC. Therefore, a party cannot fulfill the DTA’s proof-of-beneficiary requirement for nonjudicial foreclosure simply by declaring it is the holder of a nonnegotiable HELOC agreement. This does not preclude judicial remedies, but nonjudicial foreclosure is unavailable in such circumstances. View "Vargas v. RRA CP Opportunity Tr. 1" on Justia Law

Several former foster children brought lawsuits against the State of Washington, alleging that the State negligently placed them in foster homes where they suffered abuse and failed to adequately investigate reports of abuse. To support their claims, the plaintiffs requested discovery of various records from the Department of Children, Youth, and Families (DCYF), including their own child welfare records, records about their biological and foster families, reports of abuse, and information about other children placed with the same foster parents. These records were sought to show whether the State breached its duty to protect them.In response, the State asserted that disclosure of these records was barred by statutory privilege under RCW 74.04.060(1)(a) and by confidentiality requirements under RCW 13.50.100. The State moved for protective orders in the trial courts, but the trial courts denied the State’s motions, ordered the requested records produced (with redaction and protective orders to limit their use), and specified procedures to maintain confidentiality. The State sought discretionary review, and the Supreme Court of the State of Washington granted review, consolidating the cases and staying the trial courts’ orders pending its decision.The Supreme Court of the State of Washington held that while the records sought by the plaintiffs are privileged under RCW 74.04.060(1)(a), an exception in the statute applies because these lawsuits directly concern the administration of the foster care program. Therefore, the privilege does not prevent disclosure. The court also held that RCW 13.50.100 does not bar disclosure of the requested records, as the information pertains to the plaintiffs. The court affirmed the trial courts’ orders compelling discovery, denied the plaintiffs’ request for attorney fees and costs, and remanded for further proceedings. View "J.M.I. v. State" on Justia Law

After severely assaulting his mother in December 2017 and causing serious injuries, Akeel Bin-Bellah was charged by the State of Washington with first degree assault. In plea negotiations, the State agreed to reduce the original charge and, in a global agreement that also resolved an unrelated robbery case, Bin-Bellah pleaded guilty to one count of second degree assault and three counts of fourth degree assault, all relating to the same incident. As part of his plea, Bin-Bellah expressly stipulated that each count of assault represented a separate and distinct act, and acknowledged that his plea was knowing and voluntary. The plea arrangement substantially reduced his potential sentence compared to the original charges.Following sentencing in King County Superior Court, Bin-Bellah filed a motion for relief, contending that his multiple assault convictions violated double jeopardy because they all arose from a single criminal act. This motion was transferred to the Washington Court of Appeals, Division One, which granted his personal restraint petition. The Court of Appeals concluded that the record showed only one criminal act, found a double jeopardy violation, vacated the three fourth degree assault convictions, and remanded for resentencing on the remaining count.The Supreme Court of the State of Washington reviewed the case after granting discretionary review. The Supreme Court reversed the Court of Appeals. It held that under Washington’s flexible plea bargaining framework, a defendant may knowingly and voluntarily plead guilty to multiple lesser charges—even if they are legally or factually duplicative—so long as there is a factual basis for the original charge and the plea includes explicit factual stipulations to support the convictions. Because Bin-Bellah’s plea included such stipulations and was knowing and voluntary, his double jeopardy claim was foreclosed. The Supreme Court reinstated all his convictions and dismissed his personal restraint petition. View "In re Pers. Restraint of Bin-Bellah" on Justia Law

An Irish company leased two airplanes to an Indian airline under agreements designating English courts as the forum for resolving disputes. After the airline failed to keep up with lease payments, the lessor sued in England and secured a monetary judgment. Seeking to enforce that judgment in Washington, the lessor filed a recognition action in King County Superior Court, claiming the airline had interests in personal property within the state but did not identify specific assets.The airline challenged the action in King County Superior Court, arguing that the court lacked personal jurisdiction because it had no contacts, assets, or business in Washington. The superior court denied the airline’s motion to dismiss, holding that jurisdiction was not required to recognize a foreign-country judgment under Washington’s Uniform Foreign-Country Money Judgments Recognition Act. The court ultimately entered summary judgment recognizing the English judgment and ordering payment. The Court of Appeals affirmed, concluding that neither statute nor constitutional law required the creditor to show personal jurisdiction or a property nexus for recognition of such a judgment.The Supreme Court of the State of Washington granted review and reversed the lower courts. The court held that, under chapter 6.40A RCW, a judgment creditor must establish either general or specific jurisdiction over the debtor or, in the absence of such jurisdiction, demonstrate that the debtor has property within Washington before a foreign-country money judgment may be recognized. The court found that recognition actions under the Act are not purely ministerial and require adjudicative jurisdiction. The Supreme Court remanded the case for further proceedings to determine whether the debtor has property in Washington sufficient to support jurisdiction. View "Alterna Aircraft V B Ltd. v. SpiceJet Ltd." on Justia Law

A consumer purchased a pair of leggings from a national retailer’s website at an advertised sale price of $6.00, which was displayed alongside a struck-out “regular price” of $12.50. The consumer believed, based on the website’s representations, that the leggings were normally sold at $12.50 and that the $6.00 price reflected a genuine discount. After purchasing and collecting the leggings, the consumer learned that the “regular price” was rarely charged and alleged that the higher reference price was misleading. She brought a putative class action in the United States District Court for the Eastern District of Washington, claiming that the retailer’s “false discounting” scheme violated the Washington Consumer Protection Act (CPA). She alleged three forms of injury: that she would not have purchased the leggings but for the misrepresentation (“purchase price” theory), that she did not receive the benefit of the bargain, and that she paid an inflated price due to artificially increased demand (“price premium” theory).The district court dismissed the complaint with prejudice under Federal Rule of Civil Procedure 12(b)(6), finding that, although deceptive conduct was sufficiently alleged, the consumer failed to allege injury cognizable under the CPA. The court reasoned that she did not claim the leggings were worth less than the $6.00 paid or differed from what was advertised, but only that they were not worth the higher reference price.On appeal, the United States Court of Appeals for the Ninth Circuit found Washington law unclear on whether the consumer’s allegations constituted an injury to “business or property” under the CPA and certified the question to the Supreme Court of the State of Washington. The Washington Supreme Court held that, without more, a consumer who receives and retains a fungible product at the price she agreed to pay, but was influenced by a misrepresentation about price history, does not allege a cognizable injury to business or property under the CPA. The court clarified that subjective disappointment or being misled into believing one obtained a bargain does not amount to an objective economic loss as required by the statute. View "Montes v. SPARC Group LLC" on Justia Law

A woman was found dead in a Seattle park in 1998. The victim, who worked as a sex worker, had been strangled, sexually assaulted, and robbed. DNA evidence from the crime scene went unmatched for several years until, in 2004, it was linked to John Ray Stearns, who was serving time for another offense. Although probable cause existed at that time, charges were not filed until 2016. At trial, the State introduced evidence of two prior sexual assaults committed by Mr. Stearns, arguing these acts were sufficiently similar to show a common scheme or plan and to rebut his claim of consent.Following a first trial that ended in a hung jury, Mr. Stearns was convicted at retrial in King County Superior Court. On appeal, Division One of the Washington Court of Appeals initially reversed the conviction on the grounds of preaccusatorial delay but, after the Washington Supreme Court reversed and remanded, the Court of Appeals addressed remaining issues. The appellate court concluded that the trial court erred by admitting evidence of prior bad acts under the common scheme or plan exception to ER 404(b) and reversed in part.The Supreme Court of the State of Washington reviewed whether the trial court abused its discretion in admitting evidence of prior sexual assaults. The court held that the trial court did not abuse its discretion: the prior acts were markedly similar to the charged crime, and the victims and circumstances were sufficiently similar to support admission under the common scheme or plan exception. The Supreme Court clarified that the test does not require markedly similar victims, only sufficient similarities in acts and circumstances. The court also found no abuse of discretion in the trial court’s prejudice analysis. The Supreme Court reversed the Court of Appeals and reinstated Mr. Stearns’ conviction. View "State v. Stearns" on Justia Law

This case involves a defendant who was charged with four counts of rape involving three victims. Each victim testified that they did not consent to sexual activity with the defendant, and their decisions to report the assaults were interconnected—one victim’s report influenced another’s decision to come forward, and the relationships among the victims were relevant to the timing and manner of their disclosures. The defendant maintained that all sexual encounters were consensual.Before trial, the defendant repeatedly moved to sever the charges into separate trials, arguing that joinder would unfairly prejudice him. The Superior Court for Snohomish County denied these motions, finding that the charges were properly joined because they were of the same or similar character and involved related events and witnesses. The court determined that the evidence on each count was similarly strong, that the defenses were clear and substantially the same, that the jury could be properly instructed to consider each count separately, and that much of the evidence would be cross-admissible due to the interconnectedness of the victims and their reports. The jury convicted the defendant on all counts.The Washington Court of Appeals reversed the convictions, holding that the trial court abused its discretion by not severing the charges. On review, the Supreme Court of the State of Washington applied the abuse of discretion standard and concluded that the trial court had properly weighed the relevant factors. The Supreme Court held that, while not all evidence would have been cross-admissible in separate trials, the prejudice did not outweigh the benefits of joinder given the overlapping witnesses and related circumstances. Therefore, the Supreme Court reversed the Court of Appeals and remanded for further proceedings consistent with its opinion. View "State v. Krause" on Justia Law