Justia Washington Supreme Court Opinion Summaries

Shawn Bell was charged with several violent crimes. During jury selection, the State used a peremptory challenge to exclude juror 39, prompting an objection from the defense under GR 37, which addresses potential racial or ethnic bias in jury selection. The prosecutor justified the challenge by claiming juror 39 was inattentive, while the defense argued that the COVID-19 mask requirement made it difficult for jurors to follow the questioning. The trial court denied the GR 37 objection, relying on the juror's admission of inattention and the judge's own observations. Bell was subsequently convicted.Bell appealed, and the Washington Court of Appeals reversed his convictions, finding that the trial court had violated GR 37 by allowing the peremptory challenge against juror 39. The appellate court concluded that the trial court's decision was incorrect and warranted a reversal of Bell's convictions.The Supreme Court of the State of Washington reviewed the case and held that a de novo standard of review is required for GR 37 objections. The court emphasized that the analysis must consider whether an objective observer could view race or ethnicity as a factor in the peremptory challenge. The court found that the trial judge's subjective impressions of juror 39's demeanor were insufficient to justify the challenge. The court also noted that similar responses from other jurors who were not challenged raised concerns about potential bias.The Supreme Court affirmed the Court of Appeals' decision, concluding that an objective observer could view race as a factor in the State's peremptory challenge against juror 39. The court reversed Bell's convictions and remanded the case for a new trial. View "State v. Bell" on Justia Law

The case involves the Citizen Action Defense Fund (Fund) requesting the initial offers for collective bargaining agreements (CBAs) from the Washington State Office of Financial Management (OFM) under the Public Records Act (PRA). The key issue is whether the deliberative process exemption under RCW 42.56.280 applies to these initial offers after the tentative CBAs have been signed by the parties and submitted to the OFM director but before they are signed by the governor or funded by the legislature.The Thurston County Superior Court found that OFM violated the PRA by withholding the records, ruling that the deliberative process exemption did not apply once the CBAs were signed by the state’s negotiation representative and the union. The Court of Appeals reversed this decision, holding that the records were still exempt because the CBAs had not been presented to the governor for approval or funded by the legislature, and thus were not yet final.The Supreme Court of the State of Washington reviewed the case and affirmed the Court of Appeals' decision. The court held that the deliberative process exemption continues to apply until the legislature has funded the CBAs. The court reasoned that the collective bargaining process is not complete until the final step in the statutorily required implementation process, which is the approval of funding by the legislature. Therefore, the deliberative process exemption protects the documents related to collective bargaining until the CBAs are funded by the legislature. View "Citizen Action Def. Fund v. Off. of Fin. Mgmt." on Justia Law

Travis Bearden, a firefighter and paramedic for the City of Ocean Shores, joined the U.S. Army Reserves in 2013. He took periodic absences for military service, receiving paid military leave from the city. The dispute centers on military leave Bearden took between 2019 and 2021. During his first and second leaves from October 2019 to August 2020, Bearden was kept on the schedule and provided paid military leave for his scheduled workdays until his paid leave was exhausted in February 2020. The city then placed him on leave without pay status. For his third leave from August 2020 to May 2021, the city did not provide Bearden any paid military leave for the October 2020-September 2021 military fiscal year, arguing he had no scheduled workdays.Bearden filed a complaint in federal court in January 2021, asserting the city violated the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) by denying him accrued leave, including paid military leave under RCW 38.40.060. The district court granted summary judgment to the defendants, concluding Bearden was not entitled to paid military leave during his third leave because he was not scheduled to work on any day during the October 2020-September 2021 military fiscal year. Bearden appealed, and the United States Court of Appeals for the Ninth Circuit certified a question to the Washington Supreme Court regarding the interpretation of Washington’s paid military leave statute.The Washington Supreme Court held that public employees are entitled to 21 days of paid military leave for required military service during each military fiscal year, regardless of whether they are scheduled to work by the employer due to the length of their military service absence. The court emphasized that the statute’s plain language and purpose support this entitlement, and the scheduling of workdays does not limit the annual entitlement to paid military leave. View "Bearden v. City of Ocean Shores" on Justia Law

The case involves a post-dismissal challenge to a trial court’s order that permanently sealed the petitioners’ actual names and allowed them to be identified by pseudonyms in court records. The petitioners, identified as John Does P, Q, R, and S, sought to prevent Thurston County from releasing unredacted sex offender records in response to a Public Records Act (PRA) request by Donna Zink. The trial court granted the Does’ motion for voluntary dismissal and entered a permanent order to maintain the use of pseudonyms and seal a court record listing their actual names.The trial court initially allowed the Does to proceed in pseudonym to preserve their ability to seek relief in their PRA injunction action. However, over the course of the litigation, nearly all of the Does’ PRA exemption claims were rejected, and Zink received most of the records she requested. The trial court’s preliminary orders allowing pseudonyms were based on the potential harm of being identified as sex offenders. On remand, the trial court granted the Does’ motion for voluntary dismissal and permanently sealed their names, citing compelling privacy and safety concerns.The Washington Supreme Court reviewed the case and held that the trial court abused its discretion in permanently sealing the Disclosure Document and allowing the Does to remain in pseudonym. The court found that the trial court’s findings were insufficient to satisfy GR 15 or the Ishikawa factors, which require specific and compelling reasons to restrict public access to court records. The court noted that the Does’ identities as sex offenders were already publicly available, and the trial court’s order did not articulate new compelling privacy or safety concerns. The Supreme Court remanded the case with instructions to unseal the Disclosure Document, use the Does’ actual names in future proceedings, and replace the pseudonyms in court records with their actual names. View "Doe P v. Thurston County" on Justia Law

Samantha Hall-Haught was involved in a head-on collision, leading to the discovery of drug paraphernalia in her vehicle. At the hospital, a state trooper observed signs of drug use and obtained a warrant to test her blood, which revealed the presence of THC. Hall-Haught was charged with vehicular assault, and at her trial, a lab supervisor testified about the blood test results instead of the technician who conducted the test. Hall-Haught objected, arguing that her right to confront the witness against her was violated.The trial court admitted the lab results, and Hall-Haught was convicted. She appealed, and the Washington Court of Appeals affirmed the conviction, reasoning that the supervisor's independent review and testimony did not violate the confrontation clause. The court relied on the precedent set in State v. Lui, which allowed expert witnesses to testify based on data prepared by others.The Supreme Court of Washington reviewed the case and reversed the Court of Appeals' decision. The court held that the confrontation clause was violated because the lab report was testimonial, and the technician who performed the test was the actual witness against Hall-Haught. The court emphasized that the supervisor's testimony, which relied on the technician's report, was admitted for its truth, thus implicating the confrontation clause. The court remanded the case for further proceedings consistent with this opinion. View "State v. Hall-Haught" on Justia Law

Cannabis Green, a company operating three cannabis retail stores in Spokane, Washington, was investigated by the Department of Labor & Industries (L&I) following a wage complaint by a former employee in January 2019. The employee alleged that Cannabis Green failed to pay her overtime for hours worked across all three stores. L&I's investigation revealed additional wage and hour violations affecting other employees. Despite requests for payroll records and work schedules, Cannabis Green did not fully comply, leading L&I to propose a settlement agreement in August 2021, which Cannabis Green rejected.The Spokane County Superior Court dismissed L&I's complaint, agreeing with Cannabis Green that L&I needed to issue a formal order directing the employer to pay a specific sum before filing suit. The Court of Appeals affirmed this decision, holding that L&I must determine and order the payment of wages owed before initiating legal action.The Supreme Court of the State of Washington reviewed the case and reversed the lower courts' decisions. The court held that while L&I must order an employer to pay wages owed before filing a lawsuit, the statute does not require a formal administrative order or a demand for a specific sum. The court found that L&I's proposed compliance agreement and related communications provided sufficient information to constitute an informal directive to Cannabis Green to address the alleged violations. The case was remanded to the trial court for further proceedings consistent with this opinion. If L&I prevails on remand, it is entitled to attorney fees. View "Department of Labor & Industries v. Cannabis Green, LLC" on Justia Law

Jeffrey Cockrum developed mesothelioma after working for Alcoa Inc. for several decades, where he was exposed to asbestos without adequate protective measures. Alcoa was aware of the dangers of asbestos and the potential for long-term health issues, but did not provide sufficient warnings or protections. Cockrum was diagnosed with mesothelioma in 2022 and subsequently filed a personal injury lawsuit against Howmet Aerospace, Inc., the corporate successor to Alcoa, claiming deliberate intent to injure by exposing him to asbestos.The superior court granted summary judgment in favor of Howmet, concluding that Cockrum could not meet the deliberate injury exception under Washington’s Industrial Insurance Act (IIA), which requires actual knowledge that injury was certain to occur. The Court of Appeals affirmed this decision, citing the precedent set in Walston v. Boeing Co., which held that employees could not sue for latent diseases like mesothelioma because they could not meet the required level of certainty.The Supreme Court of the State of Washington reviewed the case and overruled the Walston decision, recognizing it as incorrect and harmful. The court held that in cases of latent diseases, virtual certainty is sufficient to prove an employer’s actual knowledge that injury was certain to occur. This new standard does not alter the general requirement for immediate and visible injuries but is limited to latent disease cases. The court remanded the case to the trial court to determine summary judgment under the virtual certainty standard. View "Cockrum v. C.H. Murphy/Clark-Ullman, Inc." on Justia Law

Rajiv Sangha (landlord) rented a house to Jeremy Keen and Racheal Lomas (tenant) in 2021. In November 2023, the tenant stopped paying rent. In April 2024, the landlord served a 14-day notice to pay rent or vacate, but the tenant did not respond. In May 2024, the landlord commenced an unlawful detainer action, serving the tenant with a summons and complaint. The tenant faxed a written notice of appearance to the landlord, indicating their intention to be present at any court case or appearance. Despite this, the landlord moved for a default judgment due to the tenant's failure to file an answer by the specified date. The trial court granted the default judgment and issued a writ of restitution.The tenant received the motion for default and notice of hearing but was allegedly informed by the King County Superior Court Clerk’s Office that they did not need to attend the hearing. In July 2024, the trial court found the tenant in default for lack of answer and issued the default judgment and writ of restitution. The tenant retained counsel and moved to vacate the default judgment and quash the writ, arguing that default for an appearing tenant violated their statutory right to counsel and contradicted the statutory summons language requiring a show cause hearing. The trial court denied the motion, agreeing with the landlord that the Civil Rules required an answer and that the landlord had complied with statutory notice requirements.The Supreme Court of the State of Washington reviewed the case. The court held that RCW 59.18.365(3) precludes a default judgment against a tenant who appears but does not submit a written answer in an unlawful detainer action. The tenant’s written notice of appearance constituted a response to the summons, and the trial court erred in entering a default judgment based on the tenant’s failure to answer. The Supreme Court reversed the trial court’s entry of default and remanded the case for further proceedings. The landlord's request for appellate attorney fees was denied. View "Sangha v. Keen" on Justia Law

Frank Edward Stearns was stopped by police on suspicion of driving under the influence (DUI) after a 911 caller reported that he appeared drunk and was staggering in a parking lot. The caller described Stearns and his vehicle in detail. Officer Natalie BrinJones responded to the call, observed Stearns driving erratically, and eventually stopped him. Stearns exhibited signs of intoxication, and subsequent breath tests confirmed his blood alcohol content was over three times the legal limit.Stearns was charged with DUI, failure to obey a police officer, operating a vehicle without a required interlock device, and driving with a suspended license. He moved to suppress evidence from the stop, arguing it was not supported by reasonable suspicion. The district court denied the motion, finding reasonable suspicion for the stop. Stearns was convicted on all charges except driving with a suspended license. On appeal, the superior court reversed the convictions, ruling the stop was unlawful due to lack of reasonable suspicion. The Court of Appeals affirmed the superior court's decision.The Supreme Court of the State of Washington reviewed the case and held that the stop was lawful. The court found the 911 call reliable because it was a contemporaneous eyewitness report to the emergency line, and the officer's observations corroborated the caller's report. The court concluded that the caller's description of Stearns's behavior, combined with the officer's observations, provided a sufficient factual basis for reasonable suspicion of DUI. The Supreme Court reversed the Court of Appeals and reinstated Stearns's convictions. View "City of Wenatchee v. Stearns" on Justia Law

In 2022, the Washington State Legislature enacted ESSB 5078, which prohibits the manufacture, distribution, importation, and sale of firearm magazines capable of holding more than 10 rounds of ammunition. Gator’s Custom Guns Inc. continued to sell these large capacity magazines (LCMs) after the law went into effect. The Washington attorney general issued a civil investigative demand, and Gator’s filed a petition to set aside the demand, claiming ESSB 5078 violated the right to bear arms under the Washington Constitution and the Second Amendment. The State also filed a Consumer Protection Act enforcement action against Gator’s, and the cases were consolidated.The Cowlitz County Superior Court granted summary judgment in favor of Gator’s, finding ESSB 5078 unconstitutional under both the Washington Constitution and the Second Amendment. The State sought direct review by the Washington Supreme Court, which stayed the superior court’s ruling pending review.The Washington Supreme Court held that ESSB 5078 does not violate either the Washington or United States constitutional protections of the right to bear arms. The court determined that LCMs are not “arms” within the meaning of either constitutional provision and that the right to purchase LCMs is not necessary to the core right to possess a firearm for self-defense. Consequently, the court reversed the superior court’s ruling and remanded the case for further proceedings consistent with its opinion. The court also denied the State’s request for reassignment to another superior court. View "State v. Gator's Custom Guns, Inc." on Justia Law