Justia Washington Supreme Court Opinion Summaries

The respondent left threatening messages for a woman, destroyed another person’s bicycle, and assaulted that person with a sword. He was charged with several crimes, including first degree assault, malicious mischief, felony harassment, and theft. At trial, the jury found him guilty of second degree assault with a deadly weapon, felony harassment, and third degree theft. The respondent then requested a mental health sentencing alternative, asserting he had a serious mental illness and proposing an appropriate treatment plan. The sentencing judge granted this request, imposing 36 months of community custody and declining to order any confinement time on the deadly weapon sentencing enhancement.The State appealed this aspect of the sentence, arguing that the trial court was required to impose confinement time for the deadly weapon enhancement. The Washington Court of Appeals found that the relevant sentencing statutes were ambiguous. Applying the rule of lenity, the court affirmed the decision not to impose confinement time on the deadly weapon enhancement.The Supreme Court of the State of Washington reviewed whether the sentencing court was obligated to impose confinement time on the deadly weapon enhancement when a mental health sentencing alternative is imposed. The court held that, under the Sentencing Reform Act of 1981, a deadly weapon enhancement, once determined, is part of the standard range sentence. When a court imposes a mental health sentencing alternative, the entire standard range sentence, including the deadly weapon enhancement, must be waived. The court rejected the argument that the deadly weapon enhancement must always be imposed regardless of other statutes, and found that legislative intent and statutory context support waiving confinement in such circumstances. The Supreme Court of the State of Washington affirmed the decision of the Court of Appeals. View "State v. Perrin" on Justia Law

A first-year student at Washington State University died from acute alcohol intoxication during a fraternity hazing ritual organized by the Gamma Chi chapter of Alpha Tau Omega. The fraternity, recognized by the university, held the event at its off-campus “live-out,” where underage students were encouraged and permitted to consume large amounts of alcohol as part of an initiation. The university had a long-standing relationship with the fraternity, providing benefits, oversight, and requiring adherence to university policies aimed at preventing alcohol misuse and hazing. The university was aware of prior incidents involving Gamma Chi and other fraternities related to underage drinking and hazing, and had previously sanctioned fraternities for such conduct. However, the university did not disclose Gamma Chi’s disciplinary history to the student or his family before his death.After the student’s death, his parents, acting individually and as representatives of his estate, sued the university for negligence, arguing that the university’s failure to enforce its own rules contributed to their son’s death. The Superior Court for Whitman County granted summary judgment in favor of the university, concluding that it owed no duty of care to the student under any of the plaintiffs’ legal theories. The Washington State Court of Appeals reversed in part, holding that the university’s special relationship with the fraternity gave rise to a duty to protect the student from foreseeable harm under Restatement (Second) of Torts § 315(a), but rejected other theories of duty.The Supreme Court of the State of Washington affirmed the Court of Appeals. It held that, because of the university’s long-standing, formalized, and supervisory relationship with the fraternity, and its ability to control the fraternity’s conduct through recognition and sanctions, the university owed a duty to take reasonable steps to protect the student from foreseeable harm arising from the fraternity’s alcohol and hazing practices. The case was remanded for further proceedings. View "Martinez v. Wash. State Univ." on Justia Law

A group of caregivers lived and worked at adult family homes operated by AssureCare in Washington State. Their duties included assisting residents with daily activities, preparing meals, cleaning, and administrative tasks. The caregivers worked long hours, often exceeding 24-hour shifts, and their sleep, meal, and rest breaks were regularly interrupted by residents’ needs. In exchange for their work, they received a flat daily wage and room and board, with no additional compensation for overtime or breaks. AssureCare did not keep records regarding hours worked, breaks, or leave.The caregivers filed a lawsuit against AssureCare in 2023, alleging violations of the Washington Minimum Wage Act (MWA) and arguing that the statutory exemption for “live-in” workers under former RCW 49.46.010(3)(j) was unconstitutional. The Superior Court for King County initially denied the caregivers’ motion for partial summary judgment, finding insufficient evidence that their occupation was dangerous. After submitting additional expert evidence, the caregivers renewed their motion. The superior court then granted partial summary judgment, holding that the live-in exemption violated article I, section 12 of the Washington State Constitution, as it denied a fundamental right to health and safety protections under article II, section 35. The court found no reasonable grounds for the exemption and certified the ruling for immediate review.The Supreme Court of the State of Washington reviewed the case, considering only whether the live-in exemption violated the privileges and immunities clause of the state constitution. The court held that live-in caregiving at adult family homes is a dangerous occupation requiring statutory protections. The exemption granted a privilege to employers at the caregivers’ expense without reasonable grounds. The court affirmed the superior court’s grant of partial summary judgment, holding that former RCW 49.46.010(3)(j) is unconstitutional as applied to live-in caregivers at adult family homes. The case was remanded for further proceedings. View "Bolina v. AssureCare Adult Home LLC" on Justia Law

The Washington State Legislature enacted the Climate Commitment Act (CCA) in 2021 to address climate change by capping greenhouse gas emissions from major sources, such as large fuel suppliers. The CCA included a specific exemption for motor vehicle fuel or special fuel used exclusively for agricultural purposes, provided that the buyer supplies the seller with an exemption certificate. The Department of Ecology was tasked with adopting rules to implement this exemption and determining a method for expanding it to include fuels used for transporting agricultural products on public highways. Ecology promulgated rules in 2022 that allowed suppliers to claim the exemption if they could document, through an exemption certificate, that the fuel was used for agricultural purposes. Some suppliers began imposing surcharges on fuel, including fuel for agricultural purposes, to offset compliance costs.The Washington Farm Bureau (WFB) petitioned Ecology to create a more accessible exemption mechanism and a process for refunds of surcharges, but Ecology denied the petition, reasoning that existing guidance sufficed and it lacked authority to issue refunds. WFB then filed a petition for declaratory judgment and agency review under the Washington Administrative Procedure Act in the superior court, arguing that Ecology’s rule and denial of further rulemaking exceeded statutory authority and were arbitrary and capricious. The superior court dismissed WFB’s action with prejudice.On direct review, the Supreme Court of the State of Washington affirmed the superior court’s dismissal. The court held that Ecology’s rule was reasonably consistent with the statutory language and structure of the CCA, did not exceed Ecology’s statutory authority, and was not arbitrary or capricious. The court also found that Ecology’s denial of WFB’s petition for rulemaking was based on due consideration and within the agency’s discretion. The court affirmed that Ecology was not required to implement WFB’s preferred exemption method. View "Wash. Farm Bureau v. Dep't Of Ecology" on Justia Law

Several members of the public submitted requests to a large social media company seeking information about political advertisements displayed on its platforms to users in Washington State. The company did not dispute that its responses to these requests failed to comply with Washington’s Fair Campaign Practices Act (FCPA) and the law’s implementing regulations, as it did not provide all the required information. The State of Washington, through the Attorney General’s Office, filed suit against the company, alleging multiple violations of the FCPA’s disclosure requirements.The case was heard in King County Superior Court, where both sides moved for summary judgment. The trial court granted summary judgment for the State, holding the company liable for violating the FCPA, and imposed maximum statutory penalties for each advertisement for which the required information was not disclosed. The court found the violations to be intentional, trebled both the civil penalties and attorney fees, and granted an injunction. On appeal, the Washington Court of Appeals affirmed the trial court’s rulings on liability, statutory interpretation regarding penalty calculation, and the constitutionality of the penalty assessed.Before the Supreme Court of the State of Washington, the company argued that the FCPA’s disclosure requirements violate the First Amendment as applied, that the penalty was improperly calculated, and that the penalty violated the Eighth Amendment’s excessive fines clause. The Supreme Court, with no single majority opinion, affirmed the company’s liability under the FCPA, holding that the law as applied does not violate the First Amendment. The court also let the penalty judgment stand, as no majority view existed to reverse or modify it, and further held by a majority that the penalty does not violate the Eighth Amendment. Thus, the judgment of the Court of Appeals was affirmed, upholding both the liability finding and the civil penalty. View "State v. Meta Platforms, Inc." on Justia Law

An employee of King County’s Department of Natural Resources and Parks, who is Latino and uses hearing aids, raised concerns about bias in a hiring policy and subsequently experienced several adverse events at work. After expressing his concerns about discrimination, he was reprimanded, received letters of expectation, was placed on administrative leave, given a poor performance review, suspended without pay, and reassigned to a position with less responsibility. The employee claimed these actions were retaliatory and discriminatory under the Washington Law Against Discrimination.The employee filed suit in the Superior Court for discrimination based on race, ethnicity, and disability, as well as retaliation. At trial, the jury was instructed using a single instruction that combined pattern jury instructions for “adverse employment action” from both discrimination and retaliation claims. The jury found that the county did not discriminate, but did retaliate against the employee. King County appealed, arguing that the combined instruction was misleading. The Washington Court of Appeals agreed, finding the instruction erroneous and remanding for a new trial on the retaliation claim.The Supreme Court of the State of Washington reviewed whether the jury instruction combining two definitions of “adverse employment action” was misleading and, if so, whether it constituted reversible error. The court held that while the instruction was ambiguous and potentially misleading, King County failed to establish that it suffered prejudice as a result. The ambiguity did not lower the employee’s burden of proof or prevent the county from arguing its theory of the case. Therefore, the Supreme Court reversed the Court of Appeals’ decision and remanded for further proceedings on the remaining appellate issues. The main holding is that a misleading jury instruction warrants reversal only if the challenging party demonstrates prejudice, which was not shown here. View "Verduzco v. King County" on Justia Law

Two individuals, each with multiple convictions for driving under the influence (DUI) within seven years in Washington State, challenged a state law that temporarily prohibits people with such convictions from possessing firearms. Their applications for concealed carry permits were denied based on this statute, and they subsequently filed a declaratory judgment action, arguing that the law violated their rights under the Second Amendment. The statute in question allows individuals disarmed under this provision to petition for restoration of firearm rights after five years of law-abiding conduct.The Spokane County Superior Court denied the State’s motion for judgment on the pleadings but granted its request for further factual development, ruling that there were material issues of fact—specifically, whether either petitioner posed a credible threat to public safety. The trial court allowed the as-applied constitutional challenge to proceed, focusing on whether an individualized assessment of dangerousness was required under recent Supreme Court precedent.The Supreme Court of the State of Washington granted direct interlocutory review. It held that, under the Second Amendment, the state may temporarily disarm individuals convicted of multiple DUI offenses without requiring an individualized determination of dangerousness. The court examined the nation’s historical tradition of firearm regulation, finding that longstanding analogs support disarmament of groups with a proven risk of dangerous conduct, such as repeated DUI convictions. The court reasoned that the law at issue is justified by the legislature’s determination that recidivist drunk drivers pose a special danger of firearm misuse, and that such temporary restrictions are consistent with historical tradition. The court reversed the superior court’s decision and remanded with instructions to enter judgment on the pleadings in favor of the State. View "McLellan v. Brown" on Justia Law

The case concerned a Black defendant who was convicted of second-degree felony murder. During jury selection, the prosecution used a peremptory challenge to exclude juror 40, who was white and had selected “prefer not to answer” regarding gender on a questionnaire. This juror had expressed strong concerns about racial bias in law enforcement and the criminal justice system. Defense counsel objected to the State’s peremptory strike by citing General Rule 37 (GR 37), but specifically raised only an argument about gender identity discrimination, not race or ethnicity.At trial, the King County Superior Court allowed the State’s challenge, finding that juror 40’s political views and demeanor, not their (presumed) gender identity, were valid grounds for exclusion. On appeal, the Washington Court of Appeals affirmed the conviction, holding that defense counsel’s objection based on gender identity did not preserve a GR 37 claim related to race, and thus the trial court did not err.The Supreme Court of the State of Washington reviewed the case. It clarified that an objection to a peremptory strike under GR 37 can be preserved by simply invoking the rule, but in this instance, defense counsel undermined the objection by focusing solely on gender identity. However, the Supreme Court exercised its discretion to review the race discrimination claim, emphasizing the importance of addressing racial bias even if not properly preserved below.The Supreme Court held that the State failed to comply with GR 37(i) procedures by relying on uncorroborated demeanor-based justifications for its peremptory challenge, which could not be considered. While the State’s use of juror 40’s views on law enforcement as a justification was presumptively invalid under GR 37(h), the totality of circumstances rebutted this presumption. The court concluded that an objective observer could not view race as a factor in the State’s strike and affirmed the lower court’s decision. View "State v. Hogan" on Justia Law

The defendant was charged with multiple violations involving domestic violence protection orders, stalking, and criminal impersonation. During trial, after the State presented significant evidence, the defendant chose to waive his right to a jury trial and pleaded guilty to all counts, also admitting to facts supporting an aggravating factor. Before entering his guilty plea, the defendant had attempted to represent himself but ultimately decided against it after conferring with his attorney. The trial court conducted a full plea colloquy and found the plea was knowing, voluntary, and intelligent.At sentencing, the defendant informed the court he wished to withdraw his guilty plea, claiming it was involuntary due to ineffective assistance of counsel. His appointed attorney characterized the motion as a collateral attack and declined to argue it, so the trial court permitted the defendant to present the motion himself. The trial judge denied the motion, determining it lacked merit under the applicable standard for withdrawal before judgment. No new counsel was appointed. The court then sentenced the defendant. The Washington State Court of Appeals affirmed, holding that the trial court was not required to appoint substitute counsel or hold a hearing on the withdrawal motion if it found the defendant’s claims lacked merit.The Supreme Court of the State of Washington reviewed whether the defendant was completely denied counsel at a critical stage of the prosecution—specifically, during his motion to withdraw the guilty plea. The court held that, because the defendant’s counsel remained appointed and available, and there was no actual conflict of interest or deprivation of counsel, there was not a complete denial of counsel at a critical stage. The court affirmed the judgment of the Court of Appeals. View "State v. Korsakas" on Justia Law

A woman, A.H., went to the residence of Leif Buck, with whom she shares two children, to discuss a parenting plan. During the visit, Buck became physically aggressive, holding A.H. on the couch and dragging her across the floor. When A.H. stated she would call the sheriff, Buck took her cell phone from her pocket, which prevented her from immediately contacting authorities. A.H. then told Buck she would go to the sheriff’s office, to which Buck responded he would not be present when she returned. A.H. subsequently reported the incident to the sheriff’s office and sought medical attention.Buck was charged with, among other offenses, interfering with the reporting of domestic violence under RCW 9A.36.150. At trial in the Superior Court, the jury was instructed that it could convict Buck if it found he prevented or attempted to prevent A.H. from calling 911, obtaining medical assistance, or making a report to law enforcement. The jury found Buck guilty. On appeal to the Washington Court of Appeals, Division Three, Buck argued that the statute created an alternative means crime, requiring jury unanimity as to the specific means, and cited State v. Nonog, a Division One decision to this effect. Division Three disagreed, holding that the statute did not create alternative means, and affirmed the conviction.The Supreme Court of the State of Washington granted review to resolve conflicting appellate decisions. The Supreme Court held that RCW 9A.36.150(1)(b) defines a single crime—interfering with the reporting of domestic violence—and does not establish three alternative means based on the method of reporting. The Court reasoned that the statute focuses on the defendant’s conduct, not the actions of the victim or witness, and does not present distinct criminal acts. The Supreme Court affirmed Division Three’s decision and expressly overruled the contrary holding in Division One’s Nonog decision. View "State v. Buck" on Justia Law