Justia Washington Supreme Court Opinion Summaries

Charles Scott Frazier was convicted of murder and arson against his father in 1989 and received a 50-year exceptional sentence. Nearly 30 years later, Frazier sought resentencing, citing new scientific evidence on adolescent brain development, arguing that this evidence should exempt his personal restraint petition (PRP) from the one-year time limit under RCW 10.73.100(1).The superior court transferred Frazier's motion to the Court of Appeals, which dismissed his PRP as time-barred. Frazier then sought discretionary review from the Washington Supreme Court, which granted review solely on the issue of newly discovered evidence.The Washington Supreme Court reaffirmed that the newly discovered evidence exemption can apply to sentencing evidence, including new scientific developments. However, the court emphasized that petitioners must show they acted with reasonable diligence in discovering the evidence and filing the petition, and must satisfy the five-factor test for newly discovered evidence.In Frazier's case, the court found that he did not act with reasonable diligence. Although modern scientific studies on adolescent neurodevelopment were cited as early as 2005, Frazier did not file his collateral attack until 2018. The court noted that Frazier did not provide evidence of any diligent efforts to discover the new scientific studies and file his PRP.Additionally, the court found that Frazier did not satisfy the five-factor test for newly discovered evidence. The court concluded that the new studies on adolescent brain development would not probably change the result of Frazier's sentencing, as his exceptional sentence was based on findings of cruelty and abuse of trust, which were well-supported by the record.Therefore, the Washington Supreme Court affirmed the Court of Appeals' dismissal of Frazier's PRP as time-barred. View "In re Pers. Restraint of Frazier" on Justia Law

Jim Walsh, a member of the Washington State House of Representatives, along with other appellants, submitted six initiatives to the legislature. Three of these initiatives were enacted, while the remaining three—repealing the Washington Climate Commitment Act, repealing the state’s capital gains tax, and making participation in the state’s long-term care insurance program optional—were set to appear on the November 2024 ballot. The appellants sought to prevent public investment impact disclosures from appearing on the ballot, arguing that these disclosures were not warranted.The Thurston County Superior Court denied the appellants' request for writs of mandamus and prohibition, dismissing their complaint. The court found that the capital gains tax was not impliedly repealed by another initiative and that the other two initiatives did indeed modify a "tax or fee," thus requiring public investment impact disclosures. The appellants then appealed directly to the Supreme Court of the State of Washington.The Supreme Court of the State of Washington affirmed the lower court's decision. The court held that the writs of prohibition and mandamus were not appropriate in this case. The attorney general and the secretary of state were acting within their jurisdiction and statutory obligations. The court also noted that the appellants had not demonstrated the absence of a plain, speedy, and adequate remedy in the ordinary course of legal proceedings. Therefore, the trial court's denial of relief and dismissal of the case were upheld. View "Walsh v. Hobbs" on Justia Law

On June 3, 2017, Deputy Alexander Hawley of the King County Sheriff’s Office conducted an illegal stop of Malcolm Otha McGee, suspecting a drug transaction. During the stop, Hawley obtained McGee’s identity, phone number, and seized drugs. McGee agreed to become a confidential informant but never followed up. The next day, a 911 caller reported gunfire, and a month later, the body of Keith Ayson, who had a drug dealing relationship with McGee, was found. Police used evidence from the illegal stop to obtain warrants for McGee’s phone records, which linked him to the crime scene.The trial court ruled the June 3 stop was illegal and suppressed the drug evidence, dismissing the drug charge. However, it allowed the State to use evidence from the stop to establish McGee’s motive for murder. McGee’s first trial ended in a mistrial. Before the second trial, McGee moved to suppress evidence obtained from subsequent warrants, arguing they were based on the illegal stop. The trial court denied the motion, finding the evidence was sufficiently attenuated from the illegal stop. McGee was convicted of second-degree murder and sentenced to 298 months plus a 60-month firearm enhancement.The Washington State Court of Appeals reversed McGee’s conviction, holding that the evidence obtained from the illegal stop should have been suppressed, as it was not sufficiently attenuated. The court found that subsequent warrants relied on tainted evidence, necessitating suppression of all derived evidence and McGee’s statements to police.The Washington Supreme Court affirmed the Court of Appeals, holding that the attenuation doctrine did not apply because the new criminal act did not sever the causal connection between the illegal stop and the discovery of evidence. The court emphasized the strong privacy protections under the Washington State Constitution and rejected the State’s argument to expand the attenuation doctrine. The case was remanded for a new trial. View "State v. McGee" on Justia Law

A group of 16 related LLCs, which generate all their income from investments in distressed debt instruments, sought a refund for business and occupation (B&O) taxes paid, claiming their income was deductible as "investment income" under RCW 82.04.4281. The statute allows deductions for "amounts derived from investments," but does not define "investments." The LLCs argued that their income qualified for this deduction.The Washington State Department of Revenue audited the LLCs and denied their refund claim. The LLCs challenged this decision in superior court. The superior court granted summary judgment for the Department, ruling that the legislature did not change the definition of "investments" when it amended the statute in 2002. The court relied on the precedent set in O’Leary v. Department of Revenue, which defined "investments" as "incidental investments of surplus funds." The LLCs' motion for reconsideration was denied.The LLCs appealed, and the Court of Appeals affirmed the superior court's decision. The appellate court found that the legislature did not intend to abrogate the O’Leary definition when it amended the statute. The LLCs then petitioned for review by the Washington Supreme Court.The Washington Supreme Court held that the legislature did not abrogate the O’Leary definition of "investments" when it amended RCW 82.04.4281. The court found no clear legislative intent to change the definition, noting that the amendments were primarily aimed at addressing issues raised by the Simpson decision and the ambiguous phrase "other financial businesses." Consequently, the court affirmed that "investments" continues to mean "incidental investment of surplus funds," and the LLCs could not deduct income earned from their primary business activities. The trial court and the Court of Appeals' decisions were affirmed. View "Antio, LLC v. Dep't of Revenue" on Justia Law

Lorna Smith, an appointed member of the Washington Fish and Wildlife (WFW) Commission, also held an appointed position on the Jefferson County Planning Commission. The U.S. Sportsmen’s Alliance Foundation, along with Marc Nelson and Kolby Schafer, filed a lawsuit against Smith, arguing that RCW 77.04.040 prohibits her from holding both positions simultaneously. The statute states that members of the WFW Commission cannot hold another state, county, or municipal elective or appointive office. Smith conceded that her position on the county planning commission is a county appointive position but disputed that it qualifies as an "office" under the statute.The Thurston County Superior Court reviewed the case and both parties moved for summary judgment. The court ruled in favor of the plaintiffs, determining that the planning commission position is indeed a county appointive office under RCW 77.04.040. Consequently, the court granted the plaintiffs' motion for summary judgment and ordered Smith to resign from her position on the county planning commission. Smith sought direct review of this decision, and Governor Jay Inslee filed an amicus brief supporting her.The Supreme Court of the State of Washington reviewed the case de novo, focusing on the statutory interpretation of the term "office" in RCW 77.04.040. The court concluded that the term "office" refers to a position of authority, duty, or responsibility conferred by a governmental authority for a public purpose or to exercise a public function. Applying this definition, the court held that the Jefferson County Planning Commission is an "office" under the statute. Therefore, Smith is prohibited from holding both positions simultaneously. The court affirmed the trial court's decision. View "U.S. Sportsmen's Alliance Foundation v. Smith" on Justia Law

This case involves five initiatives submitted to the Washington State legislature in 2024. The Secretary of State reviewed the signatures on the petitions for these initiatives and determined that there were enough valid signatures to certify them. The initiatives included measures on parental rights in education, repealing the state’s capital gains tax, forbidding state and local income taxes, prohibiting carbon tax credit trading, and making participation in the state’s long-term care insurance program optional. Defend Washington, along with Susan Young and Sharon Chen, challenged the adequacy of the Secretary’s review, arguing that it did not ensure the signers were legal voters.The trial court found that the Secretary’s review was adequate and dismissed the challenge. The court ruled that the Secretary’s use of statistical sampling techniques to verify signatures was consistent with state regulations and that checking signers’ addresses was not required. The Secretary had already submitted the initiatives to the legislature, which passed two of them and left the remaining three to be decided by voters in the upcoming general election.The Washington Supreme Court reviewed the case and affirmed the trial court’s decision. The court held that the Secretary’s procedure of validating signatures by matching them with voter rolls did not violate RCW 29A.72.230, which requires verification of legal voters’ names on the petition. The court found no statutory requirement to verify addresses and concluded that the Secretary’s actions were consistent with the law. The court also noted that any further requirements for signature verification procedures would need to be established by the legislature or the Secretary through rulemaking. The superior court’s judgment was affirmed. View "Defend Washington v. Hobbs" on Justia Law

King County Ordinance 19030 altered zoning and business licensing regulations for wineries, breweries, and distilleries (WBDs) in agricultural and rural areas. The ordinance aimed to support economic development but faced challenges regarding compliance with the Growth Management Act (GMA) and the State Environmental Policy Act (SEPA). The ordinance allowed for expanded WBD operations and introduced new licensing requirements, but it also raised concerns about environmental impacts and the preservation of agricultural land.The Central Puget Sound Growth Management Hearings Board found that the County failed to comply with SEPA and the GMA, invalidating parts of the ordinance. The Board's decision was appealed to the Court of Appeals, which reversed the Board's ruling. Friends of Sammamish Valley and Futurewise sought further review, arguing that the County did not adequately address environmental impacts and agricultural land preservation. The County contended that the ordinance was a "nonproject action" not requiring environmental review under SEPA and presumed valid under the GMA.The Supreme Court of Washington reviewed the case and reversed the Court of Appeals' decision, reinstating the Board's order. The Court held that the County's SEPA checklist was insufficient, failing to address the full range of probable environmental impacts. The Court emphasized that the GMA requires the conservation of agricultural land and that the ordinance's changes could significantly impact the environment. The Court concluded that the County must conduct a comprehensive environmental review to comply with SEPA and the GMA. View "King County v. Friends of Sammamish Valley" on Justia Law

In 2003, Nicole Willyard pleaded guilty to three charges in two separate cases: obstruction, unlawful possession of a controlled substance, and bail jumping. The bail jumping charge was due to her failure to appear for a hearing on the unlawful possession charge. Following the Washington Supreme Court's decision in State v. Blake, which declared the strict liability drug possession statute unconstitutional, Willyard sought to withdraw her guilty pleas for all charges.The trial court vacated her conviction for unlawful possession but denied her motions to withdraw the other guilty pleas. The Washington Court of Appeals affirmed this decision, holding that her motions to withdraw were time-barred. The court found that while Blake invalidated her unlawful possession conviction, it did not affect the validity of her other guilty pleas. The court also determined that the guilty pleas were part of an indivisible plea agreement, but the time bar applied to the obstruction and bail jumping charges.The Washington Supreme Court reviewed the case and held that Willyard's motions to withdraw her guilty pleas were time-barred. The court ruled that Blake did not open the door to untimely challenges to her guilty pleas, as subsequent changes in the law do not affect the validity of a plea that was knowing and voluntary at the time it was made. The court also concluded that unlawful possession under the former statute was not a "nonexistent crime," and thus, Willyard was not entitled to withdraw her guilty pleas on this basis. The court affirmed the Court of Appeals' decision and upheld the trial court's denial of Willyard's motions to withdraw her guilty pleas. View "State v. Willyard" on Justia Law

Nathan Scott Smith was charged with first-degree rape of a child. During jury selection, Smith sought to remove three potential jurors for cause, including one who expressed that she might agree with other jurors if she was "on the fence" about the verdict, citing her non-confrontational nature. The trial judge denied Smith's challenge, and the juror in question sat on the jury, which returned a unanimous guilty verdict.Smith appealed to the Washington Court of Appeals, arguing that the juror exhibited actual bias and should have been removed. The Court of Appeals agreed with Smith, finding that the juror's statements indicated a likelihood of actual bias, and reversed Smith's conviction. The State then sought review from the Washington Supreme Court.The Washington Supreme Court reviewed whether the trial court abused its discretion in denying Smith's for-cause challenge to the juror. The court emphasized that trial judges are best positioned to evaluate potential jurors' ability to serve impartially, given their ability to observe demeanor and tone. The Supreme Court found that the juror's statements were equivocal and did not unequivocally demonstrate actual bias. The court held that the trial judge acted within her discretion in concluding that the juror's answers reflected honest caution rather than actual bias.The Washington Supreme Court reversed the Court of Appeals' decision and reinstated Smith's conviction, holding that the trial court did not abuse its discretion in denying the for-cause challenge to the juror. View "State v. Smith" on Justia Law

In 2003 and 2006, Christopher Lee Olsen pleaded guilty to several offenses, including unlawful possession of a controlled substance. Following the Washington Supreme Court's decision in State v. Blake, which declared the state's strict liability drug possession statute unconstitutional, Olsen sought to withdraw his guilty pleas to all charges. The trial court vacated his drug possession convictions but denied his motions to withdraw his guilty pleas. The Court of Appeals affirmed this decision.The trial court vacated Olsen's drug possession convictions but denied his request to withdraw his guilty pleas, distinguishing between the invalidation of the convictions and the voluntariness of the pleas. The court also rejected Olsen's argument that his plea agreements were indivisible package deals. The Court of Appeals upheld the trial court's decision, concluding that Olsen's pleas were to valid charges at the time and that Blake did not render them involuntary. The court also found that Olsen failed to demonstrate actual and substantial prejudice.The Supreme Court of the State of Washington reviewed the case and held that Olsen's claims to withdraw his guilty pleas were time-barred. The court determined that while Blake invalidated Olsen's drug possession convictions, it did not entitle him to withdraw his guilty pleas. The court emphasized that a guilty plea that was valid when entered does not become involuntary due to a subsequent change in the law. Therefore, Olsen's motions to withdraw his guilty pleas were denied, and the Court of Appeals' decision was affirmed. View "State v. Olsen" on Justia Law