Justia Washington Supreme Court Opinion Summaries

Ahmed Mohamud Wasuge was found asleep in his car, which was blocking a lane of traffic on a residential road in King County, Washington. Police arrived after a 911 call and observed Wasuge in the driver’s seat with the engine running and the transmission in drive. Officers noted signs of intoxication, including the smell of alcohol, glassy and bloodshot eyes, and unsteady movements. Wasuge denied drinking but performed poorly on field sobriety tests, and his blood alcohol concentration (BAC) was measured at 0.076 percent. He was charged with felony driving under the influence (DUI) under the “affected by” prong of the statute, as well as operating a vehicle without a functioning ignition interlock device and driving while his license was revoked.At trial in the King County Superior Court, Wasuge attempted to suppress non-Mirandized statements, but the motion was denied. The jury could not reach a unanimous verdict on the felony DUI but convicted him of the lesser offense of being in actual physical control of a vehicle while “affected by” intoxicating liquor. He was also convicted on the other counts. On appeal, the Washington Court of Appeals held that the admission of a toxicologist’s testimony about impairment at BAC levels below the legal limit was improper but harmless due to overwhelming evidence of guilt. The court further concluded that Wasuge was not in custody for Miranda purposes when questioned by police.The Supreme Court of the State of Washington reviewed the case and affirmed the Court of Appeals. The main holdings are: (1) any error in admitting the toxicologist’s testimony was harmless under both constitutional and nonconstitutional standards, given the strength of the properly admitted evidence; and (2) courts may consider relevant and objective evidence of race and ethnicity in applying the “totality of the circumstances” custody test for Miranda purposes, though Wasuge was not in custody at the time of the contested questioning. View "State v. Wasuge" on Justia Law

Renton police and SWAT officers executed a search warrant at the apartment where Cristian Magaña Arévalo was staying with his family, seeking evidence related to the murder of Jason Hobbs. Officers ordered everyone out using a bullhorn, separated Magaña Arévalo from his family, restrained him with zip ties, and placed him in a patrol car before transporting him to a nearby parking lot. There, he was transferred to an officer’s work truck and questioned about Hobbs’s murder without receiving Miranda warnings. The officer told him he was “not under arrest” and asked if he would talk, which Magaña Arévalo agreed to. Two days later, he was interviewed again in a noncustodial setting, also without Miranda warnings.In King County Superior Court, Magaña Arévalo moved to suppress both statements, arguing the first was obtained during a custodial interrogation without Miranda warnings and the second was tainted by the initial violation. The court held a CrR 3.5 hearing and ruled both statements admissible, finding neither interrogation custodial or coerced. The jury convicted Magaña Arévalo of first degree murder, and the court sentenced him to prison. On appeal, the Washington Court of Appeals found the December 1 interrogation was custodial and that admitting the statement was error, but held the error was harmless beyond a reasonable doubt because of other strong evidence, including the December 3 statement and physical evidence.The Supreme Court of the State of Washington reviewed both parties’ petitions. It held that considering the totality of the circumstances—including restraints, isolation, police presence, and ethnicity—Magaña Arévalo was in custody during the December 1 interrogation, and admitting his statement without Miranda warnings violated his constitutional rights. However, the court found the December 3 statement was voluntary, noncustodial, and not tainted by the earlier violation. Applying a clarified harmless error standard, the court affirmed the Court of Appeals, holding the constitutional error was harmless beyond a reasonable doubt. View "State v. Magana-Arevalo" on Justia Law

Anthony Lee was accused of assaulting Amy Groff at his home near Sequim, Washington. After an evening spent together, Lee became angry with Groff, allegedly due to her drug use, theft, and verbal abuse. When they returned home, Lee reportedly fired a gun in the air, struck Groff in the head with the gun, pushed her out of his truck, kicked and hit her, and then shot at her as she ran away. Groff was later found by police with visible injuries and recounted the assault to officers.Lee was charged in the Clallam County Superior Court with two counts of second degree assault with a deadly weapon, each based on separate alleged acts: one for beating Groff with the gun and another for shooting at her. At trial, the judge admitted Groff’s statements to police under the excited utterance exception to hearsay, and instructed the jury not to consider any judicial comments as opinions on the evidence. The jury found Lee guilty on both counts, and the trial court determined the assaults were distinct acts, rejecting Lee’s double jeopardy argument. Lee appealed, raising the double jeopardy issue and, for the first time, challenging the trial judge’s comment on the evidence. The Washington Court of Appeals affirmed both convictions, finding no double jeopardy violation and no manifest constitutional error regarding the judicial comment.The Supreme Court of the State of Washington reviewed the case and held that, under the unit of prosecution analysis and considering all relevant factors, Lee’s assaultive acts constituted a single course of conduct. Therefore, two convictions for second degree assault violated double jeopardy principles. The court reversed on that issue, ordering one conviction and its firearm enhancement to be vacated. On the comment on the evidence issue, the court affirmed, finding no manifest constitutional error that would permit review for the first time on appeal. View "State v. Lee" on Justia Law

On the evening of April 12, 2022, Ralph Kinerson was stabbed following a physical altercation at his home. Both Kinerson and Barclay Dylan Bennett testified that they fought that night, but their accounts differed regarding the circumstances and who initiated the violence. Kinerson claimed Bennett attacked him at his home, while Bennett asserted that Kinerson assaulted him in the street, aided by others, and denied stabbing Kinerson. The police interviewed witnesses, including Kinerson’s neighbor and Kinerson’s daughter, Malea, whose statements became central to the subsequent trial.During trial in the Spokane County Superior Court, Bennett was charged with first degree assault. Bennett’s defense focused on alleged deficiencies in the police investigation, suggesting that officers failed to consider other suspects. On cross-examination, Bennett introduced portions of Malea’s interview with a detective to support this theory, referencing statements about another woman, Abbey Pearson, possibly stealing from Kinerson. In response, the State introduced another part of Malea’s interview, which suggested Bennett had a motive to attack Kinerson due to his relationship with Kinerson’s friend, Roberts. Bennett objected on hearsay and Sixth Amendment grounds, arguing he could not confront Malea, who was unavailable to testify. The trial court overruled the objection, finding Bennett had “opened the door” to the evidence.The Washington Court of Appeals affirmed Bennett’s conviction, concluding that any error in admitting the hearsay was invited by Bennett’s own actions and precluded review, even for constitutional claims. The Supreme Court of the State of Washington affirmed the appellate decision, holding that the statement’s admission was justified under the rule of completeness (ER 106). The Court found the statement was not offered for its truth but to contextualize the investigation, so it did not trigger the confrontation clause. Bennett’s conviction was upheld. View "State v. Bennett" on Justia Law

A resident who lived within a business and parking improvement district in Seattle requested records relating to district operations, including staff compensation, budgets, and meeting minutes. The district was managed by DBIA Services, a private nonprofit corporation that provided services funded almost entirely by assessments on local property owners, collected by the City of Seattle. DBIA managed key district programs, including public safety, sanitation, and economic development, and often identified itself as acting on behalf of the district. When the resident could not obtain all requested information, particularly staff compensation details, he brought suit alleging that DBIA was subject to Washington’s Public Records Act.In King County Superior Court, both parties moved for summary judgment. The court found that DBIA Services and the district were not a single entity and that DBIA was not the functional equivalent of a government agency under the Public Records Act, granting judgment for DBIA. The Washington Court of Appeals affirmed, using an abuse of discretion standard on summary judgment.The Supreme Court of the State of Washington reviewed the case de novo and concluded that DBIA Services is the functional equivalent of a government agency under the Telford test, considering factors such as the governmental nature of DBIA’s functions, the overwhelming public funding, and the risk that denying access would frustrate government transparency. The Supreme Court held that DBIA is subject to the Public Records Act, reversed the Court of Appeals, and remanded the case for further proceedings. The court also granted the petitioner’s request for attorney fees on appeal, to be determined by the trial court. View "Horvath v. DBIA Services" on Justia Law

Two individuals each pleaded guilty in separate cases to unlawful possession of controlled substances in Washington State. As part of their sentences, both were required to pay legal financial obligations (LFOs), which they partially satisfied through cash payments and through performing community service. Years later, following the Washington Supreme Court’s invalidation of the simple drug possession statute in State v. Blake, both individuals successfully moved to vacate their convictions and sought reimbursement for both the cash paid and the labor performed in community service that had satisfied portions of their LFOs.The trial courts vacated their convictions and reimbursed the cash payments but declined to reimburse for the value of the community service hours. Both individuals appealed. The Washington State Court of Appeals affirmed the trial courts’ decisions, holding that there was no substantive due process right to monetary reimbursement for community service work performed in lieu of LFO payments and that equal protection was not violated. The appellate court found that the appellants had not shown they were treated disparately from similarly situated individuals based on economic status, and even if there was disparate treatment, the decision to not reimburse for community service hours was rationally related to a legitimate governmental interest.The Supreme Court of the State of Washington reviewed the consolidated appeals. The court held that there is no constitutional right—fundamental or otherwise—to reimbursement for community service work performed in satisfaction of court-imposed financial obligations when convictions are later invalidated. The court found no disparate treatment based on economic status and therefore no actionable equal protection claim. The decision of the Court of Appeals and the trial courts was affirmed. View "State v. Danielson" on Justia Law

A registered voter in Pacific County, Washington filed a recall petition against an elected county commissioner, alleging two violations of the Open Public Meetings Act (OPMA) in connection with executive sessions held to discuss litigation or potential litigation following two inmate deaths at the county jail. The petition claimed the commissioner attended executive sessions on several dates without legal counsel present, as required by law, and accused her of disregarding public input and misrepresenting the decision-making process leading to the creation of a new jail services department.The Pacific County Superior Court held a sufficiency hearing and found both charges in the recall petition factually and legally sufficient, thus permitting the recall to proceed. The petitioner relied primarily on county meeting minutes and metadata from prepared statements to support the allegations, while the commissioner challenged the accuracy and reliability of the minutes and argued there was no evidence of intent to violate the law.Upon review, the Supreme Court of the State of Washington considered the sufficiency of each charge de novo. The court found that the evidence for some meetings contradicted the allegations about the absence of legal counsel, and for others, although legal counsel was not listed in the minutes, there was no evidence of intentional violation. The petitioner’s supporting exhibits only showed the commissioner received OPMA training, not that she intended to violate the Act. Regarding the second charge, the court found the allegations lacked specific facts about the date, location, and nature of the alleged misconduct and did not cite a law or standard making the conduct unlawful.The Supreme Court of Washington held both charges in the recall petition were factually and legally insufficient and reversed the superior court’s decision. View "In re Recall of Olsen" on Justia Law

An 18-year-old individual was convicted of second degree felony murder and sentenced to 300 months in prison, with an offender score that included a prior drug possession conviction. The court also imposed over $7,000 in restitution to the Crime Victims Compensation fund, covering part of the victim’s funeral expenses. Years later, following the Washington Supreme Court’s decision in State v. Blake, which invalidated certain drug possession convictions, the individual’s prior conviction was vacated, reducing his offender score and lowering his sentencing range. At the resentencing hearing, the individual specifically requested that the court consider his youth at the time of the offense as a mitigating factor. The resentencing judge declined to do so, stating that the issue of youthfulness was not relevant to the hearing and could be raised elsewhere, and imposed a sentence within the new standard range as recommended by defense counsel.The Washington Court of Appeals reviewed the case and held that, although the resentencing judge had discretion to consider youth as a mitigating factor, any error in failing to do so was harmless because the sentence imposed matched the defense’s request. The Court of Appeals also found that the restitution order was not constitutionally excessive, as it was compensatory rather than punitive.The Supreme Court of the State of Washington reversed the Court of Appeals in part. It held that the resentencing court abused its discretion by failing to meaningfully consider the individual’s youthfulness when specifically asked, as required by precedent. The court clarified that while a judge is not required to impose a lower sentence due to youth, the judge must at least consider it as a mitigating factor. The Supreme Court affirmed the Court of Appeals’ ruling that the restitution was not excessive, as it was solely compensatory. The case was remanded for a new resentencing hearing. View "State v. Ellis" on Justia Law

A petitioner sought to file a referendum challenging a specific section of a recently enacted state law concerning student and parental rights in public education. The law included provisions aimed at promoting student safety, preventing discrimination, and ensuring parental notification in certain circumstances. The legislature included an emergency clause in the bill, declaring it necessary for the immediate preservation of public peace, health, or safety, which made the law effective immediately. When the petitioner submitted the referendum to the Secretary of State, the Secretary refused to process it, citing the emergency clause as rendering the legislation exempt from the referendum process under the state constitution.After the Secretary’s refusal, the petitioner filed an original action in the Supreme Court of the State of Washington, seeking a writ of mandamus to compel the Secretary to process the referendum and to challenge the validity of the emergency clause. The court granted expedited review due to the time-sensitive nature of referendum signature collection. The petitioner argued that the Secretary had a mandatory duty to process all properly filed referenda, regardless of the presence of an emergency clause, and that the validity of such a clause was a judicial question.The Supreme Court of the State of Washington held that the Secretary of State does not have a mandatory duty to process a referendum on legislation that is, on its face, constitutionally exempt from referendum due to a valid emergency clause. The court further found that the legislature’s declaration of emergency in this case was valid, as the record and legislative history supported the need for immediate action. As a result, the petition for a writ of mandamus was denied. View "Eyman v. Hobbs" on Justia Law

Lisa Azorit-Wortham worked as a flight attendant for Alaska Airlines in March 2020. She tested positive for COVID-19 after flying on eight flights, including four transcontinental trips, during a period when neither passengers nor crew wore masks. Azorit-Wortham claimed she contracted the virus due to her work-related travel and sought workers’ compensation benefits, arguing that her illness qualified as an “occupational disease” under Washington’s Industrial Insurance Act.After the Department of Labor and Industries approved her claim, Alaska Airlines appealed to the Board of Industrial Insurance Appeals (BIIA), where an administrative law judge determined her illness did not meet the definition of an occupational disease. The BIIA affirmed this decision. Azorit-Wortham then appealed to the Pierce County Superior Court, where a jury was instructed on both the definition of “occupational disease” and the traveling employee doctrine, which extends coverage to employees while traveling for work. The jury found in her favor.Alaska Airlines appealed, and the Washington Court of Appeals reversed the trial court, holding that the traveling employee doctrine does not apply to occupational diseases and that the jury instruction on this doctrine was erroneous and prejudicial. The case was remanded to the trial court.The Supreme Court of the State of Washington reviewed the case and held that the traveling employee doctrine does apply when an employee contracts an occupational disease while traveling for work. The Court found that the trial court correctly instructed the jury on this doctrine and that the instruction did not alter the statutory definition of “occupational disease.” The Supreme Court reversed the Court of Appeals and remanded the case for further proceedings to address whether substantial evidence supported the jury’s verdict. View "Azorit-Wortham v. Department of Labor and Industries" on Justia Law