Justia Washington Supreme Court Opinion Summaries

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

M.R., a high school student and basketball player, was sexually abused by Cody Butler, a women's basketball coach at Yakima Valley Community College (YVCC), starting when she was 17 years old. The abuse continued into her adulthood, including inappropriate touching, sexual comments, and physical advances. Butler's actions had a significant negative impact on M.R.'s life, leading to substance abuse, abusive relationships, and other personal issues. In 2018, M.R. connected her experiences of abuse to her injuries while in therapy.In 2019, M.R. sued the State of Washington, YVCC, and Butler for various claims, including negligence and assault. The trial court denied the State's motion for summary judgment, which argued that M.R.'s claims were time-barred by the three-year statute of limitations in RCW 4.16.080(2). The court found that the abuse was a continuous series of events that could not be segregated. The Court of Appeals reversed, concluding that RCW 4.16.340 only applies to claims based on acts of childhood sexual abuse occurring before the plaintiff turns 18 years old.The Supreme Court of the State of Washington reviewed the case and reversed the Court of Appeals. The court held that RCW 4.16.340 does not preclude complainants from bringing claims of sexual abuse that originate from childhood sexual abuse and extend into the victim’s adulthood. The court found that the statute's plain language and legislative intent support the inclusion of claims for continuing sexual abuse that are based on intentional acts of childhood sexual abuse. The court also noted that the statute accounts for the continuing tort doctrine, allowing for claims involving a common scheme of abuse by the same perpetrator. View "M.R. v. State" on Justia Law

Abbas Salah Zghair was convicted by a jury of second-degree felony murder while committing second-degree assault with a firearm enhancement. The case revolves around the fatal shooting of Silvano Ruiz-Perez, whose body was found in an unattended field in Auburn, Washington. Evidence included cell site location data, traffic camera footage, and video surveillance, which placed Zghair and Ruiz-Perez together on the night of the shooting. Forensic evidence linked Zghair’s car to the crime scene, and Zghair admitted to owning the car and having knowledge of the shooting.The trial court sentenced Zghair to 252 months in prison. On appeal, Zghair argued that the evidence was insufficient to support his conviction as either a principal or an accomplice. The Washington Court of Appeals reversed the conviction, concluding that the evidence did not support Zghair’s conviction under either theory.The Supreme Court of the State of Washington reviewed the case. The court held that the evidence was sufficient to support Zghair’s conviction. The court emphasized that circumstantial evidence is as reliable as direct evidence and that the jury could reasonably infer Zghair’s knowledge and involvement in the crime. The court also clarified that Washington’s complicity statute does not require proof of knowledge of a specific plan to commit the crime, only general knowledge that the crime would be committed. The court found that the totality of the circumstantial evidence supported the jury’s conclusion that Zghair either committed the assault or aided in its commission.The Supreme Court of the State of Washington reversed the Court of Appeals' decision and affirmed Zghair’s conviction. View "State v. Zghair" on Justia Law

Jewels Helping Hands and Ben Stuckart challenged a proposed initiative by Spokane resident Brian Hansen, which aimed to expand the criminalization of camping within 1,000 feet of schools, parks, and childcare facilities. The initiative was a response to increased crime rates near a homeless encampment called Camp Hope. Spokane had previously adopted a comprehensive ordinance regulating public camping, which included provisions to comply with the Ninth Circuit's Martin v. City of Boise decision, barring criminalization of camping when no shelter space was available.The trial court ruled that the plaintiffs had standing but found their claims without merit, allowing the initiative to proceed to the ballot. The Court of Appeals affirmed, holding that the initiative was within the scope of the local initiative power, not a zoning ordinance, did not conflict with state law, and was legislative rather than administrative.The Washington Supreme Court reviewed the case and disagreed with the lower courts. It held that the initiative was impermissibly administrative because it modified the details of Spokane's preexisting comprehensive policy on public camping. The court emphasized that local initiatives must be legislative in nature, creating new policies rather than administering existing ones. The court reversed the lower courts' decisions, ruling that the initiative exceeded the scope of the local initiative power. View "Jewels Helping Hands v. Hansen" on Justia Law

Roxann Brown and Michelle Smith filed a lawsuit against Old Navy, alleging that the retailer sent them e-mails with subject lines containing false or misleading information about the duration of promotions, in violation of the "Commercial Electronic Mail Act" (CEMA). The plaintiffs claimed that Old Navy's e-mails falsely suggested that promotions were ending or were limited-time offers, which were extended beyond the specified time limits.The United States District Court for the Western District of Washington reviewed the case and certified a question to the Washington Supreme Court regarding the interpretation of RCW 19.190.020(1)(b). The federal court sought clarification on whether the statute prohibits any false or misleading information in the subject lines of commercial e-mails or only false or misleading information about the commercial nature of the message.The Washington Supreme Court reviewed the certified question de novo and concluded that RCW 19.190.020(1)(b) prohibits the use of any false or misleading information in the subject line of a commercial e-mail, not just information about the commercial nature of the message. The court emphasized that the statute's plain language is clear and unambiguous, and it does not require judicial construction. The court also noted that the statute's focus on subject lines is appropriate and does not lead to absurd results. The court held that mere puffery, which includes subjective statements, opinions, and hyperbole, is not prohibited by the statute. The court's decision clarifies that commercial e-mails sent to Washington residents must have truthful and non-misleading subject lines. View "Brown v. Old Navy, LLC" on Justia Law