Justia Washington Supreme Court Opinion Summaries

Several members of the public requested records from the Seattle Police Department (SPD) regarding officers who attended the January 6, 2021, rally in Washington, DC. The officers involved filed a lawsuit to prevent the release of their identities, arguing that their identities should be exempt from disclosure based on statutory and constitutional privacy rights. They sought a preliminary injunction to prevent the release of their identities within those public records.The King County Superior Court denied the officers' motion for a preliminary injunction, determining that the officers failed to show that the information in the public records was likely exempt from disclosure. The court also denied the officers' motion to proceed under pseudonyms. The officers appealed, and the Court of Appeals reversed the denial of the preliminary injunction, concluding that the First Amendment prohibited the disclosure of the officers' identities. The Court of Appeals did not evaluate whether the disclosure would violate the officers' statutory right to privacy under the Public Records Act (PRA).The Supreme Court of the State of Washington reviewed the case and held that the officers did not demonstrate a likelihood of success on the merits that their identities were exempt based on either a statutory or constitutional right to privacy. The court concluded that the officers did not have a privacy interest in their identities as public employees who attended a highly publicized event. The court also held that the officers did not show a need to litigate under pseudonyms. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "John Does v. Seattle Police Dep't" on Justia Law

A young child, Rustin Atkerson, tragically died from severe head trauma while under the care of his mother, Elaine Hurd, and her boyfriend, who had a history of domestic violence. Rustin's father, Ian Atkerson, and Rustin's estate sued the Department of Children, Youth, and Families (DCYF), alleging that their negligent investigation into reports of Rustin's injuries, including a broken arm, led to his death.The trial court denied DCYF's motion for summary judgment, ruling that Atkerson only needed to prove ordinary negligence, not gross negligence, to prevail. The court also largely excluded the testimony of retired Judge Kitty Ann Van Doorninck, who was to testify that a reasonable judge would not have removed Rustin from his mother's care based on the information available at the time. The trial court found her testimony would be unduly prejudicial.The Court of Appeals reversed the trial court's rulings, holding that the applicable standard of care was gross negligence and that the trial court erred in excluding Judge Van Doorninck's testimony. The case was then brought before the Supreme Court of the State of Washington.The Supreme Court of the State of Washington affirmed the Court of Appeals' decision, holding that RCW 4.24.595(1) applies to the early stages of child abuse and neglect investigations, requiring proof of gross negligence. The court also held that the trial court abused its discretion in excluding Judge Van Doorninck's testimony, as her testimony was relevant to the core issue of whether any negligence by the State caused a harmful placement decision. The case was remanded to the trial court for further proceedings consistent with this opinion. View "Atkerson v. State of Washington, Department of Children, Youth & Families" on Justia Law

Former Spokane police officer Jeffery Thurman was the subject of a June 13, 2019 article in the Spokesman-Review, owned by Cowles Co., which alleged he was fired for racial slurs, sexual harassment, and talk of killing black people. On June 14, 2021, Thurman filed a defamation lawsuit against Cowles Co. Shortly after, on July 25, 2021, the Uniform Public Expression Protection Act (UPEPA) took effect. Thurman amended his complaint on December 3, 2021, adding new factual allegations and a claim under the Consumer Protection Act (CPA).The trial court partially granted Cowles' special motion for expedited relief under the UPEPA, dismissing Thurman’s CPA claim but denying the motion to dismiss the defamation claim, reasoning that the defamation claim was part of the original complaint. Cowles appealed the denial of expedited relief for the defamation claim, and Thurman cross-appealed the dismissal of his CPA claim.The Washington Court of Appeals affirmed in part and reversed in part, holding that the UPEPA applied to both Thurman’s defamation and CPA claims. The majority reasoned that the defamation claim was "asserted" on a continuing basis on the UPEPA’s effective date. The dissent argued that the defamation claim was not "asserted" on or after July 25, 2021, and thus the UPEPA did not apply.The Washington Supreme Court held that Thurman’s amended defamation claim relates back to the original complaint filed on June 14, 2021, and is not subject to the UPEPA. The court reversed the Court of Appeals and remanded for further proceedings, deciding the case on statutory grounds and declining to address the constitutional arguments. View "Thurman v. Cowles Co." on Justia Law

Montreal Morgan participated in a home invasion robbery that resulted in the death of Fabian Alvarez. Following the incident, the Department of Labor and Industries (L&I) paid $10,480 in benefits under Washington’s Crime Victims Compensation Act (CVCA) for Alvarez’s medical and funeral expenses. Morgan pleaded guilty to conspiracy to commit murder in the second degree and unlawful possession of a firearm in the second degree. At his restitution hearing, Morgan requested a reduction in the restitution amount due to mitigating factors, but the trial court believed it lacked discretion under RCW 9.94A.753(7) and ordered the full amount of restitution requested by the State.The trial court’s decision was affirmed by the Court of Appeals, which agreed that RCW 9.94A.753(7) does not afford trial courts discretion to impose less restitution than the amount of CVCA benefits paid. Morgan then petitioned for review, which was granted by the Supreme Court of the State of Washington.The Supreme Court of the State of Washington held that RCW 9.94A.753(7) does not allow a trial court discretion to modify the amount of restitution owed to L&I for CVCA benefits. The court emphasized that the statutory language is unambiguous and requires the court to order restitution in the amount of benefits paid by L&I. The court affirmed the Court of Appeals' decision and upheld Morgan’s restitution order, concluding that the trial court correctly interpreted the statute as mandating full restitution for CVCA benefits without discretion for reduction based on mitigating factors. View "State v. Morgan" on Justia Law

Freedom Vans LLC, a company that converts and customizes vans into mobile houses, hired Jeremy David and Mark Springer. David, a self-taught carpenter, was hired in 2019 and later promoted to foundations manager. Springer, an automotive and maritime mechanic, was hired in 2020 as an electrician. Both employees earned less than twice the minimum wage and signed a noncompete agreement prohibiting them from engaging in any business that competed with Freedom Vans. They claimed they declined additional work offers due to fear of termination and legal action. They stopped working for Freedom Vans in 2021.David and Springer filed a class action lawsuit in 2022, alleging the noncompete agreement violated chapter 49.62 RCW, which regulates noncompete clauses in employment contracts. They sought damages and injunctive and declaratory relief. The superior court granted summary judgment to Freedom Vans, reasoning that RCW 49.62 does not restrict an employer’s right to require employee loyalty and avoidance of conflicts of interest. The court denied Freedom Vans' request for attorney fees. Both parties appealed.The Washington Supreme Court reviewed the case. The court held that noncompete agreements for employees earning less than twice the minimum wage must be reasonable and narrowly construed in light of the legislature’s intent to protect low wage workers and promote workforce mobility. The court reversed the Court of Appeals' decision, concluding that prohibiting employees from providing any kind of assistance to competitors exceeds a narrow construction of the duty of loyalty. The case was remanded to the superior court to determine the reasonableness of the noncompete agreement and assess damages and attorney fees. View "Springer v. Freedom Vans LLC" on Justia Law

J.M.H. pleaded guilty to disorderly conduct in juvenile court in 2022. The trial court judge issued a disposition order with certain conditions, which J.M.H. violated multiple times. In October 2022, the judge issued a warrant for her arrest. J.M.H.'s lawyer challenged the warrant, arguing it did not comply with JuCR 7.16, the rule for issuing juvenile warrants. The trial court denied the motion, and J.M.H. appealed.The appeal was reviewed by the Court of Appeals. By that time, the trial court judge who issued the warrant had been appointed to the Court of Appeals and sat on the panel reviewing his own decision. The panel dismissed the appeal, stating the order was not appealable under RAP 2.2(a). J.M.H. sought discretionary review, arguing it was reversible error for the judge to sit on the appellate panel.The Supreme Court of the State of Washington reviewed the case. The court held that a judge cannot review an appeal of a decision they made as a trial court judge in the same case, citing In re Murchison and In re Dependency of A.N.G. The court found that this violated due process and required automatic reversal. The Supreme Court reversed the decision and remanded the case to the Court of Appeals for further proceedings. View "State v. J.M.H." on Justia Law

Barry Chrisman was seriously injured when a tree fell on his work vehicle while driving through a riparian management zone (RMZ) in a recently logged forest area. The RMZ, a buffer of trees left standing to benefit wildlife and water quality, was part of the Lugnut timber area managed by the Washington Department of Natural Resources (DNR). Chrisman and his employer sued the State of Washington, Sierra Pacific Industries, and Precision Forestry Inc. for negligence, arguing that the defendants were not immune under the Forest Practices Act of 1974, which provides immunity for forestland owners when a tree required to be left standing in an RMZ falls and causes injury.The trial court granted summary judgment in favor of the defendants, holding that they were immune under the statute as forestland owners required to leave the RMZ trees standing. The plaintiffs appealed, and the Court of Appeals reversed the decision. The appellate court held that Sierra and Precision were not forestland owners because they did not have the right to harvest RMZ trees and that only entities with the authority to determine RMZ parameters are entitled to immunity. The court also found a genuine issue of material fact regarding whether the RMZ was properly drawn.The Supreme Court of the State of Washington reviewed the case and held that the defendants are immune under the Forest Practices Act. The court determined that the statute provides broad immunity to forestland owners, including those in actual control of the land with the right to sell or dispose of timber. The court concluded that Sierra and Precision fit the definition of forestland owners and that the immunity applies regardless of whether the RMZ was properly drawn. The court reversed the Court of Appeals' decision and affirmed the trial court's summary judgment in favor of the defendants. View "Pub. Util. Dist. No. 1 of Snohomish County v. State" on Justia Law

Anthony Vasquez was convicted of multiple offenses, including aggravated first-degree murder, unlawful possession of a firearm, and tampering with a witness, for shooting and killing Juan Garcia in 2013. Vasquez was sentenced to life without parole. On appeal, the Court of Appeals vacated the aggravated murder conviction, concluding it was not a drive-by shooting, and affirmed the other convictions. Vasquez was resentenced to 660 months. He appealed again due to a clerical error, and the Court of Appeals remanded for clarification.Following the State v. Blake decision, which held the former simple possession statute unconstitutional, Vasquez filed a CrR 7.8 motion for relief from judgment, arguing his judgment and sentence (J&S) was invalid due to a drug possession conviction. The State conceded, and Vasquez was resentenced to 620 months. The resentencing judge limited the scope of arguments, rejecting Vasquez's request to consider his youth at the time of the crime.Vasquez appealed, arguing the superior court erred by not conducting a de novo resentencing and not considering his youth. The Court of Appeals agreed, holding that resentencing should be de novo unless specifically restricted by an appellate court. The court noted that the resentencing judge should exercise independent discretion and consider all relevant arguments and evidence.The Supreme Court of the State of Washington affirmed the Court of Appeals, holding that at a resentencing hearing, the court has the same discretion as an original sentencing judge. The parties must be allowed to present mitigating and aggravating factors, and the judge must exercise independent discretion in sentencing. The case was remanded for a new resentencing hearing. View "State v. Vasquez" on Justia Law

In May 2006, Timothy Kelly was convicted of unlawful possession of a controlled substance and other burglary-related offenses. His offender scores for these offenses ranged from 11 to 14 points. Later, in November 2006, Kelly was convicted of additional offenses, including first-degree burglary and firearm-related crimes, with offender scores ranging from 21.5 to 26.5 points. In 2021, following the decision in State v. Blake, which invalidated Washington’s drug possession statute, Kelly sought resentencing. The trial court vacated his drug possession conviction and adjusted his offender scores but denied resentencing for the May 2006 convictions, as Kelly had already served his sentence.The Court of Appeals held that Kelly’s request for resentencing on his non-drug-related May 2006 convictions was time-barred under RCW 10.73.090(1) and .100. The court also ruled that the trial court lacked the authority to run Kelly’s firearm enhancements concurrently. Kelly appealed, arguing that the Blake decision was material to his sentences and that his judgment and sentence were facially invalid due to the unconstitutional conviction.The Supreme Court of Washington affirmed the Court of Appeals. The court held that while Blake was a significant change in the law, it was not material to Kelly’s non-drug-related sentences because his offender scores remained above 9 points, and his standard sentencing ranges did not change. The court also held that Kelly’s judgment and sentence were not facially invalid, as the sentencing court did not exceed its authority. Additionally, the court declined to overrule State v. Brown, which held that firearm enhancements must run consecutively and cannot be modified through an exceptional sentence. The court concluded that the invited error doctrine did not preclude the State from challenging the judgment and sentence. View "State v. Kelly" on Justia Law

Centene Corporation’s subsidiaries, Envolve Pharmacy Solutions and Coordinated Care, administer health insurance benefits in Washington under a state contract. Coordinated Care collects premiums from consumers and forwards payments to Envolve for administering the benefits. Coordinated Care pays a premiums tax instead of a business and occupation (B&O) tax. The issue is whether Coordinated Care’s payment of the premiums tax exempts Envolve from paying the B&O tax under RCW 82.04.320.The Department of Revenue historically exempted secondary corporate affiliates from the B&O tax if the primary affiliate paid the premiums tax. Envolve sought a refund based on this precedent, but the Department denied it, audited Envolve, and assessed over $3 million in back taxes, arguing that Envolve’s services were not all functionally related to insurance business.Envolve appealed to the Board of Tax Appeals, which partially upheld the Department’s decision, finding some of Envolve’s services were not functionally related to insurance. The King County Superior Court reversed, ruling that Envolve’s activities were exempt under RCW 82.04.320. The Court of Appeals affirmed, holding that Envolve’s services were functionally related to insurance business and thus exempt from B&O tax.The Supreme Court of Washington affirmed the Court of Appeals, holding that RCW 82.04.320 exempts Envolve from B&O taxation because Coordinated Care paid the premiums tax on Envolve’s work related to insurance business. The court emphasized that the statute’s plain language exempts any person engaged in insurance business upon which a premiums tax is paid, without specifying who must pay the tax. The case was remanded for further proceedings consistent with this opinion. View "Envolve Pharmacy Solutions, Inc. v. Dep't of Revenue" on Justia Law