Justia Washington Supreme Court Opinion Summaries

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

A 16-year-old girl, Luna, was involved in a fatal altercation with another teenager, S.P.T., whom she knew only through social media. The conflict began when S.P.T. arrived at Luna’s home and initiated a physical fight by punching Luna. Luna responded by using a pocketknife, resulting in S.P.T.’s death. Prior to the incident, Luna had received social media messages that she interpreted as threats, including an image suggesting gang violence. The State charged Luna with murder, and she was tried as an adult.In the Kitsap County Superior Court, the State was permitted to introduce various pieces of social media evidence and a video of Luna’s police interrogation to suggest preexisting violent intent and lack of remorse. Luna argued self-defense and sought to introduce additional social media evidence to support her fear of S.P.T., but some of this evidence was excluded. The jury found Luna guilty of intentional, but not premeditated, second-degree murder. On appeal, the Washington Court of Appeals affirmed the conviction, finding that some social media evidence was improperly admitted but deemed the error harmless. The appellate court also held that a new statute requiring juveniles to be provided counsel before interrogation did not apply retroactively to Luna’s case.The Supreme Court of the State of Washington reviewed the case. It held that the new statute, RCW 13.40.740, did not apply retroactively to Luna’s interrogation. However, the court found that Luna did not validly waive her right to silence, and her interrogation statements should have been excluded. The court also determined that several evidentiary rulings regarding social media evidence were erroneous and undermined the fairness of the trial. The Supreme Court vacated the jury verdict and remanded the case for further proceedings. View "State v. Luna" on Justia Law

Three public school teachers in Washington developed health problems after working in an older school building that contained polychlorinated biphenyls (PCBs) manufactured by Monsanto. The teachers sued Pharmacia, Monsanto’s successor-in-interest, alleging injuries from PCB exposure and brought claims under the Washington Product Liability Act (WPLA) for design defect, construction defect, and failures to warn, while also seeking punitive damages under Missouri law. After a seven-week trial, the jury found for the teachers on all claims, awarding substantial compensatory and punitive damages.The Snohomish County Superior Court, where the case was tried, ruled that Missouri law governed the issues of repose and punitive damages, while Washington law governed the substantive elements of liability. The court also admitted expert testimony estimating historic PCB exposure levels. Pharmacia challenged the verdict, but the trial court denied its post-trial motions. On appeal, the Washington Court of Appeals reversed in part, holding that Washington’s statute of repose applied, limiting the plaintiffs’ claims, and that the verdict form was insufficient for punitive damages because it did not specify which theory of liability supported the award. The Court of Appeals also found error in the admission of certain expert testimony.The Supreme Court of the State of Washington reviewed the case and partially reversed the Court of Appeals. The Supreme Court held that, under Washington’s established choice of law principles, Missouri law governs both the issues of repose and punitive damages because Missouri has the most significant relationship to those issues. The Court also held that the jury instructions and special verdict form were sufficient to sustain the punitive damages award under Missouri law, and that the challenged expert testimony was admissible under the Frye standard and ER 702. The Supreme Court reinstated the jury’s verdict and remanded for further proceedings consistent with its opinion. View "Erickson v. Pharmacia LLC" on Justia Law

After a property owner defaulted on a note secured by a deed of trust, he filed for bankruptcy in 2008, and his debt was discharged in 2009. He made no further payments on the 20-year obligation. In 2018, the interest in the deed of trust was transferred to a new entity, which initiated nonjudicial foreclosure proceedings. The property owner responded by filing a quiet title action and moved for summary judgment, arguing that the six-year statute of limitations to enforce the note and foreclose on the deed of trust began running upon the bankruptcy discharge. The trial court agreed, granted summary judgment, and quieted title in favor of the property owner.The new beneficiary appealed to the Washington Court of Appeals, Division One, which affirmed the trial court’s decision in an unpublished opinion. The beneficiary’s motions for reconsideration and petitions for review to the Washington Supreme Court were denied. Shortly after, Division One issued a published opinion in Copper Creek (Marysville) Homeowners Association v. Kurtz, which expressly disagreed with the earlier decision in this case, creating a split within the division. The beneficiary then sought relief from the quiet title judgment in the trial court under CR 60(b)(11), arguing that the divisional split and subsequent legal developments justified reopening the case. The trial court denied the motion, and the Court of Appeals affirmed.The Supreme Court of the State of Washington held that the trial court abused its discretion by applying the wrong legal standard under CR 60(b)(11). The Supreme Court determined that the combination of legal errors, the prompt actions of the beneficiary, and the divisional split constituted extraordinary circumstances justifying relief from judgment. The Supreme Court reversed the Court of Appeals and remanded the case to the trial court to vacate the quiet title judgment and for further proceedings. View "Luv v. W. Coast Servicing, Inc." on Justia Law

A federally recognized Indian tribe purchased a parcel of nonreservation land in Washington State using state and federal conservation grant funds, with the purpose of protecting salmon habitat and preserving tribal treaty fishing rights. The land was designated for conservation and was not part of any reservation. A neighboring landowner, a Washington corporation, claimed that it and its predecessors had acquired title to a strip of this land through adverse possession, based on decades of exclusive use and maintenance of a boundary fence. The corporation filed a quiet title action in Snohomish County Superior Court against both the tribe and the county, seeking to establish its ownership of the disputed strip.The Snohomish County Superior Court dismissed the action with prejudice, finding that the tribe was protected by sovereign immunity and could not be sued without its consent or an act of Congress. The corporation sought direct review by the Washington Supreme Court, which transferred the case to the Washington Court of Appeals. The Court of Appeals affirmed the dismissal, holding that tribal sovereign immunity is not subject to a common law immovable property exception unless Congress or the tribe itself clearly waives immunity. The court also noted that prior Washington cases allowing in rem jurisdiction over tribally owned nonreservation land were no longer good law in light of the United States Supreme Court’s decision in Upper Skagit Indian Tribe v. Lundgren, 584 U.S. 554 (2018).The Supreme Court of the State of Washington reviewed the case and held that state courts lack subject matter jurisdiction over adverse possession claims involving nonreservation land owned by tribes, unless there is a clear waiver of immunity by the tribe or Congress. The court further held that the common law immovable property exception does not apply to tribal sovereign immunity. The decision of the Court of Appeals was affirmed. View "Flying T Ranch, Inc. v. Stillaguamish Tribe of Indians" on Justia Law

In 1985, a 20-year-old individual committed a burglary that resulted in the fatal stabbing of a 14-year-old boy. The following year, a jury convicted him of aggravated first degree murder. At that time, Washington law required a mandatory sentence of life without the possibility of parole (LWOP) for such a conviction, and the sentencing judge stated he had no discretion to impose any other sentence. The individual has been incarcerated for nearly 40 years under this sentence.After his conviction and sentence were affirmed by the Washington Court of Appeals in 1988, the petitioner sought resentencing in 2023, arguing that recent Washington Supreme Court decisions—specifically In re Personal Restraint of Monschke and State v. Carter—rendered his mandatory LWOP sentence unconstitutional. The King County Superior Court transferred his motion to the Court of Appeals, which then certified the case for direct review by the Washington Supreme Court.The Supreme Court of the State of Washington held that its decision in Monschke constituted a significant change in the law, exempting the petitioner’s claim from the one-year time bar for collateral relief. The court found that mandatory LWOP sentences for individuals aged 18 to 20 at the time of their offense, imposed without consideration of youth as a mitigating factor, are unconstitutional under the state constitution’s prohibition on cruel punishment. The court further held that a petitioner in this situation demonstrates actual and substantial prejudice if Monschke is material to their sentence. The court granted the personal restraint petition and remanded the case to the trial court for a new sentencing hearing. View "In re Personal Restraint of Schoenhals" on Justia Law

The case concerns a man who, after a heated argument with his wife in their home, threatened her with a gun in the presence of their children. The incident escalated to physical violence and a standoff with law enforcement, ending with his surrender. The defendant was charged with multiple offenses, but relevant here are his convictions for second degree assault with a deadly weapon and felony harassment (threat to kill), both arising from the same sequence of conduct.At trial in the Superior Court, the jury convicted the defendant of both second degree assault and felony harassment, each with firearm and domestic violence aggravators. The trial court found these offenses constituted the “same criminal conduct” for sentencing purposes and imposed concurrent sentences with consecutive firearm enhancements. On appeal, the Washington Court of Appeals affirmed the convictions, rejecting the defendant’s argument that punishing both offenses violated double jeopardy protections.The Supreme Court of the State of Washington reviewed whether the two convictions violated the constitutional prohibition on double jeopardy by imposing multiple punishments for the same offense. The court held that, although both convictions were based on the same conduct, they were not the same in law because each offense required proof of a fact the other did not: assault required intentional conduct with a deadly weapon causing fear of bodily injury, while harassment required a knowing threat to kill. The court found no clear legislative intent to prohibit separate punishments for these offenses and concluded that the convictions did not violate double jeopardy. The Supreme Court of Washington affirmed the decision of the Court of Appeals and upheld the convictions. View "State v. Ray" on Justia Law

Two individuals applied for jobs at a retail liquor store chain in Washington after a new state law required employers to include wage and benefit information in all job postings. Both applicants submitted their applications through a third-party website, Indeed.com, where the postings did not include the required pay information. One of the applicants also interviewed in person and discussed pay with the store manager but ultimately declined a job offer. Both individuals then filed a class action lawsuit, seeking statutory damages for the employer’s failure to comply with the disclosure requirements.The case was initially brought in King County, Washington. The employer argued that the plaintiffs were not the type of “job applicants” the law was intended to protect, asserting that only those with a genuine or “bona fide” interest in the job should be eligible for remedies. The parties disagreed on the meaning of “job applicant” under the Washington Equal Pay and Opportunities Act (EPOA). The United States District Court for the Western District of Washington, faced with this dispute, certified a question to the Washington Supreme Court, asking what a plaintiff must prove to be considered a “job applicant” under the statute.The Supreme Court of the State of Washington held that, under RCW 49.58.110(4), a person qualifies as a “job applicant” if they apply to a specific job posting, regardless of their subjective intent or whether they are a “bona fide” or “good faith” applicant. The court concluded that the plain language of the statute does not require proof of genuine interest in the position, and that the legislature intentionally omitted such a requirement. The court’s answer clarified that subjective intent is irrelevant for eligibility to seek remedies under the EPOA. View "Branson v. Washington Fine Wine & Spirits, LLC" on Justia Law

Lester Thompson Jr. was charged with the murder of Destinie Gates-Jackson, with whom he had a long-term relationship. After previously being convicted of kidnapping and assaulting Ms. Gates-Jackson, Thompson was found driving a car containing her body, and forensic evidence indicated she died from strangulation. Thompson’s defense at trial was that Ms. Gates-Jackson died from an underlying health condition, not homicide, and he sought to subpoena her medical records to support this theory. Jeri Gates, the decedent’s mother and representative, intervened to oppose the release of these records, citing privacy concerns. The trial court denied Thompson’s motions to subpoena the records, and he was convicted of second-degree murder with a domestic violence finding.Thompson appealed his conviction to the Washington Court of Appeals, arguing, among other things, that the trial court erred in denying his request for the medical records. Ms. Gates moved to intervene in the appeal solely on the issue of the medical records, and the Court of Appeals granted her motion over Thompson’s objection. Thompson then sought review by the Supreme Court of the State of Washington, contending that the appellate court erred in permitting Ms. Gates to intervene.The Supreme Court of the State of Washington held that when a trial court has allowed a nonparty to intervene to protect a legally cognizable interest, an appellate court has the discretion to permit that nonparty to intervene on appeal, provided the intervention is limited to the same issues addressed below. The court affirmed the Court of Appeals’ decision, concluding that the appellate intervention was proper under these circumstances and within the appellate court’s discretionary authority. View "State v. Thompson" on Justia Law