Justia Washington Supreme Court Opinion Summaries

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

The City of Sammamish passed an ordinance to condemn property rights in George Davis Creek, which runs through the petitioners' property, for stormwater management and fish passage protection. The city aimed to address storm drainage issues, improve traffic safety, provide flood protection, and remove barriers to fish passage. The petitioners argued that the city lacked authority to condemn their property for fish passage purposes, citing the salmon recovery act (SRA) and a previous case, Cowlitz County v. Martin.The Superior Court denied the city's motion for condemnation, agreeing with the petitioners that the city had no authority to condemn private property for fish passage purposes. The city appealed, and the Court of Appeals reversed the decision, holding that the city had statutory authority under RCW 8.12.030 to condemn property for stormwater management. The court distinguished this case from Cowlitz County, noting that the project in question had multiple purposes, including stormwater management, which is explicitly authorized by the statute.The Supreme Court of the State of Washington reviewed the case to determine the scope of the city's statutory condemnation authority. The court held that RCW 8.12.030 grants cities the authority to condemn property for stormwater management and other public uses. The inclusion of fish passage as one of the project's purposes did not divest the city of its authority to condemn property for stormwater management. The court affirmed the Court of Appeals' decision and remanded the case to the trial court for further proceedings. View "City of Sammamish v. Titcomb" on Justia Law

The Washington State Department of Ecology (Ecology) identified nitrogen pollution from wastewater treatment plants as a significant issue for Puget Sound. The Northwest Environmental Advocates (NWEA) petitioned Ecology to include nitrogen discharge limits in their regulations. Ecology denied the petition but committed to setting nutrient loading limits at current levels for all permitted dischargers in Puget Sound through the individual permitting process. Subsequently, Ecology issued permits with varying nitrogen discharge limits.The City of Tacoma and other municipalities operating wastewater treatment plants petitioned the Thurston County Superior Court for judicial review, arguing that Ecology's commitment constituted a "rule" under the Administrative Procedure Act (APA) and was adopted without following statutory rule-making procedures. The superior court agreed, holding that Ecology's commitment was a "rule" and invalidated it. The Court of Appeals affirmed this decision, finding that Ecology's actions amounted to a directive of general applicability, thus constituting a "rule" under the APA.The Supreme Court of Washington reviewed the case and concluded that Ecology's commitment in the denial letter was not a directive of general applicability. The court found that Ecology's actions allowed for staff discretion and case-by-case analysis, rather than imposing a uniform standard. Therefore, the commitment did not meet the definition of a "rule" under RCW 34.05.010(16). The Supreme Court reversed the Court of Appeals' decision and remanded the case to the superior court for any further necessary proceedings. View "City of Tacoma v. Dep't of Ecology" on Justia Law

Cody Hart filed a petition to recall Skagit County Prosecuting Attorney Richard A. Weyrich, Skagit County Auditor Sandra F. Perkins, and Skagit County Sheriff Donald L. McDermott. Hart alleged that the officials vacated their offices by failing to file their official bonds before their new term began on January 1, 2023, among other charges. The petition was certified and transmitted by the Skagit County auditor, and Deputy Solicitor General Karl Smith was appointed to prepare the ballot synopses. The Skagit County Superior Court found the charges legally and factually insufficient to support a recall and denied Hart’s motion to amend the ballot synopses.The Skagit County Superior Court approved the ballot synopses but found the charges against all three officials legally and factually insufficient. The court determined that the officials had obtained their bonds before the new term began, and their failure to file the bonds on time did not demonstrate intent to violate the law. Additionally, the court found that the officials' actions did not constitute misfeasance, malfeasance, or a violation of their oath of office. Hart then appealed to the Supreme Court of the State of Washington.The Supreme Court of the State of Washington reviewed the case de novo and affirmed the lower court’s decision. The court held that the charges were legally and factually insufficient, as Hart failed to show intent to violate the law or willful failure to secure a bond. The court also found that the officials' actions did not amount to misfeasance, malfeasance, or a violation of their oath of office. The court concluded that the officials' prior bonds were sufficient until their new bonds were filed, and their actions did not warrant removal from office. The court denied Hart’s various motions, including those for expedited declaratory judgment and recusal of the Chief Justice. View "In re Recall of Weyrich" on Justia Law

Clifford Porter and Peggy Huckstadt were married from 1977 to 1994, during which Porter served in the military. Upon their divorce, the trial court awarded Huckstadt a fractional share of Porter’s military retirement pay. Porter retired from the military in 2002 and later worked as a surgeon. In 2009, he was involuntarily recalled to active duty, served for three years, and was promoted, which increased his retirement pay. Porter retired again in 2012. In 2022, Porter sought to clarify that Huckstadt’s share should be based on his 2002 retirement rank and salary, not the increased benefits from his 2012 retirement.The trial court disagreed, ruling that the increased benefits from Porter’s recall service were community property subject to division. The Court of Appeals affirmed, reasoning that the salary increases during the recall period were based on 17 years of community efforts during the marriage.The Supreme Court of the State of Washington reviewed the case and held that Porter’s rank and salary at his second retirement could not be used to calculate the community portion of the military pension. The court found that the “community efforts doctrine” did not apply under these specific circumstances, as the increased benefits were not a direct result of community effort and performance. The court also determined that the dissolution decree intended to value Huckstadt’s share based on Porter’s rank and salary at his first retirement in 2002, not his second retirement in 2012. Consequently, the court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings. View "In re Marriage of Porter" on Justia Law