Justia Washington Supreme Court Opinion Summaries

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Olajide Adel Fletcher was sentenced based on an offender score that erroneously included two prior juvenile adjudications, resulting in a higher standard sentence range. This miscalculation was evident on the face of the judgment and sentence (J&S). Fletcher filed a postconviction motion for a new sentencing hearing, which the superior court granted despite it being filed after the usual one-year deadline. The court found the J&S invalid on its face due to the critical errors in the offender score.The Court of Appeals reversed the superior court's decision, agreeing that the J&S was facially invalid but ruling that Fletcher's motion violated procedural rules against filing successive postconviction motions. Fletcher then filed a third postconviction motion directly with the Washington Supreme Court, arguing that the J&S's serious errors made it invalid on its face.The Washington Supreme Court reviewed the case and agreed with the lower courts that the J&S was facially invalid due to the miscalculated offender score. The court held that the sentencing court must know the correct standard range to impose an exceptional sentence fairly and in accordance with statutory requirements. The court found that the original sentencing court could not have made a fair decision given the extreme miscalculation of Fletcher's offender score and standard sentence range.The Washington Supreme Court granted Fletcher's personal restraint petition (PRP) and remanded the case to the trial court for resentencing using the accurate offender score and standard sentence range. The court emphasized that the errors in the original J&S constituted a fundamental defect resulting in a complete miscarriage of justice. View "In re the Personal Restraint of Fletcher" on Justia Law

Posted in: Criminal Law
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A trial court found that Yakima HMA LLC wrongfully withheld nearly $1.5 million in wages from its nurses over five years. In 2015, the Washington State Nurses Association (WSNA) filed a claim on behalf of 28 nurses, including Daniel Campeau. The trial court ruled in favor of WSNA, but years later, the Supreme Court of Washington reversed this decision, stating that WSNA lacked associational standing. Before the mandate was issued, Campeau filed a class action suit to recover the unpaid wages.The trial court agreed with Campeau, allowing the case to proceed under the doctrine of equitable tolling, reasoning that Campeau had diligently pursued his claims through the WSNA action and reasonably relied on the union to protect his rights. Yakima HMA appealed, and the Court of Appeals reversed the trial court's decision, concluding that American Pipe tolling was not applicable in Washington and that equitable tolling was not warranted without evidence of bad faith or misconduct by Yakima HMA.The Supreme Court of Washington reviewed the case de novo. The court held that equitable tolling could be appropriate even without bad faith by the defendant when associational standing fails, and a member promptly files a follow-on class action. The court found that equitable tolling was consistent with the purposes of the underlying labor laws and statutes of limitations, and it would prevent an unjust windfall to Yakima HMA. Therefore, the court reversed the Court of Appeals and remanded the case to the trial court for further proceedings. View "Campeau v. Yakima HMA, LLC" on Justia Law

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The case revolves around Jack Potter, a man who lived in a 23-foot travel trailer hitched to his truck, which he parked on public lots and streets in the city of Lacey, Washington. In 2019, the city passed an ordinance barring people from parking such large vehicles and trailers on public lots and streets for more than four hours per day. The city then ordered Potter to move his trailer and truck off the city hall parking lot and off Lacey streets. Potter sued the city, claiming that its new ordinance violated his state constitutional “right to reside,” which he argued was inherent in the state constitutional right to intrastate travel.The case was initially filed in Thurston County Superior Court but was later moved to the federal district court for the Western District of Washington. The district court granted summary judgment to the city on nearly all of its claims, including Potter’s state right to intrastate travel claim. The court explained that the ordinance did not fundamentally impede the right to exist or reside in a given area. It was a parking ordinance applicable to all people in Lacey, and only by extension did it restrict the manner in which a person could live in Lacey. The right to travel did not include a right to live in a certain manner.The case was then appealed to the Ninth Circuit Court of Appeals, which certified questions of state law to the Supreme Court of the State of Washington. The Supreme Court held that the RV parking ordinance did not violate Potter’s claimed Washington State constitutional right to intrastate travel. Potter had not established that his claimed right to reside was inherent in a Washington state constitutional right to intrastate travel or that it protected his preferred method of residing in Lacey: by siting his 23-foot trailer on a public street in violation of generally applicable parking ordinances. View "Potter v. City of Lacey" on Justia Law

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The Washington State Attorney General filed a lawsuit against the city of Sunnyside and several of its officials, alleging that the city's crime-free rental housing program (CFRHP) was being used to evict tenants without due process and that these evictions disproportionately impacted Latinx renters, women-headed households, and families with minor children. The city argued that the Attorney General lacked the authority to bring this suit, as the scope of the Attorney General's authority under RCW 43.10.030(1) limits their ability to act to matters that impact more people than those affected by the CFRHP. The trial court granted summary judgment in favor of the defendants.On appeal, the Supreme Court of Washington reversed and remanded the case. The court held that the Attorney General did have the authority to bring the suit, as the case involved matters of public concern in which the state had an interest. The court also found that there were genuine disputes of material fact regarding whether the city's enforcement of the CFRHP had a disparate impact on protected classes, and whether the individual respondents were entitled to qualified immunity. However, the court affirmed the trial court's grant of summary judgment on the Attorney General's claims under the Residential Landlord-Tenant Act, finding that the respondents were not landlords and therefore the Act did not apply to them. View "State v. City of Sunnyside" on Justia Law

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The case revolves around the issue of whether a criminal defendant can be required to appear for nonjury proceedings from an "in-court holding cell" without an individualized inquiry justifying such a restraint. The defendant, Cassandra Luthi, was required to appear for a nonjury hearing from an in-court holding cell at the Cowlitz County Jail courtroom. Despite Luthi’s objections, the superior court did not conduct an individualized inquiry to determine whether such a restraint was justified, believing that it was unnecessary to do so.The superior court had required Luthi to appear from an in-court holding cell for her hearing, without conducting an individualized inquiry into whether this restraint was justified for security reasons. The State argued that the in-court holding cell did not implicate the due process right to appear at trial free from all bonds or shackles except in extraordinary circumstances, and that these due process protections did not apply to Luthi’s hearing because it was not a trial and there was no jury.The Supreme Court of the State of Washington held that the in-court holding cell undermines the presumption of innocence, interferes with a defendant’s ability to communicate with counsel, and violates the dignity of the defendant and the judicial proceedings. Therefore, absent an individualized finding that such a restraint is necessary to protect essential state interests such as physical security, escape prevention, or courtroom decorum, the routine use of this in-court holding cell violates federal and state constitutional due process protections against inherently prejudicial courtroom practices. The court reversed the superior court, granted Luthi’s requested relief, and remanded for a new hearing. View "State v. Luthi" on Justia Law

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The Supreme Court of Washington State reviewed two cases involving individuals, Kimonti Dennis Carter and Shawn Dee Reite, who were originally sentenced to mandatory life without parole (LWOP) for aggravated first-degree murders they committed between the ages of 18 and 20. Both Carter and Reite had served decades in prison and had demonstrated significant personal transformation and rehabilitation. They appealed to the court to affirm their determinate sentences, which had been granted by the superior courts at resentencing.The superior courts had resentenced Carter and Reite to determinate sentences after a previous ruling by the Supreme Court of Washington State (In re Personal Restraint of Monschke) held that mandatory LWOP sentences were unconstitutional for individuals in their age group. The State appealed these resentencing decisions, arguing that the superior courts did not have the statutory authority to impose determinate sentences for aggravated first-degree murder.The Supreme Court of Washington State affirmed the determinate sentences for both Carter and Reite. The court held that the superior courts had the statutory authority to impose determinate sentences for aggravated first-degree murder for Carter and Reite. The court also held that the superior court had the authority to resentence Carter on his other convictions. However, the court found that the superior court improperly imposed three years of community custody on Reite because this was unauthorized by statute for the crime of conviction. Therefore, the court affirmed the superior court that sentenced Carter and affirmed the superior court that sentenced Reite for all but the imposition of community custody. The court reversed and remanded to the superior court only for purposes of striking the community custody term for Reite. View "State v. Carter" on Justia Law

Posted in: Criminal Law
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In the early 20th century, Jim Wallahee, a citizen of the Yakama Nation, was convicted for illegal hunting when he killed a deer on ceded Yakama land. The Yakama Nation had signed a treaty with the United States government, which explicitly reserved many rights for the Yakama people, including the right to hunt on open and unclaimed lands. Despite this, Wallahee was convicted in 1924, and his conviction was affirmed by the Supreme Court of the State of Washington, relying on precedent that has since been overturned.The lower courts did not recognize Wallahee's treaty right to hunt. The trial court convicted him, and the Supreme Court of the State of Washington affirmed his conviction, largely based on precedent established in Towessnute and Race Horse, decisions that have since been overturned. The court made a series of assertions that are both incorrect and harmful, including that “the Yak[a]ma Tribe was not an independent nation nor a sovereign,” that the Yakama people were “mere occupants” of their ancestral lands, and that the Yakama treaty was abrogated at statehood.In the present case, the Supreme Court of the State of Washington rejected the harmful logic that underpinned Wallahee's wrongful conviction and recognized that Wallahee had a clear and enforceable treaty right to hunt that deer. The court granted the motion to intervene, the motion to recall the mandate, and the motion to vacate Wallahee’s conviction. The court acknowledged that its 1927 opinion was incorrect on the law and advanced many centuries’ worth of harmful tropes about Native Americans. The court explicitly repudiated that belief and disavowed its opinions that reflected that belief. View "State v. Wallahee" on Justia Law

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In 2021, Lyra Jean Spencer filed a personal injury lawsuit against Franklin Hills Health-Spokane LLC. To serve the summons, her attorney hired a process server who, after learning that the registered agent was unavailable, served the documents to the company's human resources manager, Sheri Flavel. Franklin Hills filed a motion to dismiss the case, arguing that service on Flavel was improper as she was not authorized to accept service under RCW 4.28.080(9). The trial court granted the motion to dismiss, concluding that Spencer had not met her initial burden to show that service was proper.Spencer appealed the decision, and the Court of Appeals reversed and remanded for an evidentiary hearing. The Court of Appeals concluded that Spencer had made a prima facie showing that service to Flavel was proper and the trial court erred in dismissing the case without first holding an evidentiary hearing to determine if Flavel was a “managing agent” or “office assistant” under RCW 4.28.080(9).The Supreme Court of the State of Washington granted Franklin Hills’s petition for review. The court concluded that the service statute is to be liberally construed to effectuate the purpose of accomplishing service of process and notice to the defendant. The court held that a person may be a managing agent if they are in charge of a single department of the corporation’s business, even if their discretion is controlled somewhat by a superior, provided that they have substantial managerial responsibilities and authority to act on behalf of the corporation. The court found that Flavel, as the human resources manager, met the definition of a managing agent under the statute. Therefore, the court affirmed in part, reversed in part, and remanded for further proceedings, allowing the lawsuit to proceed to discovery and trial. View "Spencer v. Franklin Hills Health-Spokane, LLC" on Justia Law

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The case involves Andrew Bertrand, who was convicted of two counts of first-degree child molestation. Bertrand argued that his counsel was ineffective for failing to propose lesser included offense instructions on fourth-degree assault. The trial court denied Bertrand's motion, ruling that although counsel was deficient for purposes of Strickland’s first prong, Bertrand could not show prejudice as required by Strickland’s second prong. The trial court ruled that because the State had met its burden of proving each element of first-degree child molestation and the jury convicted Bertrand of those charges, he could not show prejudice.The Supreme Court of the State of Washington clarified that a defendant can show ineffective assistance based on counsel’s failure to propose a lesser included offense instruction, even if there is sufficient evidence to support the jury’s verdict. However, the court affirmed the trial court's decision, stating that Bertrand was not prejudiced by his counsel’s failure to propose the fourth-degree assault instructions. The court remanded the remaining issues to the Court of Appeals for further proceedings. View "State v. Bertrand" on Justia Law

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The case involves an action filed by Spokane County Prosecuting Attorney Lawrence Haskell against Jilma Meneses, the secretary of the Washington State Department of Social and Health Services (DSHS). The Prosecutor sought a writ of mandamus directing Meneses to comply with statutory duties under chapter 10.77 RCW and timely provide competency services in criminal proceedings. The case specifically concerned three categories of Spokane County defendants in felony criminal proceedings ordered to receive competency services from DSHS.Previously, a class action was filed in federal court, challenging DSHS's delays in providing competency services to criminal defendants in pretrial custody. The United States District Court for the Western District of Washington held these delays violated the class members’ due process rights and issued a permanent injunction against DSHS. The injunction set strict time limits for providing competency services to defendants in pretrial custody, appointed a special court monitor, and began oversight of DSHS’s efforts to comply with the injunction.In the Supreme Court of the State of Washington, DSHS argued that the court must dismiss the petition for lack of original jurisdiction because the secretary is not a state officer within the meaning of the state constitution. The court agreed with DSHS, concluding that the secretary is not a state officer. The court reasoned that a state officer must be elected, subject to impeachment, and granted a State sovereign power, none of which applied to the secretary. Therefore, the court dismissed the petition for writ of mandamus. View "Spokane County v. Meneses" on Justia Law