Justia Washington Supreme Court Opinion Summaries

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

In 2011, 17-year-old Darren Harris fatally stabbed an acquaintance and stole his wallet. Harris was charged with first-degree murder with a deadly weapon. After negotiations, Harris pleaded guilty to second-degree murder and first-degree robbery, with a joint sentence recommendation of 244 months. The trial court accepted the plea and imposed the recommended sentence.Harris later filed a personal restraint petition, arguing for resentencing based on the State v. Houston-Sconiers decision, which requires courts to consider the mitigating qualities of youth. The Court of Appeals dismissed the petition as frivolous but later granted Harris an extension to appeal. The Court of Appeals found that Harris had agreed not to seek a lesser sentence and concluded that any resentencing would breach the plea agreement. The court held that Houston-Sconiers applied retroactively but did not require resentencing, suggesting Harris could withdraw his guilty plea instead.The Supreme Court of Washington reviewed the case and held that when a trial court accepts a plea agreement with a joint sentence recommendation, it is not required to independently consider mitigating evidence of youth under Houston-Sconiers. The court emphasized the importance of plea bargaining in the criminal justice system and concluded that no error occurred when the trial court did not inquire into Harris's youth before accepting the plea agreement. The court reversed the Court of Appeals' decision in part, affirming Harris's sentence and holding that resentencing was not required. View "State v. Harris" on Justia Law

Charles Scott Frazier was convicted of murder and arson against his father in 1989 and received a 50-year exceptional sentence. Nearly 30 years later, Frazier sought resentencing, citing new scientific evidence on adolescent brain development, arguing that this evidence should exempt his personal restraint petition (PRP) from the one-year time limit under RCW 10.73.100(1).The superior court transferred Frazier's motion to the Court of Appeals, which dismissed his PRP as time-barred. Frazier then sought discretionary review from the Washington Supreme Court, which granted review solely on the issue of newly discovered evidence.The Washington Supreme Court reaffirmed that the newly discovered evidence exemption can apply to sentencing evidence, including new scientific developments. However, the court emphasized that petitioners must show they acted with reasonable diligence in discovering the evidence and filing the petition, and must satisfy the five-factor test for newly discovered evidence.In Frazier's case, the court found that he did not act with reasonable diligence. Although modern scientific studies on adolescent neurodevelopment were cited as early as 2005, Frazier did not file his collateral attack until 2018. The court noted that Frazier did not provide evidence of any diligent efforts to discover the new scientific studies and file his PRP.Additionally, the court found that Frazier did not satisfy the five-factor test for newly discovered evidence. The court concluded that the new studies on adolescent brain development would not probably change the result of Frazier's sentencing, as his exceptional sentence was based on findings of cruelty and abuse of trust, which were well-supported by the record.Therefore, the Washington Supreme Court affirmed the Court of Appeals' dismissal of Frazier's PRP as time-barred. View "In re Pers. Restraint of Frazier" on Justia Law

Jim Walsh, a member of the Washington State House of Representatives, along with other appellants, submitted six initiatives to the legislature. Three of these initiatives were enacted, while the remaining three—repealing the Washington Climate Commitment Act, repealing the state’s capital gains tax, and making participation in the state’s long-term care insurance program optional—were set to appear on the November 2024 ballot. The appellants sought to prevent public investment impact disclosures from appearing on the ballot, arguing that these disclosures were not warranted.The Thurston County Superior Court denied the appellants' request for writs of mandamus and prohibition, dismissing their complaint. The court found that the capital gains tax was not impliedly repealed by another initiative and that the other two initiatives did indeed modify a "tax or fee," thus requiring public investment impact disclosures. The appellants then appealed directly to the Supreme Court of the State of Washington.The Supreme Court of the State of Washington affirmed the lower court's decision. The court held that the writs of prohibition and mandamus were not appropriate in this case. The attorney general and the secretary of state were acting within their jurisdiction and statutory obligations. The court also noted that the appellants had not demonstrated the absence of a plain, speedy, and adequate remedy in the ordinary course of legal proceedings. Therefore, the trial court's denial of relief and dismissal of the case were upheld. View "Walsh v. Hobbs" on Justia Law

On June 3, 2017, Deputy Alexander Hawley of the King County Sheriff’s Office conducted an illegal stop of Malcolm Otha McGee, suspecting a drug transaction. During the stop, Hawley obtained McGee’s identity, phone number, and seized drugs. McGee agreed to become a confidential informant but never followed up. The next day, a 911 caller reported gunfire, and a month later, the body of Keith Ayson, who had a drug dealing relationship with McGee, was found. Police used evidence from the illegal stop to obtain warrants for McGee’s phone records, which linked him to the crime scene.The trial court ruled the June 3 stop was illegal and suppressed the drug evidence, dismissing the drug charge. However, it allowed the State to use evidence from the stop to establish McGee’s motive for murder. McGee’s first trial ended in a mistrial. Before the second trial, McGee moved to suppress evidence obtained from subsequent warrants, arguing they were based on the illegal stop. The trial court denied the motion, finding the evidence was sufficiently attenuated from the illegal stop. McGee was convicted of second-degree murder and sentenced to 298 months plus a 60-month firearm enhancement.The Washington State Court of Appeals reversed McGee’s conviction, holding that the evidence obtained from the illegal stop should have been suppressed, as it was not sufficiently attenuated. The court found that subsequent warrants relied on tainted evidence, necessitating suppression of all derived evidence and McGee’s statements to police.The Washington Supreme Court affirmed the Court of Appeals, holding that the attenuation doctrine did not apply because the new criminal act did not sever the causal connection between the illegal stop and the discovery of evidence. The court emphasized the strong privacy protections under the Washington State Constitution and rejected the State’s argument to expand the attenuation doctrine. The case was remanded for a new trial. View "State v. McGee" on Justia Law

A group of 16 related LLCs, which generate all their income from investments in distressed debt instruments, sought a refund for business and occupation (B&O) taxes paid, claiming their income was deductible as "investment income" under RCW 82.04.4281. The statute allows deductions for "amounts derived from investments," but does not define "investments." The LLCs argued that their income qualified for this deduction.The Washington State Department of Revenue audited the LLCs and denied their refund claim. The LLCs challenged this decision in superior court. The superior court granted summary judgment for the Department, ruling that the legislature did not change the definition of "investments" when it amended the statute in 2002. The court relied on the precedent set in O’Leary v. Department of Revenue, which defined "investments" as "incidental investments of surplus funds." The LLCs' motion for reconsideration was denied.The LLCs appealed, and the Court of Appeals affirmed the superior court's decision. The appellate court found that the legislature did not intend to abrogate the O’Leary definition when it amended the statute. The LLCs then petitioned for review by the Washington Supreme Court.The Washington Supreme Court held that the legislature did not abrogate the O’Leary definition of "investments" when it amended RCW 82.04.4281. The court found no clear legislative intent to change the definition, noting that the amendments were primarily aimed at addressing issues raised by the Simpson decision and the ambiguous phrase "other financial businesses." Consequently, the court affirmed that "investments" continues to mean "incidental investment of surplus funds," and the LLCs could not deduct income earned from their primary business activities. The trial court and the Court of Appeals' decisions were affirmed. View "Antio, LLC v. Dep't of Revenue" on Justia Law

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