Justia Washington Supreme Court Opinion Summaries

In 2015, Petitioner Randall Hoffman submitted a public records request to the Kittitas County Sheriff’s Office seeking police reports referencing an individual, Erin Schnebly. The clerk at the sheriff’s office did not locate any photos or videos, though the office’s electronic case management system indicted there were 95 photographs and 2 videos related to responsive reports. The clerk, telephoning Hoffman for clarification, stated she could not find any involvement by Hoffman in the incidents, and had not found any photos or videos. Based on an erroneous interpretation of RCW 42.56.050 which the parties agreed was indeed, erroneous, the clerk told Hoffman that because he was not a party involved in the reports, she could not release a majority of the documents found. Hoffman sued respondents Kittitas County and the Kittitas County Sheriff’s Office (hereinafter collectively County), alleging that the clerk’s initial response violated the Public Records Act. Hoffman argued the trial court's finding that the agency respondents lacked bad faith was reviewable de novo. But the Washington Supreme Court reviewed for abuse of discretion when imposing a penalty pursuant to the PRA, in line with the prevailing case law. The Court determined the trial court did not abuse its discretion by imposing a $15,498 penalty. View "Hoffman v. Kittitas County" on Justia Law

This case concerned whether the city of Tacoma (City) could be held liable for damages for imposing an unlawful condition on a building permit. The Church of the Divine submitted an application to the City to build a parsonage on property it owned. A single-family residence had previously been located on the property, but it had been demolished in 2012. City staff reviewed the permit application and placed a number of conditions on it, including, at issue here, a requirement that the Church dedicate a 30-foot-wide strip of land for right-of-way improvements to a street abutting the property. While the existing street was generally 60 feet wide in other areas, it was 30 feet wide next to the Church's property. This lack of uniformity had existed for around 100 years. The Church challenged the permit conditions, and the City eventually removed most of them but kept the requirement for a dedication. The Church appealed the decision to the City's hearing examiner, and the hearing examiner granted summary judgment in favor of the City. The Church appealed under the Land Use Petition Act (LUPA), in which it challenged the hearing examiner's decision and also sought damages under RCW 64.40.020. In addressing the propriety of the dedication, the court confined its review to the administrative record that had been before the hearing examiner and acknowledged that, in that record, the stated purpose by the City for imposing the dedication requirement was to create a uniform street. The court held that this reason was insufficient to justify the requirement and reversed the hearing examiner, invalidating the condition. A trial court denied the Church’s request for damages and the Church appealed. The Court of Appeals affirmed the trial court. The Washington Supreme Court revered however, finding that the City's subjective belief that the dedication was lawful did not determine what it objectively should reasonably have known. The Court of Appeals erred in reasoning otherwise. The matter was remanded for a new trial. View "Church of the Divine Earth v. City of Tacoma" on Justia Law

Two Tonasket voters petitioned to recall City Council member Jill Ritter from office. The petition made six allegations relating to improper influence over a police investigation of a relative’s son, improperly reviewing police personnel records, certain public statements made about Tonasket police, and conspiracy to disband the police force. The superior court determined all allegations were insufficient to warrant a recall election; finding no reversible error, the Washington Supreme Court affirmed that decision. View "In re Recall of Ritter" on Justia Law

Two Tonasket voters petitioned to recall City Council member Christia “Teagan” Levine from office. The petition alleged Levin committed five violations relating to certain city personnel actions, conspiracy to remove the City Attorney and cause the Mayor to resign as part of an illegal quorum, withholding public records, and conspiring to disband the city police force. After a hearing, the trial court dismissed all charges, finding them factually and legally insufficient to sustain further action. Finding no reversible error in that judgment, the Washington Supreme Court affirmed. View "In re Recall of Levine" on Justia Law

A recall petition was filed against the Mayor and three Cathlamet council members; charges stemmed from Cathlamet’s purchase of a parcel of property at 20 Butler street. The petition alleged a violation of the Washington Constitution as a gift of public funds to the seller of the Butler Street property, Bernadette Goodroe. One additional charge against one town counselor alleged violation of RCW 42.23.070(2), prohibiting municipal officials from giving or receiving gifts related to their official capacities. The Washington Supreme Court determined the charges in the recall petition was legally insufficient, because acquisition of real property is a fundamental government purpose and discretionary act that was not manifestly unreasonable under the circumstances of this case. Accordingly, the Supreme Court affirmed the superior court. View "In re Recall of Burnham" on Justia Law

Petitioner Freedom Foundation filed a public records request for documents relating to union organizing by several University of Washington (UW) faculty members. The UW asked one of the faculty to search his e-mail accounts for responsive records, and after reviewing those records, gave notice that it intended to release many of them in the absence of an injunction. Respondent Service Employees International Union 925 sued to enjoin release of any union-related records, arguing they were not "public records" under 42.56 RCW, the Washington Public Records Act. The trial court granted the injunction and the Court of Appeals affirmed. The Foundation petitioned the Washington Supreme Court for review, arguing that the "scope of employment test" employed by the trial court and affirmed on appeal, only applied to records stored on an employee's personal device, and should not have been extended to records on public agencies' e-mail servers. The Supreme Court agreed, reversed and remanded. View "Serv. Emps. Int'l Union Local 925 v. Univ. of Wash." on Justia Law

The federal district court in Washington State certified a question of law to the Washington Supreme Court. Plaintiffs Valerie Sampson and David Raymond (collectively, Sampson) were Washington residents who worked as commercial truck drivers for defendants Knight Transportation Inc., Knight Refrigerated, LLC, and Knight Port Services LLC (collectively, Knight). Plaintiffs brought this putative class action on behalf of themselves and others similarly situated for several alleged violations of Washington wage and hour laws. At issue here was Sampson's claim that piece-rate drivers must receive separate hourly compensation for all time spent "on-duty not- driving." The question the federal court posed to the Supreme Court was whether the Washington Minimum Wage Act required non-agricultural employers to pay their piece-rate employees per hour for time spent performing activities outside of piece-rate work. The Supreme Court responded: no. "All workers must be compensated for all hours worked in a work week in accordance with the Minimum Wage Act (MWA). For nonagricultural workers, WAC 296-126-021 validly allows employers to demonstrate compliance with the MWA's guaranty that Washington workers receive a minimum wage for each hour worked by ensuring that the total wages for the week do not fall below the statutory minimum wage for each hour worked. Accordingly, the plaintiffs in this case fail to demonstrate as a matter of law that they were uncompensated for time spent "loading and unloading, pre-trip inspections, fueling, detention at a shipper or consignee, washing trucks, and other similar activities." View "Sampson v. Knight Transp., Inc." on Justia Law

Group Health Cooperative (GHO) provided health insurance benefits to Nathaniel (Joel) Coon, who suffered a serious fungal infection and amputation following knee surgery at the Everett Clinic (TEC). The Coon family later settled potential negligence claims against TEC, and GHO initiated this lawsuit seeking reimbursement of its payments from the settlement proceeds. At issue before the Washington Supreme Court was whether genuine issues of material fact remained to preclude summary judgment in favor of GHO regarding whether the settlement constituted full compensation to Coon, and whether GHO suffered prejudice from the Coons’ failure to provide notice prior to finalizing the settlement. The Supreme Court concurred with the Court of Appeals’ conclusion that genuine issues of fact still remained, making summary judgment inappropriate. The matter was remanded for further proceedings. View "Grp. Health Coop. v. Coon" on Justia Law

At issue was whether the Washington State Housing Finance Commission (“Commission”) had standing to challenge the National Homebuyers Fund’s (“NHF”) authority to provide down payment assistance to Washington residents in conjunction with federally insured mortgages. The Commission alleged NHF was falsely claiming governmental authority when it provided down payment assistance in Washington, impermissibly competing with the Commission’s own activities. The Court of Appeals reversed a trial court’s summary judgment in favor of the Commission on the basis that the Commission lacked standing. The Washington Supreme Court disagreed, finding the Commission indeed had standing. View "Wash. State Hous. Fin. Comm'n v. Nat'l Homebuyers Fund, Inc." on Justia Law

Teresa Banowsky filed a claim for medical malpractice in Washington district court on the last day of the statute of limitations, seeking over $100,000. District courts could exercise jurisdiction over medical malpractice claims, but not over claims seeking over $100,000. CRLH 14A(b) directs district courts to remove or transfer cases to superior court when any party asserts a claim in excess of the district court’s jurisdiction, or seeks a remedy beyond the court’s jurisdiction. The Washington Supreme Court held CRLJ 14A(b) validly and unambiguously required the district court to transfer Banowsky’s case to superior court. View "Banowsky v. Backstrom" on Justia Law