Justia Washington Supreme Court Opinion Summaries

After an amendment to the Washington Law Against Discrimination (WLAD), Debra Loeffelholz sued the University of Washington and her superior, James Lukehart (collectively “University”), for discrimination based on sexual orientation. She alleged the sexual-orientation-based discrimination created a hostile work environment based on a series of preamendment acts and one potentially postamendment act. This case presented two related issues on appeal: (1) whether the WLAD amendment applied retroactively and, if not, whether preamendment discriminatory conduct is actionable and (2) whether a single comment made postamendment is a discriminatory act. Upon review, the Supreme Court held that the WLAD amendment is not retroactive and that the preamendment conduct was not actionable as it was not unlawful when it occurred. The postamendment, allegedly discriminatory comment is arguably similar enough to the preamendment conduct to survive summary judgment. Consequently, the Court affirmed the Court of Appeals only in reversing summary judgment for the University and clarified that the Court of Appeals erred in allowing recovery for preamendment conduct. View "Loeffelholz v. Univ. of Wash." on Justia Law

Respondent Michael Gendler made a public records request for location-specific accident reports from the Washington State Patrol (WSP). The WSP refused to provide the records unless Gendler certified that he would not use the records in any litigation against the State, claiming a federal statute (23 U.S.C. sec. 409) protected the records sought. WSP claimed the records were shielded because they were located in an electronic database that the Department of Transportation (DOT) utilized for purposes related to the federal hazard elimination program. Respondent then brought a suit under the PRA and argued section 409 did not apply to the WSP because it did not compile or collect the information for the hazard elimination program's purposes. Rather, the information was collected pursuant to WSP’s statutory duty under RCW 46.52.060. The trial court agreed and on summary judgment ordered WSP to produce the requested accident reports. The Court of Appeals affirmed. The Supreme Court also affirmed because section 409 does not extend to police accident reports generated and received by WSP pursuant to its own statutory duty. View "Gendler v. Batiste" on Justia Law

Petitioner John Hurst was charged with a felony, but he was found incompetent to stand trial. He was twice committed to a mental health treatment facility. After two 90-day periods in the facility, Petitioner failed to regain competency. The State sought a third and final mental health treatment period, lasting this time for up to 180 days. The issue before the Supreme Court centered on the standard of proof required to commit an incompetent criminal defendant charged with a felony to a third mental health treatment period. Petitioner alleged that the due process clause of the Fourteenth Amendment of the federal constitution requires that the standard of proof be "clear, cogent and convincing evidence." The Supreme Court disagreed: "the legislature's selected preponderance of the evidence standard satisfied the Due Process Clause." Accordingly, the Court affirmed the appellate court. View "Washington v. Hurst" on Justia Law

Petitioner Demar Rhome argued on direct appeal to the Supreme Court that the state and federal constitutions require independent findings of fact that a defendant is competent to waive counsel and represent himself at trial. In November of 2003, 17-year-old Lashonda Flynn was stabbed to death. Seventeen-year-old Kialani Brown confessed to the killing but pointed to Defendant as the mastermind behind the slaying. Defendant was charged in King County Superior Court with first degree murder with a deadly weapon. Defendant's mental competency became an issue at trial. After considering the evidence and arguments of counsel, the superior court found that the defense had not met the burden of proving Defendant was incompetent to stand trial. Shortly after the competency hearing, Defendant received new counsel. Defendant represented himself throughout his 2006 proceedings with counsel on stand-by. In reviewing his performance during pretrial and trial proceedings, a defense expert opined that Defendant's mental illness impacted his ability to defend himself in court. Defendant was convicted by a jury as charged and sentenced to 371 months in prison. Represented by appointed federal public defenders, Defendant filed this original personal restraint petition to challenge the trial court’s decision to allow him to waive counsel and proceed pro se. Upon review, the Supreme Court found that Defendant did not demonstrate that federal or state law requires an independent determination of mental competency to proceed pro se when a mentally ill defendant seeks to waive counsel: "[e]ven if such a rule could be crafted from [federal case law] in conjunction with this court’s precedent, Rhome cannot benefit from that rule on a personal restraint petition." The Court also concluded that Defendant failed to show the trial court abused its discretion when it found his waiver of counsel to be knowing and intelligent. The Court dismissed Defendant's petition. View "In re Pers. Restraint of Rhome" on Justia Law

The primary issue presented in this case was whether former RCW 9.92.151 (2004) or the equal protection clause of the United States Constitution requires a county jail to provide opportunities for an inmate who is yet to be sentenced to earn credit toward early release, also known as "good-time" credit. Petitioner, Teddy Talley argued that the Skamania County Jail and the Department of Corrections (Department) violated the former RCW 9.92.151(1) and the Constitution by not providing opportunities for him to earn good-time credit before his criminal conviction. Skamania County argued that the statutory issue was not properly before the Supreme Court and that its program for earning good-time credit is constitutional. The Department argued that it may rely on a county’s jail-time certification when determining the appropriate amount of good-time credit to apply toward early release. Upon review, the Supreme Court held that the matter was properly before it, and that the former RCW 9.92.151 required a county jail to provide opportunities for a presentence inmate to earn good-time credit. The Court did not reach Defendant's constitutional argument. Because the Skamania County Jail policy conflicted with the former RCW 9.92.151, the Court calculated that Defendant should have received an earned early-release credit at the statutory maximum rate of 15 percent. View "In re Pers. Restraint of Talley" on Justia Law

Ten special education students and their parents and guardians (Appellants) sued Clover Park School District for intentional torts, outrage, negligence and unlawful discrimination under state law. Clover Park moved for summary judgment to dismiss, arguing that Appellants had not exhausted the administrative remedies available under the state Individuals with Disabilities Education Act (IDEA). The trial court granted Clover Park’s motion. Upon review, the Supreme Court reversed the trial court and remanded the case, holding that IDEA’s administrative exhaustion requirement does not apply to state-law claims nor does Washington State law require exhaustion before filing such claims. View "Dowler v. Clover Park Sch. Dist. No. 400" on Justia Law

The issue before the court came from the involuntary commitment of D.F.F. The trial judge closed her proceedings to the public as a matter of course under state law. D.F.F. challenged her commitment on appeal, arguing that the mandatory closure of the proceedings violated her rights under the Washington Constitution. The Court of Appeals held that the law was unconstitutional and reversed the commitment order. The Supreme Court held upon review that "a fundamentally different brand of justice is administered when courts are open and the parties, witnesses and judge all conduct their affairs in the light of day. Providing a transcript of a closed proceedings falls far short of guaranteeing open justice." The Court affirmed the appellate court's holding that the applicable state law (MPR 1.3) is unconstitutional and reversed D.F.F.'s commitment order. The case was remanded for new commitment proceedings. View "In re Detention of D.F.F." on Justia Law

A reporter from the News Tribune newspaper sought access to the deposition of a material witness in a criminal trial. The deposition took place in a courtroom with the judge present. Without engaging in an inquiry into the factors pursuant to "Seattle Times Co. v. Ishikawa," the trial court closed the courtroom on the ground that depositions are not open to the public. The deposition was not introduced at trial and did not become part of the court's decision making process. The News Tribune sought a writ of mandamus to compel the production of the transcript and videotape of the deposition, arguing that it had the right to attend the deposition under the Washington State Constitution and the First Amendment to the federal constitution. Under the circumstances of this case, the Supreme Court concluded that neither the state or federal constitution was violated by the trial court's ruling that the deposition proceeding was not open to the public: "The News Tribune's claim that the location and presence of the judge turned the deposition into a 'hearing' to which the open courts protections apply" was incorrect. Accordingly, the Court denied the News Tribune's application for a writ of mandamus. View "Tacoma News, Inc. v. Cayce" on Justia Law

Washington law provides that the State's decision to revoke a home childcare license should be upheld if it is supported at an evidentiary hearing by a preponderance of the evidence. In a prior holding, the Supreme Court held that due process required the State to support a decision to revoke a nursing assistant's registration under a higher standard of "clear and convincing" evidence. In this case, the principal issue was whether the strictures of due process required the State to support its decision to revoke a home childcare license by the higher standard. Respondent Kathleen Hardee's license was revoked. She requested a hearing, and a review judge reversed the hearing officer's decision, finding that the Department of Early Learning proved its case by a preponderance of the evidence. The superior court and Court of Appeals affirmed the order. Upon review, the Supreme Court overruled its prior decision, and held in this case that due process required not more than a preponderance of the evidence to justify the revocation of a home child care license. View "Hardee v. Washington" on Justia Law