Justia Washington Supreme Court Opinion Summaries

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

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

In this case from the Supreme Court of the State of Washington, several construction industry associations challenged a 2018 law (RCW 39.12.015(3)) that changed the method for determining prevailing wage rates on public works projects. Prior to the law, the State used wage and hour surveys to establish the prevailing wage rates. The 2018 law directed the State to adopt the wage rates established in collective bargaining agreements (CBAs) for those trades and occupations that have CBAs.The plaintiffs argued that the new law violated a provision of the Washington Constitution (article II, section 37) because it conflicted with an older law (RCW 39.12.026(1)) that restricted the use of wage data collected by the State to the county in which the work was performed. The Court of Appeals agreed and declared the new law unconstitutional.The Supreme Court of the State of Washington reversed the Court of Appeals' decision. It held that the older law's restriction on the use of wage data applied only to data collected through wage and hour surveys, not to wage rates adopted from CBAs. Therefore, the older law did not conflict with the new law, and the new law did not violate the state constitution. The court remanded the case for further proceedings consistent with its opinion. View "Associated General Contractors Of Washington v. State" on Justia Law

In "King County v. Michael J. Abernathy et al.", the Supreme Court of the State of Washington answered a question certified by the United States District Court for the Western District of Washington. The case involved a dispute over the ownership of a 3.6 mile section of land along the shore of Lake Sammamish, known as the Corridor. In 1887, prior to Washington becoming a state, a railroad company was granted a "right-of-way" to build a railroad over the Corridor. Since then, the Corridor and surrounding shorelands have been used by various parties including individual property owners, the state, and the county. The certified question asked whether a right-of-way approved by the United States Department of the Interior under the General Railroad Right-of-Way Act of 1875 is a conveyance "patented by the United States" under Article XVII, Section 2 of the Washington State Constitution. If the land was "patented" by the federal government, it would have been owned by the railroad and later King County. If the land was not patented, Washington would have owned it at the time of statehood and later conveyed it to private parties, and the shoreland would currently belong to the homeowners, the Abernathys. The Washington Supreme Court held that the right-of-way was an easement and did not constitute a land conveyance patented by the United States. Therefore, the land belonged to Washington at the time of statehood and is presently owned by the homeowners. View "King County v. Abernathy" on Justia Law

In the State of Washington, a man named Mitchell Heng was charged with murder, arson, and robbery. He was brought before a judge for a preliminary hearing without counsel, during which the judge set bail among other things. Heng argued that counsel should have been present at this hearing. The Supreme Court of the State of Washington agreed, noting that a person charged with a crime has a right to counsel under the state and federal constitutions and under court rules. However, the court found that Heng did not demonstrate that the hearing was a critical stage of the prosecution, and it believed that the absence of counsel did not contribute to the verdict. Consequently, the court affirmed the decisions of the lower courts.The facts of the case reveal that Heng was implicated in a robbery at Sifton Market during which Amy Hooser was killed. Surveillance footage showed Heng at the scene with a blood-stained shirt and a lighter in his hands. He was charged the next day with first degree murder, first degree robbery, and first degree arson. Heng was held in jail for 31 months before his trial, during which time he made inconsistent statements during recorded phone calls about the events of the night of the crime. He was eventually convicted of first degree murder and first degree arson and was sentenced to 374 months in prison.Heng appealed his conviction, arguing that his right to counsel had been violated at a critical stage of the prosecution. The Supreme Court of the State of Washington held that while Heng should have had counsel present at his preliminary hearing, this did not constitute a critical stage of the prosecution. The court also noted that in order for an error to be considered structural and thus necessitate automatic reversal, it must have substantively affected the outcome of the case. The court determined that Heng’s case was not demonstrably affected by his counsel’s absence. As such, the court applied constitutional harmless error analysis, which requires the court to reverse unless it is persuaded beyond a reasonable doubt that the error did not contribute to the verdict. The court concluded that the failure to have counsel present at Heng’s preliminary hearing was harmless beyond a reasonable doubt, and thus affirmed the decisions of the lower courts. View "State v. Heng" on Justia Law

Michael Shawn Charlton was arrested and charged with third-degree child rape, third-degree child molestation, and indecent liberties. He appeared in preliminary hearings without counsel, which he argued on appeal was a denial of his constitutional right to counsel at critical stages of the prosecution. The Supreme Court of the State of Washington held that while the absence of counsel was indeed a constitutional error, it did not constitute a critical stage of litigation requiring automatic reversal. The court reasoned that nothing in the record suggested that Charlton's rights were lost, defenses were waived, privileges were claimed or waived, or that the outcome of the case was otherwise substantially affected by the absence of counsel. Furthermore, the court concluded that any error in not having counsel present was harmless beyond a reasonable doubt. This is because there was no evidence to suggest that the lack of counsel affected the verdict in any way. Consequently, the court affirmed the decision of the Court of Appeals. View "State v. Charlton" on Justia Law

In the case presented, plaintiff Bette Bennett alleged that she suffered a traumatic brain injury due to medical negligence by the defendant, the United States. However, the cause of her injury was not diagnosed until after the eight-year statute of repose for medical malpractice actions under Washington law had expired, making it impossible for her to timely commence her lawsuit. The United States moved to dismiss her complaint as time-barred.The Supreme Court of the State of Washington was asked to decide whether the statute of repose violates certain provisions of the Washington Constitution. The court held that while the legislature has broad authority to set time limits for commencing an action, the eight-year statute of repose for medical malpractice actions under RCW 4.16.350(3) violates the privileges and immunities clause of article I, section 12 of the Washington Constitution. The court reasoned that the statute implicates the fundamental right of state citizenship by limiting the pursuit of common law claims against certain defendants, but it does not satisfy the "reasonable ground" test under the state constitution. Therefore, the court concluded that the statute of repose is unconstitutional under independent state law. The court declined to reach the second certified question regarding whether the statute of repose unconstitutionally restricts a plaintiff's right to access the courts in violation of the Washington Constitution. View "Bennett v. United States" on Justia Law

In a prior case before the Washington Supreme Court, the Court rejected Petitioner Amanda Knight’s claim her separate convictions for felony murder (based on first-degree robbery) and first degree robbery violated the constitutional protection against double jeopardy. Double jeopardy did not apply because Knight’s felony murder and robbery convictions were premised on different conduct: the felony murder charge was based on the robbery of a safe whereas the first degree robbery was based on the robbery of a ring. Knight moved for reconsideration and that petition was denied. Here, Knight argued that given the Court’s previous holding, her conviction for felony murder had to be reversed because the jury was presented with insufficient evidence to justify a conviction for robbery of the safe. The Supreme Court concluded the basis for the felony murder conviction could not be sustained, granted Knight’s petition for relief, vacated the felony murder conviction and remanded for resentencing. View "In re Pers. Restraint of Knight" on Justia Law

A jury convicted Respondent Vanessa Valdiglesias LaValle of two counts of criminal solicitation after she told her minor son, S.G., that he could be with her “forever” if he poisoned his father. The Court of Appeals reversed the conviction on the ground that Valdiglesias LaValle’s offer to live with S.G. “forever” if S.G. killed his father did not constitute a “thing of value” within the meaning of RCW 9A.28.030(1). The Washington Supreme Court reversed the Court of Appeals. The Court held the plain meaning of “money or other thing of value” in RCW 9A.28.030(1) unambiguously included both money and things that were not money but that, like money, possessed utility, desirability, significance, and/or economic value. "Nothing in the plain language or context of the statute indicates that 'other thing of value' must be limited to things with a traditional economic or market value." View "Washington v. Valdiglesias LaValle" on Justia Law

Respondent John McWhorter pleaded guilty in adult court to crimes he committed when he was a juvenile. He later moved for resentencing to enable the trial court to consider the mitigating qualities of his youth. The superior court granted the motion for a resentencing hearing, and the State appealed this order to the Court of Appeals. That court ruled that the superior court’s order was not appealable by the State, so it dismissed the appeal. The State filed a petition for review to the Washington Supreme Court, who reversed the Court of Appeals and remanded to that court to consider the State’s appeal. View "Washington v. McWhorter" on Justia Law