Justia Washington Supreme Court Opinion Summaries

Initiative Measure 976 (I-976) was the latest in a series of initiatives about reducing or eliminating local motor vehicle excise taxes, including taxes that have been pledged to support major transportation projects in Washington state. Authorized regional transit authorities were empowered to ask their voters to approve transportation system proposals and financing secured by local taxes and fees, including local motor vehicle excise taxes. The legislature also empowered local transportation benefit districts and other local governments to impose taxes, including motor vehicle excise taxes, and fees to fund local transportation projects and to seek voter approval for additional funding. I-976 passed statewide with about 53 percent of the vote, though it was rejected by about 53 percent of the voters in the Sound Transit region, about 60 percent of King County voters, and about 70 percent of San Juan voters, who depended heavily on ferries funded by motor vehicle excise taxes. Several counties, cities, associations and private citizens (collectively challengers) challenged I-976’s constitutionality, arguing that I-976 contained multiple subjects in violation of article II, section 19’s single subject requirement. They also argued I-976 violated section 19’s subject-in-title requirement because the ballot title falsely suggested voter-approved motor vehicle taxes would not be repealed. The challengers successfully sought a preliminary injunction in King County Superior Court to block its implementation. The trial judge initially concluded that the plaintiffs were likely to prevail on the grounds that the ballot title was misleading. The Washington Supreme Court concurred I-976 contained more than one subject, and its subject was not accurately expressed in its title. Accordingly, I-976 was declared unconstitutional. View "Garfield Cty. Transp. Auth. v. Washington" on Justia Law

In 2010, Amanda Knight and accomplices ransacked James and Charlene Sanders’ home, zip-tied them, placed them face down on the floor, stole their wedding rings off their fingers at gunpoint, pistol-whipped Charlene and her son, and shot and killed James Sanders. A jury convicted Knight of multiple crimes, including felony murder in the first degree, two counts of robbery in the first degree, two counts of assault in the second degree, and burglary in the first degree. By way of personal restraint petition, Knight challenged these convictions on double jeopardy grounds, arguing that her robbery and felony murder conviction against James, as well as her robbery and assault conviction against Charlene, should have merged. The Court of Appeals held that the two convictions against James merged, but declined to review Knight’s convictions against Charlene because the Court of Appeals had previously reviewed and dismissed that double jeopardy claim on direct appeal. The Washington Supreme Court held that Knight’s convictions against James Sanders did not merge, and that review of her convictions against Charlene Sanders was barred. "Knight’s robbery and felony murder convictions against James served independent effects, falling under an exception to the double jeopardy merger doctrine. However, the Court of Appeals correctly held that Knight’s claim against her convictions in regards to Charlene is barred as it was already raised and dismissed on direct appeal. Accordingly, we affirm in part and reverse in part the Court of Appeals’ ruling, affirm Knight’s original conviction and sentence, and dismiss her personal restraint petition." View "In re Pers. Restraint of Knight" on Justia Law

A jury found Ira Cranshaw guilty of several crimes committed against two victims. The convictions included attempted first degree murder of B.B. (count I), three counts of first degree rape of B.B. (counts II, III, and IV), first degree kidnapping of B.B. (count V), harassment of B.B. (count VI), two counts of first degree rape of S.H. (counts VII and VIII), first degree kidnapping of S.H. (count IX), and harassment of S.H. (count X). On direct appeal, the Court of Appeals reversed Cranshaw’s convictions as to B.B. and remanded for a new trial on all of the counts involving her (I through VI), but it affirmed his convictions on the counts involving S.H. (counts VII through X) and remanded for resentencing on only those counts. This matter involved the proper calculation of an offender score in an unusual circumstance, which the State conceded resulted in Cranshaw receiving a longer sentence than he would have received if he had been sentenced in the normal manner. In May 2019, Cranshaw filed a personal restraint petition, raising a double jeopardy claim and a claim regarding the calculation of his offender scores. The acting chief judge dismissed the petition, and Cranshaw filed a motion for discretionary review. Cranshaw then moved to amend his motion for discretionary review, which the Washington Supreme Court allowed. After the State answered the amended motion for discretionary review, the deputy commissioner issued a ruling rejecting the double jeopardy claim. The Supreme Court determined the double jeopardy claim lacked merit, but the Court concluded Cranshaw demonstrated his judgment and sentence was facially invalid based on the offender score calculation, and he was entitled to be resentenced. View "In re Pers. Restraint of Cranshaw" on Justia Law

In May 2017, petitioner Gregg Loughbom was charged with three counts of various drug crimes: count I, delivery of controlled substances acetaminophen and hydrocodone; count II, delivery of controlled substance methamphetamine; and count III, conspiracy to deliver a controlled substance other than marijuana. These charges stemmed from two controlled drug buys conducted by a confidential informant (CI) on December 20 and 31, 2016. The information was later amended to include school zone enhancements for all three counts pursuant to RCW 69.50.435. During jury selection, the prosecutor asked, “Are there any among you who believe that we have a drug problem in Lincoln County?” He then commented, “Wow, okay. Just about every[one],” and followed with the question, “Is there anyone who feels that we don’t?” Thereafter, the prosecutor referenced the war on drugs three times. The issue this case presented for the Washington Supreme Court's review centered on whether the prosecutor committed reversible error when he repeatedly invoked the phrase, “war on drugs” during the one-day jury trial, without objection by petitioner. The Court held that the State’s framing of Loughbom’s prosecution as representative of the war on drugs denied Loughbom a fair trial and constitutes reversible error. Therefore, the Court reversed the Court of Appeals and remanded for a new trial. View "Washington v. Loughbom" on Justia Law

In 2018, the Washington legislature enacted Substitute House Bill 2887 (SHB 2887), requiring noncharter counties with populations of 400,000 or more to elect five county commissioners by 2022, when originally such counties were required to elect three. SHB 2887 would also require affected counties to fund a redistricting committee to create five districts, one for each commissioner. These counties had to hold individual district elections for these commissioners instead of countywide general elections. Spokane County, former and current Spokane County commissioners, and the Washington State Association of Counties argued this law violated article XI, section 4 of the Washington Constitution, mandating the legislature to establish a uniform system of county government, and article XI, section 5, requiring the legislature to provide for the election of county commissioners through general and uniform laws. The Washington Supreme Court held SHB 2887 was constitutional under article XI, sections 4 and 5: "the legislature may classify counties by population for any purpose that does not violate other constitutional provisions, and SHB 2887 is a general law that properly implements district-only elections for noncharter counties of a certain size." View "Spokane County v. Washington" on Justia Law

The juvenile court terminated N.B.’s parental rights to his son, M.B., while N.B. was incarcerated. N.B. made clear that he strongly desired to participate in the termination trial by phone or in person. Despite this, most of the three-day trial occurred in his absence. N.B. was allowed to appear only by phone and for only a portion of the third day. Under the circumstances, the Washington Supreme Court concluded this was not fair and violated due process. The Court therefore reversed termination and remanded for a new trial. View "In re Welfare of M.B." on Justia Law

This matter came before the Washington Supreme Court on a petition for a writ of mandamus from five inmates serving criminal sentences at different Washington Department of Corrections (Department) facilities. The Supreme Court retained jurisdiction because of the extraordinary nature of the relief petitioners sought, and because of the extraordinary danger COVID-19 (coronavirus disease) posed to inmates in Washington’s prisons. Rather, the parties agreed on a record that mainly included descriptions of the prison conditions, expert opinions on the risks that COVID-19 presented in the prison environment, and petitioners’ declarations as to their individual situations. For purposes of the Court's decision, it accepted petitioners’ factual descriptions as true. The petitioners claimed close confinement created a substantial risk of harm because of the current public health emergency caused by COVID-19. "These concerns are legitimate and well founded:" the current widely reported medical evidence suggested COVID-19 risks of serious complications or death are highest for offenders over age 50 and those with certain preexisting medical conditions, but it could also be serious for younger people and those in good health. And serious outbreaks have occurred at other prisons and jails nationwide. "But mandamus is not the answer for every emergency, and it cannot deliver the relief petitioners seek here." The Washington Supreme Court concluded that without a showing an official in the executive branch failed to perform a mandatory nondiscretionary duty, courts had no authority under law to issue a writ of mandamus, no matter how dire the emergency. Petitioners alternatively sought leave to amend their petition by filing a personal restraint petition. But on the record before the Court, they did not show respondents acted with deliberate indifference to the extreme risk that COVID-19 created for the incarcerated. "Amending their mandamus petition would therefore be futile." For these reasons, the Supreme Court dismissed the mandamus action and denied the motion to amend. View "Colvin v. Inslee" on Justia Law

In 2017, John Jackson Sr. was charged with assault in the second degree, domestic violence, for strangling his fiancee. At every court appearance, Jackson was forced to wear some form of restraints pursuant to jail policy. The trial court did not engage in any individualized determination of whether restraints were necessary for courtroom safety but, instead, filed a consolidated opinion adopting the jail policy for all superior court appearances for all incarcerated defendants. After a jury found Jackson guilty, he appealed, arguing that his constitutional right to due process was violated for being forced to wear restraints without an individualized inquiry into their necessity. The Court of Appeals concurred with this argument, but held the violation was harmless beyond a reasonable doubt. With respect to the latter portion of the appellate court's holding, the Washington Supreme Court revered, finding the State did not prove the harmlessness of the shackling, and did not show the error to be harmless beyond a reasonable doubt. The matter was remanded for a new trial with instructions that at all stages of the proceedings, the trial court make an individualized inquiry into whether shackels or restraints were necessary. View "Washington v. Jackson" on Justia Law

The plaintiff class in this case sued the State of Washington and the Office of Public Defense (OPD), alleging ongoing violations of the right to counsel in Grays Harbor County Juvenile Court. They premised state liability not only on alleged systemic, structural deficiencies in the state system, but also on the State and OPD’s alleged knowledge of Grays Harbor County’s specific failures to safeguard the constitutional right to counsel. The Washington Supreme Court determined that while the State bears responsibility to enact a statutory scheme under which local governments can adequately fund and administer a system of indigent public defense, it was not directly answerable for aggregated claims of ineffective assistance of counsel. Rather, to prevail on their claims against the State, the plaintiff class had to show that the current statutory scheme systemically failed to provide local governments, across Washington, with the authority and means necessary to furnish constitutionally adequate indigent public defense services. Given that standard, the Supreme Court rejected plaintiffs’ claims premised on the State and OPD’s alleged knowledge or awareness of Grays Harbor County’s failure to provide adequate public defense services. “Such an allegation cannot support state liability even if we could fairly impute knowledge or awareness or awareness of a particular county’s failings to the State. Plaintiffs’ claims alleging systemic, structural deficiencies in the public defense system remained viable. Therefore, the Court affirmed the superior court’s denial of the State’s motion for summary judgment in part, and remanded the matter for further proceedings. View "Davison v. Washington" on Justia Law

Julia Tucker stole a snowmobile and was convicted of theft of a motor vehicle. On appeal, she argued a snowmobile was not a motor vehicle under the relevant statute, RCW 9A.56.065. The Washington Supreme Court found snowmobiles were unambiguously included as motor vehicles under the statute. Therefore, Tucker’s conviction was affirmed. View "Washington v. Van Wolvelaere" on Justia Law