Justia Washington Supreme Court Opinion Summaries

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

Petitioner Dominique Avington argued his own trial testimony was sufficient to require a lesser included offense instruction for the shooting death of Terrance King. Specifically, Avington testified that although he fired his gun, he was not aiming directly at anyone, and he argued that his credibility should have been determined by the jury. The undisputed evidence at trial showed that the bullet that killed King did not come from Avington’s gun. As a result, Avington’s testimony about the direction of his aim did not create a question of fact for the jury as to whether he participated in King’s death under circumstances manifesting an extreme indifference to human life. The issue this case presented for the Washington Supreme Court was whether the trial court properly exercised its discretion when it declined to instruct the jury on first degree manslaughter as a lesser included offense of first degree murder by extreme indifference. Consistent with Washington v. Coryell, 483 P.3d 98 (2021), the answer was yes. "The record shows that the trial court carefully reviewed all of the evidence admitted at trial in light of the charged offenses, properly instructed the jury on accomplice liability, and properly exercised its discretion in declining to instruct the jury on a lesser included offense of first degree manslaughter." View "Washington v. Avington" on Justia Law

Acting under enhanced powers to act in an emergency under RCW 43.06.220 and related statutes, the Washington Governor Inslee imposed a moratorium on evicting people from their homes for failing to pay rent from March 2020 through June 2021. The Washington Supreme Court was asked whether this eviction moratorium was lawful. The Court concluded that it was and affirmed the courts below. View "Gonzales v. Inslee" on Justia Law

Michael Reynolds Jr. received a mandatory sentence of life in prison without possibility of parole for a crime he committed at age 33. The events triggering that sentence, though, were his two “strikes” under Washington’s “three strikes” law—one of which Reynolds committed at age 17, when he was a juvenile. If Reynolds’ current sentence constituted punishment for his earlier offense committed at age 17, then it would be unconstitutional under case law. But under the Washington Supreme Court’s more recent precedent, his current sentence did not constitute punishment for that prior offense. In Washington v. Moretti, decided two years after Bassett, the Supreme Court held that a “three strikes” sentence of mandatory life in prison without possibility of parole constituted punishment for the last crime or third “strike,” not the earlier first or second “strikes.” “And for years, we have held that our state’s ‘three strikes’ law as applied to adults does not violate article I, section 14.2 That assessment could certainly change over time. But in this case, the parties have not asked us to overrule it.” The Court therefore affirmed the Court of Appeals. View "Washington v. Reynolds" on Justia Law

Following waves of protests across the country calling for racial justice and reform of police practices, the Washington Legislature enacted several statutes in 2021 establishing requirements for tactics and equipment used by peace officers. This case concerned article XI, section 5 of the Washington Constitution and the constitutionality of RCW 10.116.030(3)(a), which required sheriffs of non charter counties receive authorization from the chair of the board of county commissioners prior to deploying tear gas in response to a riot. The trial court on motion for summary judgment, held that the statute violated article XI, section 5 by interfering with the sheriff’s core functions. Finding no reversible error in that judgment, the Washington Supreme Court affirmed. View "Snaza v. Washington" on Justia Law

In this action, the Wahkiakum School District (WSD) alleged the State of Washington “fail[ed] to amply fund the [WSD]’s needed facilities [and] infrastructure.” WSD argued that this failure violated the Washington Constitution, article IX, section 1. The complaint explained the impact of this lack of ample funding for facilities and infrastructure: “The [WSD] is a poor, rural school district located along the banks of the Columbia River. It has less than 500 students. Approximately 57% of its students are low income. It has less than 3500 registered voters. And the per capita income of its voters is approximately $29,000.” Specifically, the WSD requested that the State pay the cost of rebuilding its elementary, middle, and high schools; it estimated more than $50 million in construction costs. The State moved to dismiss for failure to state a claim (CR 12(b)(6)) and for lack of jurisdiction (CR 12(b)(1)). In support of its motion, the State argued, “[F]unding for school construction and other capital expenditures is governed by entirely different constitutional and statutory provisions that primarily look to local school districts themselves, with the State providing funding assistance. As such, WSD fails to state a claim on which relief can be granted . . . .” It also argued that the court could not award monetary damages because the legislature has not created a private right of action and monetary damages would violate separation of powers principles. The WSD conceded that it failed to file a tort claim form and thus that its claim for monetary damages was barred. The trial court granted the motion to dismiss with prejudice. After review, the Washington Supreme Court concluded the constitution did not include capital construction costs within the category of “education” costs for which the State alone must make “ample provision.” The Court thus affirmed the trial court's decision to grant the motion to dismiss. View "Wahkiakum Sch. Dist. No. 200 v. Washington" on Justia Law

Dahndre Westwood entered A.B.’s house around 4:30 a.m. A.B. saw Westwood standing in her hallway and holding a knife in his hand. Westwood told her to get undressed and threatened to kill her if she did not cooperate. A.B. screamed for help and pleaded for her life; she clawed at Westwood and knocked the knife out of his hand. During the struggle, Westwood nicked A.B. with the knife, leaving a scar on her cheek. Westwood choked and suffocated A.B. to muffle her screams for help and hit her repeatedly on the head. Several cars passed A.B.’s house while this transpired, and the headlights shone in the window. Westwood stopped his assault after the second or third set of headlights passed. He threatened A.B. that if she told anyone about the assault he would come back to kill her. Westwood then ran into the living room and out the front door. A.B. called 911 and was taken to the hospital by first responders shortly after. A jury convicted Westwood of attempted rape in the first degree, assault in the first degree, assault in the second degree, and burglary in the first degree. At sentencing, Westwood argued that his convictions encompassed the same criminal conduct for scoring purposes. The State disagreed and asked the court to apply the analysis from Washington v. Chenoweth, 370 P.3d 6 (2016). The trial court determined that the three convictions did not constitute the same criminal conduct because each of the crimes required a different statutory intent. Westwood appealed, arguing that Washington v. Dunaway, 743 P.2d 1237, 749 P.2d 160 (1987) controlled. The Court of Appeals remanded the case to the trial court for determination of whether the convictions encompassed the same criminal conduct under the analysis of Dunaway. Some lower courts found conflict between the analysis in Dunaway and that in Chenoweth. The Washington Supreme Court took the opportunity to provide guidance on the relationship between these cases and found no conflict existed. Here, the objective statutory intent analysis was the proper test. The Court affirmed the sentencing court’s decision and reversed the Court of Appeals. View "Washington v. Westwood" on Justia Law