Justia Washington Supreme Court Opinion Summaries

The issue this case presented for the Supreme Court's review centered on whether the trial court closed the courtroom during trial in violation of the defendant's rights under article I, section 22 of the Washington Constitution. The Court of Appeals reversed respondent Benito Gomez's convictions for second degree murder and six counts of first degree assault on the grounds that the trial judge effected an unconstitutional closure of the courtroom during trial by his pretrial comment that the public would not be permitted to enter the courtroom once the proceedings began. The Supreme Court reversed after review: the Court disagreed that the trial judge, by mere virtue of making this remark, fully excluded the public from entering the courtroom and, thus, there was no basis for finding a constitutional violation; and second, even if the Court could presume the brief comment was enforced, this limitation to courtroom entry did not constitute a closure. View "Washingotn v. Gomez" on Justia Law

This case involved two public school employees who were on paid administrative leave while their employer investigated allegations of misconduct. The substance behind those allegations was not in the trial court record, but the District's investigations were then-ongoing and entering their fourth year. In the spring of 2012, two media outlets submitted public records requests to the District. One request sought the "administrative leave letter given to Anthony Predisik, a Shadle Park High School counselor." The other request asked for "information on all district employees currently on paid/non-paid administrative leave." The requests returned three public records relevant to this dispute. The issue this case presented for the Supreme Court's review centered on whether public records that revealed these investigations are occurring, but do not describe the allegations being investigated, implicated the employees' privacy rights under the Public Records Act (PRA), chapter 42.56 RCW. The Court held they did not. Because no exemption applies to withhold the records from public inspection, the Court reversed and remanded with instructions to order the records at issue disclosed in their entirety without redaction. View "Predisik v. Spokane Sch. Dist. No. 81" on Justia Law

Howard Shale was an enrolled member of the Yakama Nation. He had family in the Quinault Indian Nation as well. In 1997, Shale was convicted under federal law of raping a child under 12. After Shale was released from prison, he moved to Seattle and registered as a sex offender with the King County sheriff. In 2012, a Jefferson County sheriffs detective began investigating whether Shale had moved to her county without reregistering as a sex offender. At least two officers assisted the detective in her investigation; a Jefferson County sheriffs deputy and a Quinault tribal police officer. Taken together, police reports suggested Shale was dividing his time between the two family homes. Based on the detective's report, the Jefferson County prosecutor charged Shale with failure to register with the county sheriff as a sex offender under RCW 9A.44.130(1)(a). The issue this case presented for the Supreme Court's review was whether Washington State had the power to prosecute an enrolled member of the Yakama Nation living on the Quinault Indian Nation's reservation for failing to register with the county sheriff as a sex offender. The Court found the State indeed had that power. View "Washington v. Shale" on Justia Law

Matthew Bruch was convicted of two counts of second degree child molestation and two counts of third degree rape of a child. The trial court imposed a standard range sentence of 116 months of confinement and ordered community custody for a period of "at least 4 months, plus all accrued earned early release time at the time of release." Bruch appealed his sentence, arguing that the court-imposed term of community custody was indeterminate and may exceed the statutory requirement of three years of community custody required under RCW 9.94A.701(1). The Court of Appeals rejected Bruch's challenge, as did the Supreme Court: (1) the total sentence did not exceed the applicable statutory maximum, consistent with RCW 9.94A.701(9); . there was no need for the trial court to amend Bruch's sentence to limit community custody to a maximum of three years, "[t]he statutes must be read together to assure that the trial court's intended sentence-a total term of 120 months-is not undermined by giving effect to the DOC's authority to transfer earned early release into community custody." View "Washington v. Bruch" on Justia Law

Petitioners Nicholas Blazina and Mauricio Paige-Colter were ordered to pay discretionary legal financial obligations (LFOs). The trial court record in each petitioner's case did not reflect that the trial judges considered either party's ability to pay before imposing the LFOs. Neither petitioner objected at the time. For the first time on appeal, however, both argued that the judges in their respective cases should have made an inquiry into their ability to pay, and that failing to make this inquiry warranted resentencing. The Court of Appeals declined to reach the issue because both petitioners failed to object at sentencing, and therefore failed to preserve the issue for appeal. Petitioners appealed the Court of Appeals' and trial courts' rulings to the Supreme Court, and in each case, the Court concluded that the Court of Appeals did not err in declining to reach the merits. However, exercising its own discretion, the Supreme Court reached the merits and held that the trial court had a statutory obligation to make an individualized inquiry into a defendant's current and future ability to pay before the imposition of LFOs. The cases were remanded for the trial courts to make these inquiries. View "Washington v. Blazina" on Justia Law

In 2008, teenager Philip Johnson called his close friend (and fellow Hilltop Crips gang member) defendant-respondent Marsele Henderson to say he was going to a party at a Boys and Girls Club. Henderson advised Johnson not to go because the club was too close to a rival gang's territory. Johnson went to the party, where he was shot. Henderson learned of the shooting and went to the hospital with his friends, including Koloneus D'Orman McClarron, to check on Johnson. Johnson died shortly thereafter at the hospital, although McClarron and Henderson testified that they did not learn of his death at the hospital. One of the disputed-facts in this case was how many people were in the area in front of the house prior to shots being fired, because whether a person shot into a crowd of people or whether they shot toward an area with very few people might have determined the nature of the crime. Witness testimony on this point varied significantly. Witnesses testified that either McClarron or Henderson pulled a gun and fired six shots toward the house from the street. McClarron testified that Henderson fired the shots, but Henderson testified that it was McClarron who did it. Neither could give an explanation as to why the other person fired the gun. Four people testified that the shooter yelled something related to the Hilltop Crips at the time of the shooting. Witnesses were divided about whether the shooter looked like Henderson or McClarron. prosecutors charged Henderson with first degree murder by extreme indifference. At trial, Henderson asked that the jury be instructed on the lesser included charge of first degree manslaughter. Initially, the State agreed, acknowledging that the definitions of first degree murder by extreme indifference and first degree manslaughter are "very close" and that there is "hardly a difference." The State later changed its position based on two Court of Appeals cases from 1998 and 1999: "Washington v. Pettus," (951 P.2d 284 (1998)), and "Washington v. Pastrana," (972 P.2d 557 (1999)). In both of those cases, the Court of Appeals held that the defendants were not entitled to a jury instruction on the lesser included offense of manslaughter because the defendants' actions were much more than merely reckless. The Supreme Court later narrowed the definition of reckless in the context of manslaughter in "Washington v. Gamble," (114 P.3d 646 (2005)), to specifically mean a disregard of a substantial risk of homicide. Defendant's trial counsel did not bring "Gamble" to the attention of the trial court, and as a result, the trial court agreed with the State that "Pettus" and "Pastrana" were controlling and refused to instruct on manslaughter. The jury convicted Henderson of first degree murder by extreme indifference. Henderson appealed, contending that the trial court erred when it refused to instruct the jury on first degree manslaughter. The Court of Appeals reversed Henderson's conviction, holding that he was entitled to the instruction. Upon review, the Supreme Court agreed, affirmed the Court of Appeals and reversed Henderson's conviction. View "Washington v. Henderson" on Justia Law

In 2010, the Washington Supreme Court found that the State Legislature's 2003 amendments to the state's water law were facially constitutional. In this case, Appellants Scott Cornelius, Palouse Water Conservation Network, and Sierra Club Palouse Group (collectively Cornelius) brought an as-applied constitutional claim (among other claims) against Washington State University (WSU), the Department of Ecology, and the Pollution Control Hearings Board (PCHB). Upon further review, the Supreme Court found that the amendments were applied constitutionally, and found appellants' other claims unavailing. View "Cornelius v. Dep't of Ecology" on Justia Law

In the late 1980s, Alan Meirhofer was charged with several counts of brutally raping children, along with charges of burglary and kidnapping. Meirhofer was implicated in several more child rapes. As Meirhofer finished serving his criminal sentence, the State brought SVP commitment proceedings against him under the sexually violent predator (SVP) act, chapter 71.09 RCW, in 2000. He sought a full evidentiary proceeding on whether he still met the statutory and constitutional criteria for SVP commitment. Before holding such a full evidentiary proceeding, the SVP act directs trial courts to hold an initial show cause hearing to determine whether the State has presented prima facie evidence that continued commitment is justified or the detainee has presented prima facie evidence that his or her condition has "so changed" as to warrant a new evidentiary proceeding. The trial court found the State had made its showing and Meirhofer had not. Finding no reversible error, the Supreme Court affirmed. View "In re Pers. Restraint of Meirhofer" on Justia Law

The State charged Larry Hayes with one count of leading organized crime and one count of identity theft in the first degree, among several other charges. The State alleged that Hayes was involved in a complex identity theft scheme that used stolen credit card information, including information stolen from a hair salon's customer receipts, to manufacture false identification devices and credit cards. These in turn would be used to make purchases and rent vehicles, usually from out of state, with those rental vehicles sold for cash. The State also alleged that each count (except for a drug charge) was subject to the sentence aggravators for being a major economic offense. The issue this case presented for the Washington Supreme Court's review centered on whether a trial court may impose an exceptional sentence on a defendant under the major economic offense sentence aggravators found in RCW 9.94A.535(3)(d)(i) and (iii) when that defendant's conviction was based on accomplice liability. The Court agreed with the Court of Appeals's decision that the trial court improperly applied the sentence aggravators to Hayes. View "Washington v. Hayes" on Justia Law

WestNET was a multiagency, multijurisdictional drug task force formed by an "Interlocal Drug Task Force Agreement" executed in June 2009 among several Washington State municipalities and the federal Naval Criminal Investigation Service (NCIS). The Agreement at issue here explicitly provided that because WestNET "does and must operate confidentially and without public input," "[t]he parties do not intend to create through, this Agreement, a separate legal entity subject to suit." In 2010, petitioner John Worthington filed a public records request that WestNET disclose records related to a raid of his residence four years earlier, which he alleged was conducted by the WestNET drug task force. WestNET did not respond, and instead, the Kitsap County Sheriffs Office made some initial disclosures. The sheriffs office did not indicate why it responded instead of WestNET. Dissatisfied with the response, Worthington sued for relief under the Public Records Act, serving the complaint on the address shared by the Kitsap County Sheriffs Office and the Kitsap County Prosecutor's Office. However, the complaint named WestNET as the only defendant. Because the trial court granted the defendant's CR 12(b)(6) motion to dismiss, the issue presented for the Supreme Court's review was a narrower procedural issue: can the parties to an inter local agreement establish, as a matter of law, that their own task forces do not exist for the purpose of the PRA? The Court held that the ICA did not provide the contributing agencies with such an unqualified power. In concluding that the terms of the agreement alone conclusively established WestNET's capacity for suit, the trial court deprived the plaintiff of an opportunity to present evidence in support of his argument that WestNET's actual operational structure subjects it to the PRA's purview. That approach is inconsistent with our general approach to PRA issues and the ICA itself. Accordingly, the Court reversed the Court of Appeals and remanded the case for further factual determination proceedings. View "Worthington v. WestNET" on Justia Law