Justia Washington Supreme Court Opinion Summaries

Petitioner Pamela Deskins challenged the sentence she received after a jury found her guilty of a misdemeanor violation of the cruelty to animals statute. On appeal to the Supreme Court, she argued: (1) the trial court abused its discretion when it prohibited her from owning or living with animals as a condition of probation; (2) that the trial court abused its discretion when it ordered her to forfeit any remaining animals to the Stevens County Sheriffs Office after giving her seven days to find them new homes; and (3) the trial court violated her due process rights by proceeding to sentencing 22 minutes after the verdict and imposing restitution to reimburse the county for animal care. The Supreme Court held that the forfeiture challenge was moot, and affirmed the Court of Appeals on all other issues.View "Washington v. Deskins" on Justia Law

Respondent Jeramie Owens and a friend visited a car dealership in Mount Vernon after seeing a 1967 Volkswagen (VW) Beetle with a high performance engine, roof rack and surfboard on top. They took the car on a test ride but left without purchasing the car or leaving their names. The next day, a salesman opened the dealership and discovered that the same 1967 VW Beetle that respondent test drove the day before had been stolen, and one of the dealer's keys was missing. The next business day, respondent registered a 1971 VW Beetle, the registration for which had expired in 1993. In response to a listing on Craig's List, Craig Sauvageau purchased the 1971 Beetle from respondent. Claiming that he had lost the title respondent provided Sauvageau an affidavit in lieu of title. Savageau took the car to his mechanic to have it inspected, and the mechanic discovered that the VIN registered by respondent a few days prior appeared to be brand new with reinstalled rivets. Savageau called police to report the car as potentially stolen. Police discovered the confidential VIN matched that of the stolen 1967 VW from the dealership. Respondent would later be charged with first degree taking a motor vehicle without permission, first degree trafficking in stolen property, possession of a stolen vehicle and bail jumping. A jury convicted respondent on all charges but taking a motor vehicle without permission. The issue this case presented for the Supreme Court's review involved whether whether RCW 9A.82.050(1) described alternative means of committing first degree trafficking in stolen property, and if so, whether substantial evidence supported each of the alternative means in this case. The Court of Appeals held that RCW 9A.82.050 described eight alternative means of committing the crime, and because there was insufficient evidence to support at least one of those eight means, the court reversed respondent's conviction. The Supreme Court reversed the Court of Appeals, reinstated the conviction, and held that RCW 9A.82.050 described only two alternative means, and in this case, each was supported by sufficient evidence.View "Washington v. Owens" on Justia Law

The United States District Court for the Western District of Washington certified a question of Washington law to the Washington Supreme Court. The issue centered on whether Washington law recognized a cause of action for monetary damages where a plaintiff alleges violations of the deeds of trust act (DTA), chapter 61.24 RCW, but no foreclosure sale has been completed. The Supreme Court was also asked to articulate the principles that would apply to such a claim under the DTA and the Consumer Protection Act (CPA), chapter 19.86 RCW. The Court held that the DTA does not create an independent cause of action for monetary damages based on alleged violations of its provisions where no foreclosure sale has been completed. The answer to the first certified question was no-at least not pursuant to the DT A itself. Furthermore, the Court found that under appropriate factual circumstances, DTA violations may be actionable under the CPA, even where no foreclosure sale has been completed. The answer to the second certified question was that the same principles that govern CPA claims generally apply to CPA claims based on alleged DTA violations. View "Frias v. Asset Foreclosure Servs., Inc." on Justia Law

At issue in this case was whether ERISA preempted claims made under two Washington state laws designed to ensure that workers on public projects are paid for their work: chapters 39.08 and 60.28 RCW. When the Washington Supreme Court previously addressed this issue in 1994 and 2000, it held that ERISA preempted such claims. As a result of this conflict between Washington's rule and the rule followed by federal courts, the outcome of this type of case in Washington was entirely dependent on whether the lawsuit was filed in federal or state court. This has led to forum shopping, and created inconsistent and unjust results for parties in Washington. In light of the national shift in ERISA preemption jurisprudence and the persuasive reasoning underlying that shift, the Washington Court, through this opinion, joined courts across the country and held that this type of state law was not preempted by ERISA.View "W.G. Clark Constr. Co. v. Pac. Nw. Reg'l Council of Carpenters" on Justia Law

Robert Lee Yates Jr. agreed to plead guilty to thirteen counts of aggravated first degree murder and one count of attempted first degree murder in exchange for a 408-year prison sentence. Yates sought to withdraw those guilty pleas, claiming that he should technically have been sentenced to 408 years with a possible extension to life in prison rather than a determinate 408-year sentence. Because he did not show that he was prejudiced by this difference, the Supreme Court dismissed his personal restraint petition.View "In re Pers. Restraint of Yates" on Justia Law

In 1993 Petitioner Garth Snively pled guilty to a single count of indecent liberties and two counts of first degree child molestation. Relying on the plea agreement, the trial court imposed two years of community placement on each conviction. But community placement was not authorized for indecent liberties at that time. Snively did not appeal, making the judgment and sentence final when it was filed in the trial court. In 2003 the State relied on the 1993 convictions in filing a petition alleging that Snively was a sexually violent predator subject to civil commitment. In 2006 a jury found Snively to be a sexually violent predator, resulting in his civil commitment. In 2010 Snively filed a personal restraint petition in the Court of Appeals, challenging the commitment by way of collaterally attacking his 1993 convictions. He claimed specifically that he was entitled to withdraw his guilty pleas due to the erroneous community placement term. The Court of Appeals allowed Garth Snively to withdraw his plea of guilty to indecent liberties because of a facially invalid sentence. Because Snively's sole remedy for the sentencing error was correction of the judgment and sentence, the Supreme Court reversed the Court of Appeals as to that issue. View "In re Pers. Restraint of Snively" on Justia Law

The State charged Joseph McEnroe and Michele Anderson with aggravated first degree murder and sought the death sentence for each of them. Roughly five and a half years after the State filed its notices of intent to seek the death penalty, the trial court ruled that the absence of "'sufficient mitigating circumstances to merit leniency"' was an essential element of the crime of capital murder in Washington and that the State had allege the absence of sufficient mitigating circumstances in the charging information. The trial court gave the State two weeks to amend each charging information to allege insufficient mitigating circumstances; if the State failed do to so, the court would entertain a defense motion to dismiss the State's notices of intent to seek the death penalty. The State appealed that order. Upon review, the Supreme Court reversed the trial court's decision to compel the State to amend each information or face dismissal of the notice of special sentencing proceeding. The notice of special sentencing proceeding afforded the defendants constitutionally and statutorily adequate notice that the State intended to prove the absence of sufficient mitigating circumstances to merit leniency. View "Washington v. McEnroe" on Justia Law

Timothy Dobbs engaged in a campaign of threats, harassment, and intimidation against his ex-girlfriend, C.R., that included a drive-by shooting at her home and warnings that she would "'get it"' for calling the police and she would "regret it" if she pressed charges against him. C.R. reported the increasingly violent activities of Dobbs against her. After Dobbs was arrested, he made yet another intimidating phone call to C.R., threatening that if she went forward and pressed charges against him, she would regret it. When C.R. failed to show up to testify at trial, the trial judge found that there was clear, cogent, and convincing evidence that Dobbs was the cause of her absence and thus had forfeited his confrontation right. Dobbs appealed the trial court's decision, but the Supreme Court, after its review, agreed with the trial court: "[w]hile Dobbs ha[d] the right to confront witnesses against him, he forfeited his right to confront C.R. when he chose to threaten her with violence for cooperating with the legal system. . . . To permit the defendant to profit from such conduct would be contrary to public policy, common sense and the underlying purpose of the confrontation clause." View "Washington v. Dobbs" on Justia Law

The United States District Court for the Eastern District of Washington certified a question of Washington law to the Washington Supreme Court. This lawsuit involved two consolidated suits. Plaintiffs filed an amended complaint, alleging claims under Washington's Consumer Protection Act (WCPA), chapter 19.86 RCW, and the federal Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. sections 1692-1692p. These claims were based in part on plaintiffs' assertion that Midland Funding's business arrangements and debt collection processes violated the WCAA. The questions the federal court raised were: (1) Does the definition of "collection agency" in RCW 19.16.1 00(2) include a person who purchases claims that are owed or due or asserted to be owed or due another, undertakes no activity on said delinquent consumer account but rather contracts with an affiliated collection agency to collect the purchased claims, and is the named plaintiff in a subsequent collection lawsuit for said purchased claims?; and (2) Can a company file lawsuits in Washington on delinquent consumer accounts without being licensed as a collection agency as defined by RCW 19.16.1 00(2)? The Supreme Court responded that that debt buyers fall within the definition of "collection agency" under the Washington Collection Agency Act (WCAA), chapter 19.16 RCW, when they solicit claims for collection. Accordingly, if the court finds that a company (party in this suit) solicited claims, then the company was a collection agency and it could not file collection lawsuits without a license. View "Gray v. Suttell & Assocs." on Justia Law

In 1993, petitioner Lindsey Crumpton was convicted of five counts of first degree rape and one count of residential burglary. In 2011, he petitioned the court for post-conviction deoxyribonucleic acid (DNA) testing. The superior court denied this motion, saying he had not shown a '"likelihood that the DNA evidence would demonstrate his innocence on a more probable than not basis"' as is required by RCW 10.73.170(3). The Court of Appeals affirmed. The issue this case presented for the Supreme Court's review was the standard the court should use to decide a motion for post-conviction DNA testing and whether a court should presume DNA evidence would be favorable to the convicted individual when determining if it is likely the evidence would prove his or her innocence. The Court held that a court should use such a presumption. View "Washington v. Crumpton" on Justia Law