Justia Washington Supreme Court Opinion Summaries

Petitioner Abraham MacDicken was arrested carrying a laptop bag and pushing a rolling duffel bag. He was suspected of armed robbery. The officers moved the bags a car's length away to search them. MacDicken argued that search violated his state and federal constitutional rights. The Supreme Court recently held that police may search an arrestee's person and possessions closely associated with the person at the time of arrest without violating constitutional rights; MacDicken argued the bags were not closely associated with him at the time of arrest to give police the right to search them without a warrant. The Supreme Court disagreed held the police conducted a valid search. View "Washington v. MacDicken" on Justia Law

A police detective read text messages on a cell phone police seized from Daniel Lee, who had been arrested for possession of heroin. Among other things, the detective read an incoming text message from Shawn Hinton, responded to it posing as Lee, and arranged a drug deal. Hinton was consequently arrested and charged with attempted possession of heroin. Hinton argued on appeal of his conviction that the detective's conduct violated his rights under the state and federal constitutions. Upon review, the Supreme Court agreed that Hinton's rights were violated when the officer intercepted the private text message without Lee's or Hinton's consent or warrant. Accordingly, the Court reversed the Court of Appeals' decision and Hinton's conviction. View "Washington v. Hinton" on Justia Law

The issue before the Supreme Court in this case was whether the Department of Ecology erred in determining that no environmental impact statement (EIS) was necessary for a proposed energy cogeneration project, and failed to adequately consider the effects of carbon dioxide emissions and demand for woody biomass from the state's forests. In addition, the issue on appeal centered on whether the project was exempt from the EIS requirement as part of an energy recovery facility that existed before January 1, 1989. After review, the Supreme Court concluded Ecology adequately reviewed the relevant information in determining that the project would not have significant impacts on the environment, and the project was exempt from the EIS requirement. View "PT Air Watchers v. Dep't of Ecology" on Justia Law

In this case, the trial court granted a new trial after Edwin Hawkins produced new evidence that supported his defense theory that he was framed for possessing stolen farm equipment. The Court of Appeals did not give that decision its proper deference. The Supreme Court reversed because the trial court did not abuse its wide discretion in awarding Hawkins a new trial. View "Washington v. Hawkins" on Justia Law

In early 2013, Pierce County detained the 10 respondents in this case (all patients) under the Involuntary Treatment Act (ITA). In most cases, the respondents were initially held in hospital emergency rooms or in local acute care medical hospitals. None of these sites were certified as evaluation and treatment centers under the ITA. In all cases, the county, through one of its designated mental health providers, filed petitions to hold the respondents for up to 14 more days. Several of the involuntarily detained patients moved to dismiss these 14-day petitions on the grounds that they had not been, and believed they would not be, detained in a certified evaluation and treatment facility. A trial judge found that the patients' placement in uncertified treatment centers, a/k/a "psychiatric boarding," was unlawful. Pierce County appealed, but the Supreme Court agreed with the trial judge and affirmed. View "In Re Det. of D.W." on Justia Law

Petitioner Phillip Garcia Jr. appealed his convictions for kidnapping in the first degree, burglary in the second degree, and criminal trespass in the first degree. He argued that that the evidence was insufficient to support each of the alternative means of kidnapping presented to the jury, that the trial court violated his confrontation rights by limiting his cross-examination of an adverse witness, that the trial court erroneously admitted evidence of a prior crime of dishonesty, and that the prosecutor incorrectly defined "burglary" during closing arguments. Upon review of the trial court record, the Supreme Court reversed petitioner's convictions for kidnapping in the first degree because there was insufficient evidence to support that conviction. The Court reversed the conviction for burglary in the second degree because of prejudicial trial error. But the Court affirmed his conviction for criminal trespass in the first degree because the errors petitioner claimed were harmless. View "Washington v. Garcia" on Justia Law

The State prosecuted petitioner David Gower for sex crimes against his 17-year-old stepdaughter S.E.H. In accordance with ER 404(b) and RCW 10.58.090, the State offered evidence that petitioner had committed other similar crimes against two other alleged juvenile victims, C.M. (his biological daughter) and J.K. (another stepdaughter). In a pretrial evidentiary hearing on the admissibility of that evidence, the trial court ruled it was all inadmissible under ER 404(b). But the trial court acknowledged that admissibility of that evidence under RCW 10.58.090 was a separate question and concluded that although the evidence of other sex offenses was inadmissible under ER 404(b), the evidence of the prior crimes relating to C.M. was admissible under RCW 10.58.090. In 2009, between the statute's enactment arid subsequent invalidation in 2012, the trial court admitted evidence of petitioner's prior sex offenses against him at trial. He was ultimately convicted. Because that evidence was improperly admitted and considered by the trial judge in finding petitioner guilty, the Supreme Court reversed his conviction and remanded the case for a new trial. View "Washington v. Gower" on Justia Law

The issue this case presented to the Supreme Court was whether the trial court erred in admitting evidence of a secretly recorded conversation between defendant William Kipp and his brother-in-law in violation of Washington's privacy act. Kipp was convicted of two counts of rape of a child and one count of child molestation in the second degree. Before trial, Kipp moved to suppress the recording, relying on the privacy act. The trial court ruled that the recording was not a private conversation and, therefore, not subject to suppression. A jury found Kipp guilty and he appealed. The Court of Appeals affirmed. After its review, the Supreme Court concluded that for purposes of the privacy act, when facts are undisputed, the question of whether a particular communication is private is a matter of law reviewed de novo. In this case, Kipp's conversation with his brother-in-law was private and therefore should have been suppressed. View "Washington v. Kipp" on Justia Law

The certified questions in this case centered on whether, the exemption of nonprofit religious organizations from the definition of "employer" under Washington's Law Against Discrimination (WLAD), violates article I, section 11 or article I, section 12 of the Washington Constitution. Larry Ockletree sued his former employer, Franciscan Health System (PHS), challenging the termination of his employment after he had a stroke. Ockletree, who is African-American, claimed that his termination was the result of illegal discrimination on the basis of race and disability. FHS removed the suit to federal court and moved to dismiss Ockletree's claims. FHS argued that it was exempt from WLAD as a nonprofit religious organization. Ockletree challenged the validity of the religious employer exemption under the state and federal constitutions. The district court certified questions to this court asking whether the religious employer exemption violated Washington's article I, section 11 establishment clause or its article I, section 12 privileges and immunities clause. The Washington Supreme Court answered both questions in the negative. View "Ockletree v. Franciscan Health Sys." on Justia Law

Homer Gibson applied to Kittitas County for a conditional use permit (CUP) that would allow him to conduct rock crushing and other gravel and cement production related activities on his agricultural-zoned property. Kittitas gave notice that it would hold a public hearing on the CUP. Ellensburg Cement Products, Inc. objected to the CUP application and appealed Kittitas's SEPA Determination of Non-Significance (DNS) under the county's administrative appeal procedures. Kittitas first considered the SEPA appeal in a "closed record" hearing, and upheld the DNS. It then held an "open record" public hearing on the CUP, and granted Gibson's application over Ellensburg Cement's objections. Ellensburg Cement appealed both decisions to the superior court, which affirmed, and then to the Court of Appeals, which reversed. The Court of Appeals held that Kittitas was statutorily required to hold an "open record hearing" on the appeal of the SEP A DNS and that rock crushing was not a permissible conditional use under Kittitas's relevant zoning regulations. After its review, the Supreme Court found no error with the appellate court's decision and affirmed. View "Ellensburg Cement Prods., Inc. v. Kittitas County" on Justia Law