Justia Washington Supreme Court Opinion Summaries

The trial court excluded defendant Andre Franklin's proffered evidence that someone else committed the cyberstalking-related crimes with which he was charged. The Supreme Court reversed: "the United States Constitution bars the trial court from considering the strength or weakness of the State's case in deciding whether to exclude defense-proffered other suspect evidence. [. . .] our cases hold that if there is an adequate nexus between the alleged other suspect and the crime, such evidence should be admitted. The trial court violated both of these rules: it considered the strength of the State's case against the defendant and it applied a per se standard to exclude the other suspect evidence. Thus, its exclusion of the proffered other suspect evidence was error under both our case law and our constitution." View "Washington v. Franklin" on Justia Law

Jennifer Holmes and James Lindsay entered the home of Laurence Wilkey, Holmes's former boyfriend. They tied him up, beat him, and took a number of items from his home. The State charged Holmes and Lindsay with first degree robbery, burglary, kidnapping, assault, and firearm theft. Holmes and Lindsay argued that they did not intend to commit a felony but were instead repossessing things that Wilkey had originally stolen from Holmes. A jury convicted them on most, but not all, counts. On appeal, Holmes and Lindsay argued that the prosecutor's remarks, particularly during closing arguments, constituted misconduct that prejudiced both defendants. The Court of Appeals agreed that the prosecutor committed misconduct but split as to whether that misconduct caused prejudice. "[G]iven the magnitude of the problem and the lawyers' inability to control their conduct," the Supreme Court agreed with the Court of Appeals' dissent and reversed the trial court. View "Washington v. Lindsay" on Justia Law

The issue this case presented to the Supreme Court was whether Samuel Piatnitsky unequivocally invoked his right to remain silent when he told police investigating a murder that, "I don't want to talk right now" but that he would "write it down." The Court concluded that it was, "at best," an equivocal invocation of the right to remain silent, and thus, the trial judge did not err in admitting Piatnitsky' s written confession. View "Washington v. Piatnitsky" on Justia Law

Petitioner Cesar Trochez-Jimenez appealed his conviction for murder in the second degree, arguing the statements he made during custodial interrogation should have been suppressed because they were taken in violation of his Miranda rights. The case law petitioner cited on appeal held that prior to custodial interrogation, a suspect must be informed of his right to remain silent and right to counsel, and once the suspect invokes his right to counsel, no further interrogation about any offense by any authorities could be conducted until counsel was present or the suspect initiated communication. These cases, however, involved only domestic investigations regarding domestic crimes. At issue before the Supreme Court was whether the same rule applied when a suspect requests an attorney during an interrogation conducted outside the United States by foreign authorities regarding a foreign crime. Both the trial court and Court of Appeals said it did not. The Supreme Court agreed and affirmed. View "Washington v. Trochez-Jimenez" on Justia Law

Respondent-cross-petitioner J.C. Johnson was convicted of five crimes related to several days of ongoing domestic violence against his wife. A jury convicted Johnson for holding his wife “J.J.” under his control, allowing her only to leave their apartment when Johnson left, using his Rottweiler to restrain her movements, and keeping a knife and icepick near the bed to intimidate her. For three days, Johnson severely injured his wife by choking her, hitting her with rocks, and allowing the dog to bite her. J.J. managed to escape and receive treatment for her injuries. On appeal, Johnson argued: (1) the information for the unlawful imprisonment charges were insufficient because it did not include a definition of the word “restraint;” and (2) he received ineffective assistance of counsel when his trial lawyer proposed a definition of “reckless” in jury instructions that did not include charge-specific language when the “to convict” instruction included the specific language. The Court of Appeals overturned Johnson’s unlawful imprisonment conviction because the State omitted the definition of “restrain.” The appellate court agreed with Johnson that it was error to give a jury instruction on a generic definition of “reckless,” but that trial counsel was not ineffective for proposing it. The Supreme Court reversed on the “restraint” issue, holding that charging documents need only contain essential elements of a crime, not related definitions. With regard to the “reckless” issue, the Supreme Court affirmed the Court of Appeals, but for a different reason: it was not error to instruct a jury on the generic definition as long as the jury was given a “to convict” instruction that lists every element of the crime the State needs to prove in order to convict the defendant. View "Washington v. Johnson" on Justia Law

Chiwawa Communities Association appealed the trial court's grant of summary judgment to owners of homes in the Chiwawa River Pines community. Respondents Ross and Cindy Wilkinson asked the trial court to invalidate a 2011 amendment to the community covenants prohibiting rental of their homes for less than 30 days. The issue this case presented for the Supreme Court was whether short-term vacation rentals conflicted with the covenants in place prior to 2011, if the Association validly amended the covenants to prohibit them, and if the trial court erred by striking portions of the offered evidence. Upon review, the Court concluded that short-term rentals did not violate the covenants barring commercial use of the property or restricting lots to single-family residential use. Furthermore, the Court held the Association exceeded its power to amend the covenants when it prohibited short-term vacation rentals in 2011, and the trial court did not err by granting in part motions brought by the Wilkinsons to strike evidence. View "Wilkinson v. Chiwawa Cmtys. Ass'n" on Justia Law

Appellant Roy Jorgenson was released on bond after a trial court judge found probable cause to believe he had shot someone. He was arrested with a handgun and an AR-15 rifle. Appellant was not at home at the time, nor was there any evidence that he was defending himself. He was convicted of violating RCW 9.41.040(2)(a)(iv). On appeal of his conviction, appellant argued that RCW 9.41.040(2)(a)(iv) violated his rights to bear arms under the federal and state constitutions. The Supreme Court deferred to the legislature's conclusion that when a trial judge finds probable cause to believe a defendant committed a serious offense, public safety justifies temporarily limiting that person's right to possess arms. The Court held that the statute was constitutional as applied to appellant and therefore affirmed his conviction. View "Washington v. Jorgenson" on Justia Law

Christopher Monfort was charged with one count of aggravated first degree murder for the death of a law enforcement officer. He filed a notice of special sentencing proceeding ("death penalty notice"). Monfort's defense moved to strike the notice on the basis that the county prosecutor considered the facts of the crime and lacked a factual basis for making a determination under the statute. The trial court denied the defense's motion on the first basis but granted it on the second. It stated that the county prosecutor had failed to exercise discretion as required by constitutional and statutory law. The State and defense moved for discretionary review. After considering the parties' arguments, the Supreme Court reversed the trial court, holding that a county prosecutor may consider the facts of the crime when deciding whether to file a death penalty notice, and the judiciary may review only whether a prosecutor has a "reason to believe that there are not sufficient mitigating circumstances" under RCW 10.95.040(1). View "Washington v. Monfort" on Justia Law

Petitioner Jerry Lain was sentenced to life under Washington's former indeterminate sentencing scheme. In 2010, the Indeterminate Sentencing Review Board found petitioner parolable, approved a release plan, and ordered parole with supervision. The governor revoked petitioner's parole. As a result, the Review Board tacked on 36 months to petitioner's minimum term of confinement. Petitioner challenged the revocation and additional term as-applied and facially, arguing that RCW 9.95.160 violated due process because it did not outline procedures for the governor to provide petitioner notice and an opportunity to be heard before the governor acted. The Supreme Court concluded the statute was constitutional on both its face and as applied to petitioner. View "In re Pers. Restraint of Lain" on Justia Law

In November 2006, Petitioner Bao Dinh Dang walked up to a gas pump in Seattle, lit newspaper on fire, and attempted to pump gas in order to ignite the gas. A station employee successfully knocked the flaming newspaper out of petitioner's hand with a window-washing squeegee while a customer phoned police. Petitioner was arrested, and the State charged him with attempted arson in the first degree. Petitioner moved for acquittal on the grounds of insanity. The court granted the motion, finding that petitioner was suffering from a mental disease but that he was "not a substantial danger to other persons and [did] not [. . .] present a substantial likelihood of committing felonious acts jeopardizing public safety or security, but . . . is in need of further control by the court or other persons or institutions." The court ordered petitioner conditionally released subject to various conditions. The issue before the Supreme Court in this case was whether trial courts are required to enter a finding of dangerousness before revoking the conditional release of a person acquitted of a crime by reason of insanity. Furthermore, the Court decided whether trial courts must also decide the appropriate standard of proof governing the revocation determination. The Court's conclusion was that Washington law requires trial courts to find conditionally released insanity acquittees dangerous before committing them to mental institutions against their will. The Court also concluded that a preponderance of the evidence sufficiently protects an insanity acquittee's rights in the context of revoking conditional release. Because the trial court in this case specifically determined that Bao Dinh Dang was dangerous, the trial court held that it properly revoked his conditional release. However, the trial court erred in admitting hearsay statements at Dang's revocation hearing without finding good cause for doing so but that the error was harmless beyond a reasonable doubt. View "Washington v. Dang" on Justia Law