Justia Washington Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
In re Pers. Restraint of Adams
The issue before the Supreme Court in this case involved a claim under RCW 10.73.090. Petitioner successfully argued that a 2000 judgment against him and subsequent sentence were based on an incorrectly-calculated offender score. Petitioner claims in this appeal that because he successfully challenged the score in a 2009 collateral challenge and received a new sentence, he should have been able to raise an ineffective assistance of trial counsel relating back to that challenge. The Court of Appeals dismissed the claim as untimely and because it was successive. Upon review, the Supreme Court agreed that petitioner's petition was time barred.
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Freeman v. Washington
The State Department of Transportation and the Central Puget Sound Regional Transit Authority entered into an agreement that would lease a portion of I-90 to Sound Transit for light rail. For this, Sound Transit agreed to pay an amount equal to the State's contribution to construct the light rail lanes and for the value of a 40-year lease. The appellants in this case, individuals and a non-profit, contended this lease violated state law and the state constitution. Upon review of the matter, the Supreme Court concluded the lease did not violate state law or the constitution, and affirmed the trial court's judgment.
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Washington v. Chen
The issue before the Supreme Court in this case was the conflict between the statutory requirement that limits disclosure of competency evaluations prepared under RCW 10.77 and the constitutional requirement that "justice in all cases shall be administered openly." Once the evaluation is filed, the trial court uses it to determine defendant's competency to stand trial. The trial court in this case denied defendant's motion to seal the evaluation, and defendant appealed. Upon review, the Supreme Court concluded that once a competency evaluation becomes court record, it becomes subject to the constitutional presumption of openness, which could be rebutted only when the trial court makes a specific finding that "Ishikawa" factors weigh in favor of sealing. View "Washington v. Chen" on Justia Law
Washington v. McEnroe
The Supreme Court reviewed a trial court's dismissal of notice of special death penalty sentencing proceedings. The King County prosecuting attorney appealed to the Supreme Court to decide whether he violated Washington's capital punishment statutes by considering the strength of the evidence against respondents Joseph McEnroe and Michele Anderson when he determined he would seek the death penalty. Respondents were accused of shooting and killing six people. Upon review, the Supreme Court concluded the prosecutor did not violate Washington law, reversed the trial court and remanded the case with instructions so that the cases against respondents could proceed. View "Washington v. McEnroe" on Justia Law
Friends of Columbia Gorge, Inc. v. State Energy Facility Site Evaluation Council
At issue in this case was the siting of a wind powered energy facility under the energy facilities site locations act (EFSLA). The State Energy Facility Site Evaluation Council (EFSEC), after reducing the scope of the project applied for, recommended that the governor approve the project, which she did. Opponents of the project then sought judicial review under the Administrative Procedure Act (APA). The superior court certified the issue directly to the Supreme Court. Upon review, the Court found no basis to reverse the EFSEC's recommendation or the governor's approval of the project. View "Friends of Columbia Gorge, Inc. v. State Energy Facility Site Evaluation Council" on Justia Law
Washington v. Mau
Petitioner Jennifer Mau was convicted of making false insurance claims. She challenged the sufficiency of the evidence presented against her at trial. Upon review, the Supreme Court found that the State failed to prove the existence of any "contract of insurance" underlying Petitioner's claim. Therefore the Court reversed her conviction. View "Washington v. Mau" on Justia Law
Brown v. MHN Gov’t Servs., Inc.
At issue before the Supreme Court in this matter was the narrow question of whether an arbitration agreement signed by respondents was unconscionable and therefore unenforceable under California law. Upon review, the Washington Supreme Court concluded that the forum selection and punitive damages clauses at issue were not unconscionable, but that the arbitrator selection, statute of limitations and fee shifting provisions were. Therefore, because the agreement was "permeated with unconscionability," it was unenforceable. View "Brown v. MHN Gov't Servs., Inc." on Justia Law
Lemire v. Dep’t of Ecology
Respondent and rancher Joseph Lemire was directed by the state Department of Ecology to curb pollution of a creek that ran through his property. Respondent unsuccessfully challenged the order at the Pollution Control Hearings Board. He then filed an appeal at Superior Court. That court invalidated the agency order as unsupported by substantial evidence. Furthermore, the Superior Court concluded that the agency order constituted a taking. The Department appealed. The Supreme Court reinstated the Board's order and the underlying agency order, holding that Respondent failed to establish a taking. View "Lemire v. Dep't of Ecology" on Justia Law
Washington v. Meredith
In 2010, the Washington Supreme Court addressed that first step of the Batson test in "Washington v. Rhone," (229 P.3d 752 (2010)). Chief Justice Madsen wrote a concurrence to that case stating, "I agree with the lead opinion in this case. However, going forward, I agree with the rule advocated by the dissent." This has caused lower courts to question whether, going forward, they should follow the rule in the lead opinion or the dissent of Rhone. To clarify this issue, the Court granted review in this case solely on the scope of the bright-line rule articulated in Rhone. The Court clarified that Rhone did not establish a bright-line rule and that the rule in Washington remains the rule applied in the lead opinion in Rhone.
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Lowman v. Wilbur
In "Keller v. City of Spokane," (44 P.3d 845 (2002)), the Washington Supreme Court held that the duty to design and maintain reasonably safe roadways extended "to all persons, whether negligent or fault-free." This case presented an opportunity to clarify the relationship between questions of duty and legal causation in the context of a municipality's or utility's obligation to design and maintain reasonably safe roadways. In this case, the Court held that the reasoning of Keller equally supported a determination of legal causation. Therefore, if the jury finds the negligent placement of the utility pole too close to the roadway was a cause of plaintiff's injuries when defendant's car left the roadway and struck the pole then it was also a legal cause of plaintiff's injuries.
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