Justia Washington Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Washington v. Zillyette
The State charged Brenda J. Zillyette with controlled substances homicide for the death of Austin Burrows. The information charging Zillyette with controlled substances homicide did not identify the controlled substance that Zillyette allegedly delivered that resulted in Burrows' death. The trial court convicted Zillyette, and the Court of Appeals affirmed. Upon review, the Supreme Court reversed because the information failed to set forth all of the essential elements of the crime of controlled substances homicide. View "Washington v. Zillyette" on Justia Law
Washington v. Saintcalle
Kirk Saintcalle was convicted of one count of first degree felony murder and three counts of second degree assault, all with firearm enhancements for which he was sentenced to 579 months in prison. During jury selection at Saintcalle's trial, the prosecution used a peremptory challenge to strike the only black juror in the venire, juror 34. The challenge came after the prosecution questioned juror 34 extensively during voir dire-far more extensively than any other juror, significantly after another juror made a comment about race. Saintcalle claimed on appeal to the Supreme Court that the peremptory strike was clearly racially motivated in violation of the equal protection guaranty as in "Batson v. Kentucky," (476 U.S. 79). Upon review, the Supreme Court disagreed. Batson requires a finding of purposeful discrimination, and the trial court's finding that there was no purposeful discrimination here was not clearly erroneous.
View "Washington v. Saintcalle" on Justia Law
Washington v. Clark
The Supreme Court affirmed Petitioner Michael Clark's conviction for theft on tribal trust land over which the State had jurisdiction. The Court noted that while the State lacked explicit statutory authorization to issue search warrants on tribal lands, federal law had not preempted the State's ability to do so. Further, the tribe had not used its inherent sovereignty to regulate the procedure by which state law enforcement could execute search warrants on the reservation. Petitioner moved to suppress evidence gathered on tribal land without a tribal warrant. View "Washington v. Clark" on Justia Law
Washington v. Vasquez
Petitioner Vianney Vasquez had fake social security and fake permanent resident cards in his possession when a grocery store security guard found them in a search related to shoplifting. The guard called police; petitioner was later arrested and charged with two counts of forgery. A jury convicted him, and the appellate court affirmed petitioner's convictions. On appeal to the Supreme Court, petitioner challenged the evidence presented at trial, arguing that it was insufficient to prove petitioner possessed the cards with an intent to injure or defraud. The Supreme Court concluded the evidence was indeed insufficient to prove these elements of the forgery statute, and reversed and remanded the case to the appeals court for vacation of petitioner's conviction. View "Washington v. Vasquez" on Justia Law
In re Pers. Restraint of Netherton
Petitioner Lorraine Netherton was convicted of second degree murder. Upon review of her appeal, the Supreme Court concluded that the trial court erroneously imposed a sentence enhancement based on the jury's "deadly weapon" finding. Because petitioner's appellate counsel misapprehended who represented Petitioner at a critical stage of her appeal, Petitioner lost an opportunity to get the enhancement reversed. Accordingly, the Supreme Court found Petitioner received ineffective assistance of appellate counsel, and remanded the case to the trial court for resentencing. View "In re Pers. Restraint of Netherton" on Justia Law
Washington v. Sanchez
Petitioner Josh Sanchez was adjudicated a juvenile sex offender. He petitioned against the superior court's release of his offender information to the King County Sheriff's Office when he was released back into the community. Washington law mandated that the local authorities notify the community of the offender's release and potential risk that the offender posed. The Supreme Court held that the juvenile court could release the evaluation of petitioner that resulted in his receiving offender status, and that it was not a violation of his rights to do so. View "Washington v. Sanchez" on Justia Law
Piel v. City of Federal Way
The trial court dismissed Appellant Richard Piel's suit against the City of Federal Way, finding that the existence of statutory remedies authorized under state law prevented him from establishing the "jeopardy prong" of his common law claim for wrongful termination. The Supreme Court took the opportunity of this case to better explain the jeopardy analysis and harmonize its recent decisions in "Cudney v. ALSCO, Inc." and "Korslund v. DynCorp Tri-Cities Services, Inc." with "Smith v. Bates Technical College." The "Smith" decision recognized that an employee protected by a collective bargaining agreement may bring a common law claim for wrongful termination based on the public policy provisions of RCW 41.56, notwithstanding administrative remedies available through the Public Employees Relations Commission. "Korsland" and "Cudney" did not alter "Smith's" holding. In this case, the Supreme Court reversed the lower court's dismissal and remanded this case for further proceedings. View "Piel v. City of Federal Way" on Justia Law
King County Dep’t of Dev. & Envtl. Servs. v. King County
Applicants challenged a Department of Development and Environmental Services order declaring the use of the property at issue here was not compliant with King County zoning ordinances. The assertion was that the use was established before the ordinances were revised and characterized as non-conforming. The hearing examiner found for the landowner (and county) on all relevant issues, but the superior court reversed. The appellate court reversed the superior court, and the Supreme Court reversed the appellate court. The Supreme Court held that the landowner's use was not established within the meaning of the county code. View "King County Dep't of Dev. & Envtl. Servs. v. King County" on Justia Law
Washington v. Smith
Petitioner Christopher Smith was apprehended by police on the doorstep of his motel room and charged with rape, assault, harassment, kidnapping and child rape. Prior to trial, the Supreme Court invalidated the practice of random motel registry searches. At Petitioner's suppression hearing, he argued that the evidence gathered against him was the fruit of an unlawful registry search, and therefore should have been suppressed. The trial court allowed the evidence under the inevitable discovery doctrine. The appellate court upheld Petitioner's convictions, concluding that the evidence was admissible under the attenuation and independent source doctrines. Upon review, the Supreme Court affirmed Petitioner's conviction, holding the evidence was admissible because the warrantless search that led to its discovery was justifiable under the warrant exception for when lives were in danger. View "Washington v. Smith" on Justia Law
Washington v. Tyler
An officer stopped the defendant for a traffic violation. When it turned out that the driver and his passenger both had suspended drivers' licenses and alternate arrangements could not be made, the officer arranged for a tow truck to move the car. In order to turn the vehicle over to the towing company, the officer conducted an inventory search of the vehicle and discovered methamphetamine during the search. The defendant was convicted of unlawful possession of methamphetamine and driving while his license was suspended. He appealed, arguing that the trial court abused its discretion when it denied his motion to suppress the evidence on the ground the search was pretextual. He also argued that because he did not consent to the search, it was unconstitutional. The Court of Appeals affirmed his convictions. Upon review, the Supreme Court also affirmed, finding that under article I, section 7 of the Washington State Constitution, law enforcement officers do not have to obtain consent in order to conduct an inventory search of a lawfully impounded vehicle. View "Washington v. Tyler" on Justia Law