Justia Washington Supreme Court Opinion Summaries

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. View "Washington v. Meredith" on Justia Law

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. View "Lowman v. Wilbur" on Justia Law

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

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

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

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

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

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

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

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