Justia Washington Supreme Court Opinion Summaries

Petitioner Charles Weber filed an untimely PRP asserting that he received ineffective assistance of counsel when his attorney failed to conduct a reasonable investigation of the case and failed to explore the possibility that he had been misidentified as the perpetrator. Petitioner sought to avoid the procedural time bar by arguing that the actual innocence doctrine, recognized by this court in "In re Personal Restraint of Carter, (263 P.3d 1241 (2011)), be applied to allow review of his constitutional claim. Petitioner supported his innocence claim with new evidence in the form of declarations. Upon review, the Supreme Court concluded that Petitioner's new evidence was insufficient to show he was factually innocent. Accordingly, the Court dismissed his PRP. View "In re Pers. Restraint of Weber" on Justia Law

Plaintiff Automotive United Trades Organization brought suit against Washington State and its officials, challenging the constitutionality of disbursements the State gives to Indian tribes under fuel tax compacts. The trial court dismissed the amended complaint for failure to join indispensable parties, namely the Indian tribes party to the agreements, under CR 19. The Supreme Court reversed, holding the tribes were not indispensable parties under CR 19(b). Although the tribes are necessary parties under CR 19(a) whose joinder was not feasible due to tribal sovereign immunity, equitable considerations allowed this action to proceed in their absence. View "Auto. United Trades Org. v. Washington" on Justia Law

Richard J. Dyer was a convicted rapist who denied his guilt and was therefore ineligible for sex offender treatment. He was serving a maximum term of life in prison. Though Dyer had a history of good behavior while in prison, the Indeterminate Sentence Review Board (ISRB) found Dyer unparolable for the sixth time and extended his minimum term another 60 months. In doing so, the ISRB considered Dyer's lack of sex offender treatment, along with additional evidence, and concluded he was not completely rehabilitated. Dyer filed a personal restraint petition (PRP) directly with this court, claiming the ISRB abused its discretion. Upon review, the Supreme Court affirmed the ISRB's decision. View "In re Pers. Restraint of Dyer" on Justia Law

Petitioners Ronnie Jackson Jr. and Salvador Rivera filed personal restraint petitions to challenge the firearm enhancements they received as part of their sentences, which became final in 2002. In response, the issue before the Supreme Court was whether rules it announced in "Washington v. Recuenco," (110 P.3d 188 (2005) (Recuenco I)) and "Washington v. Recuenco," (180 P.3d 1276 (2008) (Recuenco III)) applied retroactively. The rules in question were: (1) that a firearm enhancement cannot be based on a jury's general "deadly weapon" finding; and (2) that an information must particularly identify any firearm enhancements sought by the State in order to authorize such enhancements at sentencing. "In other words, [the Court] must decide if it [was] too late to challenge enhancements imposed before the Recuenco I and Recuenco III decisions." Upon review, the Court found that Recuenco I and Recuenco III were not retroactive as to either issue and held that Rivera and Jackson were not entitled to any relief on collateral review. View "In re Pers. Restraint of Jackson" on Justia Law

"A trial court must have authority to manage the parties and proceedings before it." The State argued the trial court in this case erroneously imposed sanctions in a criminal prosecution without explicitly finding bad faith. "While a finding of bad faith is the preferred basis for imposing sanctions in a criminal case, [the Supreme Court] will uphold sanctions if [it] can infer bad faith from the record . . . The trial court in this case did not make a finding of bad faith and, given concessions at oral argument, the record did not support sanctions. The Court therefore reversed. View "Washington v. Gassman" on Justia Law

This case required the Supreme Court to examine how Washington's juvenile justice laws interact with the Persistent Offender Accountability Act (POAA), also known as the "three strikes law." When Jorge Saenz was 15 years old, he agreed to waive juvenile court jurisdiction and transfer his case to adult court, where he pled guilty to two counts of felony assault in exchange for a moderately lower sentencing recommendation. As a result, seven years later he faced life in prison without the possibility of parole under the POAA. The issue for the Supreme Court's review concerned whether his waiver of juvenile court jurisdiction was valid and whether his case was properly transferred to adult court. The Court concluded that Saenz's waiver was invalid because there was virtually nothing in the record demonstrating that it was intelligently made or that Saenz was fully informed when he made it. Next, the Court held that Saenz's case was not properly transferred to adult court because the commissioner transferring the case failed to enter findings that transfer was in the best interest of the juvenile or the public as required by statute. On these facts, the Supreme Court held that Saenz's conviction could not be used as a "strike" to sentence him to spend the rest of his life in prison with no possibility of release. Instead, the Court affirmed the 561-month sentence imposed by the trial court. View "Washington v. Saenz" on Justia Law

Defendant Kenneth Lamb was charged with, among other things, 10 counts of unlawful possession of a firearm. The State alleged that Lamb was precluded from possessing firearms because of his 1991 juvenile adjudication for second degree burglary. Defendant moved to withdraw his 1991 plea of guilty and vacate the juvenile adjudication. The trial court granted his motion. The trial court also denied the State’s motion to amend the information to instead rely on another juvenile adjudication and, ultimately, dismissed the 10 unlawful possession of a firearm counts. The State appealed and the Court of Appeals reversed all three of the trial court’s rulings. The issue before the Supreme Court was the trial court's exercise of discretion in vacating judgments, in disallowing the State to amend an information in a criminal case, and in dismissing counts of an information. Upon review, the Court affirmed in part, and reversed in part, holding that in this case the trial court abused its discretion when it vacated Defendant's juvenile adjudication for second degree burglary and dismissed the 10 unlawful possession of a firearm counts against him. On these two issues, the Court affirmed the Court of Appeals. The Court reversed the Court of Appeals with respect to the trial court’s refusal to permit the State to amend the information and held that the trial court did not abuse its discretion. The case was remanded to the trial court for further proceedings. View "Washington v. Lamb" on Justia Law

Petitioner Douglas Rose challenged his convictions for unlawful possession of a stolen access device and for unlawful possession of a controlled substance. The issue before the Supreme Court was whether the credit card Petitioner possessed was an "access device" under Washington law. Further, the Court was presented with the issue of whether Petitioner's arrest, which lead to the search of his bag and discovery of the evidence eventually presented against him, was supported by probable cause. Under the facts of this case, the Supreme Court concluded that the State did not meet its burden to show that the card in question was an "access device." The Court reversed on that issue, but affirmed Petitioner's arrest on all other grounds. View "Washington v. Rose" on Justia Law

Defendant-Appellant Jamar Meneese appealed his conviction for unlawfully carrying a dangerous weapon on school grounds and for possessing a controlled substance. He claimed the weapon, an air pistol, was seized in an unlawful search at school and should have been suppressed at trial. The question on appeal was whether the school search exception to the warrant requirement applied to the search conducted by the school resource officer (SRO). The parties disputed whether the SRO was acting as a school official or a law enforcement officer at the time of the search. Upon review, the Supreme Court found that the SRO is a fully commissioned, uniformed, law enforcement officer employed by the Bellevue Police Department. He arrested and handcuffed Defendant before searching his backpack. Moreover, after arresting Defendant, the focus of the investigation was no longer on informal school discipline (an underlying purpose behind the school search exception.) Accordingly, the Court concluded the school search exception did not apply, a warrant supported by probable cause was required, and the weapon should have been suppressed. View "Washington v. Meneese" on Justia Law

This case concerned the classification of workers as employees or independent contractors for purposes of the Washington Minimum Wage Act (MWA). A class of 320 former and current FedEx Ground Package System, Inc. (FedEx) delivery drivers (hereinafter Anfinson) filed suit seeking overtime wages under the MWA and reimbursement for uniform expenses under the industrial welfare act (IWA). The dispute with respect to both claims was whether the drivers were employees or independent contractors. The parties disagreed on the correct test to distinguish these categories under the MWA; FedEx argued that the common law right-to-control standard governs while Anfinson contended that the federal Fair Labor Standards Act of 1938 (FLSA) economic-dependence test controls. The trial court gave the jury a hybrid instruction, focusing the inquiry on FedEx's right to control in light of the economic-dependence factors. The jury determined that the drivers were independent contractors. Anfinson appealed, contending, among other things, that the jury instructions misinformed the jury about the standards for determining worker status and about the requirement that class status and evidence be "common to the class members." The Court of Appeals held that the jury instruction defining the standard for determining worker status was erroneous and prejudicial and reversed. The Court of Appeals further held that the jury instruction on the burden of proof was erroneous because it misled the jury and was prejudicial. Upon review, the Supreme Court affirmed the Court of Appeals in both respects. View "Anfinson v. FedEx Ground Package Sys., Inc." on Justia Law