Justia Washington Supreme Court Opinion Summaries

Personal restraint petitioner Eric Flint maintains that his return to total confinement as a result of repeated violations of conditions of community custody violated the ex post facto clauses of the state and federal constitutions. He filed his personal restraint in the Court of Appeals, which dismissed the petition as frivolous, and the Supreme Court granted discretionary review. Upon review, the Court concluded that application of the statute to Petitioner did not create an ex post facto problem and accordingly affirmed the Court of Appeals' dismissal of Petitioner's petition. View "In re Pers. Restraint of Flint" on Justia Law

In 1994, Petitioner Darold Stenson was sentenced to death after he was found guilty of murdering his wife and business partner, Frank Hoerner. In 2009, Petitioner's counsel filed a personal restraint petition (PRP) raising a due process claim based on alleged violations of "Brady v. Maryland,"(373 U.S. 83 (1963)). Petitioner's "Brady" claim pertained to evidence consisting of photographs and an FBI file that the State had access to at the time of trial but did not provide to Petitioner's counsel until 2009. The question before the Supreme Court was whether the State violated Petitioner's rights under the mandates of "Brady" and its progeny. Because the Court held that it did, it reversed Petitioner's aggravated first degree murder conviction and his death sentence and remanded the case for a new trial. View "In re Pers. Restraint of Stenson" on Justia Law

The Supreme Court granted the State's petition to review a decision of the Court of Appeals which reversed Respondent Yussuf Abdulle's first degree theft and forgery convictions based on "Washington v. Davis" (438 P.2d 185 (1968)). The State urged the Court to overrule "Davis", arguing that it is incorrect because it rests on the mistaken view that "Miranda" requires proof of waiver beyond a reasonable doubt and harmful because it keeps relevant evidence from the trier of fact. The Court agreed that "Davis" was incorrect in light of cases that issued from the United States Supreme Court following "Miranda." Therefore, the Court reversed the Court of Appeals and reinstated Respondent's convictions. View "Washington v. Abdulle" on Justia Law

This case arose from the tragic death of a teenager Ashlie Bunch. Ashlie’s adoptive father, Steven Bunch (Bunch) brought an action under RCW 4.24.010, against the treatment center where Ashlie committed suicide, McGraw Residential Center. Ashley’s adoptive mother, Amy Kozel, sought to join the lawsuit as a necessary party under CR 19(a). The superior court denied Kozel’s motion and the Court of Appeals affirmed. Finding that Kozel satisfied statutory standing requirements and CR 19(a), the Supreme Court reversed the Court of Appeals and remanded the case for further proceedings. View "Estate of Bunch v. McGraw Residential Ctr." on Justia Law

Police executed a search warrant and arrested Petitioner Patrick Jimi Lyons when they found a marijuana growing operation on his property. Probable cause for the search warrant was based solely on information from a confidential source. The affidavit for search warrant did not establish timely probable cause because it stated when the officer received the tip, not when the informant observed the criminal activity. The trial court convicted him, but the Court of Appeals reversed Petitioner's conviction. The State appealed. Upon review, the Supreme Court concluded the search warrant did not satisfy the requirements of the Washington State Constitution article I, section 7, and the trial court properly suppressed evidence obtained in the search. View "Washington v. Lyons" on Justia Law

The Supreme Court granted the State's motion for discretionary review of a decision of the Court of Appeals that reversed Defendant Brian Siers's conviction on one count of second degree assault. That court reversed the conviction because the State did not allege an aggravating factor in the charging document. In reaching its conclusion, the Court of Appeals relied on a Supreme Court decision on the issue of whether aggravating factors must be charged in the information. The Court took the opportunity to revisit that decision and held that an aggravating factor is not the functional equivalent of an essential element, and, thus, need not be charged in the information. Because the charging document here contained the essential elements of the crimes charged and Defendant was given notice prior to trial of the State’s intent to seek an aggravated sentence, Defendant’s due process rights were not violated. The Court therefore reversed the Court of Appeals' decision and reinstated Defendant’s conviction. View "Washington v. Siers" on Justia Law

The Supreme Court granted the State's motion to review a decision of the Court of Appeals in which granted Respondent Mansour Heidari's personal restraint petition and vacated his second degree child molestation conviction. In doing so, the Court of Appeals declined the State's request to direct entry of a judgment for the lesser included offense of attempted second degree child molestation. Upon review, the Supreme Court concluded that the Court of Appeals properly declined to direct the entry of judgment of the lesser included offense, and accordingly affirmed the appellate court’s decision. View "In re Pers. Restraint of Heidari" on Justia Law

An Auburn city police officer arrested Defendant Dustin Gauntt for possessing marijuana and using drug paraphernalia. An Auburn city prosecutor brought charges against him in Auburn Municipal Court under state law. On appeal of his conviction, Defendant contended that the city did not have the authority to prosecute him for violating statutes the city had not adopted. Upon review, the Supreme Court agreed, affirming the Court of Appeals and the superior court, and remanded the case back to the Auburn Municipal Court for dismissal. View "City of Auburn v. Gauntt" on Justia Law

Business Services of America II, Inc. (BSA) sued WaferTech LLC. After the trial court dismissed BSA's claims, BSA appealed. In March 2004, the Court of Appeals affirmed dismissal of all but one claim, which it remanded for trial. After remand, the case lay mostly dormant until June 2009, when BSA noted the case for trial. WaferTech then moved for dismissal. The trial court granted the motion to dismiss, and BSA appealed. BSA argued that the trial court had no discretion to dismiss the case because CR 41(b)(1) states that if a case is noted for trial before a dismissal hearing, it "shall not" be dismissed. The Court of Appeals agreed with BSA and reversed. WaferTech sought review. Upon review, the Supreme Court affirmed the Court of Appeals and remanded the case to the trial court for further proceedings. View "Bus. Servs. of Am. II, Inc. v. WaferTech LLC" on Justia Law

Respondent Michael Gendler made a public records request for location-specific accident reports from the Washington State Patrol (WSP). The WSP refused to provide the records unless Gendler certified that he would not use the records in any litigation against the State, claiming a federal statute (23 U.S.C. sec. 409) protected the records sought. WSP claimed the records were shielded because they were located in an electronic database that the Department of Transportation (DOT) utilized for purposes related to the federal hazard elimination program. Respondent then brought a suit under the PRA and argued section 409 did not apply to the WSP because it did not compile or collect the information for the hazard elimination program's purposes. Rather, the information was collected pursuant to WSP’s statutory duty under RCW 46.52.060. The trial court agreed and on summary judgment ordered WSP to produce the requested accident reports. The Court of Appeals affirmed. The Supreme Court also affirmed because section 409 does not extend to police accident reports generated and received by WSP pursuant to its own statutory duty. View "Gendler v. Batiste" on Justia Law