Justia Washington Supreme Court Opinion Summaries

Two cases were consolidated before the Supreme Court because they were based on the same facts. Petitioners Robert Brown and Theodore Kosewicz were both involved in the kidnapping, torture, and killing of Sebastian Esquibel. At trial, Brown was convicted of first degree kidnapping and felony murder with the predicate felony being the first degree kidnapping. At a separate trial, Kosewicz was convicted of first degree kidnapping and first degree aggravated murder with the aggravating factor being the first degree kidnapping. On appeal, both Brown's and Kosewicz's first degree kidnapping convictions were overturned because of a charging defect. The Court of Appeals did not overturn Brown's felony murder conviction or Kosewicz's aggravating factor verdict. Brown and Kosewicz argued on appeal to the Supreme Court that reversal of the first degree kidnapping convictions requires reversal of the felony murder and aggravating factor verdict that were based in part on the first degree kidnapping. Upon review, the Court affirmed Brown's felony murder conviction and Kosewicz's aggravating factor verdict. View "Washington v. Kosewicz" on Justia Law

The Supreme Court was asked to determine whether Initiative 1183 (I-1183) violated the single-subject and subject-in-title rules found in article II, section 19 of the Washington State Constitution. I-1183 removed the State from the business of distributing and selling spirits and wine, imposes sales-based fees on private liquor distributors and retailers, and provides a distribution of $10 million per year to local governments for the purpose of enhancing public safety programs. Upon review of the matter, the Supreme Court held that the Appellants Washington Association for Substance Abuse and Violence Prevention, Gruss, Inc. and David Grumbois did not overcome the presumption that the initiative was constitutional, and therefore the Court affirmed summary judgment in favor of the State and the intervenors. View "Wash. Ass'n for Substance Abuse & Violence Prevention v. Washington" on Justia Law

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