Justia Washington Supreme Court Opinion Summaries

Petitioner Daniel Pannell pled guilty to incest and child molestation. His lengthy sentence was suspended pending satisfactory progress in sexual offender treatment, among other things. Petitioner failed to make satisfactory progress and his suspended sentence was revoked. He contended on appeal to the Supreme Court that he was entitled to credit for the time his sentence was suspended, at least to the extent that his time incarcerated, his time in postconfinement community custody, and his time on the suspended sentence added together exceed the statutory maximum for "class B" felonies. Upon review of the trial court record, the Supreme Court concluded Petitioner was not entitled to credit against his sentence for time spent in the community under a special sex offender sentence alternative (SSOSA) before his suspended sentence was revoked. Accordingly, the Court affirmed the trial court's judgment. View "Washington v. Pannell" on Justia Law

In 1995, Petitioner Jeffrey Coats pled guilty to conspiracy to commit murder, conspiracy to commit robbery, and robbery. He received a standard range sentence of 20 years. His judgment and sentence erroneously stated that the maximum sentence for conspiracy to commit robbery was life in prison. Fourteen years later, he filed a personal restraint petition contending that because of the erroneous statement, his judgment was not valid on its face and therefore he should have been allowed to withdraw his guilty plea. Upon review, the Supreme Court concluded that despite the error, Peititoner's judgment was valid on its face, and that the sentencing court did not exceed its authority in sentencing Petitioner. The Court remanded the case back to the sentencing court only to correct the erroneous statement pertaining to the sentence for conspiracy to commit robbery. View "In re Pers. Restraint of Coats" on Justia Law

In 2006, Petitioner Robert Danforth went to the King County Sheriff’s Office, described his history of sex offenses, and made explicit descriptions of his plans to molest boys and have intercourse with a child. He repeatedly said that he would act on his plan if he was not committed as a sex offender. The King County prosecuting attorney filed a petition to civilly commit Petitioner, but he moved for summary judgment, arguing that his actions did not constitute a "recent overt act" to qualify him for commitment. The trial court denied his motion and the Court of Appeals affirmed. Upon its review, the Supreme Court concluded that a reasonable jury could have found that Petitioner committed a threat when he gave explicit descriptions of his plans to molest boys, and thus satisfied due process requirements that the State show an offender was presently dangerous before he or she was involuntarily committed. Accordingly, the Court affirmed the trial and appellate courts' decisions. View "In re Det. of Danforth" on Justia Law

Former Pierce County Superior Court Judge Petitioner Michael Hecht was convicted of felony harassment and of patronizing a prostitute. The trial court denied his motion for an order of indigency, and the Court of Appeals denied his motion for discretionary review of that order. Petitioner sought discretionary review with the Supreme Court. The superior court denied indigency status on remand from the appellate court, finding that though he was unemployed (from resigning his post shortly after conviction) and had significant debts, the court reasoned Petitioner had "adequate means" to pay for his legal expenses. On discretionary review by the Supreme Court, Petitioner proffered evidence that he had begun receiving food stamps. The Court found that by statute an indigent person includes anyone who "at any stage of a court proceeding" receives certain types of public assistance, including "food stamps or food stamp benefits transferred electronically." Petitioner was therefore presumptively indigent. The Court granted Petitioner's motion for discretionary review and remanded the case back to the superior court for reconsideration of his motion for order of indigency. View "Washington v. Hecht" on Justia Law

Petitioner Steven Beadle appealed his convictions for first degree child molestation. At a pretrial child hearsay hearing, the four-year-old alleged victim had a serious emotional breakdown and refused to testify. The court found the child unavailable to testify at trial and admitted her out-of-court statements to family members, mental health providers, child protective services, and law enforcement. Petitioner appealed, arguing that the trial court committed reversible error by finding the victim's statements admissible. Upon review, both the Court of Appeals and the Supreme Court affirmed Defendant's convictions. View "Washington v. Beadle" on Justia Law

Petitioner Gilberto Ibarra-Cisneros and his brother Adrian Ibarra-Raya, were separately prosecuted on drug charges in November 2006. Both moved unsuccessfully to suppress evidence discovered as a result of the warrantless search of Ibarra-Raya's home. Specifically, Ibarra-Cisneros argued to suppress the evidence against him as the fruit of an unlawful use of Ibarra-Raya's cell phone, which was seized during the search. The appellate court determined that the search of the home was unlawful, but that the connection between Ibarra-Raya's cell phone and "the bindle found at Mr. Ibarra-Cisneros's feet [was] too attenuated to affect his cocaine possession conviction." Upon review, the Supreme Court concluded that the appellate court erred in relying on the "attenuation doctrine" as the basis to allow the cocaine evidence against Ibarra-Cisneros: "In light of the way this case has developed, the only fair resolution of Ibarra-Cisneros's appeal is to treat is as the Court of Appeals treated Ibarra-Raya's appeal. The State has not met its burden of purging the taint resulting from the unlawful home search." The Court remanded the case to the trial court "with the acknowledgement that, because the warrantless home search was unlawful, all evidence seized as a result must be suppressed." View "Washington v. Ibarra-Cisneros" on Justia Law

The State appealed the reversal of Respondent Ernest Carter's sentence. The Court of Appeals applied the "actual innocence doctrine" to hear Respondent's untimely personal restraint petition (PRP) and held that Respondent was erroneously sentenced as a persistent offender under the Persistent Offender Accountability Act (POAA) of the Sentencing Reform Act of 1981. In 1998, the superior court entered a judgment and sentence convicting Respondent on two counts of robbery in the first degree and sentenced him as a persistent offender to life in prison. Respondent's prior offenses included a 1983 California conviction for assault with a firearm on a police officer and a 1990 Oregon conviction for attempted murder. Respondent timely filed a direct appeal raising nine issues including a claim that his prior California assault conviction was not comparable to a Washington strike offense under the POAA and should not have been counted toward his sentence. The Court of Appeals affirmed the conviction in an unpublished opinion. Almost seven years after the mandate, Respondent filed this PRP, arguing that his due process rights were violated during his 1998 trial when he appeared in shackles and that his sentence was unlawful. Respondent argued on appeal that: (1) there had been a significant change in the law (RCW 10.73.100(6)), (2) the sentence imposed was in excess of the court’s jurisdiction (RCW 10.73.100(5)), (3) Respondent's judgment and sentence were facially invalid (RCW 10.73.090), (4) equitable tolling under Washington common law warranted review, and (5) the federal actual innocence doctrine warranted review. The Court of Appeals dismissed Carter’s shackling claim as untimely, applied the actual innocence doctrine to the comparability issue, declined to address his alternative claims for relief, vacated Respondent's persistent offender sentence, and remanded for resentencing on the comparability issue. Upon review, the Supreme Court reversed and remanded the case because the Court of Appeals erroneously applied the actual innocence doctrine to hear Respondent's untimely PRP prior to considering his other claimed exceptions to the time bar in RCW 10.73.090. View "In re Personal Restraint of Carter" on Justia Law

Defendant John Franklin challenged the Court of Appeals decision affirming his convictions and sentences on assault and drug possession charges. The Supreme Court granted review only on the question of whether Defendant was entitled to resentencing for counts I and III as a result of then-new legislation requiring sentencing courts to reduce the term of community custody when the total terms of confinement and community custody exceeded the statutory maximum. Upon review, the Supreme Court held that while the legislation applied retroactively, the legislature charged the Department of Corrections, not the sentencing court, with adjusting the length of community custody for those serving terms of confinement or community custody by modifying the end date for community custody. Thus, the Court concluded that Defendant was not entitled to resentencing by the trial court and it affirmed the Court of Appeals. View "Washington v. Franklin" on Justia Law

Defendant Alberto Perez-Valdez challenged two evidentiary decisions made by a judge of the Walla Walla County Superior Court during a trial that resulted in his conviction for one count of second degree rape of a child and one count of third degree rape of a child. He also challenged the trial court’s denial of his motions for a mistrial based on a statement made by a state witness relating to the credibility of the victims. Upon review, the Supreme Court held that the trial court did not abuse its discretion in making these decisions. Therefore, the Court affirmed Defendant's conviction. View "Washington v. Perez-Valdez" on Justia Law

Defendant Jay McKague appealed his conviction for second degree assault, and the Court of Appeals affirmed in a split decision. Defendant shoplifted a can of smoked oysters from a convenience store. The owner followed Defendant out of the store and confronted him in the parking lot. Defendant punched the owner in the head several times and pushed him to the ground, causing the owner's head to strike the pavement. He was diagnosed with a concussion without loss of consciousness, a scalp contusion and lacerations, and head and neck pain. Defendant was charged with first degree robbery, with third degree theft as an inferior offense, and second degree assault predicated on the infliction of substantial bodily injury. At Defendant's request, the court also instructed the jury on third degree assault as an inferior offense of second degree assault. The jury convicted Defendant of third degree theft and second degree assault. The dissent on the appellate panel took issue with the of the sufficiency of the evidence of “substantial bodily harm.” Specifically, the dissent disagreed with the lead opinion’s citation to a dictionary definition of the term “substantial” as including “something having substance or actual existence.” Upon review, the Supreme Court affirmed the Court of Appeals’ holding that substantial evidence supported the conviction, but in doing so the Court disapproved of the definition of “substantial bodily harm” applied by the Court of Appeals majority: "[w]e agree … that the majority applied an erroneous definition of 'substantial,' but we nonetheless affirm McKague’s conviction because the evidence was sufficient to show that [the owner's] injuries were 'substantial' under a proper definition." View "Washington v. McKague" on Justia Law