Justia Washington Supreme Court Opinion Summaries

In 2005, Petitioner Robert May violated a domestic violence protection order that prohibited him from contacting his ex-wife. As a result, Petitioner was convicted under a Seattle ordinance. On appeal, Petitioner contended that the order was invalid and that he received no notice that the "no-contact" provision of the order was a criminal offense. The superior court reversed the municipal court's conviction, but the Court of Appeals reversed the superior court to reinstate the conviction. The Supreme Court in its affirmation of the Court of Appeals concluded: "[Petitioner] made a choice to violate the plain and unambiguous terms of the domestic violence protection order . . . the collateral bar rule precludes [him from challenging] the validity of the domestic violence protection order." The Court found that the protection order itself was notice that he would be prosecuted if he violated its terms. View "City of Seattle v. May" on Justia Law

Petitioners Lisa Mullen and Kevin Dean were prosecuted for stealing funds from their employer, a Skagit County car dealership. At issue before the Supreme Court was the State's duty to disclose exculpating evidence to defendants. After their convictions, Petitioners obtained a previously sealed deposition of the dealership's accountant taken in a separate civil suit between the owner and the accountant's firm. The deposition took place before the end of the criminal trial. In a motion for a new trial, Petitioners argued that the accountant's deposition testimony supported the defense theory that the owner authorized use of the funds. Petitioners contended that the prosecution's failure to disclose the information from the deposition constituted a due process violation under "Brady v. Maryland," 373 U.S. 83. The appellate court affirmed the lower court's finding that there was no due process violation. The Supreme Court agreed after careful consideration of the trial record and the applicable legal authority. The Court found no "Brady" violation, and found that the trial court did not abuse its discretion by not granting Petitioners a new trial. View "Washingotn v. Mullen" on Justia Law

Petitioner Stephen Eugster filed suit to challenge Washington's process of electing appellate court judges and the court's procedure of assigning cases to three-judge panels. He argued that the process violated the state's constitution. In particular, Petitioner argued that the election process violates the "all elections shall be free and equal" clause of Article I, Section 19. The trial court found that Petitioner failed to state a claim upon which relief could be granted, and dismissed his case. Upon careful consideration of the state's constitution's history, as well as the legislative and case history pertaining to Washington's election of judges and the process by which cases are heard by the appellate courts, the Supreme Court affirmed the trial court's decision. View "Eugster v. State" on Justia Law

Petitioner Robert Strandy was convicted of two counts of felony murder and aggravated first degree murder. For sentencing purposes, the trial court merged the murder and aggravated murder convictions, but it did not vacate the felony murder convictions. On appeal to the Supreme Court, Petitioner argued that the trial court erred by not vacating the merged murder convictions. The Supreme Court granted discretionary review of the case and found that the trial court's omission constituted a violation of the Fifth Amendment prohibition against double jeopardy. The Court remanded the case to the trial court to vacate Petitioner's two felony murder convictions. View "In re Pers. Restraint of Strandy" on Justia Law

In this case the issue presented for the Supreme Court's review was whether a thirteen-year old was denied due process rights when she was not appointed counsel at a truancy hearing. Despite a district court's order to attend school, E.S. missed classes from 2005 to 2007. At first, E.S. and her mother attended the hearings, but were not represented by counsel, nor did they ask that counsel be present. The court explained that E.S. would be "sentenced" to house arrest, work crew and detention if she did not comply with the order, but she continued to miss school. At E.S.' last court appearance, she was represented by counsel. She was ordered to spend six days in detention with electronic monitoring. E.S., through her attorney, filed a motion to have the home detention set aside, which was denied. The Court of Appeals vacated E.S.' sentence, finding that the child's "interests in her liberty, privacy and right to education [were] in jeopardy" at the truancy hearings, and that due process required counsel at each appearance. On appeal to the Supreme Court, the School District argued that Washington courts never required the appointment of counsel to protect a child's privacy and education interests. The Supreme Court agreed with the District. Upon review of the record, the state constitution and the applicable legal authority, the Court found that E.S. was not denied due process rights because she was not appointed counsel in the initial truancy hearings. The Court reversed the Court of Appeals' decision and remanded the case for further proceedings. View "Bellevue Sch. Dist. v. E.S." on Justia Law

Petitioner Jeremy Anderson was charged with first degree child molestation for alleged contact with a minor child. At trial, a nurse from the child's treating clinic testified to statements made by the child to her. Petitioner challenged the admission of the child's statements made to the nurse as a violation of his Sixth Amendment right to confronting the witness. The Court of Appeals affirmed their admission, holding that the child's statements to the nurse were "nontestimonial" because the statements were made while the nurse made a medical examination. The Supreme Court found that the statements were "testimonial" in nature, and therefore subject to Petitioner's Sixth Amendment right to confrontation. However, the Court held that any error resulting from admitting the testimony was harmless to Petitioner. The Court affirmed the appellate court's decision but on different grounds. View "Washington v. Anderson" on Justia Law

A Seattle street performer's camera caught the shooting death of Franciso Green on tape. Police received several other eyewitness accounts of the shooting and arrested Petitioner Kevin Monday, Jr. in connection with the murder. A jury later found Petitioner guilty of first degree murder and two counts of assault. On appeal to the Supreme Court, Petitioner argued that prosecutorial misconduct and the imposition of firearms enhancements in the jury instructions at trial deprived him of a fair trial. Upon review of the trial record, the Supreme Court found that the prosecutor "injected racial prejudice into the trial proceedings" by asserting certain witnesses were unreliable and using derogatory language to characterize others. The Court reasoned that these statements "fatally tainted" the jury because it "planted the seed in the jury's mind that most of the witnesses were, at best, shading the truth to benefit [Petitioner]. Under the circumstances, we cannot say that the misconduct did not affect the jury's verdict." The Court did not reach Petitioner's "firearms enhancement" argument because it determined he was entitled to a new trial. The Court reversed the trial court's decision and remanded the case for further proceedings. View "Washington v. Monday" on Justia Law

Appellant Richard Mutch appealed his sentence of 400 months' imprisonment on rape and kidnapping charges. After his life sentence was vacated several years after his conviction, the trial court imposed an "exceptional" sentence of 400 months at re-sentencing. On appeal to the Supreme Court, Appellant challenged the trial court's authority to impose such a sentence. In particular, Appellant argued that the trial court miscalculated his "offender score," and because of the miscalculation, his 400-month sentence should be invalidated. Upon careful consideration of the trial record and the applicable legal authority, the Supreme Court affirmed the trial court's sentence. The Court found that Washington law gives trial courts the authority to impose "exceptional" sentences, and that the court did not miscalculate Appellant's "offender score." Accordingly the Court affirmed Appellant's sentence. View "Washington v. Mutch" on Justia Law

Samantha A. is a 15-year-old with a wide range of medical maladies. Samantha is unable to perform a many activities necessary for independent living. The Department of Social and Health Services (DSHS) determined that Samantha is eligible for 24-hour institutional care because of the extreme nature of her needs. Because Samantha is cared for by a single mother, Samantha qualified for the Medicaid Home and Community Based Waiver Program so that she can receive benefits at home and not be institutionalized. As part of the in-home benefits, Samantha receives Medicaid Personal Care (MPC). DSHS assessed Samantha as needing 90 hours of MPC per month. In 2005, DSHS adopted changes to its assessment formula pertaining to MPC. Under the new rules, Samantha's MPC hours were reduced. Samantha petitioned the Superior Court for review of the DSHS reassessment. The court invalidated some of the DSHS rule changes. DSHS appealed to the Supreme Court, arguing that the rule changes were valid. The Supreme Court agreed with the lower court, finding the rule changes invalid under the Medicaid laws. The Court affirmed the superior court's decision.

Petitioner Timothy Martin appealed his conviction on kidnapping and robbery charges. His principal claim on appeal was that the State prosecutor violated his constitutional rights when, on cross-examination at trial, the prosecutor inferred Petitioner had tailored his testimony to be consistent with police reports, witness statements and testimony presented by prior witnesses. After a thorough review of the pertinent case law and clauses of the federal and state constitutions, the Supreme Court found no violation of Petitionerâs constitutional rights. The Court affirmed Defendantâs conviction.