Justia Washington Supreme Court Opinion Summaries

Ahmed Mohamud Wasuge was found asleep in his car, which was blocking a lane of traffic on a residential road in King County, Washington. Police arrived after a 911 call and observed Wasuge in the driver’s seat with the engine running and the transmission in drive. Officers noted signs of intoxication, including the smell of alcohol, glassy and bloodshot eyes, and unsteady movements. Wasuge denied drinking but performed poorly on field sobriety tests, and his blood alcohol concentration (BAC) was measured at 0.076 percent. He was charged with felony driving under the influence (DUI) under the “affected by” prong of the statute, as well as operating a vehicle without a functioning ignition interlock device and driving while his license was revoked.At trial in the King County Superior Court, Wasuge attempted to suppress non-Mirandized statements, but the motion was denied. The jury could not reach a unanimous verdict on the felony DUI but convicted him of the lesser offense of being in actual physical control of a vehicle while “affected by” intoxicating liquor. He was also convicted on the other counts. On appeal, the Washington Court of Appeals held that the admission of a toxicologist’s testimony about impairment at BAC levels below the legal limit was improper but harmless due to overwhelming evidence of guilt. The court further concluded that Wasuge was not in custody for Miranda purposes when questioned by police.The Supreme Court of the State of Washington reviewed the case and affirmed the Court of Appeals. The main holdings are: (1) any error in admitting the toxicologist’s testimony was harmless under both constitutional and nonconstitutional standards, given the strength of the properly admitted evidence; and (2) courts may consider relevant and objective evidence of race and ethnicity in applying the “totality of the circumstances” custody test for Miranda purposes, though Wasuge was not in custody at the time of the contested questioning. View "State v. Wasuge" on Justia Law

Renton police and SWAT officers executed a search warrant at the apartment where Cristian Magaña Arévalo was staying with his family, seeking evidence related to the murder of Jason Hobbs. Officers ordered everyone out using a bullhorn, separated Magaña Arévalo from his family, restrained him with zip ties, and placed him in a patrol car before transporting him to a nearby parking lot. There, he was transferred to an officer’s work truck and questioned about Hobbs’s murder without receiving Miranda warnings. The officer told him he was “not under arrest” and asked if he would talk, which Magaña Arévalo agreed to. Two days later, he was interviewed again in a noncustodial setting, also without Miranda warnings.In King County Superior Court, Magaña Arévalo moved to suppress both statements, arguing the first was obtained during a custodial interrogation without Miranda warnings and the second was tainted by the initial violation. The court held a CrR 3.5 hearing and ruled both statements admissible, finding neither interrogation custodial or coerced. The jury convicted Magaña Arévalo of first degree murder, and the court sentenced him to prison. On appeal, the Washington Court of Appeals found the December 1 interrogation was custodial and that admitting the statement was error, but held the error was harmless beyond a reasonable doubt because of other strong evidence, including the December 3 statement and physical evidence.The Supreme Court of the State of Washington reviewed both parties’ petitions. It held that considering the totality of the circumstances—including restraints, isolation, police presence, and ethnicity—Magaña Arévalo was in custody during the December 1 interrogation, and admitting his statement without Miranda warnings violated his constitutional rights. However, the court found the December 3 statement was voluntary, noncustodial, and not tainted by the earlier violation. Applying a clarified harmless error standard, the court affirmed the Court of Appeals, holding the constitutional error was harmless beyond a reasonable doubt. View "State v. Magana-Arevalo" on Justia Law

Anthony Lee was accused of assaulting Amy Groff at his home near Sequim, Washington. After an evening spent together, Lee became angry with Groff, allegedly due to her drug use, theft, and verbal abuse. When they returned home, Lee reportedly fired a gun in the air, struck Groff in the head with the gun, pushed her out of his truck, kicked and hit her, and then shot at her as she ran away. Groff was later found by police with visible injuries and recounted the assault to officers.Lee was charged in the Clallam County Superior Court with two counts of second degree assault with a deadly weapon, each based on separate alleged acts: one for beating Groff with the gun and another for shooting at her. At trial, the judge admitted Groff’s statements to police under the excited utterance exception to hearsay, and instructed the jury not to consider any judicial comments as opinions on the evidence. The jury found Lee guilty on both counts, and the trial court determined the assaults were distinct acts, rejecting Lee’s double jeopardy argument. Lee appealed, raising the double jeopardy issue and, for the first time, challenging the trial judge’s comment on the evidence. The Washington Court of Appeals affirmed both convictions, finding no double jeopardy violation and no manifest constitutional error regarding the judicial comment.The Supreme Court of the State of Washington reviewed the case and held that, under the unit of prosecution analysis and considering all relevant factors, Lee’s assaultive acts constituted a single course of conduct. Therefore, two convictions for second degree assault violated double jeopardy principles. The court reversed on that issue, ordering one conviction and its firearm enhancement to be vacated. On the comment on the evidence issue, the court affirmed, finding no manifest constitutional error that would permit review for the first time on appeal. View "State v. Lee" on Justia Law

On the evening of April 12, 2022, Ralph Kinerson was stabbed following a physical altercation at his home. Both Kinerson and Barclay Dylan Bennett testified that they fought that night, but their accounts differed regarding the circumstances and who initiated the violence. Kinerson claimed Bennett attacked him at his home, while Bennett asserted that Kinerson assaulted him in the street, aided by others, and denied stabbing Kinerson. The police interviewed witnesses, including Kinerson’s neighbor and Kinerson’s daughter, Malea, whose statements became central to the subsequent trial.During trial in the Spokane County Superior Court, Bennett was charged with first degree assault. Bennett’s defense focused on alleged deficiencies in the police investigation, suggesting that officers failed to consider other suspects. On cross-examination, Bennett introduced portions of Malea’s interview with a detective to support this theory, referencing statements about another woman, Abbey Pearson, possibly stealing from Kinerson. In response, the State introduced another part of Malea’s interview, which suggested Bennett had a motive to attack Kinerson due to his relationship with Kinerson’s friend, Roberts. Bennett objected on hearsay and Sixth Amendment grounds, arguing he could not confront Malea, who was unavailable to testify. The trial court overruled the objection, finding Bennett had “opened the door” to the evidence.The Washington Court of Appeals affirmed Bennett’s conviction, concluding that any error in admitting the hearsay was invited by Bennett’s own actions and precluded review, even for constitutional claims. The Supreme Court of the State of Washington affirmed the appellate decision, holding that the statement’s admission was justified under the rule of completeness (ER 106). The Court found the statement was not offered for its truth but to contextualize the investigation, so it did not trigger the confrontation clause. Bennett’s conviction was upheld. View "State v. Bennett" on Justia Law

Two individuals each pleaded guilty in separate cases to unlawful possession of controlled substances in Washington State. As part of their sentences, both were required to pay legal financial obligations (LFOs), which they partially satisfied through cash payments and through performing community service. Years later, following the Washington Supreme Court’s invalidation of the simple drug possession statute in State v. Blake, both individuals successfully moved to vacate their convictions and sought reimbursement for both the cash paid and the labor performed in community service that had satisfied portions of their LFOs.The trial courts vacated their convictions and reimbursed the cash payments but declined to reimburse for the value of the community service hours. Both individuals appealed. The Washington State Court of Appeals affirmed the trial courts’ decisions, holding that there was no substantive due process right to monetary reimbursement for community service work performed in lieu of LFO payments and that equal protection was not violated. The appellate court found that the appellants had not shown they were treated disparately from similarly situated individuals based on economic status, and even if there was disparate treatment, the decision to not reimburse for community service hours was rationally related to a legitimate governmental interest.The Supreme Court of the State of Washington reviewed the consolidated appeals. The court held that there is no constitutional right—fundamental or otherwise—to reimbursement for community service work performed in satisfaction of court-imposed financial obligations when convictions are later invalidated. The court found no disparate treatment based on economic status and therefore no actionable equal protection claim. The decision of the Court of Appeals and the trial courts was affirmed. View "State v. Danielson" on Justia Law

An 18-year-old individual was convicted of second degree felony murder and sentenced to 300 months in prison, with an offender score that included a prior drug possession conviction. The court also imposed over $7,000 in restitution to the Crime Victims Compensation fund, covering part of the victim’s funeral expenses. Years later, following the Washington Supreme Court’s decision in State v. Blake, which invalidated certain drug possession convictions, the individual’s prior conviction was vacated, reducing his offender score and lowering his sentencing range. At the resentencing hearing, the individual specifically requested that the court consider his youth at the time of the offense as a mitigating factor. The resentencing judge declined to do so, stating that the issue of youthfulness was not relevant to the hearing and could be raised elsewhere, and imposed a sentence within the new standard range as recommended by defense counsel.The Washington Court of Appeals reviewed the case and held that, although the resentencing judge had discretion to consider youth as a mitigating factor, any error in failing to do so was harmless because the sentence imposed matched the defense’s request. The Court of Appeals also found that the restitution order was not constitutionally excessive, as it was compensatory rather than punitive.The Supreme Court of the State of Washington reversed the Court of Appeals in part. It held that the resentencing court abused its discretion by failing to meaningfully consider the individual’s youthfulness when specifically asked, as required by precedent. The court clarified that while a judge is not required to impose a lower sentence due to youth, the judge must at least consider it as a mitigating factor. The Supreme Court affirmed the Court of Appeals’ ruling that the restitution was not excessive, as it was solely compensatory. The case was remanded for a new resentencing hearing. View "State v. Ellis" on Justia Law

A 16-year-old girl, Luna, was involved in a fatal altercation with another teenager, S.P.T., whom she knew only through social media. The conflict began when S.P.T. arrived at Luna’s home and initiated a physical fight by punching Luna. Luna responded by using a pocketknife, resulting in S.P.T.’s death. Prior to the incident, Luna had received social media messages that she interpreted as threats, including an image suggesting gang violence. The State charged Luna with murder, and she was tried as an adult.In the Kitsap County Superior Court, the State was permitted to introduce various pieces of social media evidence and a video of Luna’s police interrogation to suggest preexisting violent intent and lack of remorse. Luna argued self-defense and sought to introduce additional social media evidence to support her fear of S.P.T., but some of this evidence was excluded. The jury found Luna guilty of intentional, but not premeditated, second-degree murder. On appeal, the Washington Court of Appeals affirmed the conviction, finding that some social media evidence was improperly admitted but deemed the error harmless. The appellate court also held that a new statute requiring juveniles to be provided counsel before interrogation did not apply retroactively to Luna’s case.The Supreme Court of the State of Washington reviewed the case. It held that the new statute, RCW 13.40.740, did not apply retroactively to Luna’s interrogation. However, the court found that Luna did not validly waive her right to silence, and her interrogation statements should have been excluded. The court also determined that several evidentiary rulings regarding social media evidence were erroneous and undermined the fairness of the trial. The Supreme Court vacated the jury verdict and remanded the case for further proceedings. View "State v. Luna" on Justia Law

In 1985, a 20-year-old individual committed a burglary that resulted in the fatal stabbing of a 14-year-old boy. The following year, a jury convicted him of aggravated first degree murder. At that time, Washington law required a mandatory sentence of life without the possibility of parole (LWOP) for such a conviction, and the sentencing judge stated he had no discretion to impose any other sentence. The individual has been incarcerated for nearly 40 years under this sentence.After his conviction and sentence were affirmed by the Washington Court of Appeals in 1988, the petitioner sought resentencing in 2023, arguing that recent Washington Supreme Court decisions—specifically In re Personal Restraint of Monschke and State v. Carter—rendered his mandatory LWOP sentence unconstitutional. The King County Superior Court transferred his motion to the Court of Appeals, which then certified the case for direct review by the Washington Supreme Court.The Supreme Court of the State of Washington held that its decision in Monschke constituted a significant change in the law, exempting the petitioner’s claim from the one-year time bar for collateral relief. The court found that mandatory LWOP sentences for individuals aged 18 to 20 at the time of their offense, imposed without consideration of youth as a mitigating factor, are unconstitutional under the state constitution’s prohibition on cruel punishment. The court further held that a petitioner in this situation demonstrates actual and substantial prejudice if Monschke is material to their sentence. The court granted the personal restraint petition and remanded the case to the trial court for a new sentencing hearing. View "In re Personal Restraint of Schoenhals" on Justia Law

The case concerns a man who, after a heated argument with his wife in their home, threatened her with a gun in the presence of their children. The incident escalated to physical violence and a standoff with law enforcement, ending with his surrender. The defendant was charged with multiple offenses, but relevant here are his convictions for second degree assault with a deadly weapon and felony harassment (threat to kill), both arising from the same sequence of conduct.At trial in the Superior Court, the jury convicted the defendant of both second degree assault and felony harassment, each with firearm and domestic violence aggravators. The trial court found these offenses constituted the “same criminal conduct” for sentencing purposes and imposed concurrent sentences with consecutive firearm enhancements. On appeal, the Washington Court of Appeals affirmed the convictions, rejecting the defendant’s argument that punishing both offenses violated double jeopardy protections.The Supreme Court of the State of Washington reviewed whether the two convictions violated the constitutional prohibition on double jeopardy by imposing multiple punishments for the same offense. The court held that, although both convictions were based on the same conduct, they were not the same in law because each offense required proof of a fact the other did not: assault required intentional conduct with a deadly weapon causing fear of bodily injury, while harassment required a knowing threat to kill. The court found no clear legislative intent to prohibit separate punishments for these offenses and concluded that the convictions did not violate double jeopardy. The Supreme Court of Washington affirmed the decision of the Court of Appeals and upheld the convictions. View "State v. Ray" on Justia Law

Lester Thompson Jr. was charged with the murder of Destinie Gates-Jackson, with whom he had a long-term relationship. After previously being convicted of kidnapping and assaulting Ms. Gates-Jackson, Thompson was found driving a car containing her body, and forensic evidence indicated she died from strangulation. Thompson’s defense at trial was that Ms. Gates-Jackson died from an underlying health condition, not homicide, and he sought to subpoena her medical records to support this theory. Jeri Gates, the decedent’s mother and representative, intervened to oppose the release of these records, citing privacy concerns. The trial court denied Thompson’s motions to subpoena the records, and he was convicted of second-degree murder with a domestic violence finding.Thompson appealed his conviction to the Washington Court of Appeals, arguing, among other things, that the trial court erred in denying his request for the medical records. Ms. Gates moved to intervene in the appeal solely on the issue of the medical records, and the Court of Appeals granted her motion over Thompson’s objection. Thompson then sought review by the Supreme Court of the State of Washington, contending that the appellate court erred in permitting Ms. Gates to intervene.The Supreme Court of the State of Washington held that when a trial court has allowed a nonparty to intervene to protect a legally cognizable interest, an appellate court has the discretion to permit that nonparty to intervene on appeal, provided the intervention is limited to the same issues addressed below. The court affirmed the Court of Appeals’ decision, concluding that the appellate intervention was proper under these circumstances and within the appellate court’s discretionary authority. View "State v. Thompson" on Justia Law