Justia Washington Supreme Court Opinion Summaries

Charles Scott Frazier was convicted of murder and arson against his father in 1989 and received a 50-year exceptional sentence. Nearly 30 years later, Frazier sought resentencing, citing new scientific evidence on adolescent brain development, arguing that this evidence should exempt his personal restraint petition (PRP) from the one-year time limit under RCW 10.73.100(1).The superior court transferred Frazier's motion to the Court of Appeals, which dismissed his PRP as time-barred. Frazier then sought discretionary review from the Washington Supreme Court, which granted review solely on the issue of newly discovered evidence.The Washington Supreme Court reaffirmed that the newly discovered evidence exemption can apply to sentencing evidence, including new scientific developments. However, the court emphasized that petitioners must show they acted with reasonable diligence in discovering the evidence and filing the petition, and must satisfy the five-factor test for newly discovered evidence.In Frazier's case, the court found that he did not act with reasonable diligence. Although modern scientific studies on adolescent neurodevelopment were cited as early as 2005, Frazier did not file his collateral attack until 2018. The court noted that Frazier did not provide evidence of any diligent efforts to discover the new scientific studies and file his PRP.Additionally, the court found that Frazier did not satisfy the five-factor test for newly discovered evidence. The court concluded that the new studies on adolescent brain development would not probably change the result of Frazier's sentencing, as his exceptional sentence was based on findings of cruelty and abuse of trust, which were well-supported by the record.Therefore, the Washington Supreme Court affirmed the Court of Appeals' dismissal of Frazier's PRP as time-barred. View "In re Pers. Restraint of Frazier" on Justia Law

On June 3, 2017, Deputy Alexander Hawley of the King County Sheriff’s Office conducted an illegal stop of Malcolm Otha McGee, suspecting a drug transaction. During the stop, Hawley obtained McGee’s identity, phone number, and seized drugs. McGee agreed to become a confidential informant but never followed up. The next day, a 911 caller reported gunfire, and a month later, the body of Keith Ayson, who had a drug dealing relationship with McGee, was found. Police used evidence from the illegal stop to obtain warrants for McGee’s phone records, which linked him to the crime scene.The trial court ruled the June 3 stop was illegal and suppressed the drug evidence, dismissing the drug charge. However, it allowed the State to use evidence from the stop to establish McGee’s motive for murder. McGee’s first trial ended in a mistrial. Before the second trial, McGee moved to suppress evidence obtained from subsequent warrants, arguing they were based on the illegal stop. The trial court denied the motion, finding the evidence was sufficiently attenuated from the illegal stop. McGee was convicted of second-degree murder and sentenced to 298 months plus a 60-month firearm enhancement.The Washington State Court of Appeals reversed McGee’s conviction, holding that the evidence obtained from the illegal stop should have been suppressed, as it was not sufficiently attenuated. The court found that subsequent warrants relied on tainted evidence, necessitating suppression of all derived evidence and McGee’s statements to police.The Washington Supreme Court affirmed the Court of Appeals, holding that the attenuation doctrine did not apply because the new criminal act did not sever the causal connection between the illegal stop and the discovery of evidence. The court emphasized the strong privacy protections under the Washington State Constitution and rejected the State’s argument to expand the attenuation doctrine. The case was remanded for a new trial. View "State v. McGee" on Justia Law

In 2003, Nicole Willyard pleaded guilty to three charges in two separate cases: obstruction, unlawful possession of a controlled substance, and bail jumping. The bail jumping charge was due to her failure to appear for a hearing on the unlawful possession charge. Following the Washington Supreme Court's decision in State v. Blake, which declared the strict liability drug possession statute unconstitutional, Willyard sought to withdraw her guilty pleas for all charges.The trial court vacated her conviction for unlawful possession but denied her motions to withdraw the other guilty pleas. The Washington Court of Appeals affirmed this decision, holding that her motions to withdraw were time-barred. The court found that while Blake invalidated her unlawful possession conviction, it did not affect the validity of her other guilty pleas. The court also determined that the guilty pleas were part of an indivisible plea agreement, but the time bar applied to the obstruction and bail jumping charges.The Washington Supreme Court reviewed the case and held that Willyard's motions to withdraw her guilty pleas were time-barred. The court ruled that Blake did not open the door to untimely challenges to her guilty pleas, as subsequent changes in the law do not affect the validity of a plea that was knowing and voluntary at the time it was made. The court also concluded that unlawful possession under the former statute was not a "nonexistent crime," and thus, Willyard was not entitled to withdraw her guilty pleas on this basis. The court affirmed the Court of Appeals' decision and upheld the trial court's denial of Willyard's motions to withdraw her guilty pleas. View "State v. Willyard" on Justia Law

Nathan Scott Smith was charged with first-degree rape of a child. During jury selection, Smith sought to remove three potential jurors for cause, including one who expressed that she might agree with other jurors if she was "on the fence" about the verdict, citing her non-confrontational nature. The trial judge denied Smith's challenge, and the juror in question sat on the jury, which returned a unanimous guilty verdict.Smith appealed to the Washington Court of Appeals, arguing that the juror exhibited actual bias and should have been removed. The Court of Appeals agreed with Smith, finding that the juror's statements indicated a likelihood of actual bias, and reversed Smith's conviction. The State then sought review from the Washington Supreme Court.The Washington Supreme Court reviewed whether the trial court abused its discretion in denying Smith's for-cause challenge to the juror. The court emphasized that trial judges are best positioned to evaluate potential jurors' ability to serve impartially, given their ability to observe demeanor and tone. The Supreme Court found that the juror's statements were equivocal and did not unequivocally demonstrate actual bias. The court held that the trial judge acted within her discretion in concluding that the juror's answers reflected honest caution rather than actual bias.The Washington Supreme Court reversed the Court of Appeals' decision and reinstated Smith's conviction, holding that the trial court did not abuse its discretion in denying the for-cause challenge to the juror. View "State v. Smith" on Justia Law

In 2003 and 2006, Christopher Lee Olsen pleaded guilty to several offenses, including unlawful possession of a controlled substance. Following the Washington Supreme Court's decision in State v. Blake, which declared the state's strict liability drug possession statute unconstitutional, Olsen sought to withdraw his guilty pleas to all charges. The trial court vacated his drug possession convictions but denied his motions to withdraw his guilty pleas. The Court of Appeals affirmed this decision.The trial court vacated Olsen's drug possession convictions but denied his request to withdraw his guilty pleas, distinguishing between the invalidation of the convictions and the voluntariness of the pleas. The court also rejected Olsen's argument that his plea agreements were indivisible package deals. The Court of Appeals upheld the trial court's decision, concluding that Olsen's pleas were to valid charges at the time and that Blake did not render them involuntary. The court also found that Olsen failed to demonstrate actual and substantial prejudice.The Supreme Court of the State of Washington reviewed the case and held that Olsen's claims to withdraw his guilty pleas were time-barred. The court determined that while Blake invalidated Olsen's drug possession convictions, it did not entitle him to withdraw his guilty pleas. The court emphasized that a guilty plea that was valid when entered does not become involuntary due to a subsequent change in the law. Therefore, Olsen's motions to withdraw his guilty pleas were denied, and the Court of Appeals' decision was affirmed. View "State v. Olsen" on Justia Law

Olajide Adel Fletcher was sentenced based on an offender score that erroneously included two prior juvenile adjudications, resulting in a higher standard sentence range. This miscalculation was evident on the face of the judgment and sentence (J&S). Fletcher filed a postconviction motion for a new sentencing hearing, which the superior court granted despite it being filed after the usual one-year deadline. The court found the J&S invalid on its face due to the critical errors in the offender score.The Court of Appeals reversed the superior court's decision, agreeing that the J&S was facially invalid but ruling that Fletcher's motion violated procedural rules against filing successive postconviction motions. Fletcher then filed a third postconviction motion directly with the Washington Supreme Court, arguing that the J&S's serious errors made it invalid on its face.The Washington Supreme Court reviewed the case and agreed with the lower courts that the J&S was facially invalid due to the miscalculated offender score. The court held that the sentencing court must know the correct standard range to impose an exceptional sentence fairly and in accordance with statutory requirements. The court found that the original sentencing court could not have made a fair decision given the extreme miscalculation of Fletcher's offender score and standard sentence range.The Washington Supreme Court granted Fletcher's personal restraint petition (PRP) and remanded the case to the trial court for resentencing using the accurate offender score and standard sentence range. The court emphasized that the errors in the original J&S constituted a fundamental defect resulting in a complete miscarriage of justice. View "In re the Personal Restraint of Fletcher" on Justia Law

The case revolves around the issue of whether a criminal defendant can be required to appear for nonjury proceedings from an "in-court holding cell" without an individualized inquiry justifying such a restraint. The defendant, Cassandra Luthi, was required to appear for a nonjury hearing from an in-court holding cell at the Cowlitz County Jail courtroom. Despite Luthi’s objections, the superior court did not conduct an individualized inquiry to determine whether such a restraint was justified, believing that it was unnecessary to do so.The superior court had required Luthi to appear from an in-court holding cell for her hearing, without conducting an individualized inquiry into whether this restraint was justified for security reasons. The State argued that the in-court holding cell did not implicate the due process right to appear at trial free from all bonds or shackles except in extraordinary circumstances, and that these due process protections did not apply to Luthi’s hearing because it was not a trial and there was no jury.The Supreme Court of the State of Washington held that the in-court holding cell undermines the presumption of innocence, interferes with a defendant’s ability to communicate with counsel, and violates the dignity of the defendant and the judicial proceedings. Therefore, absent an individualized finding that such a restraint is necessary to protect essential state interests such as physical security, escape prevention, or courtroom decorum, the routine use of this in-court holding cell violates federal and state constitutional due process protections against inherently prejudicial courtroom practices. The court reversed the superior court, granted Luthi’s requested relief, and remanded for a new hearing. View "State v. Luthi" on Justia Law

The Supreme Court of Washington State reviewed two cases involving individuals, Kimonti Dennis Carter and Shawn Dee Reite, who were originally sentenced to mandatory life without parole (LWOP) for aggravated first-degree murders they committed between the ages of 18 and 20. Both Carter and Reite had served decades in prison and had demonstrated significant personal transformation and rehabilitation. They appealed to the court to affirm their determinate sentences, which had been granted by the superior courts at resentencing.The superior courts had resentenced Carter and Reite to determinate sentences after a previous ruling by the Supreme Court of Washington State (In re Personal Restraint of Monschke) held that mandatory LWOP sentences were unconstitutional for individuals in their age group. The State appealed these resentencing decisions, arguing that the superior courts did not have the statutory authority to impose determinate sentences for aggravated first-degree murder.The Supreme Court of Washington State affirmed the determinate sentences for both Carter and Reite. The court held that the superior courts had the statutory authority to impose determinate sentences for aggravated first-degree murder for Carter and Reite. The court also held that the superior court had the authority to resentence Carter on his other convictions. However, the court found that the superior court improperly imposed three years of community custody on Reite because this was unauthorized by statute for the crime of conviction. Therefore, the court affirmed the superior court that sentenced Carter and affirmed the superior court that sentenced Reite for all but the imposition of community custody. The court reversed and remanded to the superior court only for purposes of striking the community custody term for Reite. View "State v. Carter" on Justia Law

The case involves Andrew Bertrand, who was convicted of two counts of first-degree child molestation. Bertrand argued that his counsel was ineffective for failing to propose lesser included offense instructions on fourth-degree assault. The trial court denied Bertrand's motion, ruling that although counsel was deficient for purposes of Strickland’s first prong, Bertrand could not show prejudice as required by Strickland’s second prong. The trial court ruled that because the State had met its burden of proving each element of first-degree child molestation and the jury convicted Bertrand of those charges, he could not show prejudice.The Supreme Court of the State of Washington clarified that a defendant can show ineffective assistance based on counsel’s failure to propose a lesser included offense instruction, even if there is sufficient evidence to support the jury’s verdict. However, the court affirmed the trial court's decision, stating that Bertrand was not prejudiced by his counsel’s failure to propose the fourth-degree assault instructions. The court remanded the remaining issues to the Court of Appeals for further proceedings. View "State v. Bertrand" on Justia Law

The case involves an action filed by Spokane County Prosecuting Attorney Lawrence Haskell against Jilma Meneses, the secretary of the Washington State Department of Social and Health Services (DSHS). The Prosecutor sought a writ of mandamus directing Meneses to comply with statutory duties under chapter 10.77 RCW and timely provide competency services in criminal proceedings. The case specifically concerned three categories of Spokane County defendants in felony criminal proceedings ordered to receive competency services from DSHS.Previously, a class action was filed in federal court, challenging DSHS's delays in providing competency services to criminal defendants in pretrial custody. The United States District Court for the Western District of Washington held these delays violated the class members’ due process rights and issued a permanent injunction against DSHS. The injunction set strict time limits for providing competency services to defendants in pretrial custody, appointed a special court monitor, and began oversight of DSHS’s efforts to comply with the injunction.In the Supreme Court of the State of Washington, DSHS argued that the court must dismiss the petition for lack of original jurisdiction because the secretary is not a state officer within the meaning of the state constitution. The court agreed with DSHS, concluding that the secretary is not a state officer. The court reasoned that a state officer must be elected, subject to impeachment, and granted a State sovereign power, none of which applied to the secretary. Therefore, the court dismissed the petition for writ of mandamus. View "Spokane County v. Meneses" on Justia Law