Justia Washington Supreme Court Opinion Summaries

Samantha Hall-Haught was involved in a head-on collision, leading to the discovery of drug paraphernalia in her vehicle. At the hospital, a state trooper observed signs of drug use and obtained a warrant to test her blood, which revealed the presence of THC. Hall-Haught was charged with vehicular assault, and at her trial, a lab supervisor testified about the blood test results instead of the technician who conducted the test. Hall-Haught objected, arguing that her right to confront the witness against her was violated.The trial court admitted the lab results, and Hall-Haught was convicted. She appealed, and the Washington Court of Appeals affirmed the conviction, reasoning that the supervisor's independent review and testimony did not violate the confrontation clause. The court relied on the precedent set in State v. Lui, which allowed expert witnesses to testify based on data prepared by others.The Supreme Court of Washington reviewed the case and reversed the Court of Appeals' decision. The court held that the confrontation clause was violated because the lab report was testimonial, and the technician who performed the test was the actual witness against Hall-Haught. The court emphasized that the supervisor's testimony, which relied on the technician's report, was admitted for its truth, thus implicating the confrontation clause. The court remanded the case for further proceedings consistent with this opinion. View "State v. Hall-Haught" on Justia Law

Frank Edward Stearns was stopped by police on suspicion of driving under the influence (DUI) after a 911 caller reported that he appeared drunk and was staggering in a parking lot. The caller described Stearns and his vehicle in detail. Officer Natalie BrinJones responded to the call, observed Stearns driving erratically, and eventually stopped him. Stearns exhibited signs of intoxication, and subsequent breath tests confirmed his blood alcohol content was over three times the legal limit.Stearns was charged with DUI, failure to obey a police officer, operating a vehicle without a required interlock device, and driving with a suspended license. He moved to suppress evidence from the stop, arguing it was not supported by reasonable suspicion. The district court denied the motion, finding reasonable suspicion for the stop. Stearns was convicted on all charges except driving with a suspended license. On appeal, the superior court reversed the convictions, ruling the stop was unlawful due to lack of reasonable suspicion. The Court of Appeals affirmed the superior court's decision.The Supreme Court of the State of Washington reviewed the case and held that the stop was lawful. The court found the 911 call reliable because it was a contemporaneous eyewitness report to the emergency line, and the officer's observations corroborated the caller's report. The court concluded that the caller's description of Stearns's behavior, combined with the officer's observations, provided a sufficient factual basis for reasonable suspicion of DUI. The Supreme Court reversed the Court of Appeals and reinstated Stearns's convictions. View "City of Wenatchee v. Stearns" on Justia Law

Abbas Salah Zghair was convicted by a jury of second-degree felony murder while committing second-degree assault with a firearm enhancement. The case revolves around the fatal shooting of Silvano Ruiz-Perez, whose body was found in an unattended field in Auburn, Washington. Evidence included cell site location data, traffic camera footage, and video surveillance, which placed Zghair and Ruiz-Perez together on the night of the shooting. Forensic evidence linked Zghair’s car to the crime scene, and Zghair admitted to owning the car and having knowledge of the shooting.The trial court sentenced Zghair to 252 months in prison. On appeal, Zghair argued that the evidence was insufficient to support his conviction as either a principal or an accomplice. The Washington Court of Appeals reversed the conviction, concluding that the evidence did not support Zghair’s conviction under either theory.The Supreme Court of the State of Washington reviewed the case. The court held that the evidence was sufficient to support Zghair’s conviction. The court emphasized that circumstantial evidence is as reliable as direct evidence and that the jury could reasonably infer Zghair’s knowledge and involvement in the crime. The court also clarified that Washington’s complicity statute does not require proof of knowledge of a specific plan to commit the crime, only general knowledge that the crime would be committed. The court found that the totality of the circumstantial evidence supported the jury’s conclusion that Zghair either committed the assault or aided in its commission.The Supreme Court of the State of Washington reversed the Court of Appeals' decision and affirmed Zghair’s conviction. View "State v. Zghair" on Justia Law

Jasper Nelson, a 19-year-old, ran away with a 12-year-old girl, A.S.J., who had left a note expressing suicidal thoughts. Law enforcement, suspecting a sexual relationship, located A.S.J. and later arrested Nelson. Nelson admitted to having sex with A.S.J. multiple times and soliciting sex from an 11-year-old girl, J.W. Nelson pleaded guilty to amended charges, including third-degree rape of a child and second-degree child molestation. The court imposed a Special Sex Offender Sentencing Alternative (SSOSA), suspending his 87-month sentence on conditions including community custody and treatment.Nelson violated his SSOSA by accessing unauthorized electronic devices and inappropriate content, leading to a revocation hearing. He admitted to the violations, and the court revoked his SSOSA, reinstating his original sentence. Nelson appealed, challenging the revocation process and several community custody conditions, including those requiring breath analysis (BA) and urinalysis (UA) testing for alcohol and drug use.The Washington Court of Appeals affirmed the revocation and addressed Nelson's challenges to the community custody conditions. The court held that the BA and UA testing conditions were valid for monitoring compliance with the prohibitions on alcohol and drug use, even though these prohibitions were not directly related to his crimes.The Washington Supreme Court reviewed the case, focusing on whether the BA and UA testing conditions violated Nelson's constitutional rights. The court held that Nelson's preenforcement challenge was not ripe for review due to the need for further factual development. However, the court addressed the merits, affirming that the BA and UA testing conditions were narrowly tailored to serve the state's compelling interest in monitoring compliance with valid community custody conditions. The court concluded that these conditions were constitutionally permissible, even if not directly related to the underlying offenses. View "State v. Nelson" on Justia Law

In 2001, a 17-year-old Morris Mullins killed a 78-year-old widow, Amy Davis, and was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At the sentencing, the court considered evidence of Mullins’s dysfunctional upbringing and psychological evaluation but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama. The district court denied his motion in 2016, and Mullins’s appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether the sentencing court properly considered Mullins’s youth and potential for change as required by Miller and subsequent cases. The court found that the sentencing judge’s comments suggested ambiguity about Mullins’s capacity for change, undermining confidence in the constitutionality of the JLWOP sentence. The court vacated Mullins’s sentence and remanded the case for resentencing, emphasizing the need to consider the constitutional implications of Mullins’s youth and potential for rehabilitation. View "Galassi v. Lowe's Home Centers, LLC" on Justia Law

Mary Mercedes was accused of animal cruelty based on evidence obtained during a warrantless search of her property. Officers visited her property multiple times after receiving complaints about the condition of her animals. During these visits, Mercedes allowed the officers to view the animals, and based on their observations, a search warrant was later issued. The officers then seized the animals, and Mercedes was charged with two counts of animal cruelty.The trial court granted Mercedes's motion to suppress the evidence obtained from the property visits, ruling that the officers' consent to enter was invalid without providing Ferrier warnings, which inform individuals of their right to refuse, limit, and revoke consent. The trial court dismissed the charges due to lack of probable cause. The State appealed, and the Court of Appeals reversed the trial court's decision, concluding that Ferrier warnings were not required for the search of Mercedes's outdoor property and remanded the case to determine if her consent was voluntary.The Supreme Court of the State of Washington reviewed the case and affirmed the Court of Appeals' decision. The court held that Ferrier warnings are required only when officers seek to enter a person's home to conduct a warrantless search for evidence of a crime. Since the officers' visits to Mercedes's property were for investigative purposes and did not involve entering her home, Ferrier warnings were not necessary. The case was remanded to the trial court to determine if Mercedes's consent was voluntary under the totality of the circumstances. View "State v. Mercedes" on Justia Law

Montreal Morgan participated in a home invasion robbery that resulted in the death of Fabian Alvarez. Following the incident, the Department of Labor and Industries (L&I) paid $10,480 in benefits under Washington’s Crime Victims Compensation Act (CVCA) for Alvarez’s medical and funeral expenses. Morgan pleaded guilty to conspiracy to commit murder in the second degree and unlawful possession of a firearm in the second degree. At his restitution hearing, Morgan requested a reduction in the restitution amount due to mitigating factors, but the trial court believed it lacked discretion under RCW 9.94A.753(7) and ordered the full amount of restitution requested by the State.The trial court’s decision was affirmed by the Court of Appeals, which agreed that RCW 9.94A.753(7) does not afford trial courts discretion to impose less restitution than the amount of CVCA benefits paid. Morgan then petitioned for review, which was granted by the Supreme Court of the State of Washington.The Supreme Court of the State of Washington held that RCW 9.94A.753(7) does not allow a trial court discretion to modify the amount of restitution owed to L&I for CVCA benefits. The court emphasized that the statutory language is unambiguous and requires the court to order restitution in the amount of benefits paid by L&I. The court affirmed the Court of Appeals' decision and upheld Morgan’s restitution order, concluding that the trial court correctly interpreted the statute as mandating full restitution for CVCA benefits without discretion for reduction based on mitigating factors. View "State v. Morgan" on Justia Law

Anthony Vasquez was convicted of multiple offenses, including aggravated first-degree murder, unlawful possession of a firearm, and tampering with a witness, for shooting and killing Juan Garcia in 2013. Vasquez was sentenced to life without parole. On appeal, the Court of Appeals vacated the aggravated murder conviction, concluding it was not a drive-by shooting, and affirmed the other convictions. Vasquez was resentenced to 660 months. He appealed again due to a clerical error, and the Court of Appeals remanded for clarification.Following the State v. Blake decision, which held the former simple possession statute unconstitutional, Vasquez filed a CrR 7.8 motion for relief from judgment, arguing his judgment and sentence (J&S) was invalid due to a drug possession conviction. The State conceded, and Vasquez was resentenced to 620 months. The resentencing judge limited the scope of arguments, rejecting Vasquez's request to consider his youth at the time of the crime.Vasquez appealed, arguing the superior court erred by not conducting a de novo resentencing and not considering his youth. The Court of Appeals agreed, holding that resentencing should be de novo unless specifically restricted by an appellate court. The court noted that the resentencing judge should exercise independent discretion and consider all relevant arguments and evidence.The Supreme Court of the State of Washington affirmed the Court of Appeals, holding that at a resentencing hearing, the court has the same discretion as an original sentencing judge. The parties must be allowed to present mitigating and aggravating factors, and the judge must exercise independent discretion in sentencing. The case was remanded for a new resentencing hearing. View "State v. Vasquez" on Justia Law

In May 2006, Timothy Kelly was convicted of unlawful possession of a controlled substance and other burglary-related offenses. His offender scores for these offenses ranged from 11 to 14 points. Later, in November 2006, Kelly was convicted of additional offenses, including first-degree burglary and firearm-related crimes, with offender scores ranging from 21.5 to 26.5 points. In 2021, following the decision in State v. Blake, which invalidated Washington’s drug possession statute, Kelly sought resentencing. The trial court vacated his drug possession conviction and adjusted his offender scores but denied resentencing for the May 2006 convictions, as Kelly had already served his sentence.The Court of Appeals held that Kelly’s request for resentencing on his non-drug-related May 2006 convictions was time-barred under RCW 10.73.090(1) and .100. The court also ruled that the trial court lacked the authority to run Kelly’s firearm enhancements concurrently. Kelly appealed, arguing that the Blake decision was material to his sentences and that his judgment and sentence were facially invalid due to the unconstitutional conviction.The Supreme Court of Washington affirmed the Court of Appeals. The court held that while Blake was a significant change in the law, it was not material to Kelly’s non-drug-related sentences because his offender scores remained above 9 points, and his standard sentencing ranges did not change. The court also held that Kelly’s judgment and sentence were not facially invalid, as the sentencing court did not exceed its authority. Additionally, the court declined to overrule State v. Brown, which held that firearm enhancements must run consecutively and cannot be modified through an exceptional sentence. The court concluded that the invited error doctrine did not preclude the State from challenging the judgment and sentence. View "State v. Kelly" on Justia Law

In 2011, 17-year-old Darren Harris fatally stabbed an acquaintance and stole his wallet. Harris was charged with first-degree murder with a deadly weapon. After negotiations, Harris pleaded guilty to second-degree murder and first-degree robbery, with a joint sentence recommendation of 244 months. The trial court accepted the plea and imposed the recommended sentence.Harris later filed a personal restraint petition, arguing for resentencing based on the State v. Houston-Sconiers decision, which requires courts to consider the mitigating qualities of youth. The Court of Appeals dismissed the petition as frivolous but later granted Harris an extension to appeal. The Court of Appeals found that Harris had agreed not to seek a lesser sentence and concluded that any resentencing would breach the plea agreement. The court held that Houston-Sconiers applied retroactively but did not require resentencing, suggesting Harris could withdraw his guilty plea instead.The Supreme Court of Washington reviewed the case and held that when a trial court accepts a plea agreement with a joint sentence recommendation, it is not required to independently consider mitigating evidence of youth under Houston-Sconiers. The court emphasized the importance of plea bargaining in the criminal justice system and concluded that no error occurred when the trial court did not inquire into Harris's youth before accepting the plea agreement. The court reversed the Court of Appeals' decision in part, affirming Harris's sentence and holding that resentencing was not required. View "State v. Harris" on Justia Law