Justia Washington Supreme Court Opinion Summaries

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

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