Justia Washington Supreme Court Opinion Summaries

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

In 1988, Darren Arends was convicted of grand theft in South Dakota, resulting in the loss of his firearm rights. In August 2023, after Washington amended its firearm restoration statute to restrict the venue for filing restoration petitions to only the county that originally imposed the prohibition, Arends filed a petition in Snohomish County Superior Court, his county of residence. He argued that he had a vested right to file under the prior version of the statute, which allowed filing in the county of residence. The State opposed, contending that Snohomish County was not the proper venue since the prohibition originated in South Dakota and that Arends had not completed all sentencing conditions.The Snohomish County Superior Court denied Arends’s petition, agreeing with the State’s arguments. The Washington Court of Appeals affirmed this decision, holding that Arends was required to file in the county that imposed the prohibition, not his county of residence. Arends then sought review by the Washington Supreme Court.The Supreme Court of the State of Washington held that the statutory venue provisions for firearm restoration petitions are procedural and do not create vested rights. The court clarified that while the legislature may set venue rules, it cannot limit the superior courts’ constitutional jurisdiction to hear such petitions. Therefore, any superior court in Washington retains original jurisdiction to consider firearm restoration petitions, regardless of the venue specified by statute. The court reversed the Court of Appeals and remanded the case to the Snohomish County Superior Court to consider the merits of Arends’s petition under the amended statute. View "Arends v. State" on Justia Law

In this case, the defendant was involved in a fatal incident at a residence where Ricardo Villaseñor was killed during a burglary. The evidence showed that multiple individuals broke into the house, and the defendant’s blood was found both at the scene and in a car associated with another suspect. The defendant claimed he was present only to buy drugs and was shot by someone else, but the trial judge found his testimony not credible. The court determined that the defendant entered the house intending to steal and participated in the burglary with another person, during which Villaseñor was killed.The Pierce County Superior Court conducted a bench trial and found the defendant guilty of felony murder predicated on burglary as an accomplice. The court entered written findings of fact and conclusions of law, specifically noting that the State did not prove the defendant was the shooter or that he knew the other participant was armed, but concluded he was guilty as an accomplice. The defendant was sentenced, with his offender score including a point for being under community custody for prior Texas drug convictions at the time of the offense. On appeal, the Washington Court of Appeals affirmed the conviction and the offender score calculation, but remanded to strike a victim penalty assessment and to address restitution interest.The Supreme Court of the State of Washington reviewed the case to clarify the proper standard for sufficiency of the evidence in bench trials and to address the offender score calculation. The court held that the correct test for sufficiency of the evidence is whether, after viewing all the evidence in the light most favorable to the State, any rational trier of fact could have found guilt beyond a reasonable doubt, as articulated in Jackson v. Virginia and adopted in State v. Green. The court clarified that its prior decision in State v. Homan did not alter this standard. The court also held that the offender score was properly calculated by including a point for community custody based on the valid out-of-state convictions. The decision of the Court of Appeals was affirmed. View "State v. Roberts" on Justia Law

Kyle Evans was charged with felony possession of a stolen vehicle in January 2024. He was not arrested but was summoned to appear for arraignment, where he pleaded not guilty and was released on personal recognizance with certain conditions. The State sought to administratively book Evans to collect his fingerprints and other identifying information, which involved patting down, handcuffing, and detaining him in a jail cell. Evans challenged this process, arguing it violated his constitutional rights under article I, section 7 of the Washington Constitution.In the King County Superior Court, Judge Johanna Bender ruled in favor of Evans, finding that the administrative booking process violated his rights by intruding on his private affairs without the necessary authority of law. Judge Bender allowed the State to collect Evans' fingerprints but prohibited the use of handcuffs, pat-downs, and detention in a cell. This decision conflicted with a ruling by Judge Melinda Young in a similar case, where the process was deemed constitutional under the Fourth Amendment.The Supreme Court of the State of Washington reviewed the case and held that King County's administrative booking process violated article I, section 7 of the Washington Constitution. The court found that the process intruded on the private affairs of pretrial releasees and that the State failed to justify this intrusion with the necessary authority of law. The court emphasized that pretrial releasees do not have diminished privacy rights simply because they have been accused of a crime. The court affirmed the trial court's order and remanded the case for further proceedings consistent with its opinion. View "State v. Evans" on Justia Law

In 2020, Kelly Balles was serving a 12-month community custody sentence for a simple drug possession conviction. During this time, he repeatedly failed to report to his community corrections officer, leading the Department of Corrections (DOC) to issue a warrant for his arrest. When law enforcement officers executed the warrant, they discovered evidence of additional violations and subsequently charged Balles with new offenses.The trial court ruled that the Washington Supreme Court's 2021 decision in State v. Blake, which found the statute criminalizing simple drug possession unconstitutional, automatically invalidated Balles's community custody term and the DOC warrant. Consequently, the court suppressed the evidence found during Balles's arrest. The State appealed, and the Court of Appeals, in a split decision, reversed the trial court's ruling, holding that the Blake decision did not automatically invalidate the outstanding warrant. The case was remanded to the trial court to address unresolved arguments.The Washington Supreme Court reviewed the case and held that the Blake decision did not automatically invalidate Balles's judgment and sentence or the DOC warrant. Instead, the conviction became eligible for vacation, and the warrant became voidable. The court emphasized that a formal process is necessary to determine the extent of Blake-related relief individuals are entitled to according to their circumstances. The court affirmed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with this opinion. View "State v. Balles" on Justia Law

Matthew Lewis pleaded guilty to multiple counts of dealing in and possessing depictions of a minor engaged in sexually explicit conduct. He had six prior convictions, three from Washington State and three from South Australia. The inclusion of the South Australian convictions increased his offender score from 6 to 9+, significantly raising the standard range sentence he faced. Lewis challenged the inclusion of these foreign convictions, but the sentencing court rejected his challenges and sentenced him to 102 months on each count, to be served concurrently, followed by 36 months of community custody.Lewis appealed to the Court of Appeals, arguing that "out-of-state convictions" did not include convictions entered in foreign countries. The Court of Appeals rejected his arguments and affirmed his sentence. Lewis then sought review from the Supreme Court of the State of Washington.The Supreme Court of the State of Washington reviewed the case de novo and concluded that the term "out-of-state convictions" in the Sentencing Reform Act (SRA) is ambiguous. The court found no helpful legislative history to clarify the term's meaning. Applying the rule of lenity, which requires ambiguous criminal laws to be construed in favor of the defendant, the court held that "out-of-state" does not include convictions entered in foreign countries. Consequently, the court reversed the Court of Appeals' decision and remanded the case for resentencing without including the South Australian convictions in Lewis's offender score. View "State v. Lewis" on Justia Law