Justia Washington Supreme Court Opinion Summaries

The issue this case presented for the Washington Supreme Court’s review centered on the eligibility criteria of the special sex offender sentencing alternative (SSOSA), which required offenders to have an established relationship with, or connection to, the victim such that the sole connection with the victim was not the commission of the crime. Petitioner Cory Pratt and his victim shared a family member in common, but did not have a direct relationship. In 2016, Pratt and his daughter attended his cousin’s birthday party. Several young girls spent the night after the party, including M.B., the 10-year-old daughter of Pratt’s aunt’s stepsister. Pratt slept in a backyard tent with the girls. The next day, M.B. told her grandmother and parents that Pratt touched her in the tent. Pratt was charged with one count of first-degree child molestation, and convicted after a two-day bench trial. Pratt requested the SSOSA sentence at issue here. The State contended he was not eligible because he did not have an “established relationship” with M.B. as required by statute: the State noted Pratt had met the child hours of the party; Pratt contended his connection was established through “familial ties.” The trial court sentenced Pratt according to SSOSA, reducing his sentence from 57 months of confinement to 12 months. The State appealed. Concluding Pratt was not “connected” to his victim as contemplated by the applicable statute, the Washington Supreme Court determined he was not eligible for a SSOSA sentence. The Court of Appeals was affirmed and the matter remanded for resentencing. View "Washington v. Pratt" on Justia Law

In 2007, petitioner Alejandro Garcia Mendoza pled guilty to unlawful possession of a controlled substance. He moved to withdraw the plea on grounds his counsel did not advise him as required by Padilla v. Kentucky, 599 U.S. 356 (2010). Petitioner also argued he did not need to show prejudice under RCW 10.40.200. The Court of Appeals concluded petitioner was raising two claims: a constitutional claim that was exempt from the time bar, and a statutory claim that was not. It dismissed his challenge as mixed without reaching the merits. The Washington Supreme Court concluded petitioner made one claim for relief: ineffective assistance of counsel for failing to advise him of the immigration consequences of his plea. The Court rejected petitioner’s argument that under RCW 10.40.200 he did not need to show prejudice to bring this claim, but since he made a prima face showing of ineffective assistance in a challenge that is time exempt, the dismissal of his petition was vacated and this matter was remanded back to the Court of Appeals for further proceedings. View "In re Pers. Restraint of Garcia-Mendoza" on Justia Law

A patient being treated for a sexual assault made statements to a sexual assault nurse examiner in the course of an exam with both medical and forensic purposes. The Washington Supreme Court held that under these circumstances, the primary purpose of nearly all of the statements was to guide the provision of medical care, not to create an out-of-court substitute for trial testimony. Thus, the statements were not testimonial, so their admission did not violate the Sixth Amendment. Furthermore, the Court held that the trial court did not abuse its discretion in admitting those statements under the hearsay exception for statements made for purposes of medical diagnosis or treatment. Finally, the Court found the trial court did err in admitting one statement describing the assailant, but the error was harmless. Accordingly, the Supreme Court reversed. View "Washington v. Burke" on Justia Law

The issue this case presented for the Washington Supreme Court's review centered on whether the state legislature could impose a duty to register as a sex offender in Washington where an individual would be required to register in the state of conviction. In 1984, respondent Benjamin Batson pleaded guilty in an Arizona court to two counts of sexual conduct with a minor. As a result of his conviction, Arizona law required Batson to register as a sex offender for life. At some point prior to April 6, 2009, Batson moved to Washington. At that time, the State required individuals to register as sex offenders only if their out-ofstate offense would have been classified as a sex offense in Washington. Since Batson’s Arizona conviction arose from sexual contact with a 16-year-old, his offense would not have been a crime in Washington. But in June 2010, the state legislature amended the sex registry statute to require registration for “[a]ny federal or out-of-state conviction for: [a]n offense for which the person would be required to register as a sex offender while residing in the state of conviction.” The Court of Appeals held that RCW 9A.44.128(10)(h) was an unconstitutional delegation of legislative authority, but the Washington Supreme Court reversed: "the legislature permissibly identified circumstances under which Washington sex offender registration requirements become operative as to individuals with out-of-state convictions." View "Washington v. Batson" on Justia Law

Simon Martinez sexually abused his daughter, Y.M., for nearly a decade, starting when she was about 5 years old. Martinez raped and sexually abused Y.M. regularly until she moved out of the family home in 2014, when she was about 14. Around that time, she told several people about the sexual abuse, including authorities. The State charged Martinez with one count of first degree rape of a child, which required it to prove Martinez raped Y.M. when she was no more than 12 years old. The State limited the charging period to three years: July 2009 to July 2012, even though there was considerable evidence the abuse continued until Y.M. was 14. The State elected not to add a charge of second degree rape. During trial, over Martinez’s objection, Y.M.’s two friends, her mother, and a friend’s mother were all permitted to testify that in 2014, Y.M. told them she had been sexually abused; this was long after the charging period, but contemporaneous with the ongoing abuse. Martinez moved to exclude Y.M.’s complaints to these witnesses as untimely since they happened so long after the charging period. The trial judge denied the motion, concluding that complaints were no longer required to be timely to be admissible. Based on those complaints, Y.M.’s testimony, and other evidence, the jury found Martinez guilty. Martinez received an indeterminate sentence of 123 months to life. Martinez largely argued on appeal that the trial court abused its discretion in allowing the four witnesses to testify. Finding no such abuse of discretion, the Washington Supreme Court affirmed his conviction and sentence. View "Washington v. Martinez" on Justia Law

In 2010, Amanda Knight and accomplices ransacked James and Charlene Sanders’ home, zip-tied them, placed them face down on the floor, stole their wedding rings off their fingers at gunpoint, pistol-whipped Charlene and her son, and shot and killed James Sanders. A jury convicted Knight of multiple crimes, including felony murder in the first degree, two counts of robbery in the first degree, two counts of assault in the second degree, and burglary in the first degree. By way of personal restraint petition, Knight challenged these convictions on double jeopardy grounds, arguing that her robbery and felony murder conviction against James, as well as her robbery and assault conviction against Charlene, should have merged. The Court of Appeals held that the two convictions against James merged, but declined to review Knight’s convictions against Charlene because the Court of Appeals had previously reviewed and dismissed that double jeopardy claim on direct appeal. The Washington Supreme Court held that Knight’s convictions against James Sanders did not merge, and that review of her convictions against Charlene Sanders was barred. "Knight’s robbery and felony murder convictions against James served independent effects, falling under an exception to the double jeopardy merger doctrine. However, the Court of Appeals correctly held that Knight’s claim against her convictions in regards to Charlene is barred as it was already raised and dismissed on direct appeal. Accordingly, we affirm in part and reverse in part the Court of Appeals’ ruling, affirm Knight’s original conviction and sentence, and dismiss her personal restraint petition." View "In re Pers. Restraint of Knight" on Justia Law

A jury found Ira Cranshaw guilty of several crimes committed against two victims. The convictions included attempted first degree murder of B.B. (count I), three counts of first degree rape of B.B. (counts II, III, and IV), first degree kidnapping of B.B. (count V), harassment of B.B. (count VI), two counts of first degree rape of S.H. (counts VII and VIII), first degree kidnapping of S.H. (count IX), and harassment of S.H. (count X). On direct appeal, the Court of Appeals reversed Cranshaw’s convictions as to B.B. and remanded for a new trial on all of the counts involving her (I through VI), but it affirmed his convictions on the counts involving S.H. (counts VII through X) and remanded for resentencing on only those counts. This matter involved the proper calculation of an offender score in an unusual circumstance, which the State conceded resulted in Cranshaw receiving a longer sentence than he would have received if he had been sentenced in the normal manner. In May 2019, Cranshaw filed a personal restraint petition, raising a double jeopardy claim and a claim regarding the calculation of his offender scores. The acting chief judge dismissed the petition, and Cranshaw filed a motion for discretionary review. Cranshaw then moved to amend his motion for discretionary review, which the Washington Supreme Court allowed. After the State answered the amended motion for discretionary review, the deputy commissioner issued a ruling rejecting the double jeopardy claim. The Supreme Court determined the double jeopardy claim lacked merit, but the Court concluded Cranshaw demonstrated his judgment and sentence was facially invalid based on the offender score calculation, and he was entitled to be resentenced. View "In re Pers. Restraint of Cranshaw" on Justia Law

In May 2017, petitioner Gregg Loughbom was charged with three counts of various drug crimes: count I, delivery of controlled substances acetaminophen and hydrocodone; count II, delivery of controlled substance methamphetamine; and count III, conspiracy to deliver a controlled substance other than marijuana. These charges stemmed from two controlled drug buys conducted by a confidential informant (CI) on December 20 and 31, 2016. The information was later amended to include school zone enhancements for all three counts pursuant to RCW 69.50.435. During jury selection, the prosecutor asked, “Are there any among you who believe that we have a drug problem in Lincoln County?” He then commented, “Wow, okay. Just about every[one],” and followed with the question, “Is there anyone who feels that we don’t?” Thereafter, the prosecutor referenced the war on drugs three times. The issue this case presented for the Washington Supreme Court's review centered on whether the prosecutor committed reversible error when he repeatedly invoked the phrase, “war on drugs” during the one-day jury trial, without objection by petitioner. The Court held that the State’s framing of Loughbom’s prosecution as representative of the war on drugs denied Loughbom a fair trial and constitutes reversible error. Therefore, the Court reversed the Court of Appeals and remanded for a new trial. View "Washington v. Loughbom" on Justia Law

This matter came before the Washington Supreme Court on a petition for a writ of mandamus from five inmates serving criminal sentences at different Washington Department of Corrections (Department) facilities. The Supreme Court retained jurisdiction because of the extraordinary nature of the relief petitioners sought, and because of the extraordinary danger COVID-19 (coronavirus disease) posed to inmates in Washington’s prisons. Rather, the parties agreed on a record that mainly included descriptions of the prison conditions, expert opinions on the risks that COVID-19 presented in the prison environment, and petitioners’ declarations as to their individual situations. For purposes of the Court's decision, it accepted petitioners’ factual descriptions as true. The petitioners claimed close confinement created a substantial risk of harm because of the current public health emergency caused by COVID-19. "These concerns are legitimate and well founded:" the current widely reported medical evidence suggested COVID-19 risks of serious complications or death are highest for offenders over age 50 and those with certain preexisting medical conditions, but it could also be serious for younger people and those in good health. And serious outbreaks have occurred at other prisons and jails nationwide. "But mandamus is not the answer for every emergency, and it cannot deliver the relief petitioners seek here." The Washington Supreme Court concluded that without a showing an official in the executive branch failed to perform a mandatory nondiscretionary duty, courts had no authority under law to issue a writ of mandamus, no matter how dire the emergency. Petitioners alternatively sought leave to amend their petition by filing a personal restraint petition. But on the record before the Court, they did not show respondents acted with deliberate indifference to the extreme risk that COVID-19 created for the incarcerated. "Amending their mandamus petition would therefore be futile." For these reasons, the Supreme Court dismissed the mandamus action and denied the motion to amend. View "Colvin v. Inslee" on Justia Law

In 2017, John Jackson Sr. was charged with assault in the second degree, domestic violence, for strangling his fiancee. At every court appearance, Jackson was forced to wear some form of restraints pursuant to jail policy. The trial court did not engage in any individualized determination of whether restraints were necessary for courtroom safety but, instead, filed a consolidated opinion adopting the jail policy for all superior court appearances for all incarcerated defendants. After a jury found Jackson guilty, he appealed, arguing that his constitutional right to due process was violated for being forced to wear restraints without an individualized inquiry into their necessity. The Court of Appeals concurred with this argument, but held the violation was harmless beyond a reasonable doubt. With respect to the latter portion of the appellate court's holding, the Washington Supreme Court revered, finding the State did not prove the harmlessness of the shackling, and did not show the error to be harmless beyond a reasonable doubt. The matter was remanded for a new trial with instructions that at all stages of the proceedings, the trial court make an individualized inquiry into whether shackels or restraints were necessary. View "Washington v. Jackson" on Justia Law