Justia Washington Supreme Court Opinion Summaries

Michael Henderson shot and killed Abubakar Abdi during an argument. Henderson was charged with felony murder based on second degree assault with a deadly weapon. Henderson contended that while acting in self-defense, he accidentally killed Abdi. The jury was instructed on justifiable homicide as a defense; it was not instructed on excusable homicide. The jury found the shooting was neither self-defense nor an accident, and found Henderson guilty of felony murder predicated on second degree assault. The Court of Appeals reversed, finding the trial court erred by not instructing the jury on excusable homicide. The Washington Supreme Court agreed with the State that the excusable homicide instruction was properly rejected: Henderson was able to adequately argue his theory of the case under the instructions that were given. The appellate court was reversed and the matter remanded for further proceedings. View "Washington v. Henderson" on Justia Law

This case concerned whether a prosecutor properly aggregated numerous offenses that would, individually, constitute theft in the second degree into two counts of theft in the first degree. Washington's common law standard for bringing multiple aggregated counts differed from that created under RCW 9A.56.010(21)(c). At issue in this appeal was whether the statutory standard or the common law standard for aggregating theft charges applied in this case and whether the State properly aggregated charges under that standard. The superior court allowed the State to aggregate charges against Gary Farnworth, II into two counts of theft in the first degree, but in a split opinion, the Court of Appeals reversed and remanded to vacate one count and resentence Farnworth. The Washington Supreme Court reversed the appellate court, finding under the facts of this case, the State acted within its discretion when it aggregated Farnworth's offenses into two counts. View "Washington v. Farnworth" on Justia Law

Scottye Miller murdered his longtime girlfriend, Tricia Patricelli, 15 days after he was released from prison on Department of Corrections (DOC)-supervised probation. Patricelli, Patricelli's family and friends, and DOC—knew that Miller had physically abused Patricelli in the past and would likely do so again if they resumed their relationship. Patricelli hid the renewed relationship from her friends, family members, and DOC. In fact, Patricelli explicitly assured DOC that she was not in a relationship with Miller, that she was moving to a place where he could not find her, and that she would call the police if she saw him. Miller's mother also verified in writing that he was sleeping at her home, though it turns out that he was actually living with Patricelli. The question this case presented for the Washington Supreme Court’s review was whether DOC was liable for Patricelli's death, despite Patricelli's, Miller's, and his mother's active and successful efforts to prevent DOC from knowing that Miller was in contact with Patricelli. The parties agree that DOC had a duty to supervise Miller while he was on probation and that DOC was not liable unless its supervision constituted “gross negligence.” The parties disagreed on whether DOC’s actions rose to the level of gross negligence. The trial court dismissed on summary judgment, finding the DOC’s failure to take additional steps to verify Patricelli’s statement’s or Miller’s housing arrangements could qualify as gross negligence. The Supreme Court reversed the Court of Appeals and affirmed the trial court's order granting summary judgment for DOC. Tricia Patricelli’s Estate failed to produce sufficient evidence to raise a genuine issue of material fact on the question of gross negligence. View "Harper v. Washington" on Justia Law

While in prison serving a life without parole sentence, Byron Scherf murdered a prison guard. He was tried, convicted of aggravated murder, and sentenced to death. In his appeal, he raised multiple claims of error: procedural, statutory, and constitutional. Based on the holding of Washington v. Gregory, No. 88086-7 (Wash. Oct. 11, 2018), the Washington Supreme Court vacated the sentence, but affirmed the conviction. View "Washington v. Scherf" on Justia Law

The question this case presented for the Washington Supreme Court’s review was whether detaining an incompetent defendant in jail for 76 days before providing competency restoration treatment violates his substantive due process rights under the Fourteenth Amendment to the United States Constitution. The trial court found Anthony Hand incompetent to stand trial and ordered Western State Hospital (WSH) to admit Hand within 15 days for competency restoration treatment. Hand remained in county jail for 61 days after the court's 15 day deadline, for a total of 76 days of confinement. Hand's competency was eventually restored through treatment at WSH. He was subsequently convicted on both charges. Hand argued the State violated his substantive due process rights by detaining him in jail for 76 days before admitting him to WSH for treatment, and that the proper remedy was dismissal with prejudice. After review, the Supreme Court affirmed the Court of Appeals and held that detaining Hand in county jail for 76 days violated his due process rights but that dismissal with prejudice, the only relief Hand requested, was not warranted. View "Washington v. Hand" on Justia Law

In 1995, Derek Gronquist was sentenced to three consecutive, 114-month terms of total confinement for three counts of attempted first-degree kidnapping with a special finding of sexual motivation. On petition to the Washington Supreme Court, Gronquist claimed his sentence expired in 2016, so his continued confinement was unlawful. The Department of Corrections contended Gronquist’s sentence was to expire in 2022. The Supreme Court determined the DOC sentence tracking system was “complicated, its explanations have been confusing and contradictory, and it has not pointed to clear legal authority directly supporting its position.” However, the Court concluded Gronquist had not shown his continued confinement was unlawful either. “DOC has no authority to change the length of Gronquist’s sentence or to run any portion of his consecutive terms concurrently. Gronquist’s proposed sentence structure, however, would require it to do so.” The Court therefore denied relief on Gronquist’s personal restraint petition. View "In re Pers. Restraint of Gronquist" on Justia Law

Tyree Jefferson was convicted by jury of first degree murder, first degree assault, and first degree unlawful possession of a firearm. On appeal, he challenged the State's use of a peremptory strike against the only African-American juror on the jury venire, contending the strike was exercised in a racially discriminatory manner. Further, Jefferson challenged the current Batson test, arguing it failed to address racial discrimination in jury selection. The Washington Supreme Court found the trial court did not err in finding no purposeful discrimination in the strike of the juror. The Court found, however, Jefferson's argument about the Batson test was well taken, modifying the Washington three-step inquiry with a new third step. View "Washington v. Jefferson" on Justia Law

In 2004, Waylon Hubbard pled guilty to second degree possession of stolen property. He was sentenced to a short term of confinement and 120 hours of community service. He was also ordered to pay legal financial obligations. By 2011, Hubbard had fulfilled his community service, and in 2013, he paid off his financial obligations. In 2016, Hubbard petitioned for a certificate and order of discharge (COD), with the effective date of February 25, 2013, the date he satisfied all the terms of his sentence. The State objected, arguing the court did not have the authority to enter an effective date that predated the date on which the court received notice that Hubbard completed his sentence. The Washington Supreme Court held the effective date of a certificate of discharge must be the state the offender completed all the terms of the sentence. View "Washington v. Hubbard" on Justia Law

When Brian Bassett was 16 years old, he was living in a "shack" with Nicholaus McDonald after Bassett's parents '"kicked [him] out'" of their home. With McDonald's assistance, Bassett snuck back into his home and shot his mother and father. His brother was drowned in the bathtub, an act that McDonald initially confessed to but later blamed on Bassett at trial. Bassett was convicted of three counts of aggravated first degree murder for the deaths of his mother, father, and brother. The judge commented that Bassett was "a walking advertisement" for the death penalty and sentenced him to three consecutive terms of life in prison without the possibility of parole. At issue here was the constitutionality of sentencing juvenile offenders to life in prison without the possibility of parole or early release. The State appealed a Court of Appeals decision holding that the provision of Washington's Miller-fix statute that allows 16- and 17-year-olds to be sentenced to life without parole violated the Washington Constitution's ban on cruel punishment. The appellate court adopted the categorical approach, rather than Washington's traditional Fain proportionality test, and found that sentencing juvenile offenders to life without parole or early release constituted cruel punishment. The Washington Supreme Court affirmed the Court of Appeals' decision and held that sentencing juvenile offenders to life without parole or early release constitutes cruel punishment and therefore is unconstitutional under article I, section 14 of the Washington Constitution. View "Washington v. Bassett" on Justia Law

In 1996, Allen Gregory raped, robbed and murdered a woman at her home. In 1998, he was investigated for another rape. In 2001, he was convicted for first degree murder and three counts of first degree rape. A jury recommended the death sentence. The sentence was reversed by the Washington Supreme Court, which found (1) the prosecutor engaged in misconduct during closing arguments in the penalty phase of the murder trial; and (2) the rape convictions were relied upon in the penalty phase of the murder case. A new jury was empaneled on remand and presided over a second special sentencing proceeding. The second jury also recommended the death sentence. With respect to the rape charges, the State determined a witness lied at the first trial, and moved to dismiss charges because of the inconsistent statements. The trial court dismissed the rape charges with prejudice. The issues this case presented for the Washington Supreme Court's review posited: (1) whether Washington's death penalty was imposed in an arbitrary and racially biased manner; (2) whether statutory proportionality review of death sentences alleviates the alleged constitutional defects of the death penalty; and (3) whether the trial court should have reconsidered arguments pertaining to the guilt phase of Gregory's trial. The Supreme Court determined precedent did not hold the death penalty was per se unconstitutional; the Court found it was imposed in an arbitrary and racially biased manner. "The death penalty, as administered in our state, fails to serve any legitimate penological goal; thus it violates article I, section 14 of our state constitution." View "Washington v. Gregory" on Justia Law