Justia Washington Supreme Court Opinion Summaries

Rolando Reyes was committed to the custody of the Department of Social and Health Services (DSHS) following a determination that he was a sexually violent predator (SVP). On appeal, Reyes requested a new SVP commitment hearing, arguing that the trial court committed structural error by closing a pretrial hearing in violation of article I, section 10 of the Washington Constitution. The Court of Appeals rejected Reyes' argument and affirmed his commitment. The issue this case presented for the Supreme Court's review centered on whether a trial court commits structural error by closing a pretrial hearing in a civil proceeding without first conducting an "Ishikawa" analysis. The Court concluded it does not, and therefore affirmed. View "In re Det. of Reyes" on Justia Law

Petitioner Adrian Ozuna challenged the sufficiency of the evidence supporting his conviction for intimidating a former witness. Ozuna contended the jury impermissibly convicted him based only on a letter he wrote that authorities confiscated before it was delivered to anyone. In affirming his conviction, the Supreme Court concluded that a rational jury could have found Ozuna guilty of the crime based on the circumstantial evidence presented at trial. View "Washington v. Ozuna" on Justia Law

Petitioner David Carson appealed his conviction on three counts of first-degree child molestation. He argued he received ineffective assistance of counsel because his attorney objected to a "Petrich" instruction proposed by the State. The Supreme Court concluded defense counsel reasonably concluded that the proposed instruction's language, tailored as it was for use in single-count cases, would have been confusing and potentially prejudicial in Carson's multicount case. Under these circumstances, Carson could not establish deficient performance. Moreover, defense counsel's objection did not prejudice Carson because the prosecution's closing argument clearly elected the acts on which the State was relying. View "Washington v. Carson" on Justia Law

In 2005, Rickey Beaver was found not guilty by reason of insanity on a charge of residential burglary. The court found that Beaver suffered from a mental disease or defect and held that he posed a substantial danger to other persons and presented a substantial likelihood of committing criminal acts jeopardizing public safety or security unless kept under further control by the court. The court committed Beaver to Western State Hospital (WSH) and to the custody of the secretary of the Department of Social and Health Services. Beaver was granted a conditional release in 2007. Between 2007 and his final discharge in 2014, Beaver violated the terms of his conditional release several times. In 2011, Beaver petitioned for final discharge. WSH recommended Beaver's final discharge, but the Public Safety Review Panel (PSRP) opposed it. A jury trial was held, but before resting, Beaver voluntarily withdrew his petition. Beaver agreed that he continued to suffer from a mental illness that made him a threat to public safety, and stipulated to an agreed order of conditional release. On conditional release, Beaver violated the terms by using cocaine, drinking alcohol, and driving a motor vehicle, and by being charged with the crime of driving under the influence of alcohol. In 2013, the State successfully moved to revoke Beaver's conditional release. Beaver appealed the trial court's order revoking his conditional release, arguing that due process required a finding of current mental illness before the court could revoke his conditional release and recommit him to WSH. While this appeal was pending, Beaver filed a petition for final discharge under RCW 10.77.200(3). Based on agreement of the parties, Beaver was granted conditional release in October 2013. Then in May 2014, again based on agreement of the parties, Beaver was granted final discharge. Although the Court of Appeals found that the case was moot, it reviewed the merits and held that substantive and procedural due process did not require a judicial finding of current mental illness before the court could revoke conditional release. The issue this case presented for the Supreme Court's review centered on the appellate court's holding. Chapter 10.27 RCW, the statutory scheme that governed insanity acquittals, required the trial court find that a conditionally released insanity acquittee violated the conditions of release or posed a threat to the public to revoke an insanity acquittee' s conditional release. The Court found that the statute did not require the trial court make a finding regarding the acquittee's mental state at a conditional release revocation hearing. The Court therefore held that the statute satisfied due process and affirmed the Court of Appeals. View "Washington v. Beaver" on Justia Law

Adam Lewis challenged two portions of a Court of Appeals opinion denying him credit for time served awaiting trial on his burglary and assault charges. After the Washington Supreme Court granted review, the State conceded that Lewis was entitled to 387 days of additional time served. The Supreme Court accepted the State's concession, struck oral argument, and remanded this case back to the trial court for sentencing. View "Washington v. Lewis" on Justia Law

The issue this case presented for the Washington Supreme Court's review was whether under the State Constitution article I, section 7, an officer may search an arrestee's backpack as a search incident to arrest when the arrestee was wearing the backpack at the moment that he was stopped by police, but not at the time he was arrested several minutes later. When Officer Erik Olson stopped and seized Antoine Brock, he had Brock remove the backpack he was wearing and placed it where Brock could not readily access it. After a period of questioning, the officer arrested Brock and then searched the backpack. Ten minutes elapsed between the time Olson separated Brock from his backpack and the arrest. The trial court denied Brock's motion to suppress the evidence taken from the backpack. The Court of Appeals reversed. Under the facts of this case, the Supreme Court held that the backpack was a part of Brock's person at the time of arrest and that the search was valid incident to arrest. View "Washington v. Brock" on Justia Law

Julio Davila appealed the Court of Appeals' decision affirming his conviction for second degree murder. At issue was whether the State violated its disclosure obligation under "Brady v. Maryland," (373 U.S. 83 (1963)), when it failed to disclose the fact that a forensic scientist who analyzed certain DNA evidence used in Davila's case had been fired for incompetence. While the Supreme Court concluded that this evidence was both favorable to the defendant and suppressed by the State in violation of its Brady obligations, the Court also concluded that the evidence was not material to the outcome of Davila's trial, given the specific facts presented in this case. View "Washington v. Davila" on Justia Law

Jose Martines was involved in a car accident. Pursuant to a warrant, a blood sample was extracted from Martines after an officer suspected he was driving while under the influence (DUI). Martines was ultimately charged with felony DUI. He sought to suppress the blood test results showing the presence of drugs on the ground that there was no probable cause to show he was under the influence of drugs, as opposed to alcohol. The trial court denied Martines's motion, and a jury convicted him. The Court of Appeals reversed Martines's conviction, holding that the blood test was an unlawful warrantless search. The court reasoned that drawing blood and testing blood constituted separate searches, each of which requires particular authorization, and that the warrant here authorized only a blood draw. The State appealed. The Supreme Court reversed the Court of Appeals and reinstated Martines's conviction, holding that the warrant authorized the drawing and testing of Martines's blood for both alcohol and drugs based on probable cause to believe Martines had committed a DUI. View "Washington v. Martines" on Justia Law

Petitioner Jerry Herron was charged with first degree rape while armed with a deadly weapon. Roughly a week and a half before trial, the trial court held an initial readiness hearing where it informed the parties that it typically used a jury questionnaire in sexual assault cases to discover sensitive information that might require questioning jurors individually. The court explained that in light of recent appellate court decisions, the practice of questioning jurors in chambers conflicted with Herron's public trial right. Thus, the court stated that "if there is any objection, I can't -- follow that procedure--." The prosecuting attorney advised that Herron would need to affirmatively waive his right to a public trial on the record in order to question jurors in chambers. Alternatively, the prosecuting attorney suggested that the court could question individual jurors in a public setting with the other jurors waiting in a separate room. Defense counsel responded that he would not object and that "if we're looking for an affirmative waiver of a public examination of these individual jurors, Mr. Herron and I are present, we're certainly willing to waive that. ... I think that's going to bear far more fruit than just simply a voir dire situation." At this point, the court inquired whether Herron understood the conversation and Herron replied that he did, expressly agreeing with the idea of conducting individual voir dire in the privacy of the judge's chambers. A jury was eventually empaneled, and Herron was found guilty of first degree rape while armed with a deadly weapon. The Court of Appeals affirmed Herron's conviction. Herron appealed, arguing the public's right to an open proceeding was violated. Finding that the Court of Appeals was correct in its ruling that Herron waived his public trial right and that he lacked standing to assert the rights of the general public, the Washington Supreme Court affirmed. View "Washington v. Herron" on Justia Law

Appellant Jonathan Gentry was convicted by jury of aggravated first degree murder of a 12-year-old girl in 1991, for which he was sentenced to death. His conviction was affirmed in 1995, and denied postconviction relief in 1999 and 2014. In 2011, Gentry moved for postconviction DNA testing, which was granted. After the DNA report on a bloodstained shoelace (that was admitted into evidence at trial) came back matching the victim's blood profile, the State moved to end further testing. In granting the State's motion, the trial court concluded that Gentry could not meet the substantive standard of RCW 10.73.170, which required a convicted person to show the likelihood that DNA evidence would demonstrate innocence on a more probable than not basis. The court concluded that the statute did not impose a presumption that further DNA testing will be favorable and exculpatory and held that, even with such a presumption, Gentry could not show probable innocence in light of the new inculpatory DNA test on the shoelace. Gentry appealed that judgment directly to the Supreme Court. The Supreme Court affirmed, finding that the trial judge acted within her discretion in determining that Gentry could not demonstrate probable innocence in light of the result of the DNA test on the shoelace, even assuming the remaining DNA evidence would have been favorable to him. View "Washington v. Gentry" on Justia Law