Justia Washington Supreme Court Opinion Summaries

William Reis was charged with manufacturing a controlled substance after a search of his home produced evidence of a marijuana grow operation. Reis moved to suppress the results of the search on the ground that the search warrant was invalid, arguing that the 2011 amendments to the Washington State Medical Use of Cannabis Act (MUCA) decriminalized the possession of cannabis for medical use. The trial court denied Reis's motion to suppress, and the Court of Appeals granted discretionary review and affirmed. After its review, the Supreme Court held that the plain language of MUCA, supported by the context in which the language appeared, the overall statutory scheme, and the legislative intent as captured in the governor's veto message, did not support the conclusion that the medical use of marijuana was not a crime. Therefore, the Supreme Court affirmed the Court of Appeals and remanded the case for trial. View "Washington v. Reis" on Justia Law

Toby Erhart's judgment and sentence on multiple counts of first degree child rape and incest became final on direct appeal in 2008. During Erhart's trial, the court interviewed several prospective jurors privately in chambers without first conducting the courtroom closure analysis required by "Washington v. Bone-Club." The jury found Erhart guilty of multiple sex offenses, and the trial court imposed an exceptional sentence. Erhart did not raise a public trial issue on direct appeal. The Court of Appeals affirmed the convictions but reversed the exceptional sentence and remanded for resentencing. In 2010 Erhart filed a personal restraint petition challenging his convictions, arguing for the first time that his constitutional right to a public trial was violated. The Court of Appeals dismissed the petition as untimely. The Supreme Court granted discretionary review. Finding that Erhart filed his personal restraint petition more than one year after his judgment and sentence became final, the petition was indeed untimely, the Supreme Court affirmed. View "In re Pers. Restraint of Erhart" on Justia Law

After his 18th birthday, Robert Wheeler was charged with, and pled guilty to, first degree child rape and first degree child molestation for offenses he committed when he was 13 or 14 years old that came to light when he was 17 and a half. His convictions had been final since 2006. The Court of Appeals held that the validity of Wheeler's guilty plea was not an appealable issue because the trial court did not independently review and rule on it; rejected Wheeler's claim of ineffective assistance, reasoning that counsel was not obligated to advance an argument that was unlikely to succeed; and dismissed Wheeler's personal restraint petition as untimely. Wheeler contended on appeal that the Washington Supreme Court had the authority to, and should have, revisited his previously rejected claim that his plea was involuntary because he was misinformed of the maximum sentences for his crimes. He also challenged his convictions as the product of unconstitutional preaccusatorial delay and sought to avoid the time bar for collateral attack by claiming he had newly discovered evidence that the State delayed filing charges until Wheeler aged out of juvenile court. The Supreme Court rejected Wheeler's arguments, and affirmed the Court of Appeals. View "Washington v. Wheeler" on Justia Law

Petitioner Ronald Wayne MacDonald entered into a plea agreement for second degree murder with the prosecutor in exchange for recommending a 5-year suspended sentence with 16 months' confinement in King County jail, with credit for time served. At sentencing, the prosecutor informed the court that the investigating officer wished to speak on behalf of the victim. The officer had remained involved throughout the plea negotiations, and the prosecutor intended for the officer to sit at counsel's table. The prosecutor asserted she did not know what the officer wanted to say. MacDonald objected, but the trial court permitted the officer to testify as a victim advocate. The officer then asked the court to impose the maximum sentence. The trial court gave MacDonald the maximum sentence, and the Court of Appeals affirmed. MacDonald moved to withdraw his plea. But because the trial court judge had retired, the motion was transferred to the Court of Appeals. The Court of Appeals denied the motion and affirmed MacDonald's conviction in an unpublished decision. Upon review, the Washington Supreme Court held that the investigating officer was functioning as a substantial arm of the prosecution and should not have been permitted to advocate against the plea bargain. Therefore, the State breached the plea agreement by undercutting the agreed sentencing recommendation. The Court reversed the Court of Appeals and remanded with instructions to permit MacDonald to either withdraw his guilty plea or seek specific performance of the plea agreement. View "Washington v. MacDonald" on Justia Law

The issue this case presented for the Supreme Court's review centered on whether the trial court closed the courtroom during trial in violation of the defendant's rights under article I, section 22 of the Washington Constitution. The Court of Appeals reversed respondent Benito Gomez's convictions for second degree murder and six counts of first degree assault on the grounds that the trial judge effected an unconstitutional closure of the courtroom during trial by his pretrial comment that the public would not be permitted to enter the courtroom once the proceedings began. The Supreme Court reversed after review: the Court disagreed that the trial judge, by mere virtue of making this remark, fully excluded the public from entering the courtroom and, thus, there was no basis for finding a constitutional violation; and second, even if the Court could presume the brief comment was enforced, this limitation to courtroom entry did not constitute a closure. View "Washingotn v. Gomez" on Justia Law

Howard Shale was an enrolled member of the Yakama Nation. He had family in the Quinault Indian Nation as well. In 1997, Shale was convicted under federal law of raping a child under 12. After Shale was released from prison, he moved to Seattle and registered as a sex offender with the King County sheriff. In 2012, a Jefferson County sheriffs detective began investigating whether Shale had moved to her county without reregistering as a sex offender. At least two officers assisted the detective in her investigation; a Jefferson County sheriffs deputy and a Quinault tribal police officer. Taken together, police reports suggested Shale was dividing his time between the two family homes. Based on the detective's report, the Jefferson County prosecutor charged Shale with failure to register with the county sheriff as a sex offender under RCW 9A.44.130(1)(a). The issue this case presented for the Supreme Court's review was whether Washington State had the power to prosecute an enrolled member of the Yakama Nation living on the Quinault Indian Nation's reservation for failing to register with the county sheriff as a sex offender. The Court found the State indeed had that power. View "Washington v. Shale" on Justia Law

Matthew Bruch was convicted of two counts of second degree child molestation and two counts of third degree rape of a child. The trial court imposed a standard range sentence of 116 months of confinement and ordered community custody for a period of "at least 4 months, plus all accrued earned early release time at the time of release." Bruch appealed his sentence, arguing that the court-imposed term of community custody was indeterminate and may exceed the statutory requirement of three years of community custody required under RCW 9.94A.701(1). The Court of Appeals rejected Bruch's challenge, as did the Supreme Court: (1) the total sentence did not exceed the applicable statutory maximum, consistent with RCW 9.94A.701(9); . there was no need for the trial court to amend Bruch's sentence to limit community custody to a maximum of three years, "[t]he statutes must be read together to assure that the trial court's intended sentence-a total term of 120 months-is not undermined by giving effect to the DOC's authority to transfer earned early release into community custody." View "Washington v. Bruch" on Justia Law

Petitioners Nicholas Blazina and Mauricio Paige-Colter were ordered to pay discretionary legal financial obligations (LFOs). The trial court record in each petitioner's case did not reflect that the trial judges considered either party's ability to pay before imposing the LFOs. Neither petitioner objected at the time. For the first time on appeal, however, both argued that the judges in their respective cases should have made an inquiry into their ability to pay, and that failing to make this inquiry warranted resentencing. The Court of Appeals declined to reach the issue because both petitioners failed to object at sentencing, and therefore failed to preserve the issue for appeal. Petitioners appealed the Court of Appeals' and trial courts' rulings to the Supreme Court, and in each case, the Court concluded that the Court of Appeals did not err in declining to reach the merits. However, exercising its own discretion, the Supreme Court reached the merits and held that the trial court had a statutory obligation to make an individualized inquiry into a defendant's current and future ability to pay before the imposition of LFOs. The cases were remanded for the trial courts to make these inquiries. View "Washington v. Blazina" on Justia Law

In 2008, teenager Philip Johnson called his close friend (and fellow Hilltop Crips gang member) defendant-respondent Marsele Henderson to say he was going to a party at a Boys and Girls Club. Henderson advised Johnson not to go because the club was too close to a rival gang's territory. Johnson went to the party, where he was shot. Henderson learned of the shooting and went to the hospital with his friends, including Koloneus D'Orman McClarron, to check on Johnson. Johnson died shortly thereafter at the hospital, although McClarron and Henderson testified that they did not learn of his death at the hospital. One of the disputed-facts in this case was how many people were in the area in front of the house prior to shots being fired, because whether a person shot into a crowd of people or whether they shot toward an area with very few people might have determined the nature of the crime. Witness testimony on this point varied significantly. Witnesses testified that either McClarron or Henderson pulled a gun and fired six shots toward the house from the street. McClarron testified that Henderson fired the shots, but Henderson testified that it was McClarron who did it. Neither could give an explanation as to why the other person fired the gun. Four people testified that the shooter yelled something related to the Hilltop Crips at the time of the shooting. Witnesses were divided about whether the shooter looked like Henderson or McClarron. prosecutors charged Henderson with first degree murder by extreme indifference. At trial, Henderson asked that the jury be instructed on the lesser included charge of first degree manslaughter. Initially, the State agreed, acknowledging that the definitions of first degree murder by extreme indifference and first degree manslaughter are "very close" and that there is "hardly a difference." The State later changed its position based on two Court of Appeals cases from 1998 and 1999: "Washington v. Pettus," (951 P.2d 284 (1998)), and "Washington v. Pastrana," (972 P.2d 557 (1999)). In both of those cases, the Court of Appeals held that the defendants were not entitled to a jury instruction on the lesser included offense of manslaughter because the defendants' actions were much more than merely reckless. The Supreme Court later narrowed the definition of reckless in the context of manslaughter in "Washington v. Gamble," (114 P.3d 646 (2005)), to specifically mean a disregard of a substantial risk of homicide. Defendant's trial counsel did not bring "Gamble" to the attention of the trial court, and as a result, the trial court agreed with the State that "Pettus" and "Pastrana" were controlling and refused to instruct on manslaughter. The jury convicted Henderson of first degree murder by extreme indifference. Henderson appealed, contending that the trial court erred when it refused to instruct the jury on first degree manslaughter. The Court of Appeals reversed Henderson's conviction, holding that he was entitled to the instruction. Upon review, the Supreme Court agreed, affirmed the Court of Appeals and reversed Henderson's conviction. View "Washington v. Henderson" on Justia Law

In the late 1980s, Alan Meirhofer was charged with several counts of brutally raping children, along with charges of burglary and kidnapping. Meirhofer was implicated in several more child rapes. As Meirhofer finished serving his criminal sentence, the State brought SVP commitment proceedings against him under the sexually violent predator (SVP) act, chapter 71.09 RCW, in 2000. He sought a full evidentiary proceeding on whether he still met the statutory and constitutional criteria for SVP commitment. Before holding such a full evidentiary proceeding, the SVP act directs trial courts to hold an initial show cause hearing to determine whether the State has presented prima facie evidence that continued commitment is justified or the detainee has presented prima facie evidence that his or her condition has "so changed" as to warrant a new evidentiary proceeding. The trial court found the State had made its showing and Meirhofer had not. Finding no reversible error, the Supreme Court affirmed. View "In re Pers. Restraint of Meirhofer" on Justia Law