Justia Washington Supreme Court Opinion Summaries

The State charged Larry Hayes with one count of leading organized crime and one count of identity theft in the first degree, among several other charges. The State alleged that Hayes was involved in a complex identity theft scheme that used stolen credit card information, including information stolen from a hair salon's customer receipts, to manufacture false identification devices and credit cards. These in turn would be used to make purchases and rent vehicles, usually from out of state, with those rental vehicles sold for cash. The State also alleged that each count (except for a drug charge) was subject to the sentence aggravators for being a major economic offense. The issue this case presented for the Washington Supreme Court's review centered on whether a trial court may impose an exceptional sentence on a defendant under the major economic offense sentence aggravators found in RCW 9.94A.535(3)(d)(i) and (iii) when that defendant's conviction was based on accomplice liability. The Court agreed with the Court of Appeals's decision that the trial court improperly applied the sentence aggravators to Hayes. View "Washington v. Hayes" on Justia Law

Odies Walker was convicted as an accomplice to first degree murder, first degree assault, first degree robbery, solicitation, and conspiracy. The issue this case presented for the Supreme Court's review centered on whether those convictions should have been reversed in light of a Power Point presentation the prosecuting attorney used during closing argument. That presentation repeatedly expressed the prosecutor's personal opinion on guilt (over 100 of its approximately 250 slides were headed with the words "DEFENDANT WALKER GUILTY OF PREMEDITATED MURDER," and one slide showed Walker's booking photograph altered with the words "GUILTY BEYOND A REASONABLE DOUBT," which were superimposed over his face in bold red letters). The prosecutor also appealed to passion and prejudice by juxtaposing photographs of the victim with photographs of Walker and his family, some altered with the addition of inflammatory captions and superimposed text. While the prosecutor was entitled to draw the jury's attention to admitted evidence, those slides, as presented, served no legitimate purpose. "Their prejudicial effect could not have been cured by a timely objection, and we cannot conclude with any confidence that Walker's convictions were the result of a fair trial." The Court reversed Walker's convictions and remanded for a new trial. View "Washington v. Walker" on Justia Law

This consolidated appeal consisted of two criminal cases. In each case, the jury convicted the defendant and found that aggravating circumstances were present. At sentencing, the trial courts deviated from the standard sentencing range and imposed exceptional sentences. While both trial courts explained on the record their reasons for deviating from the standard range, neither court entered written findings as required by statute. Both sentences were affirmed by the Court of Appeals in unpublished opinions. The issue these cases presented for the Supreme Court's review was whether an on-the-record oral ruling could substitute for written findings when a trial court imposes an exceptional sentence. After review, the Supreme Court concluded that oral findings do not satisfy the requirements of the Sentencing Reform Act of 1981. The cases were remanded for entry of written findings of fact and conclusions of law. View "Washington v. Friedlund" on Justia Law

In 2009, Maurice Clemmons shot and killed four Lakewood police officers. Petitioner Darcus Allen drove Clemmons to and from the crime scene and was charged as an accomplice. The issue on appeal to the Supreme Court was whether the prosecuting attorney committed prejudicial misconduct by misstating the standard upon which the jury could convict an accomplice. In a divided decision, the Court of Appeals recognized that the statements were improper but ultimately held that they did not amount to prejudicial misconduct. The Supreme Court disagreed and reversed the Court of Appeals. The case was remanded for a new trial. View "Washington v. Allen" on Justia Law

A jury found defendant Joel Condon guilty of several offenses including aggravated first degree (premeditated) murder and first degree felony murder, stemming from his involvement in a home invasion robbery attempt. He argued on appeal that the evidence presented against him at trial was insufficient to support the jury's verdict, and that there were errors by the trial court in instructing the jury. The Court of Appeals found there was sufficient evidence of premeditation, but that it was error to deny Condon's request for an instruction on the lesser included crime. The Supreme Court affirmed the appellate court's judgment. View "Washington v. Condon" on Justia Law

The issue central to this appeal centered on the filing of a type of report about a juvenile offender: whether a special sex offender disposition alternative (SSODA) evaluation should be filed in the official juvenile court file and therefore be open to the public. The legislature has explicitly defined the contents of the official juvenile court file as "the petition or information, motions, memorandums, briefs, findings of the court, and court orders." Since the SSODA evaluation does not fit within any of these categories, the Supreme Court held that it was not a part of the official juvenile court file. Consequently, it was subject to the general rule that all juvenile records not in the official juvenile court file must be kept confidential. View "Washington v. A.G.S." on Justia Law

The issue this case presented for the Supreme Court's review centered on whether a potential obstacle to public access constituted a courtroom closure: a sign that listed the courthouse hours. After a jury trial in Yakima County Superior Court, defendant Joey Andy was convicted of first degree burglary and second degree assault. He appealed, arguing that his right to a public trial right was violated when proceedings on some days continued after 4:00 p.m., despite a new 4:00 p.m. closing time for the courthouse. Pursuant to RAP 9.11, Andy moved to remand the case to the superior court to take "additional evidence to determine whether the courthouse doors were locked at 4 p.m. on the dates of the trial ... and if so, whether that closure barred entry to the ongoing courtroom proceedings." After review of the evidence, the Supreme Court concluded that at all times during Andy's trial proceedings, the door to the courthouse was unlocked and no member of the public was deterred from attending the proceedings by the sign. Therefore, the Court concluded that the sign did not constitute a courtroom closure and Andy's public trial right was not violated. View "Washington v. Andy" on Justia Law

In 2009, Maurice Clemmons shot and killed four Lakewood police officers. Clemmons contacted petitioners Eddie Davis and Letrecia Nelson shortly after the shootings. Based on their actions following that contact, petitioners were convicted of rendering criminal assistance and possessing a firearm. A divided Washington Supreme Court would have held that there was sufficient evidence presented at trial to support Davis' and Nelson's convictions for possession of a stolen firearm, and Davis' conviction for second degree unlawful possession of that firearm, but this was not the decision of the Court. The Court did hold that the aggravating factor found in RCW 9.94A.535(3)(r) could not justify an exceptional sentence for rendering criminal assistance as a matter of law. The result of three opinions of the Court for this case was to reversed the Court of Appeals and remanded for further proceedings. View "Washington v. Davis" on Justia Law

Petitioner Dante McWilliams received the exceptional sentence of 120 months of confinement and 18 months of community custody, which, in the aggregate, exceeded the statutory maximum for his offense. McWilliams pled guilty to a 2009 second degree assault. At sentencing, he had an offender score of7, which resulted in a standard sentencing range of 43 to 57 months of confinement. The statutory maximum sentence of confinement for second degree assault is 120 months. The plea agreement entered into by the parties recommended an exceptional sentence of confinement of 120 months-the statutory maximum-along with 18 months of community custody .. The trial court imposed this sentence as stipulated in the agreement. At that time, McWilliams did not appeal. More than one year passed after entry of judgment. McWilliams then filed this personal restraint petition directly to the Supreme Court, arguing that his judgment and sentence was facially invalid under RCW 9.94A.701(9). The Supreme Court agreed, holding that the appropriate remedy was a notation in the judgment and sentence that explicitly states that the total term of confinement and community custody actually served may not exceed the statutory maximum. View "In re Pers. Restraint of McWilliams" on Justia Law

In two separate King County Superior Court cases, petitioner Adonijah Sykes was charged with three violations of the Uniform Controlled Substances Act, chapter 69.50 RCW. Sykes successfully petitioned to participate in the King County adult drug diversion court and entered drug diversion court waivers and agreements with the State. Sykes participated in the drug diversion court program for over a year but had difficulties complying with its requirements. The State eventually moved to terminate her from the program. Sykes then moved to rescind the drug diversion court waivers and agreements and to vacate the orders granting her petitions to participate, arguing that King County's practice of holding closed "staffings" prior to holding open review hearings violated article I, section 10 of the Washington Constitution. Sykes argued the closed staffings tainted all procedures that followed, so she should have been allowed to restore her full trial rights to the underlying charges, and defend her cases as though she had never participated in drug diversion court. The State agreed that closed staffings violated article I, section 10 and chose not to assert invited error in order to have the underlying issue resolved on its merits. The drug diversion court denied Sykes' motions, holding that presumptively closed adult drug court staffings did not violate article I, section 10. The court did not reach the merits of the State's motion to terminate. After its review, the Supreme Court concluded Article I, section 10 of the Washington Constitution did not require adult drug court staffings to be presumptively open. The case was therefore remanded to the trial court for further proceedings. View "Washington v. Sykes" on Justia Law