Justia Washington Supreme Court Opinion Summaries

In 1993 Petitioner Garth Snively pled guilty to a single count of indecent liberties and two counts of first degree child molestation. Relying on the plea agreement, the trial court imposed two years of community placement on each conviction. But community placement was not authorized for indecent liberties at that time. Snively did not appeal, making the judgment and sentence final when it was filed in the trial court. In 2003 the State relied on the 1993 convictions in filing a petition alleging that Snively was a sexually violent predator subject to civil commitment. In 2006 a jury found Snively to be a sexually violent predator, resulting in his civil commitment. In 2010 Snively filed a personal restraint petition in the Court of Appeals, challenging the commitment by way of collaterally attacking his 1993 convictions. He claimed specifically that he was entitled to withdraw his guilty pleas due to the erroneous community placement term. The Court of Appeals allowed Garth Snively to withdraw his plea of guilty to indecent liberties because of a facially invalid sentence. Because Snively's sole remedy for the sentencing error was correction of the judgment and sentence, the Supreme Court reversed the Court of Appeals as to that issue. View "In re Pers. Restraint of Snively" on Justia Law

The State charged Joseph McEnroe and Michele Anderson with aggravated first degree murder and sought the death sentence for each of them. Roughly five and a half years after the State filed its notices of intent to seek the death penalty, the trial court ruled that the absence of "'sufficient mitigating circumstances to merit leniency"' was an essential element of the crime of capital murder in Washington and that the State had allege the absence of sufficient mitigating circumstances in the charging information. The trial court gave the State two weeks to amend each charging information to allege insufficient mitigating circumstances; if the State failed do to so, the court would entertain a defense motion to dismiss the State's notices of intent to seek the death penalty. The State appealed that order. Upon review, the Supreme Court reversed the trial court's decision to compel the State to amend each information or face dismissal of the notice of special sentencing proceeding. The notice of special sentencing proceeding afforded the defendants constitutionally and statutorily adequate notice that the State intended to prove the absence of sufficient mitigating circumstances to merit leniency. View "Washington v. McEnroe" on Justia Law

Timothy Dobbs engaged in a campaign of threats, harassment, and intimidation against his ex-girlfriend, C.R., that included a drive-by shooting at her home and warnings that she would "'get it"' for calling the police and she would "regret it" if she pressed charges against him. C.R. reported the increasingly violent activities of Dobbs against her. After Dobbs was arrested, he made yet another intimidating phone call to C.R., threatening that if she went forward and pressed charges against him, she would regret it. When C.R. failed to show up to testify at trial, the trial judge found that there was clear, cogent, and convincing evidence that Dobbs was the cause of her absence and thus had forfeited his confrontation right. Dobbs appealed the trial court's decision, but the Supreme Court, after its review, agreed with the trial court: "[w]hile Dobbs ha[d] the right to confront witnesses against him, he forfeited his right to confront C.R. when he chose to threaten her with violence for cooperating with the legal system. . . . To permit the defendant to profit from such conduct would be contrary to public policy, common sense and the underlying purpose of the confrontation clause." View "Washington v. Dobbs" on Justia Law

In 1993, petitioner Lindsey Crumpton was convicted of five counts of first degree rape and one count of residential burglary. In 2011, he petitioned the court for post-conviction deoxyribonucleic acid (DNA) testing. The superior court denied this motion, saying he had not shown a '"likelihood that the DNA evidence would demonstrate his innocence on a more probable than not basis"' as is required by RCW 10.73.170(3). The Court of Appeals affirmed. The issue this case presented for the Supreme Court's review was the standard the court should use to decide a motion for post-conviction DNA testing and whether a court should presume DNA evidence would be favorable to the convicted individual when determining if it is likely the evidence would prove his or her innocence. The Court held that a court should use such a presumption. View "Washington v. Crumpton" on Justia Law

The State charged Joseph Peltier in 2002 with two counts of second degree rape (as to B.M. and S.B.), one count of second degree child molestation (as to S.G.), and one count of second degree rape of a child (as to S.G.). The crimes occurred between 1993 and 2001. In 2003, to accommodate a negotiated settlement of his case, Peltier agreed to a stipulated trial on an amended information charging him with third degree rape (as to B.M. and J.D., a victim not referenced in the original information) and indecent liberties (as to S.B.). The charges as to S.G. were dismissed. In 2004, the trial judge found Peltier guilty and sentenced him. The statute of limitations on the four original charges had not yet run, but the statute of limitations for the charges he was convicted of had expired by January 1998, well before he was charged with and sentenced for them. The issue this case presented to the Supreme Court was whether a defendant could relinquish the rights conferred by the statute of limitations in a pretrial agreement. Upon review, the Court held that a defendant may expressly waive the criminal statute of limitations in a pretrial agreement when the statute of limitations on the underlying charge has not yet run at the time the defendant enters the agreement. "A statute of limitations does not affect a court's subject matter jurisdiction; it affects the authority of a court to sentence a defendant for a crime. A defendant may expressly waive a criminal statute of limitations when he or she agrees to do so when the statute of limitations has not yet run on the underlying charges. At that time, the court has authority over the charges so an express waiver is effective and will be upheld. Peltier waived the statute of limitations when the charges were still valid. We reverse the Court of Appeals and the trial court and hold that the State may refile the original charges." View "Washington v. Peltier" on Justia Law

A police detective spent five to ten minutes looking at a cell phone taken from Daniel Lee incident to his arrest for possession of heroin. The officer saw several text messages from appellant Jonathan Roden, responded to one of Roden's messages with a new message, and set up a drug deal. When Roden arrived to complete the deal, officers arrested. On appeal of his eventual conviction, Roden contended that the officer's conduct violated the state privacy act and the state and federal constitutions. Upon review, the Supreme Court agreed that the state privacy law was violated when the officer intercepted the private text message without Lee's or Roden's consent or warrant. Accordingly, the Court reversed the Court of Appeals' decision and Roden's conviction. View "Washington v. Roden" on Justia Law

Petitioner Abraham MacDicken was arrested carrying a laptop bag and pushing a rolling duffel bag. He was suspected of armed robbery. The officers moved the bags a car's length away to search them. MacDicken argued that search violated his state and federal constitutional rights. The Supreme Court recently held that police may search an arrestee's person and possessions closely associated with the person at the time of arrest without violating constitutional rights; MacDicken argued the bags were not closely associated with him at the time of arrest to give police the right to search them without a warrant. The Supreme Court disagreed held the police conducted a valid search. View "Washington v. MacDicken" on Justia Law

A police detective read text messages on a cell phone police seized from Daniel Lee, who had been arrested for possession of heroin. Among other things, the detective read an incoming text message from Shawn Hinton, responded to it posing as Lee, and arranged a drug deal. Hinton was consequently arrested and charged with attempted possession of heroin. Hinton argued on appeal of his conviction that the detective's conduct violated his rights under the state and federal constitutions. Upon review, the Supreme Court agreed that Hinton's rights were violated when the officer intercepted the private text message without Lee's or Hinton's consent or warrant. Accordingly, the Court reversed the Court of Appeals' decision and Hinton's conviction. View "Washington v. Hinton" on Justia Law

In this case, the trial court granted a new trial after Edwin Hawkins produced new evidence that supported his defense theory that he was framed for possessing stolen farm equipment. The Court of Appeals did not give that decision its proper deference. The Supreme Court reversed because the trial court did not abuse its wide discretion in awarding Hawkins a new trial. View "Washington v. Hawkins" on Justia Law

Petitioner Phillip Garcia Jr. appealed his convictions for kidnapping in the first degree, burglary in the second degree, and criminal trespass in the first degree. He argued that that the evidence was insufficient to support each of the alternative means of kidnapping presented to the jury, that the trial court violated his confrontation rights by limiting his cross-examination of an adverse witness, that the trial court erroneously admitted evidence of a prior crime of dishonesty, and that the prosecutor incorrectly defined "burglary" during closing arguments. Upon review of the trial court record, the Supreme Court reversed petitioner's convictions for kidnapping in the first degree because there was insufficient evidence to support that conviction. The Court reversed the conviction for burglary in the second degree because of prejudicial trial error. But the Court affirmed his conviction for criminal trespass in the first degree because the errors petitioner claimed were harmless. View "Washington v. Garcia" on Justia Law