Justia Washington Supreme Court Opinion Summaries
Articles Posted in Criminal Law
In re Pers. Restraint of Haghighi
The issue before the Supreme Court in this case centered on the Court's holding in "Washington v. Winterstein," (220 P.3d 1226 (2009)) and whether the inevitable discovery doctrine (which was found inconsistent with the Washington constitution) applied retroactively to judgments that were made final when decided. A jury convicted defendant Nadder Haghighi on theft and unlawful issuance of checks or drafts. The underlying issue in this personal restraint petition involved the admissibility of evidence obtained through a warrant issued in Washington, but faxed to the bank's offices in Illinois. A representative at the bank provided records requested by Washington police which did not comply with Illinois' law on domestication of out-of-state warrants. Defendant moved to suppress the records police obtained from Illinois, and appealed the trial court's denial of that motion. He also claimed on appeal he received ineffective assistance of appellate counsel. Upon review of the present case, the Court determined: (1) "Winterstein" did not apply retroactively; and, (2) defendant's ineffective assistance of appellate counsel was time barred.
View "In re Pers. Restraint of Haghighi" on Justia Law
In re Pers. Restraint of Adams
The issue before the Supreme Court in this case involved a claim under RCW 10.73.090. Petitioner successfully argued that a 2000 judgment against him and subsequent sentence were based on an incorrectly-calculated offender score. Petitioner claims in this appeal that because he successfully challenged the score in a 2009 collateral challenge and received a new sentence, he should have been able to raise an ineffective assistance of trial counsel relating back to that challenge. The Court of Appeals dismissed the claim as untimely and because it was successive. Upon review, the Supreme Court agreed that petitioner's petition was time barred.
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Washington v. Chen
The issue before the Supreme Court in this case was the conflict between the statutory requirement that limits disclosure of competency evaluations prepared under RCW 10.77 and the constitutional requirement that "justice in all cases shall be administered openly." Once the evaluation is filed, the trial court uses it to determine defendant's competency to stand trial. The trial court in this case denied defendant's motion to seal the evaluation, and defendant appealed. Upon review, the Supreme Court concluded that once a competency evaluation becomes court record, it becomes subject to the constitutional presumption of openness, which could be rebutted only when the trial court makes a specific finding that "Ishikawa" factors weigh in favor of sealing. View "Washington v. Chen" on Justia Law
Washington v. McEnroe
The Supreme Court reviewed a trial court's dismissal of notice of special death penalty sentencing proceedings. The King County prosecuting attorney appealed to the Supreme Court to decide whether he violated Washington's capital punishment statutes by considering the strength of the evidence against respondents Joseph McEnroe and Michele Anderson when he determined he would seek the death penalty. Respondents were accused of shooting and killing six people. Upon review, the Supreme Court concluded the prosecutor did not violate Washington law, reversed the trial court and remanded the case with instructions so that the cases against respondents could proceed. View "Washington v. McEnroe" on Justia Law
Washington v. Mau
Petitioner Jennifer Mau was convicted of making false insurance claims. She challenged the sufficiency of the evidence presented against her at trial. Upon review, the Supreme Court found that the State failed to prove the existence of any "contract of insurance" underlying Petitioner's claim. Therefore the Court reversed her conviction. View "Washington v. Mau" on Justia Law
Washington v. Meredith
In 2010, the Washington Supreme Court addressed that first step of the Batson test in "Washington v. Rhone," (229 P.3d 752 (2010)). Chief Justice Madsen wrote a concurrence to that case stating, "I agree with the lead opinion in this case. However, going forward, I agree with the rule advocated by the dissent." This has caused lower courts to question whether, going forward, they should follow the rule in the lead opinion or the dissent of Rhone. To clarify this issue, the Court granted review in this case solely on the scope of the bright-line rule articulated in Rhone. The Court clarified that Rhone did not establish a bright-line rule and that the rule in Washington remains the rule applied in the lead opinion in Rhone.
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Washington v. Zillyette
The State charged Brenda J. Zillyette with controlled substances homicide for the death of Austin Burrows. The information charging Zillyette with controlled substances homicide did not identify the controlled substance that Zillyette allegedly delivered that resulted in Burrows' death. The trial court convicted Zillyette, and the Court of Appeals affirmed. Upon review, the Supreme Court reversed because the information failed to set forth all of the essential elements of the crime of controlled substances homicide. View "Washington v. Zillyette" on Justia Law
Washington v. Saintcalle
Kirk Saintcalle was convicted of one count of first degree felony murder and three counts of second degree assault, all with firearm enhancements for which he was sentenced to 579 months in prison. During jury selection at Saintcalle's trial, the prosecution used a peremptory challenge to strike the only black juror in the venire, juror 34. The challenge came after the prosecution questioned juror 34 extensively during voir dire-far more extensively than any other juror, significantly after another juror made a comment about race. Saintcalle claimed on appeal to the Supreme Court that the peremptory strike was clearly racially motivated in violation of the equal protection guaranty as in "Batson v. Kentucky," (476 U.S. 79). Upon review, the Supreme Court disagreed. Batson requires a finding of purposeful discrimination, and the trial court's finding that there was no purposeful discrimination here was not clearly erroneous.
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Washington v. Clark
The Supreme Court affirmed Petitioner Michael Clark's conviction for theft on tribal trust land over which the State had jurisdiction. The Court noted that while the State lacked explicit statutory authorization to issue search warrants on tribal lands, federal law had not preempted the State's ability to do so. Further, the tribe had not used its inherent sovereignty to regulate the procedure by which state law enforcement could execute search warrants on the reservation. Petitioner moved to suppress evidence gathered on tribal land without a tribal warrant. View "Washington v. Clark" on Justia Law
Washington v. Vasquez
Petitioner Vianney Vasquez had fake social security and fake permanent resident cards in his possession when a grocery store security guard found them in a search related to shoplifting. The guard called police; petitioner was later arrested and charged with two counts of forgery. A jury convicted him, and the appellate court affirmed petitioner's convictions. On appeal to the Supreme Court, petitioner challenged the evidence presented at trial, arguing that it was insufficient to prove petitioner possessed the cards with an intent to injure or defraud. The Supreme Court concluded the evidence was indeed insufficient to prove these elements of the forgery statute, and reversed and remanded the case to the appeals court for vacation of petitioner's conviction. View "Washington v. Vasquez" on Justia Law