Justia Washington Supreme Court Opinion Summaries

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. View "Washington v. Meredith" on Justia Law

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

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. View "Washington v. Saintcalle" on Justia Law

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

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

Petitioner Lorraine Netherton was convicted of second degree murder. Upon review of her appeal, the Supreme Court concluded that the trial court erroneously imposed a sentence enhancement based on the jury's "deadly weapon" finding. Because petitioner's appellate counsel misapprehended who represented Petitioner at a critical stage of her appeal, Petitioner lost an opportunity to get the enhancement reversed. Accordingly, the Supreme Court found Petitioner received ineffective assistance of appellate counsel, and remanded the case to the trial court for resentencing. View "In re Pers. Restraint of Netherton" on Justia Law

Petitioner Josh Sanchez was adjudicated a juvenile sex offender. He petitioned against the superior court's release of his offender information to the King County Sheriff's Office when he was released back into the community. Washington law mandated that the local authorities notify the community of the offender's release and potential risk that the offender posed. The Supreme Court held that the juvenile court could release the evaluation of petitioner that resulted in his receiving offender status, and that it was not a violation of his rights to do so. View "Washington v. Sanchez" on Justia Law

Petitioner Christopher Smith was apprehended by police on the doorstep of his motel room and charged with rape, assault, harassment, kidnapping and child rape. Prior to trial, the Supreme Court invalidated the practice of random motel registry searches. At Petitioner's suppression hearing, he argued that the evidence gathered against him was the fruit of an unlawful registry search, and therefore should have been suppressed. The trial court allowed the evidence under the inevitable discovery doctrine. The appellate court upheld Petitioner's convictions, concluding that the evidence was admissible under the attenuation and independent source doctrines. Upon review, the Supreme Court affirmed Petitioner's conviction, holding the evidence was admissible because the warrantless search that led to its discovery was justifiable under the warrant exception for when lives were in danger. View "Washington v. Smith" on Justia Law

An officer stopped the defendant for a traffic violation. When it turned out that the driver and his passenger both had suspended drivers' licenses and alternate arrangements could not be made, the officer arranged for a tow truck to move the car. In order to turn the vehicle over to the towing company, the officer conducted an inventory search of the vehicle and discovered methamphetamine during the search. The defendant was convicted of unlawful possession of methamphetamine and driving while his license was suspended. He appealed, arguing that the trial court abused its discretion when it denied his motion to suppress the evidence on the ground the search was pretextual. He also argued that because he did not consent to the search, it was unconstitutional. The Court of Appeals affirmed his convictions. Upon review, the Supreme Court also affirmed, finding that under article I, section 7 of the Washington State Constitution, law enforcement officers do not have to obtain consent in order to conduct an inventory search of a lawfully impounded vehicle. View "Washington v. Tyler" on Justia Law

In 2009, Petitioner Lowell Finstad faced at least seven felony charges. After he was convicted by jury on two, he and the State negotiated a global plea agreement on the remaining charges. The agreement resulted in less prison time, and in exchange, Petitioner agreed to dismiss his appeal of the jury convictions. Under the terms of the agreement, the sentences would run concurrently. However, the State indicated that it would ask the judge to run a sentence for delivery of a controlled substance conviction consecutive to the others. From the record, it appeared that neither the State nor Petitioner nor the trial court realized that the last consecutive sentence would constitute an exceptional sentence that required special findings. The judge accepted the pleas without making any special findings. Petitioner did not appeal. Three years later, he filed a personal restraint petition contending he received an exceptional sentence that did not comply with Washington law. The State argued in response to the petition that under the facts of this case, Petitioner was not entitled to relief because he could not show he was prejudiced by the error. The Supreme Court agreed with the State and dismissed Petitioner's petition. View "In re Pers. Restraint of Finstad" on Justia Law