Justia Washington Supreme Court Opinion Summaries

Petitioners Ronnie Jackson Jr. and Salvador Rivera filed personal restraint petitions to challenge the firearm enhancements they received as part of their sentences, which became final in 2002. In response, the issue before the Supreme Court was whether rules it announced in "Washington v. Recuenco," (110 P.3d 188 (2005) (Recuenco I)) and "Washington v. Recuenco," (180 P.3d 1276 (2008) (Recuenco III)) applied retroactively. The rules in question were: (1) that a firearm enhancement cannot be based on a jury's general "deadly weapon" finding; and (2) that an information must particularly identify any firearm enhancements sought by the State in order to authorize such enhancements at sentencing. "In other words, [the Court] must decide if it [was] too late to challenge enhancements imposed before the Recuenco I and Recuenco III decisions." Upon review, the Court found that Recuenco I and Recuenco III were not retroactive as to either issue and held that Rivera and Jackson were not entitled to any relief on collateral review. View "In re Pers. Restraint of Jackson" on Justia Law

"A trial court must have authority to manage the parties and proceedings before it." The State argued the trial court in this case erroneously imposed sanctions in a criminal prosecution without explicitly finding bad faith. "While a finding of bad faith is the preferred basis for imposing sanctions in a criminal case, [the Supreme Court] will uphold sanctions if [it] can infer bad faith from the record . . . The trial court in this case did not make a finding of bad faith and, given concessions at oral argument, the record did not support sanctions. The Court therefore reversed. View "Washington v. Gassman" on Justia Law

Defendant Kenneth Lamb was charged with, among other things, 10 counts of unlawful possession of a firearm. The State alleged that Lamb was precluded from possessing firearms because of his 1991 juvenile adjudication for second degree burglary. Defendant moved to withdraw his 1991 plea of guilty and vacate the juvenile adjudication. The trial court granted his motion. The trial court also denied the State’s motion to amend the information to instead rely on another juvenile adjudication and, ultimately, dismissed the 10 unlawful possession of a firearm counts. The State appealed and the Court of Appeals reversed all three of the trial court’s rulings. The issue before the Supreme Court was the trial court's exercise of discretion in vacating judgments, in disallowing the State to amend an information in a criminal case, and in dismissing counts of an information. Upon review, the Court affirmed in part, and reversed in part, holding that in this case the trial court abused its discretion when it vacated Defendant's juvenile adjudication for second degree burglary and dismissed the 10 unlawful possession of a firearm counts against him. On these two issues, the Court affirmed the Court of Appeals. The Court reversed the Court of Appeals with respect to the trial court’s refusal to permit the State to amend the information and held that the trial court did not abuse its discretion. The case was remanded to the trial court for further proceedings. View "Washington v. Lamb" on Justia Law

Petitioner Douglas Rose challenged his convictions for unlawful possession of a stolen access device and for unlawful possession of a controlled substance. The issue before the Supreme Court was whether the credit card Petitioner possessed was an "access device" under Washington law. Further, the Court was presented with the issue of whether Petitioner's arrest, which lead to the search of his bag and discovery of the evidence eventually presented against him, was supported by probable cause. Under the facts of this case, the Supreme Court concluded that the State did not meet its burden to show that the card in question was an "access device." The Court reversed on that issue, but affirmed Petitioner's arrest on all other grounds. View "Washington v. Rose" on Justia Law

Defendant-Appellant Jamar Meneese appealed his conviction for unlawfully carrying a dangerous weapon on school grounds and for possessing a controlled substance. He claimed the weapon, an air pistol, was seized in an unlawful search at school and should have been suppressed at trial. The question on appeal was whether the school search exception to the warrant requirement applied to the search conducted by the school resource officer (SRO). The parties disputed whether the SRO was acting as a school official or a law enforcement officer at the time of the search. Upon review, the Supreme Court found that the SRO is a fully commissioned, uniformed, law enforcement officer employed by the Bellevue Police Department. He arrested and handcuffed Defendant before searching his backpack. Moreover, after arresting Defendant, the focus of the investigation was no longer on informal school discipline (an underlying purpose behind the school search exception.) Accordingly, the Court concluded the school search exception did not apply, a warrant supported by probable cause was required, and the weapon should have been suppressed. View "Washington v. Meneese" on Justia Law

William Adam Gray shot Vita M. Moimoi and Sanelive S. Hikila at close range. Moimoi suffered a serious leg wound and Hikila bled to death. Although Gray fled the scene, he was soon identified and charged with second degree felony murder, first degree assault, and unlawful possession of a firearm. Gray remained at large for almost two years before being arrested. Gray pled guilty to first degree manslaughter and second degree assault. At a sentencing hearing, the State requested restitution in an amount to be determined after the victim's assistance unit (VAU) had computed the appropriate amount. The court agreed, and Gray waived his right to be present at any future hearing. At issue in this case was whether RCW 9.94A.753(4) permitted a court to modify a restitution order more than 180 days after sentencing to include expenses that were incurred before the trial court issued its original restitution order. Upon review, the Supreme Court held that the plain language of RCW 9.94A.753(4) clearly authorizes courts to make such modifications. View "Washington v. Gray" on Justia Law

Leysa and Leah Sweany challenged the sufficiency of the evidence supporting their convictions for arson in the first degree. In 2009, a fire damaged their trailer. The State charged both with alternative means of committing arson in the first degree, relying on the means of causing "a fire or explosion which damages a dwelling," and on the means of causing "a fire or explosion on property valued at ten thousand dollars or more with intent to collect insurance proceeds." The Sweanys argued that the State failed to present sufficient evidence that the property on which they caused a fire was valued at $10,000 or more. Though the Supreme Court concluded that the Sweanys correctly argued that the relevant value was the fair market value of the property, the Court also concluded that sufficient evidence supported this element. Accordingly, the Court affirmed the Court of Appeals judgment upholding their convictions. View "Washington v. Sweany" on Justia Law

This case concerned the standard for assessing prejudice in a personal restraint petition alleging ineffective assistance of counsel. Petitioner Hoyt Crace was convicted of attempted second degree assault with a deadly weapon. This was his third strike offense, resulting in a life sentence without the possibility of early release. Petitioner brought this personal restraint petition asserting he received ineffective assistance of counsel when his trial counsel did not request an instruction on the lesser-included offense of unlawful display of a deadly weapon, a nonstrike offense. A divided Court of Appeals applied the analysis for an ineffective assistance of counsel claim set forth in "Strickland v. Washington," (466 U.S. 668 (1984)), concluding that a showing of prejudice under this analysis satisfied the “actual and substantial prejudice” showing required on collateral attack. Without the benefit of the Washington Supreme Court's decisions in "Washington v. Grier," (246 P.3d 1260 (2011)) and "Washington v. Breitung," (267 P.3d 1012 (2011)), the court then granted Petitioner's petition, holding that trial counsel’s performance was deficient and that counsel’s error prejudiced him. Upon review, the Supreme Court reversed the Court of Appeals, finding that the court correctly analyzed prejudice under the Strickland standard, Petitioner could not show prejudice arising from the omitted instruction. View "In re Pers. Restraint of Crace" on Justia Law

Petitioner Jennifer Leigh Rice, a former public school teacher, molested one of her 10-year-old students. Her conduct was found to be predatory as charged in a special allegation under RCW 9.94A.836. She also abducted the same 10-year-old boy and was convicted of kidnapping with special allegations under RCW 9.94A.835 and .837 for sexual motivation and for having a victim under age 15. The special allegations increased her sentence. Petitioner argued on appeal that her convictions should be overturned because the legislature made charging the above special allegations mandatory, in violation of the constitutional separation of powers doctrine. Further, Petitioner argued that .835 was unconstitutional because it requires a prosecuting attorney to file a special allegation whenever there is sufficient evidence to support the allegation and that .836 and .837 were unconstitutional because each requires a prosecuting attorney to file a special allegation whenever there is sufficient evidence to support the allegation and so long as the allegation will not interfere with obtaining a conviction. The Court of Appeals held that the charging statutes do not unduly limit prosecutorial discretion because even if a charging requirement is imposed, the prosecutor still must determine whether there is sufficient supporting evidence and whether the supplemental charge would interfere with obtaining a conviction. Upon review, the Supreme Court affirmed, but on grounds different than those by the appellate court. The Supreme Court found that the challenged statutes are directory rather than mandatory. "Although the statutes authorize special allegations and direct prosecuting attorneys to file them, the statutes do not attach any legal consequences to a prosecutor’s noncompliance, and the legislature elsewhere in the same chapter has acknowledged that prosecuting attorneys retain broad charging discretion notwithstanding statutory language directing them to file particular charges. . . .Our interpretation also rests on the fact that the challenged statutes would be unconstitutional if they were mandatory." The Court upheld the statutes in question and affirmed Petitioner's conviction and sentence. View "Washington v. Rice" on Justia Law

Defendant Joseph T. McEnroe sought a court order to seal documents that would have been used in support of a separate motion (his separate motion asked that he be tried second, following his codefendant’s severed trial). Before doing so, he filed a motion to waive Local General Rule (LGR) 15 and requested the opportunity to withdraw those documents in the event his motion to seal was denied. The trial court denied his motion, ruling that General Rule (GR) 15 and its local counterpart precluded withdrawal. The issue before the Washington Supreme Court therefore concerned the proper determination of the proper procedure when a party files documents contemporaneously with a motion to seal. Upon review, the Court held that LGR 15, as written, does not apply to criminal proceedings and that GR 15 does not require documents submitted with a motion to seal to be open to the public while the court considers the motion. Further, the Court held that GR 15 allows withdrawal of those documents if the trial court denies the motion to seal. Accordingly, the Court reversed the trial court and remanded with instructions to allow withdrawal in the event Defendant’s request for sealing was denied. View "Washington v. McEnroe" on Justia Law