Justia Washington Supreme Court Opinion Summaries

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

In this case, the Supreme Court was asked to resolve four issues that arose after Defendants Anthony Marquise Emery Jr. and Aaron Edward Olson were convicted at a joint trial of first degree kidnapping, first degree robbery, first degree rape, and first degree accomplice rape. The issues on appeal were: (1) whether the trial court erred in denying Olson’s motions to sever, and whether Emery’s counsel was ineffective in failing to move for severance; (2) whether the prosecutor’s statements during closing argument constitute misconduct that entitles Emery and Olson to a new trial; (3) whether the trial court erred in denying Emery’s motion for a mistrial based on Olson’s outbursts; and (4) whether Emery is entitled to a new trial based on cumulative error. The Court of Appeals affirmed the convictions. Upon review, the Supreme Court held that (1) the trial court did not abuse its discretion by denying Olson’s motions to sever, and Emery’s counsel was not ineffective in failing to move for severance; (2) the prosecutor’s statements during closing argument are improper but do not warrant a mistrial; (3) the trial court did not err in denying Emery’s motion for mistrial based on Olson’s outbursts; and (4) Emery is not entitled to a new trial based on cumulative error. Therefore the Court affirmed the Court of Appeals. View "Washington v. Emery" on Justia Law

In these two consolidated cases, the trial court instructed the jury that it must be unanimous to either accept or reject the aggravating circumstances, contrary to the Washington Supreme Court's decision in "State v. Bashaw," (234 P.3d 195 (2010)). However, the nonunanimity rule adopted in "Bashaw" was based on an incorrect rule announced in "State v. Goldberg," (72 P.3d 1083 (2003)). This rule conflicted with statutory authority, "cause[d] needless confusion, [did] not serve the policies that gave rise to it, and frustrates the purpose of jury unanimity." Accordingly, the Supreme Court took the opportunity to reconsider this portion of its holding in "Bashaw" and held that the nonunanimity rule could not stand. The Court affirmed the appellate court in upholding Petitioner Enrique Guzman Nunez's conviction and sentence, reversed the appellate court and reinstated Respondent George Ryan's exceptional sentence, and remanded both cases for further proceedings. View "Washington v. Guzman Nunez" on Justia Law

Two cases were consolidated before the Supreme Court because they were based on the same facts. Petitioners Robert Brown and Theodore Kosewicz were both involved in the kidnapping, torture, and killing of Sebastian Esquibel. At trial, Brown was convicted of first degree kidnapping and felony murder with the predicate felony being the first degree kidnapping. At a separate trial, Kosewicz was convicted of first degree kidnapping and first degree aggravated murder with the aggravating factor being the first degree kidnapping. On appeal, both Brown's and Kosewicz's first degree kidnapping convictions were overturned because of a charging defect. The Court of Appeals did not overturn Brown's felony murder conviction or Kosewicz's aggravating factor verdict. Brown and Kosewicz argued on appeal to the Supreme Court that reversal of the first degree kidnapping convictions requires reversal of the felony murder and aggravating factor verdict that were based in part on the first degree kidnapping. Upon review, the Court affirmed Brown's felony murder conviction and Kosewicz's aggravating factor verdict. View "Washington v. Kosewicz" on Justia Law

Personal restraint petitioner Eric Flint maintains that his return to total confinement as a result of repeated violations of conditions of community custody violated the ex post facto clauses of the state and federal constitutions. He filed his personal restraint in the Court of Appeals, which dismissed the petition as frivolous, and the Supreme Court granted discretionary review. Upon review, the Court concluded that application of the statute to Petitioner did not create an ex post facto problem and accordingly affirmed the Court of Appeals' dismissal of Petitioner's petition. View "In re Pers. Restraint of Flint" on Justia Law

In 1994, Petitioner Darold Stenson was sentenced to death after he was found guilty of murdering his wife and business partner, Frank Hoerner. In 2009, Petitioner's counsel filed a personal restraint petition (PRP) raising a due process claim based on alleged violations of "Brady v. Maryland,"(373 U.S. 83 (1963)). Petitioner's "Brady" claim pertained to evidence consisting of photographs and an FBI file that the State had access to at the time of trial but did not provide to Petitioner's counsel until 2009. The question before the Supreme Court was whether the State violated Petitioner's rights under the mandates of "Brady" and its progeny. Because the Court held that it did, it reversed Petitioner's aggravated first degree murder conviction and his death sentence and remanded the case for a new trial. View "In re Pers. Restraint of Stenson" on Justia Law

The Supreme Court granted the State's petition to review a decision of the Court of Appeals which reversed Respondent Yussuf Abdulle's first degree theft and forgery convictions based on "Washington v. Davis" (438 P.2d 185 (1968)). The State urged the Court to overrule "Davis", arguing that it is incorrect because it rests on the mistaken view that "Miranda" requires proof of waiver beyond a reasonable doubt and harmful because it keeps relevant evidence from the trier of fact. The Court agreed that "Davis" was incorrect in light of cases that issued from the United States Supreme Court following "Miranda." Therefore, the Court reversed the Court of Appeals and reinstated Respondent's convictions. View "Washington v. Abdulle" on Justia Law