Justia Washington Supreme Court Opinion Summaries

Petitioner David Oppelt, Jr. was accused by his stepdaughter of sexually abuse. Police investigated, but Petitioner was not charged until six years after the alleged incident. Petitioner argued that his due process rights were violated by the pre-accusatorial delay and that the charges against him should have been dismissed. The trial court disagreed, and Petitioner was convicted of child molestation. On appeal to the Supreme Court, Petitioner argued that the trial court misapplied the "pre-accusatorial delay test" for determining whether due process was violated by the delay. Upon review of the applicable legal authority, the Supreme Court concluded that the trial court engaged the proper test and found no violation of due process. The Court affirmed Petitioner's conviction. View "Washington v. Oppelt" on Justia Law

The City of Bothell charged Respondent James Barnhart with stalking within the portion of the City that falls within Snohomish County. The jury, which was composed of two King County and four Snohomish County jurors, ultimately convicted Respondent. The Court of Appeals reversed Respondent's conviction because it found the impaneling of King County jurors, though valid under state law, violated Article 1 Section 22 of the state constitution. The City appealed. Upon review, the Supreme Court affirmed the Court of Appeals finding "the composition of [Respondent's] jury violated his right to an 'impartial jury of the county in which the offense is charged to have been committed.'" The case was remanded for a new trial. View "City of Bothell v. Barnhart" on Justia Law

At issue in this case was whether the removal of a person from the courtroom during trial was a "closure" in violation of the right to a public trial and whether such a "closure" could be considered too trivial as to implicate a defendant's constitutional rights. Defendant Dean Lormor was arrested following a domestic disturbance. During his jail intake, a small bag of methamphetamine was found in his pants pocket. Defendant's daughter, who was four days shy of her fourth birthday, was excluded from the courtroom before trial. The daughter, who was terminally ill, was confined to a wheelchair and required a ventilator to breathe. Before trial, the prosecutor brought the matter up, because Defendant had either talked to or near one of the jurors regarding his daughter. The prosecutor requested that Defendant be precluded from discussing his daughter and her condition. Counsel and and Defendant acquiesced, but Defendant had concerns about eventual sentencing because he hoped to accompany his daughter to Disneyland with the Make-a-Wish Foundation. Defendant was eventually convicted on the possession charge and sentenced to 24 months. He was allowed to go to Disneyland with his daughter before serving his sentence. On appeal Defendant argued that the trial court violated his right to a public trial by excluding his daughter from trial. Additionally, Defendant argued he received ineffective assistance of counsel because his attorney failed to object to the exclusion as a cautionary measure. The appellate court determined that the exclusion was a "closure" but that the trial court's actions did not implicate Defendant's constitutional rights. The Supreme Court held that the exclusion of one person is not a closure that violates a Defendant's right to a public trial, but instead is an aspect of the court's power to control the proceedings. Under the facts of this case, the Court found that the trial court's removal of the young daughter was not an abuse of discretion. Accordingly the Court affirmed the trial court's conviction. View "Washington v. Lormor" on Justia Law

Defendant Cliff Jones challenged the trial court's denial of credit toward his sentence of community custody for the time he spent incarcerated in excess of his amended sentence of incarceration. After affirming the trial court's decision, the appeals court expressly declined to follow a sister division's holding that community custody began at completion of a sentence of confinement; an offender is entitled to credit toward a sentence of community custody for time spent incarcerated. Upon review, the Supreme Court disavowed the lower court's holding regarding credit, and affirmed the appellate division that heard Defendant's case. View "Washington v. Jones" on Justia Law

Defendant Samuel Donaghe was convicted of second degree rape. In 1995, when Defendant’s incarceration was set to end, the State filed a petition to have Defendant committed as a “sexually violent predator” (SVP). In 2000 while awaiting his for his SVP commitment trial, Defendant moved to obtain a certificate of discharge for his rape convictions. The State argued against the discharge because Defendant had not fulfilled his community placement sentence, which the State argued tolled while he was confined. The trial court agreed with the State and denied Defendant’s motion. Three years later in 2003, the court found Defendant as an SVP. The Court of Appeals affirmed that determination in 2005. In 2007, Defendant renewed his motion for a certificate of discharge, but the trial court adhered to its 2000 ruling, holding that defendant’s custodial detention tolled the running of the community placement requirement. Defendant moved for reconsideration. The appeals court held that because Defendant had been detained as an SVP, his term of community placement could not “begin” until the State released him to the supervision of the community. Therefore, his sentence was not complete, and he was not entitled to a certificate of discharge. Upon review, the Supreme Court affirmed the Court of Appeals. The Court held that the trial court had the authority to deny Defendant’s certificate of discharge because his community placement was indeed tolled by his confinement as an SVP. View "Washington v. Donaghe" on Justia Law

Defendant James Eserjose appealed his second-degree burglary conviction. In his appeal, Defendant argued that the confession he gave to a deputy sheriff was inadmissible at trial. The trial court determined that although deputies had probable cause to arrest Defendant and consent to enter the home where the arrest was made, they exceeded the scope of the consent when they entered an upstairs hallway and made the arrests. The trial court held that the arrest was unlawful. Nevertheless, the court determined that Defendant's confession was admissible and subsequently found him guilty of burglary. Upon review, the Supreme Court found that the trial court did not err in determining that Defendant's confession was admissible. Accordingly, the Court affirmed Defendant's conviction. View "Washington v. Eserjose" on Justia Law

In 2005, Petitioner Robert May violated a domestic violence protection order that prohibited him from contacting his ex-wife. As a result, Petitioner was convicted under a Seattle ordinance. On appeal, Petitioner contended that the order was invalid and that he received no notice that the "no-contact" provision of the order was a criminal offense. The superior court reversed the municipal court's conviction, but the Court of Appeals reversed the superior court to reinstate the conviction. The Supreme Court in its affirmation of the Court of Appeals concluded: "[Petitioner] made a choice to violate the plain and unambiguous terms of the domestic violence protection order . . . the collateral bar rule precludes [him from challenging] the validity of the domestic violence protection order." The Court found that the protection order itself was notice that he would be prosecuted if he violated its terms. View "City of Seattle v. May" on Justia Law

Petitioners Lisa Mullen and Kevin Dean were prosecuted for stealing funds from their employer, a Skagit County car dealership. At issue before the Supreme Court was the State's duty to disclose exculpating evidence to defendants. After their convictions, Petitioners obtained a previously sealed deposition of the dealership's accountant taken in a separate civil suit between the owner and the accountant's firm. The deposition took place before the end of the criminal trial. In a motion for a new trial, Petitioners argued that the accountant's deposition testimony supported the defense theory that the owner authorized use of the funds. Petitioners contended that the prosecution's failure to disclose the information from the deposition constituted a due process violation under "Brady v. Maryland," 373 U.S. 83. The appellate court affirmed the lower court's finding that there was no due process violation. The Supreme Court agreed after careful consideration of the trial record and the applicable legal authority. The Court found no "Brady" violation, and found that the trial court did not abuse its discretion by not granting Petitioners a new trial. View "Washingotn v. Mullen" on Justia Law

Petitioner Robert Strandy was convicted of two counts of felony murder and aggravated first degree murder. For sentencing purposes, the trial court merged the murder and aggravated murder convictions, but it did not vacate the felony murder convictions. On appeal to the Supreme Court, Petitioner argued that the trial court erred by not vacating the merged murder convictions. The Supreme Court granted discretionary review of the case and found that the trial court's omission constituted a violation of the Fifth Amendment prohibition against double jeopardy. The Court remanded the case to the trial court to vacate Petitioner's two felony murder convictions. View "In re Pers. Restraint of Strandy" on Justia Law

Petitioner Jeremy Anderson was charged with first degree child molestation for alleged contact with a minor child. At trial, a nurse from the child's treating clinic testified to statements made by the child to her. Petitioner challenged the admission of the child's statements made to the nurse as a violation of his Sixth Amendment right to confronting the witness. The Court of Appeals affirmed their admission, holding that the child's statements to the nurse were "nontestimonial" because the statements were made while the nurse made a medical examination. The Supreme Court found that the statements were "testimonial" in nature, and therefore subject to Petitioner's Sixth Amendment right to confrontation. However, the Court held that any error resulting from admitting the testimony was harmless to Petitioner. The Court affirmed the appellate court's decision but on different grounds. View "Washington v. Anderson" on Justia Law