Justia Washington Supreme Court Opinion Summaries

A Seattle street performer's camera caught the shooting death of Franciso Green on tape. Police received several other eyewitness accounts of the shooting and arrested Petitioner Kevin Monday, Jr. in connection with the murder. A jury later found Petitioner guilty of first degree murder and two counts of assault. On appeal to the Supreme Court, Petitioner argued that prosecutorial misconduct and the imposition of firearms enhancements in the jury instructions at trial deprived him of a fair trial. Upon review of the trial record, the Supreme Court found that the prosecutor "injected racial prejudice into the trial proceedings" by asserting certain witnesses were unreliable and using derogatory language to characterize others. The Court reasoned that these statements "fatally tainted" the jury because it "planted the seed in the jury's mind that most of the witnesses were, at best, shading the truth to benefit [Petitioner]. Under the circumstances, we cannot say that the misconduct did not affect the jury's verdict." The Court did not reach Petitioner's "firearms enhancement" argument because it determined he was entitled to a new trial. The Court reversed the trial court's decision and remanded the case for further proceedings. View "Washington v. Monday" on Justia Law

Appellant Richard Mutch appealed his sentence of 400 months' imprisonment on rape and kidnapping charges. After his life sentence was vacated several years after his conviction, the trial court imposed an "exceptional" sentence of 400 months at re-sentencing. On appeal to the Supreme Court, Appellant challenged the trial court's authority to impose such a sentence. In particular, Appellant argued that the trial court miscalculated his "offender score," and because of the miscalculation, his 400-month sentence should be invalidated. Upon careful consideration of the trial record and the applicable legal authority, the Supreme Court affirmed the trial court's sentence. The Court found that Washington law gives trial courts the authority to impose "exceptional" sentences, and that the court did not miscalculate Appellant's "offender score." Accordingly the Court affirmed Appellant's sentence. View "Washington v. Mutch" on Justia Law

Petitioner Timothy Martin appealed his conviction on kidnapping and robbery charges. His principal claim on appeal was that the State prosecutor violated his constitutional rights when, on cross-examination at trial, the prosecutor inferred Petitioner had tailored his testimony to be consistent with police reports, witness statements and testimony presented by prior witnesses. After a thorough review of the pertinent case law and clauses of the federal and state constitutions, the Supreme Court found no violation of Petitionerâs constitutional rights. The Court affirmed Defendantâs conviction.

Washingtonâs criminal rules authorize a trial judge to release a person before trial, subject to electronic home monitoring (EHM). If convicted of a felony, the defendant is entitled to have the days spent on pretrial EHM credited against any sentence of confinement he or she may receive. Petitioner Joshua Harris pled guilty to two misdemeanors and sought credit for his time spent on EHM. When the trial court did not give him the credit, Petitioner petitioned the Superior Court for a writ of habeas corpus alleging unlawful restraint because he did not receive the credit. The Superior Court granted the writ and ordered the trial court to grant the credit. The appellate court reversed the habeas court order. On appeal, the Supreme Court found that according to state law, there were rational bases for treating felons and misdemeanants differently when crediting EHM. Petitioner was not entitled to the credit he sought as a misdemeanant. Accordingly, the Court affirmed the appellate courtâs decision to reverse the trial courtâs grant of credit for time served under EHM.

Petitioner Michael Williams drove away from a car dealership without paying for new tires and wheels. An employee called the police, and officers tracked down Petitioner at his girlfriendâs home. Petitioner admitted that he had driven away, but to avoid discovery of an outstanding warrant against him, Petitioner gave a fake name. Petitioner was convicted of first-degree theft, making false statements to an officer, and for obstructing law enforcement by giving a fake name. Petitioner appealed his obstruction conviction, arguing that legislative history and case law show that the trial court misinterpreted the applicable statute. The appellate court affirmed the conviction. The Supreme Court reversed the appellate court, holding that obstruction requires more than just a statementâit requires some conduct in addition to making the statement. The Court vacated Petitionerâs conviction on the obstruction charge alone, but affirmed the lower courtsâ decisions in all other respects.

Petitioner Jack Sims appealed only part of his sentence stemming from child molestation charges. As his defense against the charges, Petitioner argued that the contact he had with the victim was an isolated event, and that the evidence supported his contention at trial. The Department of Corrections recommended Petitioner receive a âspecial sex offender sentencing alternativeâ (SSOSA) sentence. The recommendation was supported by testimony from an expert that opined that Petitioner had a very low risk of re-offending. The trial court ordered a lifetime âno-contactâ order, and banished Petitioner from the city and county in which the victim lived. Petitioner challenged the banishment portion of his sentence, arguing that it was unconstitutional. The Supreme Court agreed that the sentence was unconstitutional, and concluded that the proper remedy in this case would be a resentencing for the limited purpose of narrowly tailoring the geographic condition of Petitionerâs SSOSA sentence that banished him from the county. The court remanded the case to the trial court for further proceedings.

A jury found Petitioner Gale West to be a sexually violent predator, and the trial court ordered him to be civilly committed. The appellate court affirmed the lower courtâs order. Petitioner appealed, seeking a new trial because he believed he was prejudiced by the trial courtâs evidentiary rulings. The Supreme Court found that although âsome errors occurred, they were harmless.â The Court affirmed the appellate courtâs decision.

Petitioner Raymond Martinez challenged his conviction for first degree burglary, contending that the State failed to prove beyond a reasonable doubt that he was armed with a deadly weapon within the meaning of the applicable statute. At trial, a knife and sheath were admitted into evidence, but none of the witnesses provided a verbal description of the sheath, or indicated whether it was fastened or unfastened when it was found on Petitionerâs person. On appeal, Petitioner alleges the prosecutor misstated the evidence, mislead the jury, and made an inflammatory statement in his closing remarks. The Court of Appeals dismissed the petition on procedural grounds without reaching the merits. The Supreme Court reviewed the record and found that the evidence presented at trial was insufficient to sustain a first degree burglary conviction. The Court vacated Petitionerâs conviction, and remanded the case to the lower court for further proceedings.

Petitioner Glen Nichols was charged with possession of cocaine with the intent to deliver, and with possession of less than 40 grams of marijuana. Following a denial of his motion to suppress the evidence seized from his arrest, the case proceeded to a bench trial at which Petitioner was found guilty on both charges. After he was sentenced, Petitioner appealed his convictions. Petitioner filed a Personal Restraint Petition (PRP) challenging the police search of the motel registry where he was staying when he was arrested. While his appeal was pending, the Supreme Court decided State v. Surge where it held that a random, warrantless check of motel registry records was unconstitutional. The appellate court affirmed Petitionerâs convictions and denied his PRP. On appeal, Petitioner argues that in light of the Supreme Courtâs decision in the âSurgeâ case, evidence stemming from the police search of the motel registry should have been suppressed. The Court was not persuaded by his argument, holding that Petitionerâs case differed from the âSurgeâ case in that police were not doing a random check of the records, rather, they had âindividualized suspicion that drug selling activity had taken place fromâ his room. The Court affirmed the appellate courtâs decision.