Justia Washington Supreme Court Opinion Summaries

This case involved the Public Records Act (PRA) and whether, under RCW 42.56.540, the superior court could consider the identity of a public records requester when determining whether to issue an injunction. The superior court ruled it could not consider a requester's identity and scheduled a permanent injunction hearing to determine whether the records were exempt from disclosure. Franklin County sought review of the trial court's ruling regarding identity. The Court of Appeals disagreed with the superior court and held that identity could be considered under RCW 42.56.540 because a superior court's injunctive powers are equitable. It also held that RCW 42.56.565, enacted while review was pending, is retroactive. Having determined that the Court of Appeals improperly reviewed the case when the trial court had not ruled on whether the records were exempt, the Supreme Court reversed the Court of Appeals and remanded the case for a hearing on the permanent injunction. View "Franklin County Sheriff's Office v. Parmelee" on Justia Law

After an amendment to the Washington Law Against Discrimination (WLAD), Debra Loeffelholz sued the University of Washington and her superior, James Lukehart (collectively “University”), for discrimination based on sexual orientation. She alleged the sexual-orientation-based discrimination created a hostile work environment based on a series of preamendment acts and one potentially postamendment act. This case presented two related issues on appeal: (1) whether the WLAD amendment applied retroactively and, if not, whether preamendment discriminatory conduct is actionable and (2) whether a single comment made postamendment is a discriminatory act. Upon review, the Supreme Court held that the WLAD amendment is not retroactive and that the preamendment conduct was not actionable as it was not unlawful when it occurred. The postamendment, allegedly discriminatory comment is arguably similar enough to the preamendment conduct to survive summary judgment. Consequently, the Court affirmed the Court of Appeals only in reversing summary judgment for the University and clarified that the Court of Appeals erred in allowing recovery for preamendment conduct. View "Loeffelholz v. Univ. of Wash." on Justia Law

Plaintiff Automotive United Trades Organization brought suit against Washington State and its officials, challenging the constitutionality of disbursements the State gives to Indian tribes under fuel tax compacts. The trial court dismissed the amended complaint for failure to join indispensable parties, namely the Indian tribes party to the agreements, under CR 19. The Supreme Court reversed, holding the tribes were not indispensable parties under CR 19(b). Although the tribes are necessary parties under CR 19(a) whose joinder was not feasible due to tribal sovereign immunity, equitable considerations allowed this action to proceed in their absence. View "Auto. United Trades Org. v. Washington" on Justia Law

This case required the Supreme Court to examine how Washington's juvenile justice laws interact with the Persistent Offender Accountability Act (POAA), also known as the "three strikes law." When Jorge Saenz was 15 years old, he agreed to waive juvenile court jurisdiction and transfer his case to adult court, where he pled guilty to two counts of felony assault in exchange for a moderately lower sentencing recommendation. As a result, seven years later he faced life in prison without the possibility of parole under the POAA. The issue for the Supreme Court's review concerned whether his waiver of juvenile court jurisdiction was valid and whether his case was properly transferred to adult court. The Court concluded that Saenz's waiver was invalid because there was virtually nothing in the record demonstrating that it was intelligently made or that Saenz was fully informed when he made it. Next, the Court held that Saenz's case was not properly transferred to adult court because the commissioner transferring the case failed to enter findings that transfer was in the best interest of the juvenile or the public as required by statute. On these facts, the Supreme Court held that Saenz's conviction could not be used as a "strike" to sentence him to spend the rest of his life in prison with no possibility of release. Instead, the Court affirmed the 561-month sentence imposed by the trial court. View "Washington v. Saenz" on Justia Law

The issue on appeal before the Supreme Court was whether RCW 4.16.160 bars a quiet title action where the claimant alleges he adversely possessed property belonging to a private individual before a municipality acquired record title to the land. James Gorman IV, as general partner of Hollywood Vineyards Limited Partnership, claimed title to certain real property through adverse possession. The property at issue was dedicated to the city of Woodinville by a private owner in December 2005 for a roadway improvement project. Gorman owned adjacent property. In 2007, Gorman filed an action to quiet title claiming he acquired the adjacent property through a 10-year period of adverse possession that transpired while the land was still in private hands. The City moved to dismiss arguing Gorman’s claim was prohibited by RCW 4.16.160. The trial court granted the City’s motion and dismissed Gorman’s claim. The Court of Appeals reversed. It held Gorman’s claim was not barred because it is alleged the statute of limitations ran while the subject land was privately owned. Upon review, the Supreme Court concluded that RCW 4.16.160 does not bar such quiet title actions, and affirmed the appellate court's decision. The case was remanded to the trial court to determine the validity of Gorman's claim of title. View "Gorman v. City of Woodinville" on Justia Law

David Ward and Michael Whittaker were commissioners for the Jefferson County Fire Protection No. 2 (the District). Two citizens of the District, Harry Goodrich and Linda Saunders (the petitioners), initiated a recall proceeding against Ward and Whittaker, alleging various counts of misfeasance. The issue before the Supreme Court was whether the recall petition should advance to the signature-gathering phase of the recall process. Upon review, the Supreme Court affirmed the trial court and held that one of the four charges against Ward and Whittaker may advance to the next phase of the recall process. View "In re Recall of Ward" on Justia Law

This case concerned the classification of workers as employees or independent contractors for purposes of the Washington Minimum Wage Act (MWA). A class of 320 former and current FedEx Ground Package System, Inc. (FedEx) delivery drivers (hereinafter Anfinson) filed suit seeking overtime wages under the MWA and reimbursement for uniform expenses under the industrial welfare act (IWA). The dispute with respect to both claims was whether the drivers were employees or independent contractors. The parties disagreed on the correct test to distinguish these categories under the MWA; FedEx argued that the common law right-to-control standard governs while Anfinson contended that the federal Fair Labor Standards Act of 1938 (FLSA) economic-dependence test controls. The trial court gave the jury a hybrid instruction, focusing the inquiry on FedEx's right to control in light of the economic-dependence factors. The jury determined that the drivers were independent contractors. Anfinson appealed, contending, among other things, that the jury instructions misinformed the jury about the standards for determining worker status and about the requirement that class status and evidence be "common to the class members." The Court of Appeals held that the jury instruction defining the standard for determining worker status was erroneous and prejudicial and reversed. The Court of Appeals further held that the jury instruction on the burden of proof was erroneous because it misled the jury and was prejudicial. Upon review, the Supreme Court affirmed the Court of Appeals in both respects. View "Anfinson v. FedEx Ground Package Sys., Inc." on Justia Law

Christa Albice and Karen Tecca (hereinafter Tecca) inherited the property at issue in this case. In 2003, Tecca borrowed $115,500 against the property. The loan was serviced by Option One Mortgage Corporation (Option One), and Premier Mortgage Services of Washington (Premier) acted as the trustee. In 2006, Tecca defaulted on the loan and received a notice of trustee's sale. In July 2006, Tecca negotiated and entered into a forbearance agreement to cure the default. The trustee's sale originally set for September 8, 2006 was continued six times. Each continuance was tied to the payments Tecca made under the Forbearance Agreement. The foreclosure sale finally took place on February 16, 2007. Through an agent, Petitioner Ron Dickinson, successfully bid on the property. Tecca first learned the property was sold when Dickinson told Tecca they no longer owned it and needed to leave. Dickinson then filed an unlawful detainer action and sought to quiet title. Tecca countersued, seeking to quiet title in an action to set aside the nonjudicial sale. Tecca also brought suit against Option One and Premier, but the trial court dismissed the action based on an arbitration clause. Dickinson moved for summary judgment to establish that he was a BFP and entitled to quiet title. Tecca also moved for summary judgment, arguing the foreclosure sale should have been set aside because the sale occurred after the statutory deadline and Premier was not a qualified trustee with authority to conduct the sale. The trial court granted Dickinson's motion, ruling that Dickinson was a BFP and despite procedural noncompliance by the trustee. Following trial, the court concluded Premier was authorized to act as the trustee, quieted title in Dickinson, and awarded Dickinson damages. Tecca appealed. The Court of Appeals reversed, setting the sale aside. The Supreme Court affirmed the Court of Appeals: the nonjudicial foreclosure proceedings were "marred" by repeated statutory noncompliance. The financial institution acting as the lender also appeared to be acting as the trustee under a different name; the lender repeatedly accepted late payments and, at its sole discretion, rejected only the final late payment that would have cured the default; and the trustee conducted a sale without statutory authority. The Court concluded the sale was invalid. View "Albice v. Premier Mortg. Servs. of Wash., Inc." on Justia Law

The Supreme Court received a certified question from the Ninth Circuit Court of Appeals. The issue centered on whether under RCW 82.04.500 a seller may upon disclosure, recoup its business and occupation (B&O) tax by collecting a surcharge to recover gross receipts taxes in addition to its monthly service fee. The matter stems from Plaintiff-Appellant James Bowden's purchase of three cell phones and a monthly service plan for each phone at a kiosk. The phone company's monthly service fee did not include Washington's B&O tax. However, the tax was listed as a "State B and O Surcharge" on Plaintiff's monthly bills, for which he was charged various amounts for each of the phones. Upon review, the Supreme Court concluded that the phone company's monthly service fee, the sales price of its service contract, did not include the B&O surcharge. Rather, on the Agreement, the surcharge was listed separately under the "Regulatory Recovery Fee" provision described as a gross receipts surcharge. Further, the company's billing statements listed the surcharge separately like it was a sales tax, and both the sales tax and B&O fee were added on to the service fee. The Court therefore answered "no": even if disclosed under RCW 82.04-500, a seller is prohibited from recouping its B&O taxes by collecting a surcharge in addition to its monthly service fee. View "Peck v. AT&T Mobility" on Justia Law

An Auburn city police officer arrested Defendant Dustin Gauntt for possessing marijuana and using drug paraphernalia. An Auburn city prosecutor brought charges against him in Auburn Municipal Court under state law. On appeal of his conviction, Defendant contended that the city did not have the authority to prosecute him for violating statutes the city had not adopted. Upon review, the Supreme Court agreed, affirming the Court of Appeals and the superior court, and remanded the case back to the Auburn Municipal Court for dismissal. View "City of Auburn v. Gauntt" on Justia Law