Justia Washington Supreme Court Opinion Summaries

Petitioner Jaryd Schroeder sought treatment from the respondents, Dr. Steven Weighall and Columbia Basin Imaging. Schroeder was nine years old at the time and suffered from headaches, nausea, dizziness, weakness in his legs, and double vision. He underwent an MRI (magnetic resonance imaging), which Weighall reviewed and found to be normal. Schroeder's symptoms persisted. On either November 9 or 19, 2009, when he was 17, Schroeder underwent another MRI. This time the radiologist who reviewed the image found an Arnold Chiari Type I Malformation. On January 13, 2011, the day before his 19th birthday, Schroeder filed a medical malpractice action against Weighall, Columbia Basin Imaging, PC, and a third party subsequently dismissed by stipulation. Weighall asserted that the action was barred by the statute of limitations codified at RCW 4.16.350 and subject to the minority tolling exemption codified at RCW 4.16.190(2). Schroeder and his mother discovered Weighall's alleged omission November 2009 when Schroeder was still a minor. If not for RCW 4.16.190(2), the one-year statute of limitations applicable to his claim would have tolled until his 18th birthday. The ultimate issue before the Supreme Court was the constitutionality of RCW 4. 16. 190(2). Upon review, the Supreme Court concluded that RCW 4.16.190(2) violated article I, section 12 of the Washington State Constitution, and therefore reversed the trial court's summary judgment order dismissing Schroeder's medical malpractice action. View "Schroeder v. Weighall" on Justia Law

In 2010, two Fare Enforcement Officers entered a train car at the Rainier Beach station and instructed all passengers to present proof of fare. When FEO Willet asked fifteen-year-old K.L.B. and his two companions to present proof of fare payment, they gave him their bus transfers. FEO Willet informed them that while bus transfers used to be valid on the light-rail, they were no longer accepted. The three young males were instructed by FEO Willet to exit the train at the next station. The FEOs asked the three males for identification once they exited the train. All three were either unable or unwilling to provide identification. K.L.B. was temporarily detained at the Othello station. The King County Sheriff's Office was called to assist in identifying K.L.B. and his companions so they could potentially be cited for fare evasion. Deputy Adams then asked K.L.B. to identify one of his male companions. He responded that he did not know his companion's full name and that he: knew him only as '"Marty."' Deputy Adams returned to the station and used a computer database to identify "Marty." There was an assault warrant out for "Marty's" arrest. K.L.B. was charged with two counts of making a false or misleading statement to a public servant under RCW 9A.76. 175. K.L.B. was found guilty of making a false statement to FEO Willet (count II). He was found not guilty of making a false statement to Deputy Adams (count I). K.L.B. appealed to Division One of the Court of Appeals, which affirmed his conviction. K.L.B. argued that a Sound Transit FEO was not a "public servant" as defined in RCW 9A.04.110(23). He also argued that the definition of "public servant" was unconstitutionally vague and that to convict a person of making a false or misleading statement to a public servant, the State must prove that the defendant knew the statement was made to a public servant. The Court of Appeals affirmed the trial court's conclusion that under the statute, FEO Willet was a public servant at the time K.L.B. made the false statement. The Supreme Court held that under these circumstances, because FEOs are not government employees, are not officers of government, and do not perform a governmental function, they are not "public servants" as defined by the statute. View "Washington v. K.L.B." on Justia Law

Petitioner Josh Sanchez was adjudicated a juvenile sex offender. He petitioned against the superior court's release of his offender information to the King County Sheriff's Office when he was released back into the community. Washington law mandated that the local authorities notify the community of the offender's release and potential risk that the offender posed. The Supreme Court held that the juvenile court could release the evaluation of petitioner that resulted in his receiving offender status, and that it was not a violation of his rights to do so. View "Washington v. Sanchez" 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

Petitioner Daniel Posey,Jr. committed two counts of second degree rape when he was sixteen years old. A jury convicted him, and the superior court sentenced him as an adult. On direct review, the Supreme Court remanded Petitioner's case with instructions that a juvenile court sentence him. Prior to the Court's mandate, Petitioner turned twenty-one. On remand, Petitioner challenged the juvenile court's authority to sentence him. The presiding judge agreed. The superior court resentenced Petitioner as an adult, but imposed a sentence consistent with the standard juvenile range. Upon review, the Supreme Court concluded the issue of this case was whether legislation relating to juvenile courts could deprive the superior courts of their constitutional jurisdiction. The Court held that the legislature did not have the power to alter that constitutional grant of felony jurisdiction. The Court thus affirmed the sentence imposed on remand by the superior court, and affirmed the Court of Appeals' decision upholding Petitioner's original sentence. View "Washington v. Posey" on Justia Law

In this case the issue presented for the Supreme Court's review was whether a thirteen-year old was denied due process rights when she was not appointed counsel at a truancy hearing. Despite a district court's order to attend school, E.S. missed classes from 2005 to 2007. At first, E.S. and her mother attended the hearings, but were not represented by counsel, nor did they ask that counsel be present. The court explained that E.S. would be "sentenced" to house arrest, work crew and detention if she did not comply with the order, but she continued to miss school. At E.S.' last court appearance, she was represented by counsel. She was ordered to spend six days in detention with electronic monitoring. E.S., through her attorney, filed a motion to have the home detention set aside, which was denied. The Court of Appeals vacated E.S.' sentence, finding that the child's "interests in her liberty, privacy and right to education [were] in jeopardy" at the truancy hearings, and that due process required counsel at each appearance. On appeal to the Supreme Court, the School District argued that Washington courts never required the appointment of counsel to protect a child's privacy and education interests. The Supreme Court agreed with the District. Upon review of the record, the state constitution and the applicable legal authority, the Court found that E.S. was not denied due process rights because she was not appointed counsel in the initial truancy hearings. The Court reversed the Court of Appeals' decision and remanded the case for further proceedings. View "Bellevue Sch. Dist. v. E.S." on Justia Law

K.N.J. was born in 2005 to Marquesha Everett and Petitioner Michael Jenkins. K.N.J. suffered extreme abuse at the hands of her mother. After discovery of the abuse, K.N.J. was removed from her mother's care and placed in foster care. Petitioner was served with a summons and petition for a dependency hearing. A judge pro tempore presided over the initial hearing. The mother consented to the judge's hearing the case. Petitioner did not appear and was not represented by counsel. The judge pro tempore entered a default order of dependency despite her status and Petitioner's lack of consent. Subsequent hearings were held, and an elected judge presided over them. Petitioner did not appear until the permanency planning hearing. Petitioner moved to dismiss the case, asserting that the original dependency order was void because Petitioner did not consent to a judge pro tempore. The trial court denied Petitioner's motion to dismiss and terminated his parental rights. Petitioner appealed the termination to the Supreme Court. The Court found that K.N.J.'s dependency was amply proved at the termination trial where Petitioner was present and represented by counsel. Furthermore the trial court's findings supported the termination of Petitioner's parental rights. The Court affirmed the decisions of the lower court.