Justia Washington Supreme Court Opinion SummariesArticles Posted in Public Benefits
Washington v. Catling
In 2016, Washington charged Jason Catling with two counts of delivery of heroin. Pursuant to a plea deal, Catling pleaded guilty to one count in exchange for the State's agreement to dismiss the other, and to recommend a residential drug offender sentencing alternative (DOSA). During the sentencing hearing, Catling's attorney argued that because Catling's sole source of income was Social Security disability benefits, the trial court should not impose any legal financial obligations (LFOs), including mandatory obligations, based on the Washington Supreme Court's decision in City of Richland v. Wakefield, 380 P.3d 459 (2016), which had just issued the day before Catling's sentencing hearing. The trial court took the LFO matter under advisement, finding Catling's sole source of income were benefits totaling $753 per month. The trial court ultimately issued an order imposing LOFs totaling $800, finding LFOs could be ordered when a person was indigent and whose only source of income was social security disability. The Court of Appeals held that the particular obligations imposed here did not violate the federal antiattachment statute, but remanded for clarification of the payment order. The Supreme Court reversed the Court of Appeals in part, holding that the trial court erred in imposing a $200 filing fee on Catling. Further, the case was remanded to the sentencing court for a determination of whether Catling previously provided a DNA sample; if so, then the trial court's imposition of a $100 DNA collection fee was in error. The Supreme Court affirmed the imposition of the $500 crime victim fund assessment, but remanded for the trial court to revise the judgment and sentence and repayment order to comply with HB 1783, and to indicate the LFO could not be satisfied out of Catling's Social Security benefits. View "Washington v. Catling" on Justia Law
Wash. Educ. Ass’n v. Dep’t of Ret. Sys.
The Washington Department of Retirement Services (DRS) and the State of Washington appealed an order granting summary judgment to a class of public employee unions and unaffiliated employees and holding that the 2011 repeal of legislation granting future uniform cost of living adjustments (UCOLA) to the respondents' monthly pension payments was an unconstitutional impairment of the State's contractual obligation with its employees. The Supreme Court found that because the legislature reserved its right to repeal the pension rights at issue and the original enactment of UCOLA did not impair any existing contract rights of state employees. Accordingly, the Supreme Court reversed. View "Wash. Educ. Ass'n v. Dep't of Ret. Sys." on Justia Law
Wash. Educ. Ass’n v. Dep’t of Ret. Sys.
The issue this case presented to the Supreme Court was whether the Washington legislature's 2007 repeal of gain sharing-a pension enhancement provided in years of extraordinary investment return-unconstitutionally impaired the contract between the State and its employees. The Court held that the legislature reserved its right to repeal a benefit in the original enactment of that benefit and the enactment did not impair any preexisting contractual right. As to the employees' alternative argument, the Court held that the explanatory materials provided by the Department of Retirement Systems (DRS) do not rise to the level of making a promise or creating an inconsistent statement and thus reject the employees' contention that the state was estopped from repealing the gain-sharing benefit at issue in this case. Accordingly, the Court reversed the trial court's award of summary judgment to the employees. View "Wash. Educ. Ass'n v. Dep't of Ret. Sys." on Justia Law
Campbell v. Dep’t of Emp’t Sec.
Robert Campbell quit his job as a school teacher in anticipation of accompanying his wife to Finland on her Fulbright grant. Campbell applied for unemployment benefits for the months between his resignation in June 2010 and his family's planned departure in February 2011. His request was denied because the Department of Employment Security determined that Campbell did not qualify for benefits as claimed under RCW 50.20.050(2)(b)(iii), known as the "quit to follow" provision. On appeal, the superior court reversed, but the Court of Appeals reinstated the agency action. The Supreme Court affirmed the Court of Appeals and held that Campbell's resignation from his job seven months before the planned relocation was not reasonable as contemplated by the statute. View "Campbell v. Dep't of Emp't Sec." on Justia Law
Dolan v. King County
King County sought ways to provide legal defense services to indigent criminal defendants. The County settled on a system of using nonprofit corporations to provide services funded through and monitored by the County's Office of the Public Defender (OPD). Over time, the County took steps to improve and make these nonprofit organizations more accountable to the County. In so doing, it asserted more control over the groups that provided defender services. Respondents are employees of the defender organizations who sued the County for state employee benefits. They argued the County's funding and control over their "independent" organizations essentially made them state employees for the purposes of participating in the Public Employees Retirement System (PERS). Applying the pertinent statues and common law principles, the Supreme Court agreed that employees of the defender organizations are "employees" under state law, and, as such, are entitled to be enrolled in the PERS. View "Dolan v. King County" on Justia Law
Samantha A. v. Dep’t of Soc. & Health Servs.
Samantha A. is a 15-year-old with a wide range of medical maladies. Samantha is unable to perform a many activities necessary for independent living. The Department of Social and Health Services (DSHS) determined that Samantha is eligible for 24-hour institutional care because of the extreme nature of her needs. Because Samantha is cared for by a single mother, Samantha qualified for the Medicaid Home and Community Based Waiver Program so that she can receive benefits at home and not be institutionalized. As part of the in-home benefits, Samantha receives Medicaid Personal Care (MPC). DSHS assessed Samantha as needing 90 hours of MPC per month. In 2005, DSHS adopted changes to its assessment formula pertaining to MPC. Under the new rules, Samantha's MPC hours were reduced. Samantha petitioned the Superior Court for review of the DSHS reassessment. The court invalidated some of the DSHS rule changes. DSHS appealed to the Supreme Court, arguing that the rule changes were valid. The Supreme Court agreed with the lower court, finding the rule changes invalid under the Medicaid laws. The Court affirmed the superior court's decision.