Justia Washington Supreme Court Opinion Summaries

King County Ordinance 19030 altered zoning and business licensing regulations for wineries, breweries, and distilleries (WBDs) in agricultural and rural areas. The ordinance aimed to support economic development but faced challenges regarding compliance with the Growth Management Act (GMA) and the State Environmental Policy Act (SEPA). The ordinance allowed for expanded WBD operations and introduced new licensing requirements, but it also raised concerns about environmental impacts and the preservation of agricultural land.The Central Puget Sound Growth Management Hearings Board found that the County failed to comply with SEPA and the GMA, invalidating parts of the ordinance. The Board's decision was appealed to the Court of Appeals, which reversed the Board's ruling. Friends of Sammamish Valley and Futurewise sought further review, arguing that the County did not adequately address environmental impacts and agricultural land preservation. The County contended that the ordinance was a "nonproject action" not requiring environmental review under SEPA and presumed valid under the GMA.The Supreme Court of Washington reviewed the case and reversed the Court of Appeals' decision, reinstating the Board's order. The Court held that the County's SEPA checklist was insufficient, failing to address the full range of probable environmental impacts. The Court emphasized that the GMA requires the conservation of agricultural land and that the ordinance's changes could significantly impact the environment. The Court concluded that the County must conduct a comprehensive environmental review to comply with SEPA and the GMA. View "King County v. Friends of Sammamish Valley" on Justia Law

The City of Sammamish passed an ordinance to condemn property rights in George Davis Creek, which runs through the petitioners' property, for stormwater management and fish passage protection. The city aimed to address storm drainage issues, improve traffic safety, provide flood protection, and remove barriers to fish passage. The petitioners argued that the city lacked authority to condemn their property for fish passage purposes, citing the salmon recovery act (SRA) and a previous case, Cowlitz County v. Martin.The Superior Court denied the city's motion for condemnation, agreeing with the petitioners that the city had no authority to condemn private property for fish passage purposes. The city appealed, and the Court of Appeals reversed the decision, holding that the city had statutory authority under RCW 8.12.030 to condemn property for stormwater management. The court distinguished this case from Cowlitz County, noting that the project in question had multiple purposes, including stormwater management, which is explicitly authorized by the statute.The Supreme Court of the State of Washington reviewed the case to determine the scope of the city's statutory condemnation authority. The court held that RCW 8.12.030 grants cities the authority to condemn property for stormwater management and other public uses. The inclusion of fish passage as one of the project's purposes did not divest the city of its authority to condemn property for stormwater management. The court affirmed the Court of Appeals' decision and remanded the case to the trial court for further proceedings. View "City of Sammamish v. Titcomb" on Justia Law

The Washington State Attorney General filed a lawsuit against the city of Sunnyside and several of its officials, alleging that the city's crime-free rental housing program (CFRHP) was being used to evict tenants without due process and that these evictions disproportionately impacted Latinx renters, women-headed households, and families with minor children. The city argued that the Attorney General lacked the authority to bring this suit, as the scope of the Attorney General's authority under RCW 43.10.030(1) limits their ability to act to matters that impact more people than those affected by the CFRHP. The trial court granted summary judgment in favor of the defendants.On appeal, the Supreme Court of Washington reversed and remanded the case. The court held that the Attorney General did have the authority to bring the suit, as the case involved matters of public concern in which the state had an interest. The court also found that there were genuine disputes of material fact regarding whether the city's enforcement of the CFRHP had a disparate impact on protected classes, and whether the individual respondents were entitled to qualified immunity. However, the court affirmed the trial court's grant of summary judgment on the Attorney General's claims under the Residential Landlord-Tenant Act, finding that the respondents were not landlords and therefore the Act did not apply to them. View "State v. City of Sunnyside" on Justia Law

The case revolves around the Benton County Water Conservancy Board (the Board) and the Washington State Department of Ecology (the Department). The Department primarily manages the state's water resources, while the Board has coextensive authority to process voluntary water right transfers between water right holders. The dispute arose when the Board challenged a department policy (Policy 1070) concerning certain water right transfers. The Board claimed that it suffered injury-in-fact from the Department's refusal to accept certain administrative division forms pursuant to the policy.The case was first heard in the superior court, which granted summary judgment to the Board and directed the Department to accept administrative division requests from the Board. The Department appealed, and the Court of Appeals reversed the decision, holding that the Board lacked standing to challenge the Department's action.The Supreme Court of the State of Washington affirmed the decision of the Court of Appeals. The court held that the Board lacked standing to challenge Department Policy 1070. The Board failed to demonstrate how it suffered injury-in-fact from the Department’s refusal to accept certain administrative division forms pursuant to the policy. The Board suffered no prejudice and its interests would not be redressed by invalidating the policy. The court concluded that the Board's interests were indirect and inchoate, and it failed to establish injury-in-fact under the Administrative Procedure Act. Therefore, the Board lacked standing to pursue this challenge to the Department’s use of Policy 1070. View "Benton County Water Conservancy Board v. Department of Ecology" on Justia Law

The case involves AURC III LLC, an Oregon limited liability company, and several Washington and Delaware limited liability companies collectively referred to as Point Ruston. Point Ruston purchased a 97-acre former copper smelter and environmental clean-up site located on the Puget Sound waterfront in Ruston and Tacoma, Washington, for $169,000,000 and developed it in phases. To fund the second phase of development, Point Ruston negotiated a $66 million loan from American United Development Group, which created AURC III LLC to raise and manage funds from foreign investors seeking United States residency. After disbursing the full amount of the loan, AURC filed an amended complaint against Point Ruston, alleging that Point Ruston was delinquent on interest payments in breach of its loan agreement. The superior court ordered Point Ruston and AURC to engage in arbitration as per their loan agreement.The arbitrator issued an interim award only on the amount of current and default interest due and awarded $10,969,015 to AURC. The arbitrator then issued a final award for the same amount, as well as awarding attorney fees and arbitration fees and expenses. In total, Point Ruston was required to pay over $11.4 million. AURC moved to confirm the award and for presentation of judgment. Initially, Point Ruston agreed AURC was “entitled to confirmation of the Award and entry of a Final Judgment” but opposed attaching the arbitrator’s awards to that judgment. Before the court could enter the written confirmation order and judgment, Point Ruston paid the award and filed a motion to dismiss the case as moot because no live dispute remained. After AURC alerted the court that it received the award amount from Point Ruston, the court denied the motion to dismiss. The court entered the confirmation order with the interim and final awards attached as exhibits, as well as a judgment against Point Ruston. AURC filed a full satisfaction of judgment.Point Ruston appealed on two grounds. It challenged (1) the superior court’s denial of the motion to dismiss and (2) the court’s decision to attach the arbitration awards to the confirmation order. Division Two of the Court of Appeals affirmed in an unpublished opinion. Point Ruston sought review in the Supreme Court of the State of Washington, which was granted.The Supreme Court of the State of Washington held that when a party seeks a confirmation order, RCW 7.04A.220 requires issuance of the order subject to narrow exceptions inapplicable here. Payment of an arbitration award does not render the underlying case moot. The court also held that attaching an arbitrator’s award merely identifies the basis for the confirmation order. Accordingly, the court affirmed the Court of Appeals. View "AURC III, LLC v. Point Ruston Phase II, LLC" on Justia Law

A dispute arose between the Gardens Condominium (a Washington nonprofit corporation) and Farmers Insurance Exchange (a California company) over the interpretation of a resulting loss exception in an all-risk insurance policy. The Gardens Condominium discovered water damage to the roof's fireboard, sheathing, and several sleepers and joists in 2019, caused by faulty construction which led to insufficient ventilation in the roof assembly. They sought coverage for the cost of repairing the damage, which was denied by Farmers Insurance Exchange, who argued that the damage was excluded under the faulty workmanship exclusion in the policy.The trial court ruled in favor of Farmers Insurance Exchange, stating that the policy intended to exclude damage where an uncovered event, such as faulty workmanship, initiated a sequence of events causing damage. The Court of Appeals disagreed, finding that the resulting loss exception preserved coverage.The case reached the Supreme Court of the State of Washington. The court, following a de novo review, sided with the Court of Appeals, stating that a resulting loss exception must have effect to preserve coverage for loss resulting from covered perils, even if the peril is the natural consequence of an excluded peril. The court concluded that a resulting loss exception to the faulty workmanship exclusion revives coverage, even if the faulty workmanship exclusion would otherwise deny it. The case was remanded to the trial court for further proceedings consistent with the Supreme Court's opinion. View "Gardens Condominium v. Farmers Insurance Exchange" on Justia Law

In this case from the Supreme Court of the State of Washington, several construction industry associations challenged a 2018 law (RCW 39.12.015(3)) that changed the method for determining prevailing wage rates on public works projects. Prior to the law, the State used wage and hour surveys to establish the prevailing wage rates. The 2018 law directed the State to adopt the wage rates established in collective bargaining agreements (CBAs) for those trades and occupations that have CBAs.The plaintiffs argued that the new law violated a provision of the Washington Constitution (article II, section 37) because it conflicted with an older law (RCW 39.12.026(1)) that restricted the use of wage data collected by the State to the county in which the work was performed. The Court of Appeals agreed and declared the new law unconstitutional.The Supreme Court of the State of Washington reversed the Court of Appeals' decision. It held that the older law's restriction on the use of wage data applied only to data collected through wage and hour surveys, not to wage rates adopted from CBAs. Therefore, the older law did not conflict with the new law, and the new law did not violate the state constitution. The court remanded the case for further proceedings consistent with its opinion. View "Associated General Contractors Of Washington v. State" on Justia Law

In "King County v. Michael J. Abernathy et al.", the Supreme Court of the State of Washington answered a question certified by the United States District Court for the Western District of Washington. The case involved a dispute over the ownership of a 3.6 mile section of land along the shore of Lake Sammamish, known as the Corridor. In 1887, prior to Washington becoming a state, a railroad company was granted a "right-of-way" to build a railroad over the Corridor. Since then, the Corridor and surrounding shorelands have been used by various parties including individual property owners, the state, and the county. The certified question asked whether a right-of-way approved by the United States Department of the Interior under the General Railroad Right-of-Way Act of 1875 is a conveyance "patented by the United States" under Article XVII, Section 2 of the Washington State Constitution. If the land was "patented" by the federal government, it would have been owned by the railroad and later King County. If the land was not patented, Washington would have owned it at the time of statehood and later conveyed it to private parties, and the shoreland would currently belong to the homeowners, the Abernathys. The Washington Supreme Court held that the right-of-way was an easement and did not constitute a land conveyance patented by the United States. Therefore, the land belonged to Washington at the time of statehood and is presently owned by the homeowners. View "King County v. Abernathy" on Justia Law

In Washington State, a second-tier subcontractor, Velazquez Framing LLC, was not paid for the work it did on property owned by Cascadia Homes Inc., a general contracting company. High End Construction LLC, who had been contracted by Cascadia, subcontracted the work to Velazquez without informing Cascadia. After completing the work, Velazquez filed a lien for labor and materials without giving prelien notice, which resulted in a dispute over whether prelien notice was required for labor liens under Chapter 60.04 of the Revised Code of Washington (RCW). The Supreme Court of the State of Washington ruled that, based on the plain language of the relevant statutes and legislative history, prelien notice is not required for labor liens. The court noted that while Velazquez could not lien for its materials and equipment without providing prelien notice, it could lien for its labor. The case was remanded to the trial court to determine the value of the labor performed. The court's decision reversed the rulings of the Court of Appeals and the trial court, both of which had concluded that prelien notice was required. View "Velazquez Framing, LLC v. Cascadia Homes, Inc." on Justia Law

In Washington, a couple, the Lewises, moved into a rental property owned by another couple, the Ridgways. After the Lewises moved out, a dispute arose over the return of their security deposit. The Ridgways claimed the Lewises caused damage to the property and deducted repair costs from the deposit. The Lewises disputed these charges, and the case was sent to arbitration. During arbitration, the Lewises were awarded the full amount of their security deposit, but the Ridgways were given attorney fees under the small claims statute. The Lewises attempted to appeal the arbitration award and a pre-arbitration order granting partial summary judgment to the Ridgways. However, the Lewises did not personally sign their request for a trial de novo, a requirement under court rules and the arbitration statute.The Washington Supreme Court held that the Lewises' request for a trial de novo was ineffective because they did not personally sign the request, as required by the court rule and the arbitration statute. The court also held that, absent a valid request for a trial de novo, the Lewises could not appeal the pre-arbitration order granting partial summary judgment to the Ridgways. The court further stated that the question of who should be considered the prevailing party for the purpose of any attorney fee award needed further consideration, and remanded the case back to the lower court for determination of attorney fees. View "Crossroads Mgmt., LLC v. Ridgway" on Justia Law