Justia Washington Supreme Court Opinion Summaries

The issue before the Supreme Court in this case was whether particular officers and employees of a bank owed a quasi-fiduciary duty to particular bank depositors. Michael and Theresa Annechino deposited a large amount of money at a bank specifically to ensure that their savings would be protected by the Federal Deposit Insurance Corporation (FDIC). The Annechinos relied on bank employees’ recommendations of how to structure their accounts to meet FDIC coverage rules. Unfortunately, the bank went into receivership, and the FDIC found that nearly $500,000 of the Annechinos’ deposits were not insured. The Annechinos alleged that individual officers and employees of the bank owed them a duty, the breach of which resulted in their loss. The trial court granted summary judgment in favor of the individual defendants, and the Court of Appeals affirmed. Upon review, the Supreme Court affirmed the Court of Appeals. The officers and employees of the bank did not owe the Annechinos a quasi-fiduciary duty. Holding the officers and employees personally liable under these facts would have contravened established law regarding liability for acts committed on behalf of a corporation or principal. View "Annechino v. Worthy" on Justia Law

An employee of a church who claimed she was harmed by actions of a church's minister brought numerous claims against the church and the minister. At this point in the proceedings, the case involved her negligent retention, negligent supervision, and Title VII sex discrimination claims against the church. The Court of Appeals, reversing the trial court's grant of partial summary judgment, ruled that these claims were not barred by the First Amendment to the United States Constitution as the trial court had determined. Upon review of the matter, the Supreme Court reversed the Court of Appeals and reinstated the trial court's grant of summary judgment on the negligent retention and supervision claims. "Under the First Amendment, allowing these claims to go forward would violate the First Amendment right of the church to select and supervise its ministers as well as the First Amendment right of a hierarchical religious organization to be free of government involvement in the decisions made by its ecclesiastical tribunals. We remand the Title VII claims for further proceedings." View "Erdman v. Chapel Hill Presbyterian Church" on Justia Law

The Automotive United Trades Organization (AUTO) and Tower Energy Group (Tower) brought an as-applied state constitutional challenge to a tax based on the possession of petroleum as a hazardous substance. AUTO and Tower claimed that the hazardous substances tax (HST) violated article II, section 40 of the state constitution because the revenue from motor vehicle fuel was not being "placed in a special fund to be used exclusively for highway purposes." The trial court held on summary judgment that AUTO's claim was barred because it was not filed within a reasonable time under the Uniform Declaratory Judgments Act (UDJA) and that the HST does not violate article II, section 40. Upon review, the Supreme Court reversed in part and affirmed in part. The Court reversed the trial court in barring AUTO and Tower from bringing their constitutional challenge because to do so would deprive the Supreme Court of its vested power to determine the constitutionality of specific legislation. The Court affirmed the trial court, however, in granting summary judgment to the State because article II, section 40 provides that "this section shall not be construed to include revenue from general or special taxes or excises not levied primarily for highway purposes." View "Auto. United Trades Org. v. Washington" on Justia Law

Parties David Koenig and Thurston County sought review of a decision by the Court of Appeals which held that a special sex offender sentencing alternative (SSOSA) evaluation could be disclosed under the Public Records Act (PRA), but a victim impact statement could not. The Court of Appeals found that both the SSOSA evaluation and victim impact statement were investigative records. The court then determined the victim impact statement was exempt under the essential-to-effective-law enforcement prong of the investigative records exemption but concluded the SSOSA evaluation was not exempt. Upon review, the Supreme Court held that neither the SSOSA evaluation nor the victim impact statement are investigative records within the meaning of RCW 42.56.240. Accordingly, the Court reversed in part, affirmed in part and remanded the case for further proceedings. View "Koenig v. Thurston County" on Justia Law

Three certified questions came before the court from the Ninth Circuit Court of Appeals concerning application of the farm labor contractors act (FLCA), chapter 19.30 RCW. The primary question asked whether a trial court, if awarding statutory damages under the civil remedies provision of the FLCA must award $500 per plaintiff per violation. Upon review, the Washington Supreme Court answered in the affirmative. The second question asked whether requiring a trial court to award $500 per plaintiff per violation violated due process or public policy; the Court answered in the negative, expressly limiting its analysis and holding on this question to state due process principles and statutes. The third question asked whether the FLCA provided for awarding statutory damages to persons who have not been shown to have been aggrieved by a particular violation. "Because our standing jurisprudence tracks that of the United States Supreme Court, we leave to the Ninth Circuit to answer this question based on its standing jurisprudence and the standing jurisprudence of the Supreme Court." View "Perez-Farias v. Global Horizons, Inc." on Justia Law

Kevin Coe challenged a Court of Appeals decision that affirmed his 2008 commitment as a sexually violent predator (SVP). The trial court admitted evidence of several unadjudicated sexual offenses, and allowed an expert psychologist to rely on that evidence. In addition to these challenges, Coe claimed his trial counsel was ineffective, that his due process confrontation rights were violated, and that he was entitled to a new trial under the cumulative error doctrine. Finding no reversible error in any of Coe’s claims, the Supreme Court affirmed his commitment. View "In re Det. of Coe" on Justia Law

This interlocutory appeal concerned a discovery dispute involving birth injuries sustained by Jordan Gallinat at Southwest Washington Medical Center in Vancouver, Washington, in 1996. In June 2009, Douglas Fellows, as litigation guardian for Gallinat, filed a complaint alleging medical negligence and corporate negligence against Dr. Daniel Moynihan, Dr. Kathleen Hutchinson, and the Center. The trial court determined that the Center's credentialing, privileging, and personnel records for the doctors were protected from disclosure under the quality improvement privilege (RCW 70.41.200(3)). This case also implicated the applicability of the peer review privilege codified in RCW 4.24.250. After the Court of Appeals denied discretionary review, the Supreme Court court granted petition for review. Because the Court found that the trial court erred in concluding that no other information or records need be disclosed, it remanded the case for in camera review of the records sought by Fellows. View "Fellows v. Moynihan" on Justia Law

In a medical malpractice case, Louis Diaz sought a new trial because the trial court admitted evidence that he settled before trial with two of the defendants. Diaz contended that the trial court misapplied RCW 7.70.080 in ruling the evidence admissible. Upon review, the Supreme Court agreed, concluding that: (1) RCW 7.70.080 permitted only a settling health care provider, not the nonsettling defendants, to introduce evidence of the settlement; (2) to the extent it dealt with settlements, RCW 7.70.080 was superseded by subsequent statutes that treat settlements inconsistently with subsection .080; and (3) the trial court's reading of RCW 7.70.080 would have violated the separation of powers doctrine. However, having found error, the Supreme Court held that the error was harmless because no settlement evidence was admitted at trial, the issue was a minor feature of a fairly lengthy trial, and the court gave a curative instruction at Diaz's request, which was presumed the jury followed. View "Diaz v. Washington" on Justia Law

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

The Supreme Court granted Respondent Ryan Enquist's petition to review a decision of the Court of Appeals in which that court affirmed the trial court's award of costs and reasonable attorney's fees to Petitioner Jeffery Niccum at a trial de novo following mandatory arbitration. The Court of Appeals held that the trial court properly subtracted statutory costs and attorney fees from Niccum's offer of compromise before determining that Enquist failed to improve his position for purposes of MAR 7.3. Upon review, the Court determined the appellate court's conclusion was in error, and reversed. View "Niccum v. Enquist" on Justia Law