Justia Washington Supreme Court Opinion Summaries

In 1997, Cecil Davis raped, robbed, and murdered 65-year-old Yoshiko Couch. A jury found him guilty of aggravated first degree murder and unanimously agreed that no mitigating factors warranted leniency, and was sentenced to death. On direct appeal, the Supreme Court upheld the conviction and sentence. The Court later granted Davis's personal restraint petition (PRP) and reversed his sentence because jurors had seen him in shackles. At the new penalty proceeding, the jury found no mitigating factors warranting leniency and Davis was again sentenced to death. This appeal followed. Finding no reversible error in Davis's second penalty proceeding, the Supreme Court again affirmed Davis's death sentence. View "Washington v. Davis" 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

This case centered on whether the recreational use immunity statute, RCW 4.24.200-.210, applied under the circumstances where a landowner, who otherwise operates an admission fee-based camp, allows a group access for no charge. During the group’s stay at the camp, plaintiff was injured when riding a slide on the property. The camp asserted recreational use immunity as a defense to the claim. On summary judgment, the trial court ruled that the camp was not immune from liability under the statute because it normally charged fees for the recreational use. This interlocutory appeal was certified after the trial court found there was likely a substantial ground for difference of opinion. Upon review, the Supreme Court affirmed and held that recreational use immunity is not available under these circumstances because the property was not open to the general public. View "Cregan v. Fourth Mem'l Church" on Justia Law

Petitioner Charles Weber filed an untimely PRP asserting that he received ineffective assistance of counsel when his attorney failed to conduct a reasonable investigation of the case and failed to explore the possibility that he had been misidentified as the perpetrator. Petitioner sought to avoid the procedural time bar by arguing that the actual innocence doctrine, recognized by this court in "In re Personal Restraint of Carter, (263 P.3d 1241 (2011)), be applied to allow review of his constitutional claim. Petitioner supported his innocence claim with new evidence in the form of declarations. Upon review, the Supreme Court concluded that Petitioner's new evidence was insufficient to show he was factually innocent. Accordingly, the Court dismissed his PRP. View "In re Pers. Restraint of Weber" 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

Richard J. Dyer was a convicted rapist who denied his guilt and was therefore ineligible for sex offender treatment. He was serving a maximum term of life in prison. Though Dyer had a history of good behavior while in prison, the Indeterminate Sentence Review Board (ISRB) found Dyer unparolable for the sixth time and extended his minimum term another 60 months. In doing so, the ISRB considered Dyer's lack of sex offender treatment, along with additional evidence, and concluded he was not completely rehabilitated. Dyer filed a personal restraint petition (PRP) directly with this court, claiming the ISRB abused its discretion. Upon review, the Supreme Court affirmed the ISRB's decision. View "In re Pers. Restraint of Dyer" on Justia Law

Petitioners Ronnie Jackson Jr. and Salvador Rivera filed personal restraint petitions to challenge the firearm enhancements they received as part of their sentences, which became final in 2002. In response, the issue before the Supreme Court was whether rules it announced in "Washington v. Recuenco," (110 P.3d 188 (2005) (Recuenco I)) and "Washington v. Recuenco," (180 P.3d 1276 (2008) (Recuenco III)) applied retroactively. The rules in question were: (1) that a firearm enhancement cannot be based on a jury's general "deadly weapon" finding; and (2) that an information must particularly identify any firearm enhancements sought by the State in order to authorize such enhancements at sentencing. "In other words, [the Court] must decide if it [was] too late to challenge enhancements imposed before the Recuenco I and Recuenco III decisions." Upon review, the Court found that Recuenco I and Recuenco III were not retroactive as to either issue and held that Rivera and Jackson were not entitled to any relief on collateral review. View "In re Pers. Restraint of Jackson" on Justia Law

"A trial court must have authority to manage the parties and proceedings before it." The State argued the trial court in this case erroneously imposed sanctions in a criminal prosecution without explicitly finding bad faith. "While a finding of bad faith is the preferred basis for imposing sanctions in a criminal case, [the Supreme Court] will uphold sanctions if [it] can infer bad faith from the record . . . The trial court in this case did not make a finding of bad faith and, given concessions at oral argument, the record did not support sanctions. The Court therefore reversed. View "Washington v. Gassman" 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 Federal District Court for the Western District of Washington has asked the Washington Supreme Court to answer three certified questions relating to two home foreclosures pending in King County. In both cases, the Mortgage Electronic Registration System Inc. (MERS), in its role as the beneficiary of the deed of trust, was informed by the loan servicers that the homeowners were delinquent on their mortgages. MERS then appointed trustees who initiated foreclosure proceedings. The primary issue was whether MERS was a lawful beneficiary with the power to appoint trustees within the deed of trust act if it did not hold the promissory notes secured by the deeds of trust. A plain reading of the applicable statute leads the Supreme Court to conclude that only the actual holder of the promissory note or other instrument evidencing the obligation may be a beneficiary with the power to appoint a trustee to proceed with a nonjudicial foreclosure on real property. "Simply put, if MERS does not hold the note, it is not a lawful beneficiary." The Court was unable to determine the "legal effect" of MERS not being a lawful beneficiary based on the record underlying these cases. Furthermore, the Court was asked to determine if a homeowner had a Consumer Protection Act (CPA), chapter 19.86 RCW, claim based upon MERS representing that it was a beneficiary. The Court concluded that a homeowner may, "but it would turn on the specific facts of each case." View "Bain v. Mortg. Elec. Registration Sys." on Justia Law