Justia Washington Supreme Court Opinion Summaries

The issue on appeal before the Supreme Court was whether RCW 4.16.160 bars a quiet title action where the claimant alleges he adversely possessed property belonging to a private individual before a municipality acquired record title to the land. James Gorman IV, as general partner of Hollywood Vineyards Limited Partnership, claimed title to certain real property through adverse possession. The property at issue was dedicated to the city of Woodinville by a private owner in December 2005 for a roadway improvement project. Gorman owned adjacent property. In 2007, Gorman filed an action to quiet title claiming he acquired the adjacent property through a 10-year period of adverse possession that transpired while the land was still in private hands. The City moved to dismiss arguing Gorman’s claim was prohibited by RCW 4.16.160. The trial court granted the City’s motion and dismissed Gorman’s claim. The Court of Appeals reversed. It held Gorman’s claim was not barred because it is alleged the statute of limitations ran while the subject land was privately owned. Upon review, the Supreme Court concluded that RCW 4.16.160 does not bar such quiet title actions, and affirmed the appellate court's decision. The case was remanded to the trial court to determine the validity of Gorman's claim of title. View "Gorman v. City of Woodinville" on Justia Law

This case concerned the dissolution of marriage and foreign travel restrictions imposed as part of a parenting plan under RCW 26.09.191(3). The restrictions were imposed by the trial court based on evidence that the father made threats to abscond with his children to India. The father denied making such threats and claimed the restrictions are not supported by the trial court’s findings. He further argued the court committed prejudicial error by allowing improper expert testimony regarding “risk factors” for child abduction. The Court of Appeals affirmed the trial court’s parenting plan and travel restrictions, concluding the admission of risk factor evidence was improper but not prejudicial. Upon review, the Supreme Court affirmed the Court of Appeals except for its conclusion that the trial court erred by admitting the expert testimony. The Court upheld the travel restrictions because the trial court’s findings were supported by substantial evidence and admission of the expert testimony was not an abuse of discretion. View "In re Marriage of Katare" on Justia Law

Defendant Kenneth Lamb was charged with, among other things, 10 counts of unlawful possession of a firearm. The State alleged that Lamb was precluded from possessing firearms because of his 1991 juvenile adjudication for second degree burglary. Defendant moved to withdraw his 1991 plea of guilty and vacate the juvenile adjudication. The trial court granted his motion. The trial court also denied the State’s motion to amend the information to instead rely on another juvenile adjudication and, ultimately, dismissed the 10 unlawful possession of a firearm counts. The State appealed and the Court of Appeals reversed all three of the trial court’s rulings. The issue before the Supreme Court was the trial court's exercise of discretion in vacating judgments, in disallowing the State to amend an information in a criminal case, and in dismissing counts of an information. Upon review, the Court affirmed in part, and reversed in part, holding that in this case the trial court abused its discretion when it vacated Defendant's juvenile adjudication for second degree burglary and dismissed the 10 unlawful possession of a firearm counts against him. On these two issues, the Court affirmed the Court of Appeals. The Court reversed the Court of Appeals with respect to the trial court’s refusal to permit the State to amend the information and held that the trial court did not abuse its discretion. The case was remanded to the trial court for further proceedings. View "Washington v. Lamb" on Justia Law

Plaintiff Leo Macias worked as a tool keeper in a shipyard and his job required that he maintain respirators that other workers wore to filter out dangerous contaminants. Plaintiff and his wife Patricia brought this suit against the respirator manufacturers, alleging that cleaning and maintaining the respirators exposed Mr. Macias to asbestos, causing him to develop mesothelioma. The plaintiffs claimed that the manufacturers owed a duty to warn Mr. Macias of the danger that he could be exposed to harmful asbestos dust when he cleaned and maintained the respirators. The respirator manufacturers moved for summary judgment on the ground that as a matter of law they owed no duty to warn. The trial court denied the motion. The Court of Appeals reversed, holding that under Washington case law the defendants did not owe a duty to warn because they did not manufacture the asbestos-containing products that were the source of the asbestos to which Mr. Macias was exposed. Upon review, the Supreme Court reversed the Court of Appeals. In the two precedential cases, the Court held that generally a manufacturer does not have a duty to warn of the dangers inherent in a product that it does not manufacture, sell, or supply. However, "Simonetta" and "Braaten" did not control in this case because the duty at issue was to warn of the danger of asbestos exposure inherent in the use and maintenance of the defendant manufacturers’ own products- - the respirators. View "Macias v. Saberhagen Holdings, Inc." on Justia Law

David Ward and Michael Whittaker were commissioners for the Jefferson County Fire Protection No. 2 (the District). Two citizens of the District, Harry Goodrich and Linda Saunders (the petitioners), initiated a recall proceeding against Ward and Whittaker, alleging various counts of misfeasance. The issue before the Supreme Court was whether the recall petition should advance to the signature-gathering phase of the recall process. Upon review, the Supreme Court affirmed the trial court and held that one of the four charges against Ward and Whittaker may advance to the next phase of the recall process. View "In re Recall of Ward" on Justia Law

Rogelio and Elaine Ruvalcaba brought suit to condemn an easement across neighboring property held by individual landowners, referred to collectively as the "Day Group Petitioners." The Ruvalcabas argued that they were entitled to an easement because their property is landlocked and contended that there is an overriding public policy against rendering landlocked property useless. The Day Group Petitioners contended that the Ruvalcabas voluntarily landlocked their property through severance of the parcel and failed to bring a condemnation action for 35 years. The trial court granted summary judgment to the Day Group Petitioners and dismissed. The Court of Appeals reversed. Upon review, the Supreme Court reversed the Court of Appeals and affirmed the trial court’s order granting summary judgment to the Day Group Petitioners. View "Ruvalcaba v. Baek" on Justia Law

Petitioner Douglas Rose challenged his convictions for unlawful possession of a stolen access device and for unlawful possession of a controlled substance. The issue before the Supreme Court was whether the credit card Petitioner possessed was an "access device" under Washington law. Further, the Court was presented with the issue of whether Petitioner's arrest, which lead to the search of his bag and discovery of the evidence eventually presented against him, was supported by probable cause. Under the facts of this case, the Supreme Court concluded that the State did not meet its burden to show that the card in question was an "access device." The Court reversed on that issue, but affirmed Petitioner's arrest on all other grounds. View "Washington v. Rose" on Justia Law

Defendant-Appellant Jamar Meneese appealed his conviction for unlawfully carrying a dangerous weapon on school grounds and for possessing a controlled substance. He claimed the weapon, an air pistol, was seized in an unlawful search at school and should have been suppressed at trial. The question on appeal was whether the school search exception to the warrant requirement applied to the search conducted by the school resource officer (SRO). The parties disputed whether the SRO was acting as a school official or a law enforcement officer at the time of the search. Upon review, the Supreme Court found that the SRO is a fully commissioned, uniformed, law enforcement officer employed by the Bellevue Police Department. He arrested and handcuffed Defendant before searching his backpack. Moreover, after arresting Defendant, the focus of the investigation was no longer on informal school discipline (an underlying purpose behind the school search exception.) Accordingly, the Court concluded the school search exception did not apply, a warrant supported by probable cause was required, and the weapon should have been suppressed. View "Washington v. Meneese" on Justia Law

This case concerned the classification of workers as employees or independent contractors for purposes of the Washington Minimum Wage Act (MWA). A class of 320 former and current FedEx Ground Package System, Inc. (FedEx) delivery drivers (hereinafter Anfinson) filed suit seeking overtime wages under the MWA and reimbursement for uniform expenses under the industrial welfare act (IWA). The dispute with respect to both claims was whether the drivers were employees or independent contractors. The parties disagreed on the correct test to distinguish these categories under the MWA; FedEx argued that the common law right-to-control standard governs while Anfinson contended that the federal Fair Labor Standards Act of 1938 (FLSA) economic-dependence test controls. The trial court gave the jury a hybrid instruction, focusing the inquiry on FedEx's right to control in light of the economic-dependence factors. The jury determined that the drivers were independent contractors. Anfinson appealed, contending, among other things, that the jury instructions misinformed the jury about the standards for determining worker status and about the requirement that class status and evidence be "common to the class members." The Court of Appeals held that the jury instruction defining the standard for determining worker status was erroneous and prejudicial and reversed. The Court of Appeals further held that the jury instruction on the burden of proof was erroneous because it misled the jury and was prejudicial. Upon review, the Supreme Court affirmed the Court of Appeals in both respects. View "Anfinson v. FedEx Ground Package Sys., Inc." on Justia Law

William Adam Gray shot Vita M. Moimoi and Sanelive S. Hikila at close range. Moimoi suffered a serious leg wound and Hikila bled to death. Although Gray fled the scene, he was soon identified and charged with second degree felony murder, first degree assault, and unlawful possession of a firearm. Gray remained at large for almost two years before being arrested. Gray pled guilty to first degree manslaughter and second degree assault. At a sentencing hearing, the State requested restitution in an amount to be determined after the victim's assistance unit (VAU) had computed the appropriate amount. The court agreed, and Gray waived his right to be present at any future hearing. At issue in this case was whether RCW 9.94A.753(4) permitted a court to modify a restitution order more than 180 days after sentencing to include expenses that were incurred before the trial court issued its original restitution order. Upon review, the Supreme Court held that the plain language of RCW 9.94A.753(4) clearly authorizes courts to make such modifications. View "Washington v. Gray" on Justia Law