Justia Washington Supreme Court Opinion Summaries

The primary issue presented in this case was whether former RCW 9.92.151 (2004) or the equal protection clause of the United States Constitution requires a county jail to provide opportunities for an inmate who is yet to be sentenced to earn credit toward early release, also known as "good-time" credit. Petitioner, Teddy Talley argued that the Skamania County Jail and the Department of Corrections (Department) violated the former RCW 9.92.151(1) and the Constitution by not providing opportunities for him to earn good-time credit before his criminal conviction. Skamania County argued that the statutory issue was not properly before the Supreme Court and that its program for earning good-time credit is constitutional. The Department argued that it may rely on a county’s jail-time certification when determining the appropriate amount of good-time credit to apply toward early release. Upon review, the Supreme Court held that the matter was properly before it, and that the former RCW 9.92.151 required a county jail to provide opportunities for a presentence inmate to earn good-time credit. The Court did not reach Defendant's constitutional argument. Because the Skamania County Jail policy conflicted with the former RCW 9.92.151, the Court calculated that Defendant should have received an earned early-release credit at the statutory maximum rate of 15 percent. View "In re Pers. Restraint of Talley" on Justia Law

Defendants John Gordon and Charles Bukovsky were each charged with second-degree murder in the beating death of Brian Lewis. The State also sought two aggravating sentencing factors: deliberate cruelty and particular vulnerability of the victim. The jury was instructed to determine whether the aggravators were present, but the instructions did not define "deliberate cruelty" or "particular vulnerability." Defendants did not object to the instructions on that basis. The jury found the defendants guilty and also found the aggravators applied. The trial court imposed exceptional sentences. The issue on appeal to the Supreme Court was whether the failure to provide detailed instructions defining the meaning of "deliberate cruelty" or "particular vulnerability" was a manifest error of constitutional magnitude that could be addressed for the first time on appeal. The Court held that it is not and therefore reversed the Court of Appeals. View "Washington v. Gordon" on Justia Law

RCW 60.04.091(2) requires mechanics' liens to be "acknowledged pursuant to chapter 64.08 RCW." In other words, an authorized person must certify in writing that the signor executed the lien freely and voluntarily. RCW 60.04.091(2) also includes a sample claim of lien that the statute states "shall be sufficient" but that does not include language satisfying the acknowledgment requirement. Contractors Athletic Fields Inc. and Hos Bros.Construction Inc. each filed claims of lien that used the sample form and did not contain certificates of acknowledgment. In each case, the lower court concluded the lien was invalid. Upon review, the Supreme Court disagreed with the trial courts and held that a claim of lien in the sample form is valid despite the absence of a proper acknowledgment. View "Williams v. Athletic Field, Inc." on Justia Law

The trial court in this case ruled that under the Washington courts' application of "Frye v. United States," there must be general acceptance in the relevant scientific community that a particular type of in utero toxic exposure can cause a particular type of birth defect before expert testimony on causation is admissible. Plaintiff Julie Anderson worked for Akzo Nobel Coatings, Inc., from 1998 until she filed a safety complaint with the Washington State Department of Labor and Industries (L&I) and was fired. While it was not officially part of her job, Plaintiff regularly mixed paint. Employees were required by official company policy to wear respirators when mixing paint, but there was reason to believe that the policy was not rigorously enforced and may have been actively undermined by management. Plaintiff gave birth to a son in January 2000. By 2003, it was clear the child suffered from "medical abnormalities." He was diagnosed with a neuronal migration defect, congenital hemiplegia, microcephalus, and a multicystic dysplastic kidney, among other things, along with "delays in motor, communication, cognitive, and adaptive behavior." Upon review of the trial record, the Supreme Court disagreed with the trial court's interpretation and subsequent ruling on the issue. The Court held that the Frye test is not implicated if the theory and the methodology relied upon and used by the expert to reach an opinion on causation is generally accepted by the relevant scientific community. The Court affirmed the trial court's rulings on comparative fault and wrongful discharge. The case was remanded back to the trial court for further proceedings. View "Anderson v. Akzo Nobel Coatings, Inc." on Justia Law

The issue central to this case involved a trial court's method of valuing stock options in a dissolution proceeding. After separating, Daniel and Teresa Farmer entered into a stipulated agreement dividing their community assets, including several thousand stock options Daniel had received from his employer during the marriage. Under the terms of the agreement, Teresa could decide when to exercise her share of the stock options. Before entry of the decree of dissolution, however, Daniel fraudulently exercised all of the options. The trial court was unaware of this when it awarded Teresa half of the community stock options in the final decree. When the facts came to light, Teresa moved for relief from the dissolution decree by asking the court to invoke its equitable authority to award her damages for her loss. The court assessed damages based on the present value of the stock options as calculated by Teresa's expert witness. The Court of Appeals affirmed, deferring to the trial court's equitable discretion to make Teresa whole. Upon review, the Supreme Court affirmed the Court of Appeals finding that the trial court did not abuse its discretion in calculating damages to Teresa. View "In re Marriage of Farmer" on Justia Law

The attorney general of Washington made the State a plaintiff in a multistate lawsuit in federal court challenging the constitutionality of the health care reform legislation recently passed by Congress. The city of Seattle sought a writ of mandamus directing the attorney general to withdraw the State of Washington from the litigation. Upon review of the applicable statutory authority, the Supreme Court held that a writ of mandamus was not available because the attorney general had no clear duty to withdraw the State of Washington from the federal litigation: "[s]tatutory authority vests the attorney general with the discretionary authority to participate in the litigation at issue. [The Court] also determine[d], however, that this result is not constitutionally compelled; the Washington Constitution does not vest the attorney general with any common law authority. It is for the people of the state of Washington, through their elected representatives or through the initiative process, to define the role of the attorney general." View "City of Seattle v. McKenna" on Justia Law

On certification from the U.S. District Court for the Eastern District of Washington, the Supreme Court considered whether the Washington Industrial Safety and Health Act of 1973 (WISHA), and Washington’s laws prohibiting driving while under the influence (DUI) are inadequate to promote the public policies underlying them. Plaintiff Matthew Cudney, whose employment was terminated by ALSCO Inc., asserted a claim in federal court for wrongful discharge in violation of public policy. Plaintiff alleged that he was terminated in retaliation for reporting that a managerial employee drove a company vehicle during business hours while that employee was intoxicated. The issues presented for certification pertained to (1) whether WISHA adequately promotes the public policy of insuring workplace safety and protecting workers who report safety violations so as to preclude a separate claim by a terminated employee for wrongful discharge in violation of public policy; and (2) whether the DUI laws adequately promote the public policy of protecting the public from drunken drivers so as to preclude a separate claim by a terminated employee for wrongful discharge in violation of public policy. In response, the Court held that both WISHA and the state’s DUI laws adequately promote the stated public policies. View "Cudney v. Alsco, Inc." on Justia Law

Commissioner of Public Lands Peter Goldmark sought a writ of mandamus to compel Attorney General Robert McKenna to pursue an appeal of a trial court decision in a condemnation action. Although Mr. McKenna provided representation at the trial court, he refused to pursue the appeal based on his evaluation of the merits of the case. The commissioner wished to appeal, which he discussed with his general counsel, an assistant attorney general. Then the commissioner and the attorney general exchanged correspondence and met on at least one occasion, but the attorney general refused to file the appeal for the commissioner. The attorney general also refused to appoint a special assistant attorney general (SAAG) to pursue the appeal for the commissioner. Upon review, the Supreme Court found that the issue in this case was one of first impression: the Court had never been "squarely presented" with an instance of the attorney general refusing to represent a state officer on an appeal. "Under the statutes, the responsibility is clear." Because the Court found no discretion within the attorney general’s statutory duty, the Court issued the writ and directed the attorney general to provide the commissioner with legal representation. View "Goldmark v. McKenna" on Justia Law

The Supreme Court considered whether a tribal police officer who observed Defendant Loretta Lynn Eriksen commit a traffic infraction on the Lummi Reservation could validly stop her outside the reservation and detain her until county police arrived. The Court concluded that the tribe’s inherent sovereign powers did not authorize this extraterritorial stop and detention. "While the territorial limits on the Lummi Nation’s sovereignty create serious policy problems, such as the incentive for intoxicated drivers to race for the reservation border, the solution does not lie in judicial distortion of the doctrine of inherent sovereignty. Instead, these issues must be addressed by use of political and legislative tools, such as cross-deputization or mutual aid pacts, to ensure that all law enforcement officers have adequate authority to protect citizens’ health and safety in border areas. We urge the Lummi Nation and Whatcom County to work together to solve the problems made evident by this case; but if they can or will not do so, we will not manipulate the law to achieve a desirable policy result." Accordingly, the Court concluded the stop and detention of Defendant were invalid. The Court reversed the superior court’s decision and remand to the district court for further proceedings. View "Washington v. Eriksen" on Justia Law

Ten special education students and their parents and guardians (Appellants) sued Clover Park School District for intentional torts, outrage, negligence and unlawful discrimination under state law. Clover Park moved for summary judgment to dismiss, arguing that Appellants had not exhausted the administrative remedies available under the state Individuals with Disabilities Education Act (IDEA). The trial court granted Clover Park’s motion. Upon review, the Supreme Court reversed the trial court and remanded the case, holding that IDEA’s administrative exhaustion requirement does not apply to state-law claims nor does Washington State law require exhaustion before filing such claims. View "Dowler v. Clover Park Sch. Dist. No. 400" on Justia Law