Justia Washington Supreme Court Opinion Summaries

Defendant James Eserjose appealed his second-degree burglary conviction. In his appeal, Defendant argued that the confession he gave to a deputy sheriff was inadmissible at trial. The trial court determined that although deputies had probable cause to arrest Defendant and consent to enter the home where the arrest was made, they exceeded the scope of the consent when they entered an upstairs hallway and made the arrests. The trial court held that the arrest was unlawful. Nevertheless, the court determined that Defendant's confession was admissible and subsequently found him guilty of burglary. Upon review, the Supreme Court found that the trial court did not err in determining that Defendant's confession was admissible. Accordingly, the Court affirmed Defendant's conviction. View "Washington v. Eserjose" on Justia Law

In 2005, Petitioner Robert May violated a domestic violence protection order that prohibited him from contacting his ex-wife. As a result, Petitioner was convicted under a Seattle ordinance. On appeal, Petitioner contended that the order was invalid and that he received no notice that the "no-contact" provision of the order was a criminal offense. The superior court reversed the municipal court's conviction, but the Court of Appeals reversed the superior court to reinstate the conviction. The Supreme Court in its affirmation of the Court of Appeals concluded: "[Petitioner] made a choice to violate the plain and unambiguous terms of the domestic violence protection order . . . the collateral bar rule precludes [him from challenging] the validity of the domestic violence protection order." The Court found that the protection order itself was notice that he would be prosecuted if he violated its terms. View "City of Seattle v. May" on Justia Law

In 1994, Respondent Sylvia Smith began to experience pain in her wrists and swelling in her arms. She was prescribed splints to wear while working for Petitioner Crown, Cork & Seal as a "bagger." In 1997, Respondent sustained an injury at work when a forklift ran over and fractured her leg. In 2005, the Department of Labor & Industries (L&I) determined that because of the forklift accident Respondent was permanently and totally disabled. L&I ordered Crown to place Respondent on the pension rolls. L&I also issued an order that denied Crown "second injury fund" coverage. On Crown's appeal, the superior court reversed the L&I orders. The court concluded that Respondent's wrist injuries preexisted the forklift injury and as such did not constitute a "previous bodily disability." L&I appealed to the Court of Appeals, who reversed the superior court's ruling. The question before the Supreme Court was what constituted a "previous bodily disability" for second injury fund coverage. The Court responded by holding that a "previous bodily injury" under state law is one that "effectively impacts an employee's performance in the workplace or materially diminishes the employee's functional ability to perform the routine activities associated with daily living." The Court affirmed the Court of Appeal's holding in favor of Respondent. View "Crown, Cork & Seal v. Smith" on Justia Law

Petitioners Lisa Mullen and Kevin Dean were prosecuted for stealing funds from their employer, a Skagit County car dealership. At issue before the Supreme Court was the State's duty to disclose exculpating evidence to defendants. After their convictions, Petitioners obtained a previously sealed deposition of the dealership's accountant taken in a separate civil suit between the owner and the accountant's firm. The deposition took place before the end of the criminal trial. In a motion for a new trial, Petitioners argued that the accountant's deposition testimony supported the defense theory that the owner authorized use of the funds. Petitioners contended that the prosecution's failure to disclose the information from the deposition constituted a due process violation under "Brady v. Maryland," 373 U.S. 83. The appellate court affirmed the lower court's finding that there was no due process violation. The Supreme Court agreed after careful consideration of the trial record and the applicable legal authority. The Court found no "Brady" violation, and found that the trial court did not abuse its discretion by not granting Petitioners a new trial. View "Washingotn v. Mullen" on Justia Law

Petitioner Stephen Eugster filed suit to challenge Washington's process of electing appellate court judges and the court's procedure of assigning cases to three-judge panels. He argued that the process violated the state's constitution. In particular, Petitioner argued that the election process violates the "all elections shall be free and equal" clause of Article I, Section 19. The trial court found that Petitioner failed to state a claim upon which relief could be granted, and dismissed his case. Upon careful consideration of the state's constitution's history, as well as the legislative and case history pertaining to Washington's election of judges and the process by which cases are heard by the appellate courts, the Supreme Court affirmed the trial court's decision. View "Eugster v. State" on Justia Law

Petitioner Robert Strandy was convicted of two counts of felony murder and aggravated first degree murder. For sentencing purposes, the trial court merged the murder and aggravated murder convictions, but it did not vacate the felony murder convictions. On appeal to the Supreme Court, Petitioner argued that the trial court erred by not vacating the merged murder convictions. The Supreme Court granted discretionary review of the case and found that the trial court's omission constituted a violation of the Fifth Amendment prohibition against double jeopardy. The Court remanded the case to the trial court to vacate Petitioner's two felony murder convictions. View "In re Pers. Restraint of Strandy" on Justia Law

In 2007, the city council of Woodinville (City) unanimously denied two applications submitted by Respondent Phoenix Development, Inc. (Phoenix) to rezone a parcel of undeveloped property. The superior court dismissed Phoenix's petition, holding that Phoenix failed to establish that the City failed to follow its own procedure when it denied Phoenix's applications. The Supreme Court found that substantial evidence in the record supported the City's decision to deny Phoenix's requests under the controlling city ordinance. The Court affirmed the superior court's decision to dismiss Phoenix's applications. View "Phoenix Dev., Inc. v. City Of Woodinville" on Justia Law

In this case the issue presented for the Supreme Court's review was whether a thirteen-year old was denied due process rights when she was not appointed counsel at a truancy hearing. Despite a district court's order to attend school, E.S. missed classes from 2005 to 2007. At first, E.S. and her mother attended the hearings, but were not represented by counsel, nor did they ask that counsel be present. The court explained that E.S. would be "sentenced" to house arrest, work crew and detention if she did not comply with the order, but she continued to miss school. At E.S.' last court appearance, she was represented by counsel. She was ordered to spend six days in detention with electronic monitoring. E.S., through her attorney, filed a motion to have the home detention set aside, which was denied. The Court of Appeals vacated E.S.' sentence, finding that the child's "interests in her liberty, privacy and right to education [were] in jeopardy" at the truancy hearings, and that due process required counsel at each appearance. On appeal to the Supreme Court, the School District argued that Washington courts never required the appointment of counsel to protect a child's privacy and education interests. The Supreme Court agreed with the District. Upon review of the record, the state constitution and the applicable legal authority, the Court found that E.S. was not denied due process rights because she was not appointed counsel in the initial truancy hearings. The Court reversed the Court of Appeals' decision and remanded the case for further proceedings. View "Bellevue Sch. Dist. v. E.S." on Justia Law

In Fall 2010, former employees and representatives of the Town of Coulee filed a petition to recall Mayor Rick Heiberg. Of eleven charges, only two were found by the courts to be factually and legally sufficient to support a recall election. On appeal to the Supreme Court, it was determined that the two surviving claims against the mayor were not legally sufficient to support a recall. The Court reversed the lower courts' decisions and dismissed the recall petition. View "In re Recall of Heiberg" on Justia Law

Petitioner Jeremy Anderson was charged with first degree child molestation for alleged contact with a minor child. At trial, a nurse from the child's treating clinic testified to statements made by the child to her. Petitioner challenged the admission of the child's statements made to the nurse as a violation of his Sixth Amendment right to confronting the witness. The Court of Appeals affirmed their admission, holding that the child's statements to the nurse were "nontestimonial" because the statements were made while the nurse made a medical examination. The Supreme Court found that the statements were "testimonial" in nature, and therefore subject to Petitioner's Sixth Amendment right to confrontation. However, the Court held that any error resulting from admitting the testimony was harmless to Petitioner. The Court affirmed the appellate court's decision but on different grounds. View "Washington v. Anderson" on Justia Law