Justia Washington Supreme Court Opinion Summaries

Articles Posted in Washington Supreme Court
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The state Department of Social and Health Services found Petitioner Resa Raven neglected an elderly incapacitated person in her care. Petitioner challenged that finding, arguing that the evidence used against her could not be the basis of the Department's finding. The Supreme Court concluded that petitioner's good-faith determination that her ward opposed being placed in a nursing home could not serve as the basis for a neglect finding. Furthermore, the Court concluded that the evidence did not support the Department's determination that petitioner neglected her ward. View "Raven v. Dep't of Soc. & Health Servs." on Justia Law

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Petitioner Josh Sanchez was adjudicated a juvenile sex offender. He petitioned against the superior court's release of his offender information to the King County Sheriff's Office when he was released back into the community. Washington law mandated that the local authorities notify the community of the offender's release and potential risk that the offender posed. The Supreme Court held that the juvenile court could release the evaluation of petitioner that resulted in his receiving offender status, and that it was not a violation of his rights to do so. View "Washington v. Sanchez" on Justia Law

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At issue in this case was a dispute regarding one rural public hospital district's ability to provide services once it acquired a medical group that operated outside its boundaries (and within the boundaries of another's). The superior court granted a writ of prohibition against Skagit Valley to stop from operating within United General's boundaries. Skagit Valley challenged the superior court's decision to issue the writ. But finding that the trial court properly granted the writ of prohibition, the Supreme Court affirmed. View "Skagit County Pub. Hosp. Dist. No. 304 v. Skagit County Pub. Hosp. Dist. No. 1" on Justia Law

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The trial court dismissed Appellant Richard Piel's suit against the City of Federal Way, finding that the existence of statutory remedies authorized under state law prevented him from establishing the "jeopardy prong" of his common law claim for wrongful termination. The Supreme Court took the opportunity of this case to better explain the jeopardy analysis and harmonize its recent decisions in "Cudney v. ALSCO, Inc." and "Korslund v. DynCorp Tri-Cities Services, Inc." with "Smith v. Bates Technical College." The "Smith" decision recognized that an employee protected by a collective bargaining agreement may bring a common law claim for wrongful termination based on the public policy provisions of RCW 41.56, notwithstanding administrative remedies available through the Public Employees Relations Commission. "Korsland" and "Cudney" did not alter "Smith's" holding. In this case, the Supreme Court reversed the lower court's dismissal and remanded this case for further proceedings. View "Piel v. City of Federal Way" on Justia Law

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Applicants challenged a Department of Development and Environmental Services order declaring the use of the property at issue here was not compliant with King County zoning ordinances. The assertion was that the use was established before the ordinances were revised and characterized as non-conforming. The hearing examiner found for the landowner (and county) on all relevant issues, but the superior court reversed. The appellate court reversed the superior court, and the Supreme Court reversed the appellate court. The Supreme Court held that the landowner's use was not established within the meaning of the county code. View "King County Dep't of Dev. & Envtl. Servs. v. King County" on Justia Law

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Petitioner Patrick Kofmehl bought a piece of land from Baseline Lake, LLC. By closing, the parties disputed the amount of land to be covered by their sales contract. Petitioner was willing to close only if the disputed parcel was included; the sale ultimately failed to close. The trial court invalidated the contract for failing to comply with the statute of frauds and denied specific performance to either party. The issue on appeal to the Supreme Court was whether Petitioner was entitled to recover his down payment before the dispute arise. Upon review, the Court concluded that because neither party breached the contract. The Court affirmed the appellate court which reversed the grant of summary judgment that granted restitution. View "Kofmehl v. Baseline Lake, LLC" on Justia Law

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Newman Park, LLC was formed for the sole purpose of developing a piece of property. In 2004, it took out a loan to purchase the property at issue in this suit. In 2008, without knowledge of the other owners in Newman Park, one member went to Columbia Community Bank and requested a loan for his 95%-owned company, Trinity. Trinity had nothing to do with Newman Park, but the Bank's loan to Trinity was secured by a second deed of trust on the Newman Park property. The issue before the Supreme Court in this case was whether the Bank, who was tricked into refinancing the property that the borrower lacked authority to pledge as security, could benefit from equitable subrogation when that Bank had no preexisting interest in the property. The property-owner/debtor argued that the Bank's lack of the preexisting interest barred it from equitable subrogation because of the "volunteer rule" which would characterize it as an intermeddler. The Court rejected the volunteer rule as a bar to equitable subrogation. The Court affirmed the appellate court which held that the defrauded Bank was entitled to be equitably subrogated as first priority lienholder. View "Columbia Cmty. Bank v. Newman Park, LLC" on Justia Law

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Petitioner Christopher Smith was apprehended by police on the doorstep of his motel room and charged with rape, assault, harassment, kidnapping and child rape. Prior to trial, the Supreme Court invalidated the practice of random motel registry searches. At Petitioner's suppression hearing, he argued that the evidence gathered against him was the fruit of an unlawful registry search, and therefore should have been suppressed. The trial court allowed the evidence under the inevitable discovery doctrine. The appellate court upheld Petitioner's convictions, concluding that the evidence was admissible under the attenuation and independent source doctrines. Upon review, the Supreme Court affirmed Petitioner's conviction, holding the evidence was admissible because the warrantless search that led to its discovery was justifiable under the warrant exception for when lives were in danger. View "Washington v. Smith" on Justia Law

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An officer stopped the defendant for a traffic violation. When it turned out that the driver and his passenger both had suspended drivers' licenses and alternate arrangements could not be made, the officer arranged for a tow truck to move the car. In order to turn the vehicle over to the towing company, the officer conducted an inventory search of the vehicle and discovered methamphetamine during the search. The defendant was convicted of unlawful possession of methamphetamine and driving while his license was suspended. He appealed, arguing that the trial court abused its discretion when it denied his motion to suppress the evidence on the ground the search was pretextual. He also argued that because he did not consent to the search, it was unconstitutional. The Court of Appeals affirmed his convictions. Upon review, the Supreme Court also affirmed, finding that under article I, section 7 of the Washington State Constitution, law enforcement officers do not have to obtain consent in order to conduct an inventory search of a lawfully impounded vehicle. View "Washington v. Tyler" on Justia Law

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In 2009, Petitioner Lowell Finstad faced at least seven felony charges. After he was convicted by jury on two, he and the State negotiated a global plea agreement on the remaining charges. The agreement resulted in less prison time, and in exchange, Petitioner agreed to dismiss his appeal of the jury convictions. Under the terms of the agreement, the sentences would run concurrently. However, the State indicated that it would ask the judge to run a sentence for delivery of a controlled substance conviction consecutive to the others. From the record, it appeared that neither the State nor Petitioner nor the trial court realized that the last consecutive sentence would constitute an exceptional sentence that required special findings. The judge accepted the pleas without making any special findings. Petitioner did not appeal. Three years later, he filed a personal restraint petition contending he received an exceptional sentence that did not comply with Washington law. The State argued in response to the petition that under the facts of this case, Petitioner was not entitled to relief because he could not show he was prejudiced by the error. The Supreme Court agreed with the State and dismissed Petitioner's petition. View "In re Pers. Restraint of Finstad" on Justia Law