Justia Washington Supreme Court Opinion Summaries

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

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

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

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

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

Abeda Jafar filed an action in superior court to obtain a parenting plan involving her 19-month old son. She also filed a motion under GR 34 to waive all mandatory fees and surcharges on the basis of indigency. The trial court found that Jafar was indigent, but granted her only a partial waiver of the fees and surcharges. The issue before the Supreme Court was whether under GR 34 trial courts had discretion to grant partial waivers of fees and surcharges. The Court held that GR 34 provided a uniform standard for determining whether an individual is indigent, and further required the court to waive all fees and costs for individuals who meet this standard. Accordingly, the Court vacated and remanded the trial court's order with instructions to waive all filing fees and surcharges. View "Jafar v. Webb" on Justia Law

In 2003, members of the Committee Against the VietCong Flag disseminated an e-mail message throughout the Olympia Vietnamese community accusing Duc Tan and the Vietnamese Community of Thurston County (VCTC), a nonprofit corporation, of engaging in procommunist activities. Additionally, defendant Norman Le authored three newsletter articles repeating allegations from the e-mail and also accusing Tan and the VCTC of being undercover Viet Cong agents. Tan and the VCTC sued the authors of the publications for defamation. The trial judge determined that Tan and the VCTC were public figures as a matter of law at summary judgment. The case then proceeded to trial where a jury found Le and his coauthors liable for defamation and awarded Tan and the VCTC $310,000 in damages. The Court of Appeals reversed and remanded for dismissal, finding the statements in the e-mail and newsletters were protected opinion supported by disclosed facts, with the exception of the allegation that members of the VCTC, including Tan, were undercover Viet Cong agents. The court found Tan and the VCTC failed to make the requisite showing that the authors published any of the statements with actual malice. Upon review, the Supreme Court concluded that the defamatory statements made by Nonnan Le and the other authors were not protected opinion and therefore actionable. The Court also held that that clear, cogent, and convincing evidence supported the jury's finding of actual malice with respect to those statements. The Court therefore reversed the Court of Appeals and reinstated the jury's verdict. View "Tan v. Le" on Justia Law

The issue before the Supreme Court in this case concerned the public disclosure of Seattle Housing Authority (SHA) grievance hearing decisions pursuant to the Public Records Act (PRA), chapter 42.56 RCW. SHA hearing decisions contain welfare recipients' personal information; this information is exempt from disclosure under the PRA, but the PRA requires redaction and disclosure of public records insofar as all exempt material can be removed. Applicable federal regulations do not exempt the hearing decisions from disclosure, nor do applicable federal regulations preempt the PRA. Thus, in this case, the Supreme Court concluded that the trial court properly ordered SHA to produce the grievance hearing decisions pursuant to the redaction requirement of the PRA, properly ordered SHA to produce the responsive records in electronic format and to establish necessary policies and procedures to ensure compliance with the PRA, and properly awarded statutory damages. The Court therefore affirmed the trial court and awarded respondent Resident Action Council (RAC) its attorney fees on appeal. View "Resident Action Council v. Seattle Hous. Auth." on Justia Law

The issue before the Supreme Court in this case was whether the trial court violated petitioner Brandon Coristine's constitutional rights by offering an affirmative defense instruction over his objection. Petitioner argued that offering the instruction to the jury violated his right to control his defense. Upon review, the Supreme Court held that where a defendant chooses not to argue or invoke an affirmative defense, offering an instruction on the defense over the defendant's objection violates the Sixth Amendment to the United States Constitution. The Court reversed the Court of Appeals and remanded the case for a new trial. View "Washington v. Coristine" on Justia Law

In 2010, Mike Siegel moved to intervene and to unseal the court file in the criminal case of "Washington v. Richardson,"(King County Superior Court No. 93-1-02331-2). The court file was originally sealed in 2002. The trial court authorized intervention but denied the motion to unseal. Siegel petitioned the Supreme Court for direct review of the trial court's order denying his motion to unseal. The deputy clerk denied appeal as a matter of right and redesignated the matter as a motion for discretionary review. The Court granted direct discretionary review. Siegel argued that: (1) the trial court erred in denying his motion to unseal because it failed to perform an "Ishikawa" analysis and failed to comply with GR 15; (2) the denial of his motion to unseal is appealable as of right; and (3) he should have been entitled to attorney fees under RAP 18 .1. Because the trial court failed to apply Ishikawa and GR 15( e )(2); and failed to articulate its reasons for continued sealing on the record, the Supreme Court remanded the case back to the trial court to determine if the records should remain sealed under Ishikawa and GR 15(e)(2). View "Washington v. Richardson" on Justia Law