Justia Washington Supreme Court Opinion Summaries

James R. Hardman and his mother Alice Hardman, certified professional guardians, are the court-appointed guardians of more than twenty Department of Social and Health Services (DSHS) clients residing at the Fircrest School, a residential habilitation center (RHC) in the city of Shoreline. The Hardmans also engage in extensive advocacy activities, lobbying officials at the local, state, and federal levels to keep Fircrest and other RHCs open and to oppose efforts to place Fircrest residents in community-based programs that the Hardmans believe provide inadequate care. In their triennial guardian reports, the Hardmans requested compensation for their advocacy activities. DSHS opposed the fee requests, arguing that the advocacy work was outside the scope of the guardians' duties. The Court of Appeals denied the Hardmans' request for advocacy fees, finding that the advocacy work did not provide a direct benefit to the indidivual wards. Upon review of the trial court record and the parties' appellate briefs, the Supreme Court found that the Hardmans were not entitled to the compensation because the advocacy activities were neither individualized to serve a particular ward's best interests nor necessary to perform their guardianship duties. The Court affirmed the Court of Appeals. View "In re Guardianship of Lamb" on Justia Law

In 1995, Petitioner Jeffrey Coats pled guilty to conspiracy to commit murder, conspiracy to commit robbery, and robbery. He received a standard range sentence of 20 years. His judgment and sentence erroneously stated that the maximum sentence for conspiracy to commit robbery was life in prison. Fourteen years later, he filed a personal restraint petition contending that because of the erroneous statement, his judgment was not valid on its face and therefore he should have been allowed to withdraw his guilty plea. Upon review, the Supreme Court concluded that despite the error, Peititoner's judgment was valid on its face, and that the sentencing court did not exceed its authority in sentencing Petitioner. The Court remanded the case back to the sentencing court only to correct the erroneous statement pertaining to the sentence for conspiracy to commit robbery. View "In re Pers. Restraint of Coats" on Justia Law

In 2006, Petitioner Robert Danforth went to the King County Sheriff’s Office, described his history of sex offenses, and made explicit descriptions of his plans to molest boys and have intercourse with a child. He repeatedly said that he would act on his plan if he was not committed as a sex offender. The King County prosecuting attorney filed a petition to civilly commit Petitioner, but he moved for summary judgment, arguing that his actions did not constitute a "recent overt act" to qualify him for commitment. The trial court denied his motion and the Court of Appeals affirmed. Upon its review, the Supreme Court concluded that a reasonable jury could have found that Petitioner committed a threat when he gave explicit descriptions of his plans to molest boys, and thus satisfied due process requirements that the State show an offender was presently dangerous before he or she was involuntarily committed. Accordingly, the Court affirmed the trial and appellate courts' decisions. View "In re Det. of Danforth" on Justia Law

Former Pierce County Superior Court Judge Petitioner Michael Hecht was convicted of felony harassment and of patronizing a prostitute. The trial court denied his motion for an order of indigency, and the Court of Appeals denied his motion for discretionary review of that order. Petitioner sought discretionary review with the Supreme Court. The superior court denied indigency status on remand from the appellate court, finding that though he was unemployed (from resigning his post shortly after conviction) and had significant debts, the court reasoned Petitioner had "adequate means" to pay for his legal expenses. On discretionary review by the Supreme Court, Petitioner proffered evidence that he had begun receiving food stamps. The Court found that by statute an indigent person includes anyone who "at any stage of a court proceeding" receives certain types of public assistance, including "food stamps or food stamp benefits transferred electronically." Petitioner was therefore presumptively indigent. The Court granted Petitioner's motion for discretionary review and remanded the case back to the superior court for reconsideration of his motion for order of indigency. View "Washington v. Hecht" on Justia Law

Petitioner Steven Beadle appealed his convictions for first degree child molestation. At a pretrial child hearsay hearing, the four-year-old alleged victim had a serious emotional breakdown and refused to testify. The court found the child unavailable to testify at trial and admitted her out-of-court statements to family members, mental health providers, child protective services, and law enforcement. Petitioner appealed, arguing that the trial court committed reversible error by finding the victim's statements admissible. Upon review, both the Court of Appeals and the Supreme Court affirmed Defendant's convictions. View "Washington v. Beadle" on Justia Law

Petitioner Helen Immelt sounded a car horn at length in front of a neighbor’s house in the early morning hours. She was arrested for violating a Snohomish County noise ordinance that included amongst its prohibited noise disturbances horn honking for a purpose other than public safety, or originating from an officially sanctioned parade or other public event. She challenged the horn ordinance as overbroad and in violation of free speech protections. Upon review, the Supreme Court found that the ordinance was overbroad, and reversed Petitioner's conviction. View "Washington v. Immelt" on Justia Law

As part of the distribution of property following the dissolution of Kenneth Treiger and J’Amy Lyn Owens’ marriage, a home belonging to them (the Maplewood property) was sold, and, pursuant to a trust agreement, the proceeds were deposited in a trust account. Bank of America NA (the Bank), which had obtained a writ of attachment on the Maplewood property, filed a declaratory judgment action to determine each party’s rights to the proceeds. This presented two issues for the Supreme Court's review: (1) to determine whether the “Supplemental Decree of Dissolution” (Supplemental Decree) established a lien on the Maplewood property in favor of Treiger; and (2) to determine whether various documents were valid judgments. Upon review, the Court concluded that the Supplemental Decree established an equitable lien on the Maplewood property in favor of Treiger in the amount of one-half of the proceeds of the court-ordered sale of the property. Furthermore, Documents "1375" and "13761" were valid judgments entitling Treiger to further awards but that Document "1370" was properly not given separate effect. Accordingly, the Court affirm in part and reversed in part the decision of the Court of Appeals. View "Bank of America, NA v. Owens" on Justia Law

Petitioner Gilberto Ibarra-Cisneros and his brother Adrian Ibarra-Raya, were separately prosecuted on drug charges in November 2006. Both moved unsuccessfully to suppress evidence discovered as a result of the warrantless search of Ibarra-Raya's home. Specifically, Ibarra-Cisneros argued to suppress the evidence against him as the fruit of an unlawful use of Ibarra-Raya's cell phone, which was seized during the search. The appellate court determined that the search of the home was unlawful, but that the connection between Ibarra-Raya's cell phone and "the bindle found at Mr. Ibarra-Cisneros's feet [was] too attenuated to affect his cocaine possession conviction." Upon review, the Supreme Court concluded that the appellate court erred in relying on the "attenuation doctrine" as the basis to allow the cocaine evidence against Ibarra-Cisneros: "In light of the way this case has developed, the only fair resolution of Ibarra-Cisneros's appeal is to treat is as the Court of Appeals treated Ibarra-Raya's appeal. The State has not met its burden of purging the taint resulting from the unlawful home search." The Court remanded the case to the trial court "with the acknowledgement that, because the warrantless home search was unlawful, all evidence seized as a result must be suppressed." View "Washington v. Ibarra-Cisneros" on Justia Law

The State appealed the reversal of Respondent Ernest Carter's sentence. The Court of Appeals applied the "actual innocence doctrine" to hear Respondent's untimely personal restraint petition (PRP) and held that Respondent was erroneously sentenced as a persistent offender under the Persistent Offender Accountability Act (POAA) of the Sentencing Reform Act of 1981. In 1998, the superior court entered a judgment and sentence convicting Respondent on two counts of robbery in the first degree and sentenced him as a persistent offender to life in prison. Respondent's prior offenses included a 1983 California conviction for assault with a firearm on a police officer and a 1990 Oregon conviction for attempted murder. Respondent timely filed a direct appeal raising nine issues including a claim that his prior California assault conviction was not comparable to a Washington strike offense under the POAA and should not have been counted toward his sentence. The Court of Appeals affirmed the conviction in an unpublished opinion. Almost seven years after the mandate, Respondent filed this PRP, arguing that his due process rights were violated during his 1998 trial when he appeared in shackles and that his sentence was unlawful. Respondent argued on appeal that: (1) there had been a significant change in the law (RCW 10.73.100(6)), (2) the sentence imposed was in excess of the court’s jurisdiction (RCW 10.73.100(5)), (3) Respondent's judgment and sentence were facially invalid (RCW 10.73.090), (4) equitable tolling under Washington common law warranted review, and (5) the federal actual innocence doctrine warranted review. The Court of Appeals dismissed Carter’s shackling claim as untimely, applied the actual innocence doctrine to the comparability issue, declined to address his alternative claims for relief, vacated Respondent's persistent offender sentence, and remanded for resentencing on the comparability issue. Upon review, the Supreme Court reversed and remanded the case because the Court of Appeals erroneously applied the actual innocence doctrine to hear Respondent's untimely PRP prior to considering his other claimed exceptions to the time bar in RCW 10.73.090. View "In re Personal Restraint of Carter" on Justia Law

Linda Mohr suffered a trauma-induced stroke and became permanently disabled. She and her husband, Charles, claimed that negligent treatment by her health care providers caused Mrs. Mohr a loss of the chance of a better outcome. In "Herskovits v. Group Health Cooperative of Puget Sound," the Supreme Court recognized the "lost chance doctrine" in a survival action when the plaintiff died following the alleged failure of his doctor to timely diagnose his lung cancer. The Mohr's case "compel[led]" consideration of whether, in the medical malpractice context, there was a cause of action for a lost chance, even when the ultimate result is some serious harm short of death. The Supreme Court held that there was such a cause of action and, accordingly, reversed the order of summary judgment. View "Mohr v. Grantham" on Justia Law