Justia Washington Supreme Court Opinion Summaries

The Supreme Court granted the State's petition to review a decision of the Court of Appeals in which that court reversed the trial court's denial of Defendant Bobby Ray Thompson's motion for postconviction deoxyribonucleic acid (DNA) testing. In reaching its decision, the Court of Appeals held that the trial court erred in considering a postarrest statement that Defendant made to the police, but which was not admitted in evidence. The Supreme Court found that the Court of Appeals correctly determined that the trial court improperly relied on Defendant's unadmitted statement in denying the motion for postconviction DNA testing. The Court affirmed the Court of Appeals. View "Washington v. Thompson" on Justia Law

Several issues arose after a special deputy prosecuting attorney failed to attend a pretrial hearing and a superior court judge appointed a local defense attorney to take her place. The State appealed the resulting judgment and sentence and the trial court's refusal to vacate its appointment. The Court of Appeals found the appointment was improper and vacated the defendant's guilty plea. Affirming the Court of Appeals' holdings that the State has a right to appeal and that a superior court may appoint an attorney to replace any special prosecuting attorney, the Supreme Court found that the appointed attorney in this case was not qualified to serve as a prosecuting attorney due to a conflict of interest. In addition, the Court affirmed the Court of Appeals' holdings that the "de facto official" doctrine could not save the attorney's appointment and that remand of the case did not violate the double jeopardy clause. The Court reversed the appellate court's holding that on remand, the case be tried to a different judge, noting that nothing in the record of this case suggested the judge displayed "animosity or bias, but simply demonstrated frustration at [the special deputy prosecuting attorney's] repeated failure to appear." View "Washington v. Tracer" on Justia Law

Four Mason County residents brought suit in Mason County Superior Court challenging the validity of an ordinance, which levied a special assessment on nonforest lands within the Mason Conservation District. The superior court ruled for the residents, concluding that the county ordinance is an unconstitutional tax. The Court of Appeals reversed that decision. Upon review, the Supreme Court reversed the Court of Appeals, holding that the ordinance was invalid on statutory grounds. View "Cary v. Mason County" on Justia Law

Petitioner Kenneth Budik was one of two victims of a shooting in Spokane. The other victim, Adama Walton, died as a result of the shooting. Based on Petitioner's statements that he did not know who was responsible for the crime, he was charged with, and convicted of, first degree rendering criminal assistance. Insufficient evidence supported Petitioner's conviction; accordingly, the Supreme Court reversed the Court of Appeals and vacated his conviction. The Court held that in order to prove that a defendant has rendered criminal assistance "by use of . . . deception," the State must show that the defendant made some affirmative act or statement; mere false disavowal of knowledge is insufficient to sustain a conviction for rendering criminal assistance. View "Washington v. Budik" on Justia Law

Respondent Bonnie Anthis won a civil suit against Petitioner Walter Copland for the wrongful death of her husband, Harvey Anthis. Respondent sought to collect Petitioner's only known asset, his retirement pension, to satisfy the judgment. Petitioner, a retired police officer, argued that his Law Enforcement Officers' and Firefighters' Retirement System (LEOFF) pension money could not be garnished even after it has been deposited into his personal bank account. The trial court disagreed and ruled that the money in the account could be garnished. Petitioner appealed, and the Court of Appeals certified the question to the Supreme Court. Upon review, the Supreme Court affirmed the trial court: Washington has one statute that exempts a beneficiary's money "whether [it] be in the actual possession of such person or be deposited or loaned." Other exemption statutes exempt only "[t]he right . . . to a . . .retirement allowance." The survey of case law and the plain language in the LEOFF exemption statutes indicate that the latter statutes exempt funds before they are given into the hands of the beneficiary, but not after receipt. View "Anthis v. Copland" on Justia Law

Respondent Lester Ray Jim, an enrolled member of the Yakama Nation, was cited by for unlawfully retaining undersized sturgeon. This occurred at the Maryhill Treaty Fishing Access Site (Maryhill), a plot of land set aside by Congress exclusively for the use of four Columbia River tribes to exercise their treaty fishing rights. The State argued it has rightfully assumed criminal jurisdiction at Maryhill. Upon review, the Supreme Court disagreed. The Court held that Maryhill was reserved and held by the United States for the exclusive use of tribal members and that the State therefore lacked criminal jurisdiction to cite Respondent. View "Washington v. Jim" on Justia Law

The Supreme Court consolidated "Matsyuk v. State Farm Fire & Casualty Company" and "Weismann v. Safeco Insurance Company of Illinois" for the purpose of clarifying the pro rata sharing rule announced in several precedential cases, including "Mahler v. Szucs" (957 P.2d 632). The rule is based on the "common fund" exception to the "American rule" on attorney fees. The rule requires personal injury protection (PIP) insurers to share pro rata in the attorney fees incurred by injured persons when the PIP insurer wins at trial. Plaintiffs in these cases recovered PIP funds as insureds under policies held by the tortfeasors. They incurred attorney fees arising from the recovery of the liability insurance. The insurance companies attempted to offset the funds expended under PIP policies by reducing plaintiffs' award under the tortfeasors' liability insurance. The Court of Appeals held that neither plaintiff was entitled to recoup a pro rata share of attorney fees. Upon review, the Supreme Court reversed the appellate court, holding that the pro rata fee sharing rule applied in this context. View "Matsyuk v. State Farm Fire & Cas. Co." on Justia Law

Petitioner James Eastmond was convicted of first degree robbery and first degree burglary. At sentencing, the trial court imposed an enhancement on Petitioner's sentence, based on the jury's determination that he was armed with a deadly weapon. While Petitioner's case was pending, the Supreme Court had decided "Washington v. Recuenco (110P.3d 188 (2005)) in which the Court recognized that sentences like Petitioner's violated the Sixth Amendment to the federal constitution. Petitioner then brought a personal restraint petition to challenge the firearm enhancement. The issue presented to the Supreme Court was whether in these circumstances prejudice could be conclusively presumed on collateral review, or whether Petitioner needed to demonstrate actual prejudice. Upon review of the matter, the Supreme Court concluded that the rule announced in "Washington v. Williams-Walker (225 P.3d 913 (2010) did not apply retroactively, and as such, Petitioner needed to demonstrate actual prejudice. Because he had not done so, the Court dismissed his petition. View "In re Pers. Restraint of Eastmond" on Justia Law

The city of Tacoma has franchise agreements with Pierce County and the cities of Fircrest, University Place, and Federal Way (Municipalities) to provide them with water services. The issue before the Supreme Court was whether those franchise agreements required Tacoma to both maintain fire hydrants and bear the maintenance costs of those hydrants. Tacoma raised questions about the impact of the agreements' indemnification clauses had on this dispute. Upon review, the Supreme Court held that the franchise agreements contractually required Tacoma to provide hydrants to the Municipalities, and that the indemnification provisions did not preclude this case. View "City of Tacoma v. City of Bonney Lake" on Justia Law

Petitioner John Hurst was charged with a felony, but he was found incompetent to stand trial. He was twice committed to a mental health treatment facility. After two 90-day periods in the facility, Petitioner failed to regain competency. The State sought a third and final mental health treatment period, lasting this time for up to 180 days. The issue before the Supreme Court centered on the standard of proof required to commit an incompetent criminal defendant charged with a felony to a third mental health treatment period. Petitioner alleged that the due process clause of the Fourteenth Amendment of the federal constitution requires that the standard of proof be "clear, cogent and convincing evidence." The Supreme Court disagreed: "the legislature's selected preponderance of the evidence standard satisfied the Due Process Clause." Accordingly, the Court affirmed the appellate court. View "Washington v. Hurst" on Justia Law