Justia Washington Supreme Court Opinion Summaries

Defendant Alberto Perez-Valdez challenged two evidentiary decisions made by a judge of the Walla Walla County Superior Court during a trial that resulted in his conviction for one count of second degree rape of a child and one count of third degree rape of a child. He also challenged the trial court’s denial of his motions for a mistrial based on a statement made by a state witness relating to the credibility of the victims. Upon review, the Supreme Court held that the trial court did not abuse its discretion in making these decisions. Therefore, the Court affirmed Defendant's conviction. View "Washington v. Perez-Valdez" on Justia Law

Defendant Jay McKague appealed his conviction for second degree assault, and the Court of Appeals affirmed in a split decision. Defendant shoplifted a can of smoked oysters from a convenience store. The owner followed Defendant out of the store and confronted him in the parking lot. Defendant punched the owner in the head several times and pushed him to the ground, causing the owner's head to strike the pavement. He was diagnosed with a concussion without loss of consciousness, a scalp contusion and lacerations, and head and neck pain. Defendant was charged with first degree robbery, with third degree theft as an inferior offense, and second degree assault predicated on the infliction of substantial bodily injury. At Defendant's request, the court also instructed the jury on third degree assault as an inferior offense of second degree assault. The jury convicted Defendant of third degree theft and second degree assault. The dissent on the appellate panel took issue with the of the sufficiency of the evidence of “substantial bodily harm.” Specifically, the dissent disagreed with the lead opinion’s citation to a dictionary definition of the term “substantial” as including “something having substance or actual existence.” Upon review, the Supreme Court affirmed the Court of Appeals’ holding that substantial evidence supported the conviction, but in doing so the Court disapproved of the definition of “substantial bodily harm” applied by the Court of Appeals majority: "[w]e agree … that the majority applied an erroneous definition of 'substantial,' but we nonetheless affirm McKague’s conviction because the evidence was sufficient to show that [the owner's] injuries were 'substantial' under a proper definition." View "Washington v. McKague" on Justia Law

Defendant Chucco Robinson erroneously believed that his earlier juvenile convictions had washed out and no longer counted toward his offender score. Based upon this understanding and after extensive negotiations largely focused on an offender score that would lead to a mutually acceptable sentence, he pled guilty. Before sentencing, he learned that his juvenile convictions would count toward his offender score, significantly increasing the statutory sentencing range he faced. Defendant immediately moved to withdraw his plea. After a hearing, the trial court granted the motion, finding that Defendant's misunderstanding of the consequences of Washington sentencing law was reasonable, though erroneous, and that the plea was not made knowingly, voluntarily, and intelligently. The State contended on appeal that the trial judge abused her discretion when she allowed Defendant to withdraw his plea. The Supreme Court found the ruling was within the sound discretion of the trial court. The Court reversed the Court of Appeals and remanded for further proceedings. View "Washington v. Robinson" on Justia Law

The issue central to this case involved a Public Records Act (PRA) request and a definition of the scope of discovery allowed in PRA-provoked lawsuits, what constitutes an adequate search for requested records, and whether a party may be prevailing when it possesses some responsive documents at the time suit is filed. On February 16, 2005, a copy machine at Spokane County's Building and Planning Department (BPD) printed copies of an undated office seating chart. This chart showed cubicle arrangements of employees at the BPD, but it also included two names within a cubicle of those who had not yet been hired, designated “Ron & Steve.” This caused quite a stir among the BPD employees, many of whom already suspected the BPD of illegal hiring practices. On February 19, 2005, the chart and an accompanying letter were anonymously transmitted to the Neighborhood Alliance of Spokane County (the Alliance). The Alliance took interest in this matter when Steve Harris, son of the BPD Commissioner, and Ron Hand, a former employee, were hired in March. Essentially, the Alliance wanted to know when the “Ron & Steve” seating chart was created. It sought to prove, using the BPD’s own records, that the undated chart was created prior to job postings for the positions later filled by Ron and Steve. The Alliance petitioned the Supreme Court for review, arguing that the Court of Appeals’ decision regarding discovery was contrary to case law and that the Court rejected the Freedom of Information Act's (FOIA) “prevailing party” doctrine. The County cross-petitioned. It argued the appellate court’s decision created a new cause of action under the PRA because it significantly heightened the requirements of an adequate search, and such penalties will continue to accrue until the date of final judgment, including all appeals, thereby punishing an agency for exercising its right to appeal. The Supreme Court held that discovery in a PRA case is the same as in any other civil action and is therefore governed only by relevancy considerations, The Court adopted FOIA standards of reasonableness regarding an adequate search. The Court partly and partly affirmed the appellate court's decision, and remanded the case for further proceedings. View "Neighborhood Alliance of Spokane County v. County of Spokane" on Justia Law

A public school teacher or other certificated employee discharged by a school district may obtain review by a hearing officer and appeal an adverse decision of the hearing officer to superior court. But the legislature did not give school districts the right to appeal an adverse hearing officer decision. When a hearing officer decided in favor of Petitioner David Vinson and against Respondent Federal Way School District, the school district sought review of the decision by statutory writ of certiorari. The superior court denied the writ, but the Court of Appeals reversed, finding sufficient cause to terminate Vinson. Upon review, the Supreme Court held that the statutory writ was not available to the school district. In contrast, the constitutional writ was always available to a party seeking relief from arbitrary, capricious, or illegal acts. However, the Court found that the hearing officer acted within the limits of his statutory authority, and his final decision was not arbitrary or capricious. The Court reversed the Court of Appeals and reinstated the attorney fees awarded by the superior court. View "Federal Way Sch. Dist. No. 210 v. Vinson" on Justia Law

Petitioner Demar Rhome argued on direct appeal to the Supreme Court that the state and federal constitutions require independent findings of fact that a defendant is competent to waive counsel and represent himself at trial. In November of 2003, 17-year-old Lashonda Flynn was stabbed to death. Seventeen-year-old Kialani Brown confessed to the killing but pointed to Defendant as the mastermind behind the slaying. Defendant was charged in King County Superior Court with first degree murder with a deadly weapon. Defendant's mental competency became an issue at trial. After considering the evidence and arguments of counsel, the superior court found that the defense had not met the burden of proving Defendant was incompetent to stand trial. Shortly after the competency hearing, Defendant received new counsel. Defendant represented himself throughout his 2006 proceedings with counsel on stand-by. In reviewing his performance during pretrial and trial proceedings, a defense expert opined that Defendant's mental illness impacted his ability to defend himself in court. Defendant was convicted by a jury as charged and sentenced to 371 months in prison. Represented by appointed federal public defenders, Defendant filed this original personal restraint petition to challenge the trial court’s decision to allow him to waive counsel and proceed pro se. Upon review, the Supreme Court found that Defendant did not demonstrate that federal or state law requires an independent determination of mental competency to proceed pro se when a mentally ill defendant seeks to waive counsel: "[e]ven if such a rule could be crafted from [federal case law] in conjunction with this court’s precedent, Rhome cannot benefit from that rule on a personal restraint petition." The Court also concluded that Defendant failed to show the trial court abused its discretion when it found his waiver of counsel to be knowing and intelligent. The Court dismissed Defendant's petition. View "In re Pers. Restraint of Rhome" on Justia Law

The primary issue presented in this case was whether former RCW 9.92.151 (2004) or the equal protection clause of the United States Constitution requires a county jail to provide opportunities for an inmate who is yet to be sentenced to earn credit toward early release, also known as "good-time" credit. Petitioner, Teddy Talley argued that the Skamania County Jail and the Department of Corrections (Department) violated the former RCW 9.92.151(1) and the Constitution by not providing opportunities for him to earn good-time credit before his criminal conviction. Skamania County argued that the statutory issue was not properly before the Supreme Court and that its program for earning good-time credit is constitutional. The Department argued that it may rely on a county’s jail-time certification when determining the appropriate amount of good-time credit to apply toward early release. Upon review, the Supreme Court held that the matter was properly before it, and that the former RCW 9.92.151 required a county jail to provide opportunities for a presentence inmate to earn good-time credit. The Court did not reach Defendant's constitutional argument. Because the Skamania County Jail policy conflicted with the former RCW 9.92.151, the Court calculated that Defendant should have received an earned early-release credit at the statutory maximum rate of 15 percent. View "In re Pers. Restraint of Talley" on Justia Law

Defendants John Gordon and Charles Bukovsky were each charged with second-degree murder in the beating death of Brian Lewis. The State also sought two aggravating sentencing factors: deliberate cruelty and particular vulnerability of the victim. The jury was instructed to determine whether the aggravators were present, but the instructions did not define "deliberate cruelty" or "particular vulnerability." Defendants did not object to the instructions on that basis. The jury found the defendants guilty and also found the aggravators applied. The trial court imposed exceptional sentences. The issue on appeal to the Supreme Court was whether the failure to provide detailed instructions defining the meaning of "deliberate cruelty" or "particular vulnerability" was a manifest error of constitutional magnitude that could be addressed for the first time on appeal. The Court held that it is not and therefore reversed the Court of Appeals. View "Washington v. Gordon" on Justia Law

RCW 60.04.091(2) requires mechanics' liens to be "acknowledged pursuant to chapter 64.08 RCW." In other words, an authorized person must certify in writing that the signor executed the lien freely and voluntarily. RCW 60.04.091(2) also includes a sample claim of lien that the statute states "shall be sufficient" but that does not include language satisfying the acknowledgment requirement. Contractors Athletic Fields Inc. and Hos Bros.Construction Inc. each filed claims of lien that used the sample form and did not contain certificates of acknowledgment. In each case, the lower court concluded the lien was invalid. Upon review, the Supreme Court disagreed with the trial courts and held that a claim of lien in the sample form is valid despite the absence of a proper acknowledgment. View "Williams v. Athletic Field, Inc." on Justia Law

The trial court in this case ruled that under the Washington courts' application of "Frye v. United States," there must be general acceptance in the relevant scientific community that a particular type of in utero toxic exposure can cause a particular type of birth defect before expert testimony on causation is admissible. Plaintiff Julie Anderson worked for Akzo Nobel Coatings, Inc., from 1998 until she filed a safety complaint with the Washington State Department of Labor and Industries (L&I) and was fired. While it was not officially part of her job, Plaintiff regularly mixed paint. Employees were required by official company policy to wear respirators when mixing paint, but there was reason to believe that the policy was not rigorously enforced and may have been actively undermined by management. Plaintiff gave birth to a son in January 2000. By 2003, it was clear the child suffered from "medical abnormalities." He was diagnosed with a neuronal migration defect, congenital hemiplegia, microcephalus, and a multicystic dysplastic kidney, among other things, along with "delays in motor, communication, cognitive, and adaptive behavior." Upon review of the trial record, the Supreme Court disagreed with the trial court's interpretation and subsequent ruling on the issue. The Court held that the Frye test is not implicated if the theory and the methodology relied upon and used by the expert to reach an opinion on causation is generally accepted by the relevant scientific community. The Court affirmed the trial court's rulings on comparative fault and wrongful discharge. The case was remanded back to the trial court for further proceedings. View "Anderson v. Akzo Nobel Coatings, Inc." on Justia Law