Justia Washington Supreme Court Opinion Summaries

A minor, J.H.-M., was adjudicated guilty of second-degree rape by forcible compulsion. The juvenile court imposed a Special Sex Offender Disposition Alternative, including 30-40 weeks of confinement, suspended for a 24-month supervision period. Conditions of supervision included maintaining employment or school enrollment, compliance with treatment requirements, and registration. Although the sentencing judge verbally declined to impose a condition prohibiting sexually explicit material, the written order included this prohibition.J.H.-M. appealed to the Court of Appeals, arguing that the condition prohibiting sexually explicit material was unconstitutionally vague and overbroad. The State initially moved to concede error based on the judge's verbal statement, but Division One of the Court of Appeals denied the motion and directed briefing on the merits. The Court of Appeals affirmed the condition, concluding it was not unconstitutionally vague or overbroad, distinguishing it from a similar condition in a previous case, State v. Padilla.The Supreme Court of the State of Washington reviewed the case. The court held that the condition prohibiting sexually explicit material was not unconstitutionally vague. The court reasoned that the term "sexually explicit conduct" was sufficiently defined by prior case law and the referenced statute, former RCW 9.68A.011(4), which provided specific examples of prohibited acts. The court concluded that the condition provided adequate notice of proscribed conduct and ascertainable standards to prevent arbitrary enforcement. The Supreme Court affirmed the imposition of the condition and the decision of the Court of Appeals. View "State v. J.H.-M." on Justia Law

Jasper Nelson, a 19-year-old, ran away with a 12-year-old girl, A.S.J., who had left a note expressing suicidal thoughts. Law enforcement, suspecting a sexual relationship, located A.S.J. and later arrested Nelson. Nelson admitted to having sex with A.S.J. multiple times and soliciting sex from an 11-year-old girl, J.W. Nelson pleaded guilty to amended charges, including third-degree rape of a child and second-degree child molestation. The court imposed a Special Sex Offender Sentencing Alternative (SSOSA), suspending his 87-month sentence on conditions including community custody and treatment.Nelson violated his SSOSA by accessing unauthorized electronic devices and inappropriate content, leading to a revocation hearing. He admitted to the violations, and the court revoked his SSOSA, reinstating his original sentence. Nelson appealed, challenging the revocation process and several community custody conditions, including those requiring breath analysis (BA) and urinalysis (UA) testing for alcohol and drug use.The Washington Court of Appeals affirmed the revocation and addressed Nelson's challenges to the community custody conditions. The court held that the BA and UA testing conditions were valid for monitoring compliance with the prohibitions on alcohol and drug use, even though these prohibitions were not directly related to his crimes.The Washington Supreme Court reviewed the case, focusing on whether the BA and UA testing conditions violated Nelson's constitutional rights. The court held that Nelson's preenforcement challenge was not ripe for review due to the need for further factual development. However, the court addressed the merits, affirming that the BA and UA testing conditions were narrowly tailored to serve the state's compelling interest in monitoring compliance with valid community custody conditions. The court concluded that these conditions were constitutionally permissible, even if not directly related to the underlying offenses. View "State v. Nelson" on Justia Law

The case involves a dispute between several plaintiffs, who are independent distributors for Nu Skin Enterprises Inc., and the defendants, which include Nu Skin and its affiliates. The plaintiffs allege that Nu Skin operates an unlawful pyramid scheme, making it difficult for distributors to profit from product sales alone, and instead requiring them to recruit new distributors to earn money. The plaintiffs filed a lawsuit in Spokane County Superior Court, asserting claims under various state and federal laws.In the lower courts, Nu Skin filed a motion to dismiss the case for improper venue based on a forum-selection clause in the parties' contract, which designated Utah as the exclusive forum for dispute resolution. The Spokane County Superior Court denied Nu Skin's motion, ruling that the case did not fall within the contractual definition of a "Dispute" and that Spokane County was a proper venue. Nu Skin sought reconsideration, which was also denied, and then moved for discretionary review.The Washington Supreme Court reviewed the case and addressed whether CR 12(b)(3) is the correct procedural mechanism to enforce a contractual forum-selection clause designating a non-Washington forum. The court held that CR 12(b)(3) is not the appropriate procedure for such enforcement. The court reasoned that the plain language of CR 12(b)(3) authorizes dismissal only when venue is "improper" according to Washington's venue statutes and court rules, which do not account for contractual forum-selection clauses. Therefore, a forum-selection clause cannot render a statutorily authorized venue "improper" under CR 12(b)(3). The court affirmed the denial of Nu Skin's motion to dismiss and remanded the case to the superior court for further proceedings consistent with its opinion. View "Raab v. Nu Skin Enters., Inc." on Justia Law

Tracy Hall filed a class action lawsuit against Walgreens Boots Alliance, Inc. and Walgreen Co., alleging that the company deceptively marketed a cough medicine containing dextromethorphan hydrobromide as "nondrowsy," despite drowsiness being a known side effect. The FDA regulates over-the-counter medicines, including antitussives, but does not require a drowsiness warning for the specific drug in question. Hall claimed that the labeling violated Washington's Consumer Protection Act (CPA).The United States District Court for the Northern District of Illinois reviewed the case and denied Walgreens' motion to dismiss. Walgreens argued that the labeling fell within the CPA's statutory safe harbor, which exempts actions permitted by regulatory bodies. The federal court then certified the question to the Supreme Court of the State of Washington, asking whether the labeling decision fell within the statutory safe harbor under RCW 19.86.170.The Supreme Court of the State of Washington concluded that the statutory safe harbor applies only to actions expressly permitted by a regulatory body. Since the FDA had not specifically permitted labeling the cough medicine as "nondrowsy," the court held that the activity did not fall within the statutory safe harbor. The court answered the certified question in the negative, indicating that the labeling did not qualify for the exemption under the CPA. View "Hall v. Walgreens Boots Alliance, Inc." on Justia Law

In 2001, a 17-year-old Morris Mullins killed a 78-year-old widow, Amy Davis, and was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At the sentencing, the court considered evidence of Mullins’s dysfunctional upbringing and psychological evaluation but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama. The district court denied his motion in 2016, and Mullins’s appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether the sentencing court properly considered Mullins’s youth and potential for change as required by Miller and subsequent cases. The court found that the sentencing judge’s comments suggested ambiguity about Mullins’s capacity for change, undermining confidence in the constitutionality of the JLWOP sentence. The court vacated Mullins’s sentence and remanded the case for resentencing, emphasizing the need to consider the constitutional implications of Mullins’s youth and potential for rehabilitation. View "Galassi v. Lowe's Home Centers, LLC" on Justia Law

In Washington State, most voters cast their votes by mail, and each voter must swear under oath that they are eligible to cast that ballot. Election workers must verify that the signature on the voter’s sworn ballot declaration matches the signature on file. If the signature cannot be verified, the ballot may be challenged, and if the voter does not cure their ballot in time, their vote will not be counted. The plaintiffs argue that this signature verification process results in some lawfully cast ballots not being counted, thus violating the due process, privileges and immunities, and freedom of elections clauses of the state constitution.The trial court denied all parties' summary judgment motions and adopted the Anderson-Burdick framework to determine the level of scrutiny for the case. The court concluded that additional factual development was required and reserved ruling on whether signature verification was severable from the rest of the statutory scheme. The defendants moved to certify the trial court’s order for immediate review, which the plaintiffs did not oppose. The court certified two questions for review: the appropriate standard of judicial review for the plaintiffs’ facial challenges and whether any party is entitled to summary judgment under that standard.The Washington Supreme Court reviewed the case and concluded that signature verification, when coupled with the increasingly expansive cure system, does not facially violate the state constitution. The court held that the defendants are entitled to summary judgment, reversing in part, affirming in part, and remanding for entry of summary judgment in favor of the defendants. The court emphasized that the right to vote is fundamental and that the signature verification process, as part of a robust system of checks, provides both security and ease of voting. View "Vet Voice Foundation v. Hobbs" on Justia Law

Mary Mercedes was accused of animal cruelty based on evidence obtained during a warrantless search of her property. Officers visited her property multiple times after receiving complaints about the condition of her animals. During these visits, Mercedes allowed the officers to view the animals, and based on their observations, a search warrant was later issued. The officers then seized the animals, and Mercedes was charged with two counts of animal cruelty.The trial court granted Mercedes's motion to suppress the evidence obtained from the property visits, ruling that the officers' consent to enter was invalid without providing Ferrier warnings, which inform individuals of their right to refuse, limit, and revoke consent. The trial court dismissed the charges due to lack of probable cause. The State appealed, and the Court of Appeals reversed the trial court's decision, concluding that Ferrier warnings were not required for the search of Mercedes's outdoor property and remanded the case to determine if her consent was voluntary.The Supreme Court of the State of Washington reviewed the case and affirmed the Court of Appeals' decision. The court held that Ferrier warnings are required only when officers seek to enter a person's home to conduct a warrantless search for evidence of a crime. Since the officers' visits to Mercedes's property were for investigative purposes and did not involve entering her home, Ferrier warnings were not necessary. The case was remanded to the trial court to determine if Mercedes's consent was voluntary under the totality of the circumstances. View "State v. Mercedes" on Justia Law

Angela Knight and her two children lived in a rental unit managed by the King County Housing Authority. In January 2023, the Housing Authority served a three-day notice to vacate due to alleged nuisance and criminal conduct, including unauthorized guests, excessive garbage, and activities leading to police reports involving shootings and stolen property. Despite previous warnings and a transfer to another unit, the issues persisted. When the Knights did not vacate, the Housing Authority filed for an unlawful detainer.A commissioner of the King County Superior Court ruled that the property fell under the CARES Act's 30-day notice requirement for evictions, as the Knights were given only three days' notice. Consequently, the unlawful detainer petition was denied, and the eviction action was dismissed without prejudice. The Housing Authority appealed this decision.The Washington Court of Appeals, Division One, held that the 30-day notice requirement under the CARES Act applies only to evictions for nonpayment of rent, disagreeing with Division Two's broader interpretation in a similar case. Andre Knight sought discretionary review from the Washington Supreme Court to resolve this conflict.The Washington Supreme Court held that § 9058(c) of the CARES Act requires a 30-day notice only for evictions due to nonpayment of rent. The court affirmed the Court of Appeals' decision, clarifying that the CARES Act's notice provision does not extend to all types of evictions. The case was remanded for further proceedings consistent with this opinion. View "Hous. Auth. v. Knight" on Justia Law

Several members of the public requested records from the Seattle Police Department (SPD) regarding officers who attended the January 6, 2021, rally in Washington, DC. The officers involved filed a lawsuit to prevent the release of their identities, arguing that their identities should be exempt from disclosure based on statutory and constitutional privacy rights. They sought a preliminary injunction to prevent the release of their identities within those public records.The King County Superior Court denied the officers' motion for a preliminary injunction, determining that the officers failed to show that the information in the public records was likely exempt from disclosure. The court also denied the officers' motion to proceed under pseudonyms. The officers appealed, and the Court of Appeals reversed the denial of the preliminary injunction, concluding that the First Amendment prohibited the disclosure of the officers' identities. The Court of Appeals did not evaluate whether the disclosure would violate the officers' statutory right to privacy under the Public Records Act (PRA).The Supreme Court of the State of Washington reviewed the case and held that the officers did not demonstrate a likelihood of success on the merits that their identities were exempt based on either a statutory or constitutional right to privacy. The court concluded that the officers did not have a privacy interest in their identities as public employees who attended a highly publicized event. The court also held that the officers did not show a need to litigate under pseudonyms. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "John Does v. Seattle Police Dep't" on Justia Law

A young child, Rustin Atkerson, tragically died from severe head trauma while under the care of his mother, Elaine Hurd, and her boyfriend, who had a history of domestic violence. Rustin's father, Ian Atkerson, and Rustin's estate sued the Department of Children, Youth, and Families (DCYF), alleging that their negligent investigation into reports of Rustin's injuries, including a broken arm, led to his death.The trial court denied DCYF's motion for summary judgment, ruling that Atkerson only needed to prove ordinary negligence, not gross negligence, to prevail. The court also largely excluded the testimony of retired Judge Kitty Ann Van Doorninck, who was to testify that a reasonable judge would not have removed Rustin from his mother's care based on the information available at the time. The trial court found her testimony would be unduly prejudicial.The Court of Appeals reversed the trial court's rulings, holding that the applicable standard of care was gross negligence and that the trial court erred in excluding Judge Van Doorninck's testimony. The case was then brought before the Supreme Court of the State of Washington.The Supreme Court of the State of Washington affirmed the Court of Appeals' decision, holding that RCW 4.24.595(1) applies to the early stages of child abuse and neglect investigations, requiring proof of gross negligence. The court also held that the trial court abused its discretion in excluding Judge Van Doorninck's testimony, as her testimony was relevant to the core issue of whether any negligence by the State caused a harmful placement decision. The case was remanded to the trial court for further proceedings consistent with this opinion. View "Atkerson v. State of Washington, Department of Children, Youth & Families" on Justia Law