Justia Washington Supreme Court Opinion Summaries

Chris Williams was fined in Spokane Municipal Court for speeding in a school zone, an infraction captured by a traffic safety camera. Williams did not contest the infraction when it was issued, but before the Washington Supreme Court, he argued the camera was improperly positioned to photograph vehicles outside of the school zone. As a result, Williams contended that his infraction and the resulting municipal court judgment were invalid. Instead of moving to vacate the judgment in municipal court, Williams filed a putative class action complaint in superior court against the City of Spokane (City) and American Traffic Solutions Inc. (ATS), seeking a refund of his fine and declaratory and injunctive relief. The trial court denied the defendants’ motion for summary judgment. The Court of Appeals reversed, holding that Williams’s complaint had to be dismissed. The Supreme Court found that in accordance with court rules, statutes, and case law, Williams had to seek a refund of his infraction fine from the municipal court that issued the judgment. Until he did, Williams did not have standing to seek declaratory or injunctive relief. Therefore, all of his claims were precluded. The Court affirmed the appellate court and remanded this case to the superior court for dismissal of Williams’s complaint. View "Williams v. City of Spokane" on Justia Law

Petitioner Daniel Elwell was charged with one count of residential burglary. He disagreed with his assigned trial counsel about a number of issues, including the probable merit of a motion to suppress based on an alleged unlawful search. Elwell ultimately filed a written motion to suppress the stolen item, although counsel assisted by eliciting testimony and presenting oral argument before the court. The trial court denied Elwell’s motion to suppress, and he was convicted. The Court of Appeals affirmed, holding that Elwell’s motion to suppress was properly denied on the basis of the open view doctrine and that Elwell’s right to counsel had not been violated. The Washington Supreme Court found the open view doctrine did not justify the police officer’s actions in this case. Instead, the Court held that the officer engaged in an unlawful, warrantless search in violation of article I, section 7 of the Washington Constitution. Therefore, it was error to deny Elwell’s motion to suppress. However, the Court found the error was harmless. Further, the Court held Elwell was not deprived of the right to counsel. View "Washington v. Elwell" on Justia Law

James Hamre died when an Amtrak train derailed in Dupont, Washington, in 2017. He was survived by his mother, who lived with him, and three adult siblings. Under the wrongful death statutes in effect at the time, James’ mother could recover for his wrongful death because she was dependent on him, while his siblings could recover nothing because they did not rely on James financially. The wrongful death beneficiary statute in effect at that time also denied any recovery to beneficiaries like parents or siblings if they did not reside in the United States. In 2018, one of James’ brothers, acting as his personal representative, agreed to a settlement and release with the National Railroad Passenger Corporation (aka Amtrak), on behalf of their mother, the only then qualifying wrongful death beneficiary. In 2019, the Washington Legislature amended RCW 4.20.020 to remove the requirement that second tier beneficiaries (parents and siblings) be both dependent on the decedent and residents of the United States. It explicitly stated that the amendment should apply retroactively to claims that were not time barred. In 2020, James’ siblings who qualified as beneficiaries under the revised statute brought wrongful death actions against Amtrak. Amtrak argued that retroactive application would violate its contracts clause and due process rights under the Washington Constitution. The federal district court certified two questions to the Washington Supreme Court to address the issue of retroactivity, and the Supreme Court concluded the Washington State Legislature intended the 2019 amendments to RCW 4.20.020 to apply retroactively to permit newly qualified second tier beneficiaries to assert wrongful death claims that were not time barred. View "Kellogg v. Nat'l R.R. Passenger Corp." on Justia Law

Matt Surowiecki Sr. sued the Hat Island Community Association (HICA), arguing that HICA violated its governing documents by not charging assessments on an equitable basis. After review, the Washington Supreme Court concluded HICA’s governing documents granted the association broad discretion in setting assessments, and that the association’s decision on assessments was entitled to substantial deference. Here, the association’s elected board of trustees made the decision to raise funds through a combination of use-based fees and per-lot assessments as authorized in its governing documents. This decision was ratified by a vote of the members. Surowiecki’s evidence established, at most, that there might be more than one equitable way to distribute the costs of maintaining the community’s obligations. He did not show, however, shown as a matter of law that either the process used, or the result reached, was not equitable. View "Bangerter v. Hat Island Cmty. Ass'n" on Justia Law

Julie Fairbanks began dating Charmarke Abdi-Issa shortly after she moved to Seattle with her dog, Mona. Mona was a small Chihuahua and Dachshund mix. Fairbanks testified she was close to Mona. Abdi-Issa, however, had a history of disliking Mona. Abdi-Issa was abusive toward Fairbanks and Mona, even threatening to kill them both. Abdi-Issa insisted on taking the dog for a walk. Witnesses saw Abdi-Issa kick Mona so hard it went airborne and into some nearby bushes. A witness called police; police discovered the dog still alive, under a bush. When it was transported to a nearby veterinary clinic, the dog had died. A necropsy found that Mona had died from multiple instances of blunt force trauma. The State charged Abdi-Issa with first degree animal cruelty under RCW 16.52.205 and sought a domestic violence designation under RCW 10.99.020 and RCW 9A.36.041(4). The State also charged two sentencing aggravators: (1) that the crime had a destructive and foreseeable impact on persons other than the victim under RCW 9.94A.535(3)(r) and (2) that Abdi-Issa’s conduct during the crime of domestic violence manifested deliberate cruelty or intimidation of the victim, RCW 9.94A.635(3)(h)(iii). Abdi-Issa unsuccessfully moved to dismiss the domestic violence designation and aggravators multiple times. The Court of Appeals vacated the domestic violence designation, the no- contact order, and the impact on others sentencing aggravator. The Washington Supreme Court was asked to determine whether the trial court correctly concluded that animal cruelty could be a crime of domestic violence. The Court was also asked whether the trial court properly instructed the jury that it could find this crime had a destructive and foreseeable impact on persons other than the victim. The Supreme Court affirmed the trial court on both issues. View "Washington v. Abdi-Issa" on Justia Law

K.W. was removed from his long-term placement with his relative, “Grandma B.,” after she took a one-day trip and did not notify the social worker of the trip. The consequence of this removal resulted in tremendous upheaval in K.W.’s life and violated the requirements of RCW 13.34.130. Though K.W. was legally free, the placement preferences set out in the statute still applied, and the court erred in failing to apply them and failing to place K.W. with relatives. View "In re Dependency of K.W." on Justia Law

Lori Shavlik sought to recall Snohomish County Sheriff Adam Fortney. Her petition was the fourth to recall Sheriff Fortney since he took office on January 1, 2020. As the fourth attempt to recall Sheriff Fortney, the charges in Shavlik’s current petition overlapped with charges brought in previous recall petitions. Shavlik raised three issues on appeal: (1) the trial court erred by finding charges 3 through 8 insufficient; (2) the trial court erred by finding charges 1(e) and 2 barred under res judicata; and (3) the trial court and the Snohomish County Prosecutor’s Office deprived her of a fair and impartial hearing. After review, the Washington Supreme Court rejected all three claims of error, affirmed the trial court, and awarded Sheriff Fortney costs on appeal. View "In re Recall of Fortney" on Justia Law

The Commission on Judicial Conduct (Commission) ruled that Judge David Keenan, a King County Superior Court judge, violated the Code of Judicial Conduct (CJC or Code) when he approved a bus advertisement for North Seattle College. The ad pictured him and stated, in part, “A Superior Court Judge, David Keenan got into law in part to advocate for marginalized communities.” North Seattle College was a nonprofit community college where Judge Keenan received both his high school and his associate’s degrees. The ad ran for three weeks as part of North Seattle College’s fall enrollment campaign. The Washington Supreme Court concluded Judge Keenan’s conduct did not violate Rules 1.1, 1.2, or 1.3 of the Code. He did not violate his duty to be, and to appear, impartial, and he did not abuse the prestige of his office. The Court therefore reversed the Commission’s decision and dismissed the charges. View "In re Keenan" on Justia Law

Justin Jennings was convicted of felony murder and unlawful possession of a firearm for the killing of Chris Burton. At trial, the court held that a toxicology report showing Burton had methamphetamine in his system at the time of death was inadmissible because it was irrelevant and speculative. Jennings appealed, arguing the exclusion of the report violated his constitutional right to present a defense. The Court of Appeals affirmed. Jennings sought review of that decision and also challenged his sentence in light of the Washington Supreme Court’s recent decision in Washington v. Blake, 481 P.3d 521 (2021). The Supreme Court affirmed the Court of Appeals’ holding that the trial court’s exclusion of the toxicology report did not violate Jennings’ right to present a defense. However, the Court clarified the test that applied to a claimed constitutional violation of the right to present a defense. In addition, the Court vacated Jennings’ sentence and remanded to the trial court for resentencing in light of Blake. View "Washington v. Jennings" on Justia Law

The issue this case presented for the Washington Supreme Court's review centered on the amount of reimbursement that counties were entitled to from the State for costs associated with purchasing, installing, and operating additional ballot boxes. In order to answer that question, the Court first had to consider the relationship between RCW 29A.40.170 (the ballot box statute), RCW 29A.04.430 (the reimbursement statute, or "Section 430"), and RCW 43.135.060 (the unfunded mandate statute). The Supreme Court held Section 430 controlled over the unfunded mandate statute and provided reimbursement only of the State’s proportional share for the costs of compliance with the ballot box statute. Further, the Court held that the 2020 amendment of Section 430 did not violate article II, section 37 of the Washington Constitution and that respondents Snohomish, Kittitas, and Whitman Counties could not claim any vested right that would require the Court to invalidate the retroactive effect of Section 430. The Court therefore reversed the order granting partial summary judgment and remanded to the trial court for further proceedings. View "Wash. State Ass'n of Counties v. Washington" on Justia Law