Justia Washington Supreme Court Opinion Summaries

In 1988, Darren Arends was convicted of grand theft in South Dakota, resulting in the loss of his firearm rights. In August 2023, after Washington amended its firearm restoration statute to restrict the venue for filing restoration petitions to only the county that originally imposed the prohibition, Arends filed a petition in Snohomish County Superior Court, his county of residence. He argued that he had a vested right to file under the prior version of the statute, which allowed filing in the county of residence. The State opposed, contending that Snohomish County was not the proper venue since the prohibition originated in South Dakota and that Arends had not completed all sentencing conditions.The Snohomish County Superior Court denied Arends’s petition, agreeing with the State’s arguments. The Washington Court of Appeals affirmed this decision, holding that Arends was required to file in the county that imposed the prohibition, not his county of residence. Arends then sought review by the Washington Supreme Court.The Supreme Court of the State of Washington held that the statutory venue provisions for firearm restoration petitions are procedural and do not create vested rights. The court clarified that while the legislature may set venue rules, it cannot limit the superior courts’ constitutional jurisdiction to hear such petitions. Therefore, any superior court in Washington retains original jurisdiction to consider firearm restoration petitions, regardless of the venue specified by statute. The court reversed the Court of Appeals and remanded the case to the Snohomish County Superior Court to consider the merits of Arends’s petition under the amended statute. View "Arends v. State" on Justia Law

In this case, the defendant was involved in a fatal incident at a residence where Ricardo Villaseñor was killed during a burglary. The evidence showed that multiple individuals broke into the house, and the defendant’s blood was found both at the scene and in a car associated with another suspect. The defendant claimed he was present only to buy drugs and was shot by someone else, but the trial judge found his testimony not credible. The court determined that the defendant entered the house intending to steal and participated in the burglary with another person, during which Villaseñor was killed.The Pierce County Superior Court conducted a bench trial and found the defendant guilty of felony murder predicated on burglary as an accomplice. The court entered written findings of fact and conclusions of law, specifically noting that the State did not prove the defendant was the shooter or that he knew the other participant was armed, but concluded he was guilty as an accomplice. The defendant was sentenced, with his offender score including a point for being under community custody for prior Texas drug convictions at the time of the offense. On appeal, the Washington Court of Appeals affirmed the conviction and the offender score calculation, but remanded to strike a victim penalty assessment and to address restitution interest.The Supreme Court of the State of Washington reviewed the case to clarify the proper standard for sufficiency of the evidence in bench trials and to address the offender score calculation. The court held that the correct test for sufficiency of the evidence is whether, after viewing all the evidence in the light most favorable to the State, any rational trier of fact could have found guilt beyond a reasonable doubt, as articulated in Jackson v. Virginia and adopted in State v. Green. The court clarified that its prior decision in State v. Homan did not alter this standard. The court also held that the offender score was properly calculated by including a point for community custody based on the valid out-of-state convictions. The decision of the Court of Appeals was affirmed. View "State v. Roberts" on Justia Law

Kyle Evans was charged with felony possession of a stolen vehicle in January 2024. He was not arrested but was summoned to appear for arraignment, where he pleaded not guilty and was released on personal recognizance with certain conditions. The State sought to administratively book Evans to collect his fingerprints and other identifying information, which involved patting down, handcuffing, and detaining him in a jail cell. Evans challenged this process, arguing it violated his constitutional rights under article I, section 7 of the Washington Constitution.In the King County Superior Court, Judge Johanna Bender ruled in favor of Evans, finding that the administrative booking process violated his rights by intruding on his private affairs without the necessary authority of law. Judge Bender allowed the State to collect Evans' fingerprints but prohibited the use of handcuffs, pat-downs, and detention in a cell. This decision conflicted with a ruling by Judge Melinda Young in a similar case, where the process was deemed constitutional under the Fourth Amendment.The Supreme Court of the State of Washington reviewed the case and held that King County's administrative booking process violated article I, section 7 of the Washington Constitution. The court found that the process intruded on the private affairs of pretrial releasees and that the State failed to justify this intrusion with the necessary authority of law. The court emphasized that pretrial releasees do not have diminished privacy rights simply because they have been accused of a crime. The court affirmed the trial court's order and remanded the case for further proceedings consistent with its opinion. View "State v. Evans" on Justia Law

In 2020, Kelly Balles was serving a 12-month community custody sentence for a simple drug possession conviction. During this time, he repeatedly failed to report to his community corrections officer, leading the Department of Corrections (DOC) to issue a warrant for his arrest. When law enforcement officers executed the warrant, they discovered evidence of additional violations and subsequently charged Balles with new offenses.The trial court ruled that the Washington Supreme Court's 2021 decision in State v. Blake, which found the statute criminalizing simple drug possession unconstitutional, automatically invalidated Balles's community custody term and the DOC warrant. Consequently, the court suppressed the evidence found during Balles's arrest. The State appealed, and the Court of Appeals, in a split decision, reversed the trial court's ruling, holding that the Blake decision did not automatically invalidate the outstanding warrant. The case was remanded to the trial court to address unresolved arguments.The Washington Supreme Court reviewed the case and held that the Blake decision did not automatically invalidate Balles's judgment and sentence or the DOC warrant. Instead, the conviction became eligible for vacation, and the warrant became voidable. The court emphasized that a formal process is necessary to determine the extent of Blake-related relief individuals are entitled to according to their circumstances. The court affirmed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with this opinion. View "State v. Balles" on Justia Law

Matthew Lewis pleaded guilty to multiple counts of dealing in and possessing depictions of a minor engaged in sexually explicit conduct. He had six prior convictions, three from Washington State and three from South Australia. The inclusion of the South Australian convictions increased his offender score from 6 to 9+, significantly raising the standard range sentence he faced. Lewis challenged the inclusion of these foreign convictions, but the sentencing court rejected his challenges and sentenced him to 102 months on each count, to be served concurrently, followed by 36 months of community custody.Lewis appealed to the Court of Appeals, arguing that "out-of-state convictions" did not include convictions entered in foreign countries. The Court of Appeals rejected his arguments and affirmed his sentence. Lewis then sought review from the Supreme Court of the State of Washington.The Supreme Court of the State of Washington reviewed the case de novo and concluded that the term "out-of-state convictions" in the Sentencing Reform Act (SRA) is ambiguous. The court found no helpful legislative history to clarify the term's meaning. Applying the rule of lenity, which requires ambiguous criminal laws to be construed in favor of the defendant, the court held that "out-of-state" does not include convictions entered in foreign countries. Consequently, the court reversed the Court of Appeals' decision and remanded the case for resentencing without including the South Australian convictions in Lewis's offender score. View "State v. Lewis" on Justia Law

Shawn Bell was charged with several violent crimes. During jury selection, the State used a peremptory challenge to exclude juror 39, prompting an objection from the defense under GR 37, which addresses potential racial or ethnic bias in jury selection. The prosecutor justified the challenge by claiming juror 39 was inattentive, while the defense argued that the COVID-19 mask requirement made it difficult for jurors to follow the questioning. The trial court denied the GR 37 objection, relying on the juror's admission of inattention and the judge's own observations. Bell was subsequently convicted.Bell appealed, and the Washington Court of Appeals reversed his convictions, finding that the trial court had violated GR 37 by allowing the peremptory challenge against juror 39. The appellate court concluded that the trial court's decision was incorrect and warranted a reversal of Bell's convictions.The Supreme Court of the State of Washington reviewed the case and held that a de novo standard of review is required for GR 37 objections. The court emphasized that the analysis must consider whether an objective observer could view race or ethnicity as a factor in the peremptory challenge. The court found that the trial judge's subjective impressions of juror 39's demeanor were insufficient to justify the challenge. The court also noted that similar responses from other jurors who were not challenged raised concerns about potential bias.The Supreme Court affirmed the Court of Appeals' decision, concluding that an objective observer could view race as a factor in the State's peremptory challenge against juror 39. The court reversed Bell's convictions and remanded the case for a new trial. View "State v. Bell" on Justia Law

The case involves the Citizen Action Defense Fund (Fund) requesting the initial offers for collective bargaining agreements (CBAs) from the Washington State Office of Financial Management (OFM) under the Public Records Act (PRA). The key issue is whether the deliberative process exemption under RCW 42.56.280 applies to these initial offers after the tentative CBAs have been signed by the parties and submitted to the OFM director but before they are signed by the governor or funded by the legislature.The Thurston County Superior Court found that OFM violated the PRA by withholding the records, ruling that the deliberative process exemption did not apply once the CBAs were signed by the state’s negotiation representative and the union. The Court of Appeals reversed this decision, holding that the records were still exempt because the CBAs had not been presented to the governor for approval or funded by the legislature, and thus were not yet final.The Supreme Court of the State of Washington reviewed the case and affirmed the Court of Appeals' decision. The court held that the deliberative process exemption continues to apply until the legislature has funded the CBAs. The court reasoned that the collective bargaining process is not complete until the final step in the statutorily required implementation process, which is the approval of funding by the legislature. Therefore, the deliberative process exemption protects the documents related to collective bargaining until the CBAs are funded by the legislature. View "Citizen Action Def. Fund v. Off. of Fin. Mgmt." on Justia Law

Travis Bearden, a firefighter and paramedic for the City of Ocean Shores, joined the U.S. Army Reserves in 2013. He took periodic absences for military service, receiving paid military leave from the city. The dispute centers on military leave Bearden took between 2019 and 2021. During his first and second leaves from October 2019 to August 2020, Bearden was kept on the schedule and provided paid military leave for his scheduled workdays until his paid leave was exhausted in February 2020. The city then placed him on leave without pay status. For his third leave from August 2020 to May 2021, the city did not provide Bearden any paid military leave for the October 2020-September 2021 military fiscal year, arguing he had no scheduled workdays.Bearden filed a complaint in federal court in January 2021, asserting the city violated the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) by denying him accrued leave, including paid military leave under RCW 38.40.060. The district court granted summary judgment to the defendants, concluding Bearden was not entitled to paid military leave during his third leave because he was not scheduled to work on any day during the October 2020-September 2021 military fiscal year. Bearden appealed, and the United States Court of Appeals for the Ninth Circuit certified a question to the Washington Supreme Court regarding the interpretation of Washington’s paid military leave statute.The Washington Supreme Court held that public employees are entitled to 21 days of paid military leave for required military service during each military fiscal year, regardless of whether they are scheduled to work by the employer due to the length of their military service absence. The court emphasized that the statute’s plain language and purpose support this entitlement, and the scheduling of workdays does not limit the annual entitlement to paid military leave. View "Bearden v. City of Ocean Shores" on Justia Law

The case involves a post-dismissal challenge to a trial court’s order that permanently sealed the petitioners’ actual names and allowed them to be identified by pseudonyms in court records. The petitioners, identified as John Does P, Q, R, and S, sought to prevent Thurston County from releasing unredacted sex offender records in response to a Public Records Act (PRA) request by Donna Zink. The trial court granted the Does’ motion for voluntary dismissal and entered a permanent order to maintain the use of pseudonyms and seal a court record listing their actual names.The trial court initially allowed the Does to proceed in pseudonym to preserve their ability to seek relief in their PRA injunction action. However, over the course of the litigation, nearly all of the Does’ PRA exemption claims were rejected, and Zink received most of the records she requested. The trial court’s preliminary orders allowing pseudonyms were based on the potential harm of being identified as sex offenders. On remand, the trial court granted the Does’ motion for voluntary dismissal and permanently sealed their names, citing compelling privacy and safety concerns.The Washington Supreme Court reviewed the case and held that the trial court abused its discretion in permanently sealing the Disclosure Document and allowing the Does to remain in pseudonym. The court found that the trial court’s findings were insufficient to satisfy GR 15 or the Ishikawa factors, which require specific and compelling reasons to restrict public access to court records. The court noted that the Does’ identities as sex offenders were already publicly available, and the trial court’s order did not articulate new compelling privacy or safety concerns. The Supreme Court remanded the case with instructions to unseal the Disclosure Document, use the Does’ actual names in future proceedings, and replace the pseudonyms in court records with their actual names. View "Doe P v. Thurston County" on Justia Law

Samantha Hall-Haught was involved in a head-on collision, leading to the discovery of drug paraphernalia in her vehicle. At the hospital, a state trooper observed signs of drug use and obtained a warrant to test her blood, which revealed the presence of THC. Hall-Haught was charged with vehicular assault, and at her trial, a lab supervisor testified about the blood test results instead of the technician who conducted the test. Hall-Haught objected, arguing that her right to confront the witness against her was violated.The trial court admitted the lab results, and Hall-Haught was convicted. She appealed, and the Washington Court of Appeals affirmed the conviction, reasoning that the supervisor's independent review and testimony did not violate the confrontation clause. The court relied on the precedent set in State v. Lui, which allowed expert witnesses to testify based on data prepared by others.The Supreme Court of Washington reviewed the case and reversed the Court of Appeals' decision. The court held that the confrontation clause was violated because the lab report was testimonial, and the technician who performed the test was the actual witness against Hall-Haught. The court emphasized that the supervisor's testimony, which relied on the technician's report, was admitted for its truth, thus implicating the confrontation clause. The court remanded the case for further proceedings consistent with this opinion. View "State v. Hall-Haught" on Justia Law