Justia Washington Supreme Court Opinion Summaries

The issue in this case was whether the Washington legislature extended a privilege or immunity to religious and other nonprofit, secular employers and whether, in providing the privilege or immunity, the legislature affected a fundamental right without a reasonable basis for doing so. Lawmakers enacted Washington’s Law Against Discrimination (WLAD) to protect citizens from discrimination in employment, and exempted religious nonprofits from the definition of “employer.” In enacting WLAD, the legislature created a statutory right for employees to be free from discrimination in the workplace while allowing employers to retain their constitutional right, as constrained by state and federal case law, to choose workers who reflect the employers’ beliefs when hiring ministers. Matthew Woods brought an employment discrimination action against Seattle’s Union Gospel Mission (SUGM). At trial, SUGM successfully moved for summary judgment pursuant to RCW 49.60.040(11)’s religious employer exemption. Woods appealed to the Washington Supreme Court, contesting the constitutionality of the statute. SUGM argued RCW 49.60.040(11)’s exemption applied to its hiring decisions because its employees were expected to minister to their clients. Under Our Lady of Guadalupe School v. Morrissey-Berru, 140 S. Ct. 2049 (2020), plaintiff’s employment discrimination claim must yield in a few limited circumstances, including where the employee in question was a minister. Whether ministerial responsibilities and functions discussed in Our Lady of Guadalupe were present in Woods’ case was not decided below. The Supreme Court determined RCW 49.60.040(11) was constitutional but could be constitutionally invalid as applied to Woods. Accordingly, judgment was reversed and the case remanded to the trial court to determine whether SUGM met the ministerial exception. View "Woods v. Seattle's Union Gospel Mission" on Justia Law

Gabriel Anderson, a student of the Ferndale School District (Ferndale), was killed by a vehicle while on an off campus walk with his physical education (PE) class. Anderson’s estate alleged negligence by Ferndale. The trial court dismissed the claim, granting Ferndale summary judgment based on a lack of duty. The Court of Appeals reversed, determining that there were sufficient factual issues on duty and proximate causation. Ferndale challenged the Court of Appeals’ analysis of proximate cause. The issue presented for the Washington Supreme Court's review was whether Ferndale was entitled to summary judgment dismissal based on proximate causation. While the Court of Appeals erred in analyzing legal causation, the Supreme Court found it properly concluded that material issues of fact existed concerning proximate causation. The Supreme Court therefore affirmed the Court of Appeals’ decision to reverse summary judgment dismissal of the negligence claim against Ferndale. View "Meyers v. Ferndale Sch. Dist." on Justia Law

In this case, the superior court did not clearly state that it was “arresting or vacating” Respondent Anthony Waller’s judgment, or even granting his motion, in its first order on his CrR 7.8 motion. Instead, it skipped straight ahead to ordering a resentencing hearing. This case presented a question about the application of RAP 2.2(b)(3) in this unusual context: Does a series of superior court orders retaining jurisdiction of a CrR 7.8 motion, scheduling a resentencing hearing, ordering the prisoner transported for that resentencing hearing, and clarifying that the first order did indeed grant the CrR 7.8 motion, amount to granting the motion and “vacating” the old sentence within the meaning of RAP 2.2(b)(3)? The Washington Supreme Court held that it did, and reversed the Court of Appeals. "[W]hen a superior court receives a CrR 7.8 motion, it should follow the CrR 7.8(c) procedures. Pursuant to those procedures, the court should ordinarily hold a show cause hearing before granting relief." View "Washington v. Waller" on Justia Law

Washington’s strict liability drug possession statute, RCW 69.50.4013, made possession of a controlled substance a felony punishable by up to five years in prison, plus a hefty fine; leads to deprivation of numerous other rights and opportunities; and did this without proof that the defendant even knew they possessed the substance. In 2016, police executed a search warrant in Spokane, Washington, seeking evidence of stolen vehicles. They arrested three people on the property, including petitioner Shannon Blake. At the jail, a corrections officer discovered a small baggy containing methamphetamine in the coin pocket of Blake’s jeans. The State charged Blake with possession of a controlled substance. At a bench trial, Blake relied on the affirmative defense of "unwitting possession:" a friend bought the jeans secondhand and gave them to Blake two days before Blake's arrest; Blake never used methamphetamine and did not know drugs were in the pocket; and Blake's boyfriend testified Blake was not a drug user. The trial court found Blake possessed drugs without finding her possession was intentional or knowing. The court concluded Blake did not meet her burden proving her possession was unwitting. This case presented an issue of first impression for the Washington Supreme Court: whether the strict liability drug possession statute with these substantial penalties for such innocent, passive conduct exceeded the legislature’s police power. The Court concluded the answer was yes, this exceeded the State's police power. Blake's conviction was vacated. View "Washington v. Blake" on Justia Law

The Freedom Foundation was a nonprofit organization that describes itself as committed to “advanc[ing] individual liberty, free enterprise and limited, accountable government in the Evergreen State.” The Foundation brought citizen’s actions against Teamsters Local 117; Service Employees International Union Political Education and Action Fund (SEIU PEAF); and Governor Inslee, the Department of Social and Health Services, and Service Employees International Union 775 for various alleged violations of Washington’s Fair Campaign Practices Act (FCPA). In consolidated appeals, the issue common to all was whether the Freedom Foundation satisfied the FCPA’s prerequisites before filing their citizen’s actions. In each case, the superior courts ruled the Foundation failed to meet a 10-day deadline required by the FCPA and, accordingly, entered judgment for respondents. After review, the Washington Supreme Court agreed and affirmed. With respect to the Foundation's suit against the Teamsters Local 117, the Supreme Court determined that though the superior court erred by granting judgment on the pleadings to the union, the court’s entry of judgment would have been proper as summary judgment, and was thus affirmed. This result precluded the Foundation’s other challenges to the superior court’s rulings, which were therefore not addressed. As to the union's cross-appeal of its counterclaim against the Foundation under 42 U.S.C. 1983, the Foundation was not a state actor, was not wielding powers traditionally and exclusively reserved to the State, and therefore was not subject to suit under section 1983. View "Freedom Found. v. Teamsters Local 117" on Justia Law

This case involved a recall petition against Thurston County, Washington, Sheriff John Snaza. Petitioner Arthur West alleged Snaza committed a recallable offense because he stated in a press release that he would not enforce an order issued by the Washington State secretary of health intended to combat the COVID-19 (coronavirus) pandemic. Snaza appealed the trial court’s conclusion that the recall charge was factually and legally sufficient. The Washington Supreme Court concluded Snaza had discretion and his exercise of discretion (stating he would not criminally enforce the order) was not manifestly unreasonable. Therefore, the recall charge was neither factually nor legally sufficient, and the trial court's decision was reversed. View "In Re Recall of Snaza" on Justia Law

In 1978, 17-year-old Carl Brooks pleaded guilty to eight counts of first degree robbery, first degree rape, first degree kidnapping, first degree assault, second degree murder, and first degree burglary, all while armed with a deadly weapon. Over the span of three days, Brooks carjacked, robbed, and raped a woman while her son was present; attempted to rob a couple where gunfire between Brooks and the male victim led to the shooting death of the victim’s wife; carjacked and robbed a third woman; and threatened a fourth woman in her home, demanded financial information, and assaulted her. Brooks had prior convictions in both juvenile and adult court. At the time, sentencing in Washington was “indeterminate:” trial courts sentenced offenders to the maximum amount of time that could be served. But the amount of time the offender would actually serve was largely controlled by the Board of Prison Terms and Paroles (parole board) who would set the minimum term, taking into account recommendations by the trial court and prosecutor. The judge ordered five of the life sentences to run concurrently, and the remaining three to run consecutively, effectively sentencing Brooks to four consecutive “blocks” (or groupings) of life sentences. Both the prosecutor and the court recommended that the parole board give Brooks minimum terms of life. Departing from the recommendations slightly, the parole board set minimum terms of 20, 25, 25, and 20 years for the four blocks, for a minimum total of 90 years. Not long after Brooks was sentenced, the Washington legislature replaced the indeterminate sentencing system with a determinate system. For those sentenced under the former indeterminate sentencing system who were still incarcerated, the Indeterminate Sentence Review Board (ISRB) (the successor to the parole board) was directed to “attempt to make [parole] decisions reasonably consistent” with the Sentencing Reform Act. While Brooks has been serving his time, the United States Supreme Court held that mandatory life-without-parole sentences for juveniles violate the Eighth Amendment’s prohibition on cruel and unusual punishment. The Washington Supreme Court determined that by its plain language, RCW 9.94A.730 applies to Brooks’ sentence. The ISRB was ordered to provide Brooks with a hearing under RCW 9.94A.730 that presumed release. Accordingly, the Court granted the Personal Restraint Petitioned, reversed the Court of Appeals, and remanded to the ISRB for further proceedings. View "In re Pers. Restraint of Brooks" on Justia Law

The Washington State Bar Association (WSBA) Board of Governors (BOG) terminated the WSBA executive director during a closed executive session. WSBA member Lincoln Beauregard sued the WSBA, alleging that the vote to fire the executive director violated the Open Public Meetings Act (OPMA). He demanded that the executive director be reinstated. The trial court held that the OPMA applied to the WSBA and granted Beauregard a preliminary injunction, but not for the requested relief of reinstating the executive director. Instead, the injunction required the WSBA to comply with the OPMA. Because the OPMA did not apply to the WSBA and because the superior court ordered relief that Beauregard never requested, the Washington Supreme Court reversed the preliminary injunction. View "Beauregard v. Wash. State Bar Ass'n" on Justia Law

At issue in this case was whether the general-specific rule applied to a second degree manslaughter charge stemming from a workplace death. The State initially charged Phillip Numrich under the Washington Industrial Safety and Health Act of 1973 (WISHA), RCW 49.17.190(3), the specific statute that punished employer conduct resulting in employee death. The State also charged the employer with second degree manslaughter. The trial court denied the employer’s motion to dismiss the manslaughter charge based on the general-specific rule, and the employer sought and was granted direct review. Specifically, the issue before the Washington Supreme Court was whether the trial court properly denied Numrich’s motion to dismiss a second degree manslaughter charge when one of his employees was killed at the construction site. While consideration of the employer’s motion for direct discretionary review was pending, the State moved to amend the information to add an alternative charge of first degree manslaughter. The trial court granted the motion to amend but sua sponte imposed sanctions against the State based on the timing of the amendment. The employer sought review of the order granting the amendment and the State sought review of the order imposing sanctions. The Washington Supreme Court concluded the trial court did not err in denying the employer’s motion to dismiss the manslaughter charge under the general–specific rule. Furthermore, the Court held the trial court did not err in granting the State’s motion to amend the information to add an alternative first degree manslaughter charge. Finally, the Court held the trial court did not err in imposing sanctions on the State under the circumstances of this case. View "Washington v. Numrich" on Justia Law

Long before his judgment and sentence was final, Vincent Fowler hired and paid an attorney, John Crowley, to prepare and file his personal restraint petition (PRP). But after repeatedly and falsely assuring his client he was working on the PRP, Crowley stopped responding to calls. As the one-year time bar approached and it became apparent Crowley had abandoned him, Fowler hired a new attorney. Fowler learned Crowley had resigned his law license rather than face professional discipline for failing to diligently represent other clients, among other things. Before the time bar passed, Fowler’s present counsel filed a “placeholder” PRP explaining he needed additional time to get Fowler’s legal file and investigate grounds for relief. After the time bar had passed, counsel filed a “supplemental” PRP arguing Fowler’s trial attorney was ineffective. The Court of Appeals dismissed the PRP as untimely. The Washington Supreme Court determined equitable tolling was warranted in this case. "The misconduct of Fowler’s attorney was egregious and Fowler exercised diligence." The Court reversed the Court of Appeals and remanded for consideration on the merits. View "In re Pers. Restraint of Fowler" on Justia Law