Justia Washington Supreme Court Opinion Summaries

In 2010, Amanda Knight and accomplices ransacked James and Charlene Sanders’ home, zip-tied them, placed them face down on the floor, stole their wedding rings off their fingers at gunpoint, pistol-whipped Charlene and her son, and shot and killed James Sanders. A jury convicted Knight of multiple crimes, including felony murder in the first degree, two counts of robbery in the first degree, two counts of assault in the second degree, and burglary in the first degree. By way of personal restraint petition, Knight challenged these convictions on double jeopardy grounds, arguing that her robbery and felony murder conviction against James, as well as her robbery and assault conviction against Charlene, should have merged. The Court of Appeals held that the two convictions against James merged, but declined to review Knight’s convictions against Charlene because the Court of Appeals had previously reviewed and dismissed that double jeopardy claim on direct appeal. The Washington Supreme Court held that Knight’s convictions against James Sanders did not merge, and that review of her convictions against Charlene Sanders was barred. "Knight’s robbery and felony murder convictions against James served independent effects, falling under an exception to the double jeopardy merger doctrine. However, the Court of Appeals correctly held that Knight’s claim against her convictions in regards to Charlene is barred as it was already raised and dismissed on direct appeal. Accordingly, we affirm in part and reverse in part the Court of Appeals’ ruling, affirm Knight’s original conviction and sentence, and dismiss her personal restraint petition." View "In re Pers. Restraint of Knight" on Justia Law

Duane Young bought a new 2014 Toyota Tacoma pickup truck with a limited package of additional features from a dealership in Burlington, Washington. Young paid about $36,000 for the truck. At the time Young was researching his purchase, the Toyota website, Toyota’s advertising and the "Monroney label" incorrectly asserted that the vehicle had an outside temperature display on the rearview mirror along with some other displays. Some of the displays had been moved to the dashboard, but the outside temperature display was no longer available. A Toyota Tacoma truck with the colors and features Young wanted was not available in Eugene, Oregon, where he lived. Young called dealerships in Washington and Oregon until he found what he wanted in Burlington. He negotiated the purchase over the phone, paid a deposit, and, on October 30, 2013, flew to Burlington to pick up his truck. Shortly before Young flew to Burlington, Toyota Motor Sales U.S.A. (Toyota) realized that its advertising was incorrect and that some 2014 Toyota Tacoma trucks had been shipped with an incorrect Monroney label. Before the error was corrected, 147 vehicles, including three in Washington State, were sold with the representation that they had the enhanced rearview mirror with the temperature display when they did not. After realizing its mistake, Toyota offered $100 compensation to each consumer who had purchased a truck without the advertised feature. Young declined that offer and several others, including an offer to replace the display with aftermarket equipment. After the parties were unable to negotiate a satisfactory resolution, Young brought a CPA suit against Toyota, and after a two day bench trial, judgment was rendered in Toyota's favor. The judge concluded Young had failed to prove the first element of his CPA claim because he had not shown Toyota’s false statements of fact about the vehicle had the capacity to deceive a substantial portion of the public. The judge also found, among other things, that Young had failed to prove public interest; causation; injury; or that Toyota had violated the automobile dealers practices act. Finding no reversible error in the trial court's judgment, the Washington Supreme Court affirmed. View "Young v. Toyota Motor Sales, U.S.A." on Justia Law

A jury found Ira Cranshaw guilty of several crimes committed against two victims. The convictions included attempted first degree murder of B.B. (count I), three counts of first degree rape of B.B. (counts II, III, and IV), first degree kidnapping of B.B. (count V), harassment of B.B. (count VI), two counts of first degree rape of S.H. (counts VII and VIII), first degree kidnapping of S.H. (count IX), and harassment of S.H. (count X). On direct appeal, the Court of Appeals reversed Cranshaw’s convictions as to B.B. and remanded for a new trial on all of the counts involving her (I through VI), but it affirmed his convictions on the counts involving S.H. (counts VII through X) and remanded for resentencing on only those counts. This matter involved the proper calculation of an offender score in an unusual circumstance, which the State conceded resulted in Cranshaw receiving a longer sentence than he would have received if he had been sentenced in the normal manner. In May 2019, Cranshaw filed a personal restraint petition, raising a double jeopardy claim and a claim regarding the calculation of his offender scores. The acting chief judge dismissed the petition, and Cranshaw filed a motion for discretionary review. Cranshaw then moved to amend his motion for discretionary review, which the Washington Supreme Court allowed. After the State answered the amended motion for discretionary review, the deputy commissioner issued a ruling rejecting the double jeopardy claim. The Supreme Court determined the double jeopardy claim lacked merit, but the Court concluded Cranshaw demonstrated his judgment and sentence was facially invalid based on the offender score calculation, and he was entitled to be resentenced. View "In re Pers. Restraint of Cranshaw" on Justia Law

When a lessee does not timely exercise an option contained in a lease agreement, special circumstances may warrant granting them extra time to exercise the option. In this case, petitioner Burbank Properties LLC mailed its notice shortly after the deadline had passed, and the trial court awarded Burbank an equitable grace period to exercise the option on summary judgment where it was undisputed that no valuable permanent improvements were made. The Washington Supreme Court granted review to decide valuable permanent improvements to the property were a necessary prerequisite to granting the equitable grace period. The Court held that granting an equitable grace period was proper only when a lessee made valuable improvements to property that would result in an inequitable forfeiture if the lessee was not given a grace period. View "Borton & Sons, Inc. v. Burbank Properties, LLC" on Justia Law

The "[Indian Child Welfare Act] ICWA and [Washington State Indian Child Welfare Act] WICWA were enacted to remedy the historical and persistent state-sponsored destruction of Native families and communities. . . . The acts provide specific protections for Native children in child welfare proceedings and are aimed at preserving the children’s relationships with their families, Native communities, and identities. The acts also require states to send notice to tribes so that tribes may exercise their independent rights and interests to protect their children and, in turn, the continuing existence of tribes as thriving communities for generations to come." At issue in this case was whether the trial court had “reason to know” that M.G and Z.G. were Indian children at a 72-hour shelter care hearing. The Washington Supreme Court held that a trial court had “reason to know” that a child was an Indian child when a participant in the proceeding indicates that the child has tribal heritage. "We respect that tribes determine membership exclusively, and state courts cannot establish who is or is not eligible for tribal membership on their own." The Court held that an indication of tribal heritage was sufficient to satisfy the “reason to know” standard. Here, participants in a shelter care hearing indicated that M.G. and Z.G. had tribal heritage. The trial court had “reason to know” that M.G. and Z.G. were Indian children, and it erred by failing to apply ICWA and WICWA standards to the proceeding. View "In re Dependency of Z.J.G." on Justia Law

Evette Burgess and Lithia Motors, Inc. entered into arbitration to resolve an employment dispute. During arbitration proceedings, Burgess filed a motion with the court to terminate arbitration, alleging that Lithia and the arbitrator breached the arbitration agreement. The superior court denied Burgess’s motion, citing a lack of jurisdiction, and certified the matter for direct review, which the Washington Supreme Court granted. Under the FAA, the Supreme Court determined judicial review was limited to deciding gateway disputes, which concern enforceability of the arbitration clause, and addressing the award after arbitration. Therefore, the Supreme Court affirmed the superior court. View "Burgess v. Lithia Motors, Inc." on Justia Law

After a night of drinking with friends, Kimberly Gerlach fell from the second-story balcony of her boyfriend’s unit at the Cove Apartments when the railing gave way. Gerlach sued, arguing Cove’s failure to repair the railing caused her fall and violated Cove’s duties to tenants and their guests. A jury agreed and found Cove was 93 percent at fault for Gerlach’s injuries. The Court of Appeals overturned this verdict and remanded for a new trial, finding the trial court erred by excluding evidence of Gerlach’s blood alcohol concentration (BAC) and by not dismissing Gerlach’s statutory claim under the Residential Landlord-Tenant Act of 1973 (RLTA). After review, the Washington Supreme Court reversed the appeals court: (1) the trial court did not abuse its discretion by excluding BAC evidence that was only minimally relevant to Cove’s affirmative defense and risked prejudicing the jury against Gerlach.; and (2) while the trial court should not have allowed Gerlach’s RLTA claim, "this error alone does not justify a new trial because the jury’s verdict remains valid as to Gerlach’s common law claim." View "Gerlach v. The Cove Apartments, LLC" on Justia Law

In May 2017, petitioner Gregg Loughbom was charged with three counts of various drug crimes: count I, delivery of controlled substances acetaminophen and hydrocodone; count II, delivery of controlled substance methamphetamine; and count III, conspiracy to deliver a controlled substance other than marijuana. These charges stemmed from two controlled drug buys conducted by a confidential informant (CI) on December 20 and 31, 2016. The information was later amended to include school zone enhancements for all three counts pursuant to RCW 69.50.435. During jury selection, the prosecutor asked, “Are there any among you who believe that we have a drug problem in Lincoln County?” He then commented, “Wow, okay. Just about every[one],” and followed with the question, “Is there anyone who feels that we don’t?” Thereafter, the prosecutor referenced the war on drugs three times. The issue this case presented for the Washington Supreme Court's review centered on whether the prosecutor committed reversible error when he repeatedly invoked the phrase, “war on drugs” during the one-day jury trial, without objection by petitioner. The Court held that the State’s framing of Loughbom’s prosecution as representative of the war on drugs denied Loughbom a fair trial and constitutes reversible error. Therefore, the Court reversed the Court of Appeals and remanded for a new trial. View "Washington v. Loughbom" on Justia Law

In 2018, the Washington legislature enacted Substitute House Bill 2887 (SHB 2887), requiring noncharter counties with populations of 400,000 or more to elect five county commissioners by 2022, when originally such counties were required to elect three. SHB 2887 would also require affected counties to fund a redistricting committee to create five districts, one for each commissioner. These counties had to hold individual district elections for these commissioners instead of countywide general elections. Spokane County, former and current Spokane County commissioners, and the Washington State Association of Counties argued this law violated article XI, section 4 of the Washington Constitution, mandating the legislature to establish a uniform system of county government, and article XI, section 5, requiring the legislature to provide for the election of county commissioners through general and uniform laws. The Washington Supreme Court held SHB 2887 was constitutional under article XI, sections 4 and 5: "the legislature may classify counties by population for any purpose that does not violate other constitutional provisions, and SHB 2887 is a general law that properly implements district-only elections for noncharter counties of a certain size." View "Spokane County v. Washington" on Justia Law

In 2018, the Washington Department of Children, Youth and Families (Department) moved to terminate J.J.'s parental rights to her three children. After closing arguments, the trial court orally ruled that the Department had not met its burden to prove by clear, cogent, and convincing evidence that the Department had offered all necessary services or that there was no reasonable likelihood of J.J. correcting her parental deficiencies in the near future. But instead of dismissing the termination petition, the trial court continued the trial without entering any findings of fact or conclusions of law. Two months later, the trial court heard more evidence and then terminated J.J.’s parental rights to all three of her children. J.J. appealed, arguing that the trial court violated her right to due process when it continued the trial after finding that the Department had not met its burden of proof. The Court of Appeals affirmed the termination. The Washington Supreme Court reversed the Court of Appeals and dismissed the termination petition, holding the trial court indeed violated J.J.’s right to due process when it continued the trial after finding the Department had not met its burden of proof. View "In re Welfare of D.E." on Justia Law