Justia Washington Supreme Court Opinion Summaries

Petitioner Kasey Harmon, a 53-year-old woman in failing health, was evicted from her home following a default judgment and writ of restitution. During the eviction, Harmon obtained an ex parte order staying enforcement of the judgment. The Court of Appeals reversed, concluding that the Residential Landlord-Tenant Act of 1973 (RLTA) prohibited such an order. The Washington Supreme Court concluded the RLTA did not apply to tenants, like Harmon, who contested entry of a default judgment in unlawful detainer actions: these actions were governed by the Civil Rules. Accordingly, the Supreme Court reversed the Court of Appeals' decision, including the award of appellate attorney fees and costs to Reynolds. View "Randy Reynolds & Assocs. v. Harmon" on Justia Law

L.M. suffered a severe injury during birth and subsequently sued Laura Hamilton, the midwife who delivered him, for negligence. Hamilton prevailed at trial. On appeal, L.M. argued the trial court erred by admitting evidence that natural forces of labor could have caused the injury and testimony from a biomechanical engineer to the same effect. L.M. argued the trial court should have excluded the evidence under Frye v. United States, 293 F. 1013 (1923), and the testimony under ER 702. The Washington Supreme Court found that under Frye, the trial court had to exclude evidence that was not based on generally accepted science. And under ER 702, the trial court had to exclude testimony from unqualified experts and testimony that was unhelpful to the jury. L.M.'s challenge concerned the extent to which the challenged science had to be "generally accepted." And his ER 702 challenge hinged on the amount of discretion an appellate court granted a trial court under the rule. Finding the trial court did not abuse its discretion in admitting the challenged evidence, the Washington Supreme Court affirmed the trial and appellate courts. View "L.M. v. Hamilton" on Justia Law

In Washington State, cities, towns, and counties are empowered to enact criminal codes, employ law enforcement officers, and operate jails. Currently, cities, towns, and counties were "responsible for the prosecution, adjudication, sentencing, and incarceration of misdemeanor and gross misdemeanor offenses committed by adults in their respective jurisdictions, and referred from their respective law enforcement agencies." They can carry out these responsibilities directly, through their own courts, law enforcement agencies, and jails, or through agreements with other jurisdictions. The issue this case presented for the Washington Supreme Court’s review was whether, in the absence of a prior interlocal agreement, a county was entitled to seek reimbursement from cities for the cost of medical services provided to jail inmates who were (1) arrested by city officers and (2) held in the county jail on felony charges. The Court concluded it was not. View "Thurston County v. City of Olympia" on Justia Law

This case centered on contempt sanctions imposed against the Department of Social and Health Services (DSHS) for failing to timely complete competency evaluations for criminal defendants. Specifically, the issue reduced to whether the State waived its sovereign immunity under RCW 7.21.030 to the imposition of interest concerning imposed contempt sanctions. The Washington Supreme Court found no waiver under this statute's plain language or in the context presented. The Court also determined whether remedial sanctions ran from the date of the trial court's oral ruling imposing the sanctions or the filing of the written sanction order, holding the oral ruling determining contempt and imposing sanctions triggered the running of the contempt sanctions. View "Dep't of Soc. & Health Servs. v. Sims" on Justia Law

Diana Merritt was convicted of ten counts of mortgage fraud in 2015. The actual crimes were committed between 2008 and 2009, but law enforcement did not discover the extent of those crimes until 2014. Merritt argued the charging document did not sufficiently provide information that the alleged charges occurred within the applicable statute of limitations. She also argued failure to comply with the statute of limitations constituted a violation of her due process rights. The Court of Appeals affirmed Merritt's convictions, and finding no reversible error, so too did the Washington Supreme Court. View "Washington v. Merritt" on Justia Law

In 1998, petitioner Christal Fields pled guilty to attempted second degree robbery for trying to snatch a woman's purse. As a result, Fields was permanently disqualified from working at any licensed childcare facility in Washington pursuant to Department of Early Learning (DEL) regulations. At issue in this case was the extent to which a criminal record could preclude a person from supporting herself through lawful employment in her chosen field. The Washington Supreme Court held DEL's regulations prohibiting any individualized consideration of Fields' qualifications at the administrative level violated her federal right to due process as applied. The Court reversed the Court of Appeals and remanded for further administrative proceedings. View "Fields v. Dep't of Early Learning" on Justia Law

James Yancey, a military veteran with no prior criminal history, was caught selling drugs in a school zone. He pled guilty, but asked the trial court for a lenient sentence. The State objected for a drug offender sentencing alternative (DOSA) because the relevant DOSA statute allowed only a prison-based (not residential based) sentence for defendants with a standard range like the one Yancey had. Over the State's objection, the trial court imposed a residential-based DOSA, and the Court of Appeals affirmed. The Washington Supreme Court found that based on the plain language of the DOSA statute, the trial court lacked jurisdiction to sentence Yancey to a residential-based DOSA. The sentence was vacated and the matter remanded for a new sentencing hearing. View "Washington v. Yancey" on Justia Law

Michael Gehrke and Christopher Pineyro had a history of conflict; Pineyro died after being stabbed in a streetfight with Gehrke. When police arrived, Gehrke admitted to striking Pineyro, claiming self-defense. Gehrke was originally charged with second degree murder, predicated on second degree assault. Immediately before the State rested its case, the trial court allowed it to amend its charges to include first degree manslaughter. A jury found Gehrke guilty of first degree manslaughter, but not second degree murder. On appeal, Gehrke asked the Washington Supreme Court to vacate his conviction and dismiss with prejudice, arguing the amendment to the charges brought against him violated his constitutional right to be informed of those charges. The Supreme Court agreed with Gehrke, reversed the Court of Appeals and remanded the case to the trial court to vacate Gehrke's conviction, dismissal of first degree manslaughter with prejudice, and for further proceedings. View "Washington v. Gehrke" on Justia Law

In 2015, Derek Salte came home to find an unfamiliar truck parked in his driveway, with a man, Petitioner John Mayfield, asleep in the driver's seat. After being asked to leave, the truck would not move. Mayfield got out through the passenger side, ran away, leaving the door open with the engine and windshield wipers still running. Salte called police; a responding officer turned off the truck's engine, placed the keys on the driver's seat, and closed the passenger door. The officer did not search for or observe anything in the passenger compartment. The officer spotted Mayfield walking on the other side of the street; Salte identified him as the person who was in the truck. The officer believed Mayfield was trying to walk past them without making contact, which seemed odd given the truck was Mayfield's (and not stolen). Mayfield was eventually asked about recent drug use, consented to a pat-down search, and consented to a search of the truck. Police discovered methamphetamine in the truck and arrested Mayfield. Mayfield was charged with one count of possession of a controlled substance with intent to deliver. He moved to suppress the drugs found in the truck, arguing he was unlawfully seized. The issue this case presented for the Washington Supreme Court's review centered on the attenuation doctrine: where evidence obtained in violation of the Fourth Amendment is not subjection to exclusion if the connection between the constitutional police conduct and the evidence is remote or was interrupted by some intervening circumstance. The Supreme Court determined the Washington exclusionary rule was not categorically incompatible with the attenuation doctrine, but attenuation had to be narrow and apply only where intervening circumstances have genuinely severed the causal connection between the misconduct and the discovery of evidence. The Court found no intervening circumstances to satisfy the attenuation doctrine in this case as a matter of law. Therefore, Mayfield's motion to suppress should have been granted, and reversed the appeals court's holding otherwise. View "Washington v. Mayfield" on Justia Law

Christopher Floeting alleged a Group Health Cooperative employee repeatedly sexually harassed him while he was seeking medical treatment. He sued Group Health for the unwelcome and offensive sexual conduct under the Washington Law Against Discrimination, which made it unlawful for any person or the person's agency or employee to commit an act of discrimination in any place of public accommodation. The trial court dismissed on summary judgment, pursuant to Group Health's argument the employment discrimination standard applied. The Court of Appeals reversed. Group Health argued the Washington Supreme Court should import workplace sexual harassment doctrines into the public accommodations context, thereby limiting its employer liability. Declining to do so, the Supreme Court affirmed the appellate court. View "Floeting v. Grp. Health Coop." on Justia Law