Justia Washington Supreme Court Opinion Summaries

Scottye Miller murdered his longtime girlfriend, Tricia Patricelli, 15 days after he was released from prison on Department of Corrections (DOC)-supervised probation. Patricelli, Patricelli's family and friends, and DOC—knew that Miller had physically abused Patricelli in the past and would likely do so again if they resumed their relationship. Patricelli hid the renewed relationship from her friends, family members, and DOC. In fact, Patricelli explicitly assured DOC that she was not in a relationship with Miller, that she was moving to a place where he could not find her, and that she would call the police if she saw him. Miller's mother also verified in writing that he was sleeping at her home, though it turns out that he was actually living with Patricelli. The question this case presented for the Washington Supreme Court’s review was whether DOC was liable for Patricelli's death, despite Patricelli's, Miller's, and his mother's active and successful efforts to prevent DOC from knowing that Miller was in contact with Patricelli. The parties agree that DOC had a duty to supervise Miller while he was on probation and that DOC was not liable unless its supervision constituted “gross negligence.” The parties disagreed on whether DOC’s actions rose to the level of gross negligence. The trial court dismissed on summary judgment, finding the DOC’s failure to take additional steps to verify Patricelli’s statement’s or Miller’s housing arrangements could qualify as gross negligence. The Supreme Court reversed the Court of Appeals and affirmed the trial court's order granting summary judgment for DOC. Tricia Patricelli’s Estate failed to produce sufficient evidence to raise a genuine issue of material fact on the question of gross negligence. View "Harper v. Washington" on Justia Law

While in prison serving a life without parole sentence, Byron Scherf murdered a prison guard. He was tried, convicted of aggravated murder, and sentenced to death. In his appeal, he raised multiple claims of error: procedural, statutory, and constitutional. Based on the holding of Washington v. Gregory, No. 88086-7 (Wash. Oct. 11, 2018), the Washington Supreme Court vacated the sentence, but affirmed the conviction. View "Washington v. Scherf" on Justia Law

The question this case presented for the Washington Supreme Court’s review was whether detaining an incompetent defendant in jail for 76 days before providing competency restoration treatment violates his substantive due process rights under the Fourteenth Amendment to the United States Constitution. The trial court found Anthony Hand incompetent to stand trial and ordered Western State Hospital (WSH) to admit Hand within 15 days for competency restoration treatment. Hand remained in county jail for 61 days after the court's 15 day deadline, for a total of 76 days of confinement. Hand's competency was eventually restored through treatment at WSH. He was subsequently convicted on both charges. Hand argued the State violated his substantive due process rights by detaining him in jail for 76 days before admitting him to WSH for treatment, and that the proper remedy was dismissal with prejudice. After review, the Supreme Court affirmed the Court of Appeals and held that detaining Hand in county jail for 76 days violated his due process rights but that dismissal with prejudice, the only relief Hand requested, was not warranted. View "Washington v. Hand" on Justia Law

In 1995, Derek Gronquist was sentenced to three consecutive, 114-month terms of total confinement for three counts of attempted first-degree kidnapping with a special finding of sexual motivation. On petition to the Washington Supreme Court, Gronquist claimed his sentence expired in 2016, so his continued confinement was unlawful. The Department of Corrections contended Gronquist’s sentence was to expire in 2022. The Supreme Court determined the DOC sentence tracking system was “complicated, its explanations have been confusing and contradictory, and it has not pointed to clear legal authority directly supporting its position.” However, the Court concluded Gronquist had not shown his continued confinement was unlawful either. “DOC has no authority to change the length of Gronquist’s sentence or to run any portion of his consecutive terms concurrently. Gronquist’s proposed sentence structure, however, would require it to do so.” The Court therefore denied relief on Gronquist’s personal restraint petition. View "In re Pers. Restraint of Gronquist" on Justia Law

Tyree Jefferson was convicted by jury of first degree murder, first degree assault, and first degree unlawful possession of a firearm. On appeal, he challenged the State's use of a peremptory strike against the only African-American juror on the jury venire, contending the strike was exercised in a racially discriminatory manner. Further, Jefferson challenged the current Batson test, arguing it failed to address racial discrimination in jury selection. The Washington Supreme Court found the trial court did not err in finding no purposeful discrimination in the strike of the juror. The Court found, however, Jefferson's argument about the Batson test was well taken, modifying the Washington three-step inquiry with a new third step. View "Washington v. Jefferson" on Justia Law

In 2004, Waylon Hubbard pled guilty to second degree possession of stolen property. He was sentenced to a short term of confinement and 120 hours of community service. He was also ordered to pay legal financial obligations. By 2011, Hubbard had fulfilled his community service, and in 2013, he paid off his financial obligations. In 2016, Hubbard petitioned for a certificate and order of discharge (COD), with the effective date of February 25, 2013, the date he satisfied all the terms of his sentence. The State objected, arguing the court did not have the authority to enter an effective date that predated the date on which the court received notice that Hubbard completed his sentence. The Washington Supreme Court held the effective date of a certificate of discharge must be the state the offender completed all the terms of the sentence. View "Washington v. Hubbard" on Justia Law

The Washington Supreme Court was presented an issue of first impression: whether Washington should adopt the "apparent manufacturer" doctrine for common law product liability claims predating the 1981 product liability and tort reform act (WPLA). By this opinion, the Court joined the clear majority of states that formally adopted the apparent manufacturer doctrine. Applying that doctrine to the particular facts of this case, the Court held genuine issues of material fact existed as to whether a reasonable consumer could have believed Pfizer was a manufacturer of asbestos products that caused Vernon Rublee's illness and death. The Court reversed the court of appeals and remanded this case for further proceedings. View "Rublee v. Carrier Corp." on Justia Law

Heidi Hendrickson filed suit against the Moses Lake School District to recover for injuries she suffered while operating a table saw in a woodshop class at Moses Lake High School. The jury found the District was negligent, but that its negligence was not a proximate cause of Hendrickson's injuries. Hendrickson appealed, arguing the trial court erred in instructing the jury that the District owed a her a duty of ordinary care instead of a heightened duty. The Court of Appeals agreed with Hendrickson and reversed, remanding for a new trial. The Washington Supreme Court disagreed with the appellate court, however, finding school districts were subject to an ordinary duty of care. As a result, the Supreme Court reinstated the jury's verdict. View "Hendrickson v. Moses Lake Sch. Dist." on Justia Law

Former foster children brought a case against the Department of Social and Health Service (DSHS) alleging negligence in failing to protect them from the tortious or criminal acts of their foster (and later, adoptive) parents. At the close of evidence, the trial court granted the Department's CR 50 motion and dismissed the children's claims of negligence concerning the preadoption-foster care period. The Court of Appeals reversed, holding DSHS owed them a common law duty to protect dependent foster children from foreseeable harm based on the special relationship between DSHS and such children. The Washington Supreme Court agreed with this reasoning, and remanded for trial on the children's preadoption claims. View "H.B.H. v. Washington" on Justia Law

In 2012, Washington voters approved I-1240, codified at chapter 28A.710 RCW, which created a public charter school system.In League of Women Voters v. Washington, 184 Wn.2d 393 (2015), the Washington Supreme Court held that I-1240 violated article IX, section 2 of the Washington Constitution, finding I-1240 incorrectly designated charter schools as common schools and then impermissibly supported them with money allocated for common schools. Because the unconstitutional provisions of I-1240 were not severable, the Court did not reach the other challenges raised by the plaintiffs. In 2016, the Washington legislature enacted the Charter School Act with amendments designed to cure its constitutional defects. Plaintiffs brought suit seeking a declaratory judgment that the new Act was facially unconstitutional. A number of charter schools joined the suit as intervenor-respondents. On cross motions for summary judgment, the trial court concluded that the Act did not on its face violate the Washington Constitution. Plaintiffs then sought direct review from the Washington Supreme Court. "While each side of the discussion may have legitimate points of view, it is not the province of this court to express favor or disfavor of the legislature's policy decision to create charter schools. . . . We conclude that its only unconstitutional provision is severable, and thus we affirm the trial court in part and hold that the remainder of the Charter School Act is constitutional on its face." View "El Centro de la Raza v. Washington" on Justia Law