Justia Washington Supreme Court Opinion Summaries

Defendants Hai Nguyen and Dominique Norris' cases were consolidated for the Washington Supreme Court's review; the issue they shared was whether the community custody conditions imposed by their respective sentencing courts were sufficiently crime related or unconstitutionally vague. Each case involved a defendant convicted of sexually assaulting a minor. For Nguyen, the sentencing court imposed a condition prohibiting defendant from possessing or viewing sexually explicit material. The Supreme Court determined that condition was not unconstitutionally vague and crime related. For Norris, the sentencing court imposed conditions requiring defendant to inform community corrections officers of any "dating relationship" and prohibited defendant from entering any "sex-related business." The Supreme Court determined the dating condition was unconstitutionally vague but that the sex-related business condition was crime related. View "Washington v. Nguyen" on Justia Law

A cemetery operator challenged a fine imposed when it relocated cremains without giving prior notification of its actions to next of kin. The operator claimed it was acting under its own rules in disinterring 37 sets of cremains without notice, and therefore acting under authority of law. The Washington Supreme Court concluded the operator's rules did not supersede state statutes, and therefore affirmed the Court of Appeals which upheld the fine. View "Southwick, Inc. v. Washington" on Justia Law

David Martin's employment with Gonzaga University was terminated. He sued, alleging he was wrongfully discharged because of whistle-blowing, and asserted a private cause of action under RCW 49.12.250 for an alleged violation of the statute's requirement he be provided with his complete personnel file. Gonzaga successfully moved for summary judgment, dismissing the case, and the Court of Appeals affirmed dismissal of the wrongful discharge, but remanded the personnel file claim for further findings of fact. The issue this appeal presented for the Washington Supreme Court's review centered on whether the Court of Appeals applied the proper test to Martin's whistle-blower claim. The Supreme Court determined the appellate court applied the incorrect standard, and that the personnel file claim was not yet justiciable. So the Supreme Court affirmed dismissal of the whistle-blower claim, and reversed the personnel file claim, finding Gonzaga was entitled to summary judgment on both claims. View "Martin v. Gonzaga Univ." on Justia Law

The Washington civil forfeiture statute allows law enforcement agencies to seize and take ownership of property that had a sufficient factual nexus to certain controlled substance violations; if law enforcement cannot prove the forfeiture is authorized, the claimant would be entitled to have the property returned and receive reasonable attorneys' fees incurred to get the property back. This case presented two issues of first impression for the Washington Supreme Court regarding the attorney fee provision of the statute: (1) who qualifies as a claimant when the property at issue is owned by a corporation; and (2) is a substantially prevailing claimant's fee award strictly limited to fees incurred in the forfeiture proceeding itself? The Court held: (1) a corporate shareholder who did not file a claim in the forfeiture case is not a claimant and cannot recover fees pursuant to the statute's plain language; and (2) the award is not strictly limited to fees incurred in the forfeiture proceeding itself - the statute gives courts discretion to award fees from the related criminal case if reasonably incurred for the primary purpose of resisting the forfeiture. View "Olympic Peninsula Narcotics Enf't Team v. Junction City Lots 1 through 12 Inclusive" on Justia Law

The issue this case presented for the Washington Supreme Court's review centered on whether the state Department of Ecology's then-current wast discharge permitting process complied with RCW 90.48.520 and its requirement for permit conditions to "require all known, available and reasonable methods" to control toxicants in the applicant's wastewater. Specifically, the issue was whether the statute required the Department to use a more sensitive testing method not recognized by the Department or the U.S. EPA as reliable for permit compliance purposes. The Supreme Court determined that it did not require such testing, and affirmed the Court of Appeals. View "Puget Soundkeeper All. v. Dep't of Ecology" on Justia Law

Washington voters referred Initiative 940 ("I-940") to the Legislature; I-940 was an initiative concerning police reform. The legislature also passed a conditional bill, ESHB 3003, purporting to prospectively amend 1-940 if it passed later-in this case, just a few minutes later. But that conditional, prospective bill violated the explicit language and allocation of legislative power contained in article II, section 1 of the Washington Constitution. A divided Washington Supreme Court majority affirmed a superior court's decision to issue a writ of mandamus compelling the Washington Secretary of State to place I-940 on the ballot. View "Eyman v. Wyman" on Justia Law

Constant vigilance is a job requirement for Garda CL Northwest, Inc., a company that operates armored transportation services. Garda requires those employees to maintain vigilance even when they take lunch breaks. The Court of Appeals ruled this constant vigilance policy deprived employees of a meaningful meal period, as guaranteed under WAC 296-126-092. The court also ruled the policy violated the Washington Minimum Wage Act. Violations of the MWA mandates employers double exemplary damages unless certain exceptions apply. At issue before the Washington Supreme Court was whether : (1) Garda carried its burden of showing a debatable dispute over whether the employees waived their state law right to meal periods in their collective bargaining agreements; and (2) plaintiffs could recover both prejudgment interest and double exemplary damages for the same wage violation. The Supreme Court determined Garda failed to prove a bona fide dispute based on waiver, and that aggrieved workers could recover both double exemplary damages and prejudgment interest for the same wage violation. The Court of Appeals was reversed for holding to the contrary, and the matter remanded for further proceedings. View "Hill v. Garda CL Nw, Inc." on Justia Law

Sixteen-year-old Tyler Watkins was charged with first degree burglary as an adult. The former RCW 13.04.030(1) (2009) provided that juvenile courts had to automatically decline jurisdiction over 16- and 17-year-olds charged with certain offenses. Watkins argued his due process rights were violated because the automatic decline component of the statute applied without him first having a hearing on whether the juvenile court should have retained jurisdiction. The Washington Supreme Court held the automatic decline did not violate due process because juveniles did not have a constitutional right to be tried in juvenile court. View "Washington v. Watkins" on Justia Law

Kenneth Linville, Jr. was charged with leading a wave of burglaries throughout Thurston County, Washington. The State charged Linville with one count of "leading organized crime," in addition to 137 other offenses. Some of those 127 were listed in RCW 9A.82.010(4) as predicate offenses, which when combined, formed the requisite "pattern of criminal profiteering" on which "leading organized crime" was based. Some of the 127 were not listed in the statute as predicate crimes at all. The issue for the Washington Supreme Court's contemplation was whether the "joinder bar" rule of RCW 9A.80.085, permitted both predicate and nonpredicate crimes to be joined in a single "leading organized crime" information. Linville argued the State was barred from joining charges outside of the predicated offenses listed in RCW 9A.82.010(4). Linville also argued he received ineffective assistance of counsel because trial counsel did not move to sever the unlisted offenses. The Supreme Court determined the Criminal Profiteering Act supported Linville's interpretation. However, the Court did not find Linville showed counsel was ineffective for choosing to defend against these crimes in one prosecution rather than several. The Court reversed and remanded to the Court of Appeals for further proceedings. View "Washington v. Linville" on Justia Law

After unsuccessfully representing himself at trial, Jerome Curry Jr. appealed his drug convictions to the Court of Appeals, challenging the trial court's decision to allow Curry to represent himself. The Court of Appeals reversed, holding that the trial court should not have granted Curry's request to proceed pro se. The State appealed. Before the Washington Supreme Court could determine whether the trial court abused its discretion when it granted Curry's request for self-representation, it first had to determine whether Curry's request to represent himself was unequivocal. The Court held that it was, therefore reversing the Court of Appeals and remanding to the appellate court to resolve the remaining outstanding issues. View "Washington v. Curry" on Justia Law