Justia Washington Supreme Court Opinion Summaries

In 1993, respondents Brock and Diane Maslonka purchased land bordering the Pend Oreille River. A dam had been constructed on the river in 1955. The previous owners informed the Maslonkas that the land occasionally flooded. In 2016, the Maslonka sued the Pend Oreille Public Utility District (PUD), alleging its operation of the dam entitled them to damages based on inverse condemnation, trespass, nuisance and negligence. The trial court found the subsequent purchaser rule barred the inverse condemnation claim, and the PUD established a prescriptive easement barring the trespass and nuisance claims. The Court of Appeals reversed, finding the PUD could not benefit from the subsequent purchaser rule because it failed to prove its conduct constituted a taking prior ro the Maslonkas’ purchase. The Washington Supreme Court held that an inverse condemnation claimant must show the subsequent purchaser rule does not bar their suit. Further, an inverse condemnation claimant barred by the subsequent purchaser rule has no viable tort claim if the tort is based ont he’s same government conduct. The Court reversed the Court of Appeals and remanded to the trial court to reinstate its summary judgment orders. View "Maslonka v. Pub. Util. Dist. No. 1 of Pend Oreille County" on Justia Law

DH was taken into emergency custody on an involuntary 72-hour hold as authorized by former RCW 71.05.153(1) (2019). Instead of filing for a 14-day commitment court order, the State let the 72-hour hold expire and did not release DH, although he had been asking to leave for days. The State kept him detained overnight and evaluated him again the next morning for a new 72-hour hold and filed a petition for a 14-day commitment. At DH’s subsequent 14-day hold hearing, he argued that he was entitled to dismissal because the State had totally disregarded the requirements of the ITA. The court denied the motion to dismiss and granted the new 14-day petition. The Washington Supreme Court held that when the State totally disregards the requirements of the ITA by holding someone despite lacking the authority under the ITA to do so, the ITA petition shall be dismissed. in this case, the State totally disregarded the requirements of the ITA when it failed to release DH at the end of the 72-hour period as mandated by statute. The trial court abused its discretion when it did not so hold and did not dismiss the new petition. Accordingly, the Supreme Court reversed the Court of Appeals and remanded to the trial court for dismissal of the petition and any further proceedings. The Court also granted review of whether failure to inform a committed person about a loss of firearm rights for involuntary treatment constituted a “manifest error affecting a constitutional right” such that the Court should review the unpreserved issue under RAP 2.5(a)(3). Given its resolution of dismissal of the petition the Court declined to reach this issue. View "In re Det. of D.H." on Justia Law

NG, CM, and AC were all involuntarily detained under the Washington involuntary treatment act (ITA). NG and CM were confined at Western State Hospital for more than a month after the court orders authorizing their continued civil commitments expired. Even after hospital staff realized the court orders had expired, they continued to hold NG and CM. Staff summoned designated crisis responders to initiate “new” ITA proceedings. AC was detained under a valid court order but was involuntarily medicated at an evaluation and treatment center before a court hearing despite asserting her statutory right to not be. The trial judge continued the hearing for a day to allow AC to appear un- medicated. The Washington Supreme Court held that when the State totally disregards the requirements of the ITA by holding someone despite lacking the authority under the ITA to do so, the ITA petition shall be dismissed. "Beginning 'new' ITA proceedings while someone is being held without authority of law is not an acceptable remedy." In NG’s and CM’s cases, the Court concluded the requirements of the ITA were totally disregarded and therefore reversed the Court of Appeals and remanded to the trial courts for dismissal. In AC’s case, the Court concluded the requirements of the ITA were not totally disregarded and that she was not held without authority of law. In that case, the Court affirmed the courts below. View "In re Det. of A.C." on Justia Law

Gary and Jeanette Merritt own four residential properties in Marysville, Washington. Between 2005 and 2007, the Merritts opened five home equity lines of credit (HELOCs), executing five five promissory notes (notes or HELOC agreements) in favor of USAA Federal Savings Bank. The Merritts secured these loans by executing deeds of trust on the properties with USAA as the beneficiary. In November 2012, the Merritts filed for Chapter 7 bankruptcy. The Merritts stopped making their monthly payments on the USAA loans prior to the November 2012 bankruptcy filing. USAA never accelerated any of the loans or acted to foreclose on the properties. In 2020, the Merritts filed four quiet title complaints seeking to remove USAA’s liens on each of the properties. Relying on Edmundson v. Bank of America, NA, 378 P.3d 272 (2016), the Merritts argued that the six-year statute of limitations to enforce the deeds of trust expired six years after February 12, 2013, the day before their bankruptcy discharge. In October 2020, the Merritts moved for summary judgment in each case. In November 2020, the trial court denied each of these motions. In February 2021, USAA moved for summary judgment in each case. USAA argued that the plaintiffs were not entitled to quiet title because the statute of limitations to foreclose on the deeds of trust would not begin to run until the maturity date of each loan, the earliest of which will occur in 2025. The Court of Appeals affirmed the trial court, holding that the the six-year statute of limitations had not begun to run on enforcement of the deeds of trust since none of the loans had yet matured. The issue this case presented for the Washington Supreme Court's review was whether a bankruptcy discharge triggered the statute of limitations to enforce a deed of trust. The Court affirmed the Court of Appeals and the trial court and hold that bankruptcy discharge did not trigger the statute of limitations to enforce a deed of trust. View "Merritt v. USAA Federal Savings Bank" on Justia Law

The property at issue in this case was a residential home that was purchased in 2007 by Shawn and Stephanie Kurtz. The house was located in a subdivision, which required property owners to pay homeowners association (HOA) assessments to petitioner Copper Creek (Marysville) Homeowners Association. If the assessments were not paid, then Copper Creek was entitled to foreclose on its lien. However, Copper Creek’s lien was “subordinate to any security interest perfected by a first deed of trust or mortgage granted in good faith and for fair value upon such Lot.” The Kurtzes stopped paying their HOA assessments and the home loan in varying times in 2010. The Kurtzes (in the process of divorcing) individually filed for bankruptcy. Neither returned to the house, nor did they make any further payments toward their home loan or their HOA assessments. However, there was no attempt to foreclose on the deed of trust. As a result, the house sat vacant for years and fell into disrepair. The Kurtzes remained the property owners of record and HOA assessments continued to accrue in their names. In 2018, Copper Creek recorded a notice of claim of lien for unpaid HOA assessments, fees, costs, and interest. In January 2019, Copper Creek filed a complaint against the Kurtzes seeking foreclosure on the lien and a custodial receiver for the property. The issue this case presented concerned the statute of limitations to foreclose on a deed of trust securing an installment loan after the borrower receives an order of discharge in bankruptcy. As detailed in Merritt v. USAA Federal Savings Bank, No. 100728-1 (Wash. July 20, 2023), the Washington Supreme Court held that a new foreclosure action on the deed of trust accrues with each missed installment payment, even after the borrower’s personal liability is discharged. Actions on written contracts are subject to a six-year statute of limitations. Therefore, the nonjudicial foreclosure action on the deed of trust in this case was timely commenced as to all unpaid installments within the preceding six years, regardless of the borrowers’ bankruptcy discharge orders. In addition, the Court held the trial court properly exercised its discretion to award fees as an equitable sanction for respondents’ litigation misconduct. View "Copper Creek (Marysville) Homeowners Ass'n v. Kurtz" on Justia Law

Alaska Airlines’ (AA’s) Collective Bargaining Agreement with its flight attendants required those flight attendants to schedule vacation days in advance. The Department of Labor & Industries (L&I) argued that RCW 49.12.270 displaced the CBA’s mandatory advance scheduling requirement term without explicitly saying so. AA argued that it did not. The Washington Supreme Court agreed with AA: "It takes more to displace a mandatory CBA term than RCW 49.12.270 contains. In fact, RCW 49.12.270 explicitly preserves non-choice-of-leave terms of the CBA and RCW 49.12.290 bars interpreting RCW 49.12.270 to 'reduce any provision in a [CBA].'" The Court therefore held that RCW 49.12.270 did not displace the advance scheduling requirement of the CBA. View "Alaska Airlines v. Dep't of Labor & Indus." on Justia Law

In this case, three Latino voters from Franklin County, Washington alleged that the county’s system for electing its board of commissioners violated the Washington voting rights act of 2018 (WVRA) by “dilut[ing] the votes of Latino/a voters.” The plaintiffs (respondents on appeal) ultimately settled with defendants Franklin County and the Franklin County Board of Commissioners. The issues on appeal were raised by James Gimenez, a Franklin County voter who was allowed to intervene by the trial court. Immediately after his motion to intervene was granted, Gimenez moved to dismiss the plaintiffs’ claim, arguing that the plaintiffs did not have standing and that the WVRA was facially invalid. The trial court denied Gimenez’s motion to dismiss, and he was not an active participant in the case thereafter. After the trial court entered a final order approving the parties’ settlement, Gimenez appealed directly to the Washington Supreme Court, arguing that in his view, the WVRA protected some Washington voters but excluded others. Based on this interpretation, Gimenez argued that plaintiffs did not have standing because the WVRA did not protect Latinx voters from Franklin County as a matter of law. Gimenez also argued that the WVRA was repealed by implication and was facially unconstitutional because it required local governments to implement electoral systems that favored protected voters and disfavored others on the basis of race. The Supreme Court disagreed with Gimenez's interpretation of the WVRA, and found plaintiffs had stnging and the WVRA was valid and constitutional on its face. View "Portugal v. Franklin County" on Justia Law

Interlocutory review was granted to challenge a trial court’s denial of a suppression motion of evidence observed during a warrantless entry into a dwelling. The trial court concluded that the entry was justified, applying what cases characterized as the “community caretaking exception” to the warrant requirement, based on rendering emergency aid and conducting a health and safety check. At issue before the Washington Supreme Court whether the United States Supreme Court’s Fourth Amendment case, Caniglia v. Strom, 141 S. Ct. 1596 (2021), required the Washington Court to reevaluate the state constitution article I, section 7 cases recognizing exceptions to the warrant requirement. Petitioner Ului Lakepa Teulilo argued that the United States Supreme Court invalidated the community caretaking exception to the warrant requirement as applied to the home, and therefore, under the supremacy clause, Washington state cases recognizing a health and safety check exception under the same doctrine were invalid. To this, the Washington Supreme Court disagreed, and affirmed the trial court. View "Washington v. Teulilo" on Justia Law

These cases concerned whether bail may be denied under article I, section 20 of the Washington Constitution for defendants charged with a class A felony. Patrick Sargent was denied bail and was in custody pretrial for charges of first-degree attempted murder, domestic violence, and felony harassment, domestic violence. As charged, and based on his offender score, Sargent faced a determinate sentence of about 20-25 years. Sargent appealed, alleging he was unlawfully restrained because he was unconstitutionally denied bail. He claimed his crimes, as charged, were not punishable by the possibility of life in prison. The Court of Appeals held that article I, section 20 applied to all class A felonies because all class A felonies carried a statutory maximum sentence of life. In the consolidated case, Leonel Gonzalez was similarly denied bail and was in custody pretrial for first-degree felony murder and unlawful possession of a firearm. As charged, he faced about 34-46 years. In denying bail, the trial court relied on Sargent and the plain language of article I, section 20, concluding that because Gonzalez was facing a class A felony with a maximum of life in prison, the trial court could constitutionally deny bail. Gonzalez appealed directly to the Washington Supreme Court. After review, the Supreme Court affirmed the Court of Appeals in Sargent’s case and denied Sargent’s personal restraint petition (PRP). In addition, the Supreme Court affirmed the trial court in Gonzalez’s case. The Court agreed with the State and lower courts that the plain language of the constitution focused on whether the offense in general, not as charged, could possibly be punished by life in prison. The cases were remanded to the trial courts for further proceedings. View "In re Pers. Restraint of Sargent" on Justia Law

The federal district court in Washington State certified a question of law to the Washington Supreme Court. Washington law required group life insurance policies to have an incontestability clause providing that “the validity of the policy shall not be contested, except for nonpayment of premiums, after it has been in force for two years from its date of issue.” The certified question in this case asked whether an insurer could invalidate a life insurance policy after this two-year period on grounds that the policies were void ab initio or never “in force.” New York Life Insurance (NY Life) issued two life insurance policies to Lorenzo Mitchell, naming his nephew, Simon Mitchell, as the sole beneficiary. Lorenzo died more than two years after the policies were issued, and Simon sought to collect on the policies. NY Life became aware that Lorenzo had Down syndrome and lived with significant intellectual disabilities. These facts raised questions about the circumstances under which the policies were issued. NY Life sued Simon in federal district court seeking declaratory relief that the policies were void ab initio under three possible theories: imposter fraud, incapacity, and lack of an insurable interest. The Washington Supreme Court concluded NY Life’s first and third claims were not barred by that provision. “In contrast, lack of capacity does not, on its own, render an insurance contract void; it renders it at most voidable. Because a voidable contract is not void ab initio, we hold the incontestability provision bars NY Life’s second claim.” View "New York Life Ins. Co. v. Mitchell" on Justia Law