Justia Washington Supreme Court Opinion Summaries

Ryan Peeler was serving a prison sentence on a Snohomish County charge at the Washington Corrections Center (WCC) when he requested a final disposition of an untried charge in Skagit County. By the time that the Skagit County prosecutor received Peeler's final disposition request, however, the Department of Corrections (DOC) had transported him to the King County jail to await trial on unrelated charges. Peeler was not returned to WCC until well after the Skagit County prosecutor received his request. The State failed to bring Peeler to trial in Skagit County within 120 days of receiving his final disposition request. The Supreme Court affirmed the Court of Appeals' decision that even though Peeler was physically located in King County when the State received his final disposition request, his request was valid and the State failed to meet the 120-day deadline to bring him to trial in Skagit County. View "Washington v. Peeler" on Justia Law

As applied to Washington, the holding in "Padilla v. Kentucky," (559 U.S. 356 (2010) was an affirmation of the duty to provide effective assistance of counsel, which included the duty to reasonably research and apply relevant statutes. However, language in certain Washington appellate cases made it appear that this rule did not apply to RCW 10.40.200. "Padilla" superseded those cases, significantly changing state law. Muhammadou Jagana raised a claim that would have been rejected before "Padilla" based on those superseded appellate cases. The Washington Supreme Court therefore reversed the Court of Appeals' order dismissing Jagana's personal restraint petition (PRP) and remanded to the trial court for an evidentiary hearing. However, Yung-Cheng Tsai's claim was available before "Padilla," and Tsai did in fact raise his claim with the assistance of an attorney in 2008. That motion was denied based on an issue of law not affected by Padilla, and Tsai did not appeal. The Court therefore affirmed the Court of Appeals' order dismissing Tsai's PRP. View "In Re Pers. Restraint of Yung-Cheng Tsai" on Justia Law

William Reis was charged with manufacturing a controlled substance after a search of his home produced evidence of a marijuana grow operation. Reis moved to suppress the results of the search on the ground that the search warrant was invalid, arguing that the 2011 amendments to the Washington State Medical Use of Cannabis Act (MUCA) decriminalized the possession of cannabis for medical use. The trial court denied Reis's motion to suppress, and the Court of Appeals granted discretionary review and affirmed. After its review, the Supreme Court held that the plain language of MUCA, supported by the context in which the language appeared, the overall statutory scheme, and the legislative intent as captured in the governor's veto message, did not support the conclusion that the medical use of marijuana was not a crime. Therefore, the Supreme Court affirmed the Court of Appeals and remanded the case for trial. View "Washington v. Reis" on Justia Law

Toby Erhart's judgment and sentence on multiple counts of first degree child rape and incest became final on direct appeal in 2008. During Erhart's trial, the court interviewed several prospective jurors privately in chambers without first conducting the courtroom closure analysis required by "Washington v. Bone-Club." The jury found Erhart guilty of multiple sex offenses, and the trial court imposed an exceptional sentence. Erhart did not raise a public trial issue on direct appeal. The Court of Appeals affirmed the convictions but reversed the exceptional sentence and remanded for resentencing. In 2010 Erhart filed a personal restraint petition challenging his convictions, arguing for the first time that his constitutional right to a public trial was violated. The Court of Appeals dismissed the petition as untimely. The Supreme Court granted discretionary review. Finding that Erhart filed his personal restraint petition more than one year after his judgment and sentence became final, the petition was indeed untimely, the Supreme Court affirmed. View "In re Pers. Restraint of Erhart" on Justia Law

After his 18th birthday, Robert Wheeler was charged with, and pled guilty to, first degree child rape and first degree child molestation for offenses he committed when he was 13 or 14 years old that came to light when he was 17 and a half. His convictions had been final since 2006. The Court of Appeals held that the validity of Wheeler's guilty plea was not an appealable issue because the trial court did not independently review and rule on it; rejected Wheeler's claim of ineffective assistance, reasoning that counsel was not obligated to advance an argument that was unlikely to succeed; and dismissed Wheeler's personal restraint petition as untimely. Wheeler contended on appeal that the Washington Supreme Court had the authority to, and should have, revisited his previously rejected claim that his plea was involuntary because he was misinformed of the maximum sentences for his crimes. He also challenged his convictions as the product of unconstitutional preaccusatorial delay and sought to avoid the time bar for collateral attack by claiming he had newly discovered evidence that the State delayed filing charges until Wheeler aged out of juvenile court. The Supreme Court rejected Wheeler's arguments, and affirmed the Court of Appeals. View "Washington v. Wheeler" on Justia Law

Scott Walter Maziar sustained injuries while on board a ferry operated by the Washington State Department of Corrections (DOC). Maziar used the ferry to get to and from work. Since Maziar was injured at sea, he brought a general maritime negligence claim against the DOC. He initially requested a jury trial, but he moved to strike his demand because he thought that no jury trial right existed for general maritime negligence cases. The DOC objected, but the trial court agreed with Maziar, struck his jury request, and awarded him damages after a bench trial. The Court of Appeals affirmed the trial court on the jury trial issue but on different grounds, holding that although a jury trial right generally applied to general maritime negligence actions in state court. The State did not have a constitutional or statutory jury trial right in tort actions. The issue this case presented on appeal was whether the State had a jury trial right in tort actions. The Court held that it does: several statutes read together demonstrate that the legislature meant to treat the State as if it were a private party with regard to matters of civil procedure and confer on any party (including the State) the right to have a jury determine most matters of fact. Accordingly, the Court reversed the Court of Appeals and remanded for a jury trial. View "Maziar v. Dep't of Corr." on Justia Law

The parties in this case, the Gamboas and Clarks, owned adjoining parcels of land separated by a gravel road in a rural area in Yakima County. Since coming to the parcel in 1992, the Gamboas used the gravel road as a driveway to access their home and some of their alfalfa crop. When the Clarks came to their parcel in 1995, they used the road to farm grapes, including watering the grape plants and spraying for weeds. The trial court found that "[t]he Gamboas and the Clarks both used the roadway as described above without any disputes until 2008. Each party was aware of the other's use of the roadway, but no one objected to the other's use until a dispute arose in 2008." A dispute arose over the Gamboas' dogs and the Clarks' irrigation practices, and "it eventually escalated into a dispute over which of them owned the land on which the roadway was situated." This case presented for the Supreme Court's review the issue of whether the Gamboas met one of the requirements of the rule that would allow them to continue using the road. Specifically, the Gamboas had to show that their use of the road was adverse to the Clarks. Since the evidence showed a reasonable inference that the Clarks let the Gamboas use the road out of "neighborly acquiescence," the Supreme Court held that the Gamboas did not show that their use of the road was adverse to the Clarks. Therefore, the Gamboas could not continue using the road. View "Gamboa v. Clark" on Justia Law

Patricia Doss filed a claim for workers' compensation with the Department of Labor and Industries after suffering chemical exposure during the course of employment with The Boeing Company. The exposure permanently aggravated her preexisting asthma, and she needed ongoing medical treatment as a result of these combined injuries. The Department determined that the combined effects of Doss's preexisting asthma and the aggravation of this condition during her Boeing employment rendered her permanently totally disabled. A right knee injury also contributed to Doss's preexisting disability. Due to her permanent total disability, the Department awarded Doss a pension. Boeing agreed to pay for the portion of the pension attributable to Doss' workplace injury but challenged the Department's order requiring it to pay for her postpension medical treatment. Boeing argued that the cost of this treatment should also be covered by the second injury fund. Boeing appealed to the Board. The issue this case presented for the Supreme Court's review centered on whether Boeing, as a self-insured employer, was entitled to second injury fund relief for a Doss' postpension medical costs. The Washington Supreme Court held that the plain language of the governing statutes did not allow a charge to the second injury fund for postpension medical treatment. Accordingly, the Court reversed the Court of Appeals. View "Boeing Co. v. Dep't of Labor & Indus." on Justia Law

Petitioner Ronald Wayne MacDonald entered into a plea agreement for second degree murder with the prosecutor in exchange for recommending a 5-year suspended sentence with 16 months' confinement in King County jail, with credit for time served. At sentencing, the prosecutor informed the court that the investigating officer wished to speak on behalf of the victim. The officer had remained involved throughout the plea negotiations, and the prosecutor intended for the officer to sit at counsel's table. The prosecutor asserted she did not know what the officer wanted to say. MacDonald objected, but the trial court permitted the officer to testify as a victim advocate. The officer then asked the court to impose the maximum sentence. The trial court gave MacDonald the maximum sentence, and the Court of Appeals affirmed. MacDonald moved to withdraw his plea. But because the trial court judge had retired, the motion was transferred to the Court of Appeals. The Court of Appeals denied the motion and affirmed MacDonald's conviction in an unpublished decision. Upon review, the Washington Supreme Court held that the investigating officer was functioning as a substantial arm of the prosecution and should not have been permitted to advocate against the plea bargain. Therefore, the State breached the plea agreement by undercutting the agreed sentencing recommendation. The Court reversed the Court of Appeals and remanded with instructions to permit MacDonald to either withdraw his guilty plea or seek specific performance of the plea agreement. View "Washington v. MacDonald" on Justia Law

The issue this case presented for the Supreme Court's review centered on whether the trial court closed the courtroom during trial in violation of the defendant's rights under article I, section 22 of the Washington Constitution. The Court of Appeals reversed respondent Benito Gomez's convictions for second degree murder and six counts of first degree assault on the grounds that the trial judge effected an unconstitutional closure of the courtroom during trial by his pretrial comment that the public would not be permitted to enter the courtroom once the proceedings began. The Supreme Court reversed after review: the Court disagreed that the trial judge, by mere virtue of making this remark, fully excluded the public from entering the courtroom and, thus, there was no basis for finding a constitutional violation; and second, even if the Court could presume the brief comment was enforced, this limitation to courtroom entry did not constitute a closure. View "Washingotn v. Gomez" on Justia Law