Justia Washington Supreme Court Opinion Summaries

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

The United States Bankruptcy Court for the Western District of Washington certified a question of Washington law to the Washington Supreme Court. The question centered on Washington's homestead exemption law, chapter 6.13 RCW, and whether it applied extraterritorially to real property located in other states. The Supreme Court responded in the negative: Washington's homestead exemption law did not apply to real property outside of Washington. View "In re Bankr. Pet. of Wieber" on Justia Law

The plaintiffs' complaint alleged that two groups of defendants, (1) Premera, Premera Blue Cross, and Life Wise Health Plan of Washington (collectively Premera) and (2) the Washington Alliance for Healthcare Insurance Trust and its trustee, F. Bentley Lovejoy (collectively WAHIT), colluded and made false and misleading representations to the plaintiffs that induced the plaintiffs to purchase health insurance policies under false pretenses. Plaintiff-policyholders claimed that Premera and WAHIT violated the Washington Consumer Protection Act (CPA). The plaintiffs requested only two specific forms of damages: (1) for the "unfair business practices and excessive overcharges for premiums," the plaintiffs requested "the sum of the excess premiums paid to the defendants;" and (2) "[i]f the surplus is excessive and unreasonable," the plaintiffs asserted that "the amount of the excess surplus should be refunded to the subscribers who have paid the high premiums causing the excess." On Premera and WAHIT's motion, the trial court dismissed the Policyholders' suit in its entirety based on the filed rate, primary jurisdiction, and exhaustion of remedies doctrines. Specifically, the trial court dismissed all claims of class B (small group) and class C (individuals) pursuant to CR 12(b )( 6) and dismissed all claims of class A (large group) on summary judgment under CR 56. The Court of Appeals reversed the trial court in relation to certain of the Policyholders' CPA claims. Because awarding the specific damages requested by the plaintiffs would require a court to inappropriately substitute its judgment for that of the Office of the Insurance Commissioner (OIC), the Supreme Court affirmed the trial court's dismissal of the plaintiffs' claims. View "McCarthy Fin., Inc. v. Premera" on Justia Law

This case involved two public school employees who were on paid administrative leave while their employer investigated allegations of misconduct. The substance behind those allegations was not in the trial court record, but the District's investigations were then-ongoing and entering their fourth year. In the spring of 2012, two media outlets submitted public records requests to the District. One request sought the "administrative leave letter given to Anthony Predisik, a Shadle Park High School counselor." The other request asked for "information on all district employees currently on paid/non-paid administrative leave." The requests returned three public records relevant to this dispute. The issue this case presented for the Supreme Court's review centered on whether public records that revealed these investigations are occurring, but do not describe the allegations being investigated, implicated the employees' privacy rights under the Public Records Act (PRA), chapter 42.56 RCW. The Court held they did not. Because no exemption applies to withhold the records from public inspection, the Court reversed and remanded with instructions to order the records at issue disclosed in their entirety without redaction. View "Predisik v. Spokane Sch. Dist. No. 81" on Justia Law

Matthew Bruch was convicted of two counts of second degree child molestation and two counts of third degree rape of a child. The trial court imposed a standard range sentence of 116 months of confinement and ordered community custody for a period of "at least 4 months, plus all accrued earned early release time at the time of release." Bruch appealed his sentence, arguing that the court-imposed term of community custody was indeterminate and may exceed the statutory requirement of three years of community custody required under RCW 9.94A.701(1). The Court of Appeals rejected Bruch's challenge, as did the Supreme Court: (1) the total sentence did not exceed the applicable statutory maximum, consistent with RCW 9.94A.701(9); . there was no need for the trial court to amend Bruch's sentence to limit community custody to a maximum of three years, "[t]he statutes must be read together to assure that the trial court's intended sentence-a total term of 120 months-is not undermined by giving effect to the DOC's authority to transfer earned early release into community custody." View "Washington v. Bruch" on Justia Law

Howard Shale was an enrolled member of the Yakama Nation. He had family in the Quinault Indian Nation as well. In 1997, Shale was convicted under federal law of raping a child under 12. After Shale was released from prison, he moved to Seattle and registered as a sex offender with the King County sheriff. In 2012, a Jefferson County sheriffs detective began investigating whether Shale had moved to her county without reregistering as a sex offender. At least two officers assisted the detective in her investigation; a Jefferson County sheriffs deputy and a Quinault tribal police officer. Taken together, police reports suggested Shale was dividing his time between the two family homes. Based on the detective's report, the Jefferson County prosecutor charged Shale with failure to register with the county sheriff as a sex offender under RCW 9A.44.130(1)(a). The issue this case presented for the Supreme Court's review was whether Washington State had the power to prosecute an enrolled member of the Yakama Nation living on the Quinault Indian Nation's reservation for failing to register with the county sheriff as a sex offender. The Court found the State indeed had that power. View "Washington v. Shale" on Justia Law