Justia Washington Supreme Court Opinion Summaries

This consolidated appeal consisted of two criminal cases. In each case, the jury convicted the defendant and found that aggravating circumstances were present. At sentencing, the trial courts deviated from the standard sentencing range and imposed exceptional sentences. While both trial courts explained on the record their reasons for deviating from the standard range, neither court entered written findings as required by statute. Both sentences were affirmed by the Court of Appeals in unpublished opinions. The issue these cases presented for the Supreme Court's review was whether an on-the-record oral ruling could substitute for written findings when a trial court imposes an exceptional sentence. After review, the Supreme Court concluded that oral findings do not satisfy the requirements of the Sentencing Reform Act of 1981. The cases were remanded for entry of written findings of fact and conclusions of law. View "Washington v. Friedlund" on Justia Law

In 2009, Maurice Clemmons shot and killed four Lakewood police officers. Petitioner Darcus Allen drove Clemmons to and from the crime scene and was charged as an accomplice. The issue on appeal to the Supreme Court was whether the prosecuting attorney committed prejudicial misconduct by misstating the standard upon which the jury could convict an accomplice. In a divided decision, the Court of Appeals recognized that the statements were improper but ultimately held that they did not amount to prejudicial misconduct. The Supreme Court disagreed and reversed the Court of Appeals. The case was remanded for a new trial. View "Washington v. Allen" on Justia Law

The issue this case presented for the Supreme Court's review centered on a challenge to the State Liquor Control Board's spirits distribution licensing fee structure brought by Association of Washington Spirits and Wine Distributors (Association). Specifically, the Association challenged the Board's decision to exempt distillers who distribute their own manufactured spirits and others acting as distributors pursuant to certificates of approval from contributing to a shortfall of $104.7 million in licensing fees imposed on persons holding spirits distributor licenses. The Association asked the Supreme Court to hold that the distillers must contribute proportionately to eliminating the shortfall. The Court rejected the Association's arguments, holding that the Board acted within its authority and did not act arbitrarily or capriciously. Additionally, the Board did not violate the privileges and immunities clause of article I, section 12 of the Washington State Constitution. View "Ass'n of Wash. Spirits & Wine Distribs. v. Liquor Control Bd." on Justia Law

A jury found defendant Joel Condon guilty of several offenses including aggravated first degree (premeditated) murder and first degree felony murder, stemming from his involvement in a home invasion robbery attempt. He argued on appeal that the evidence presented against him at trial was insufficient to support the jury's verdict, and that there were errors by the trial court in instructing the jury. The Court of Appeals found there was sufficient evidence of premeditation, but that it was error to deny Condon's request for an instruction on the lesser included crime. The Supreme Court affirmed the appellate court's judgment. View "Washington v. Condon" on Justia Law

In consolidated cases, the issue common to all and presented for the Supreme Court's review centered on whether guarantors of commercial loans whose own property have not been foreclosed are protected from deficiency judgments under the deeds of trust act (DTA) after the borrower's property has been foreclosed. The Supreme Court found they are not. View "Wash. Fed. v. Harvey" on Justia Law

Petitioners William Ralph and William Forth et al. (Forth) appealed the dismissal of their separate actions against the State of Washington Department of Natural Resources, Weyerhaeuser Company, and Green Diamond Resource Company (collectively DNR). They sought monetary damages for the flooding of real property located in Lewis County. At issue was the distinction between venue and jurisdiction, in the context of the applicable statutory authority that actions "for any injuries to real property" "shall be commenced" in the county in which the property is located, RCW 4.12.010(1). Case law from the 1940s and 1950s held that RCW 4.12.010 was jurisdictional, so that an improperly commenced action must be dismissed if filed in a superior court outside the local county. More recently, the Washington Supreme Court interpreted similar (but not identical) statutes to prescribe only venue in light of article IV, section 6 of the Washington State Constitution, which grants universal original subject matter jurisdiction to the superior courts. In dicta in "Five Corners Family Farmers v. Washington," (268 P.3d 892 (2011)), the Court suggested that it might reconsider earlier precedent. By its opinion in this case, the Court reconsidered that earlier precedent, and held that RCW 4.12.010 related to venue, not jurisdiction. Accordingly, the Court reversed the trial court's holding in this case and remanded for further proceedings. View "Ralph v. Dep't of Natural Res." on Justia Law

The issue central to this appeal centered on the filing of a type of report about a juvenile offender: whether a special sex offender disposition alternative (SSODA) evaluation should be filed in the official juvenile court file and therefore be open to the public. The legislature has explicitly defined the contents of the official juvenile court file as "the petition or information, motions, memorandums, briefs, findings of the court, and court orders." Since the SSODA evaluation does not fit within any of these categories, the Supreme Court held that it was not a part of the official juvenile court file. Consequently, it was subject to the general rule that all juvenile records not in the official juvenile court file must be kept confidential. View "Washington v. A.G.S." on Justia Law

The issue this case presented for the Supreme Court's review centered on whether a potential obstacle to public access constituted a courtroom closure: a sign that listed the courthouse hours. After a jury trial in Yakima County Superior Court, defendant Joey Andy was convicted of first degree burglary and second degree assault. He appealed, arguing that his right to a public trial right was violated when proceedings on some days continued after 4:00 p.m., despite a new 4:00 p.m. closing time for the courthouse. Pursuant to RAP 9.11, Andy moved to remand the case to the superior court to take "additional evidence to determine whether the courthouse doors were locked at 4 p.m. on the dates of the trial ... and if so, whether that closure barred entry to the ongoing courtroom proceedings." After review of the evidence, the Supreme Court concluded that at all times during Andy's trial proceedings, the door to the courthouse was unlocked and no member of the public was deterred from attending the proceedings by the sign. Therefore, the Court concluded that the sign did not constitute a courtroom closure and Andy's public trial right was not violated. View "Washington v. Andy" on Justia Law

Donald Martin was killed by a machine at a paper plant. His widow Nina Martin tried to sue the company that installed the machine, but that company no longer existed. Martin had difficulty discerning which company was responsible for the installation company's liability because the merger and acquisition history of the installation company was complicated. Because of that complicated history, Martin sued the incorrect company and did not realize who the responsible party was until after the statute of limitations period expired. The issue this case presented for the Washington Supreme Court's review centered on whether Martin met the requirements of the rule that allowed such plaintiffs to add the correct defendant after the statute of limitations period expired, and whether her inability to identify the correct defendant was due to inexcusable neglect. The Court held that it was not: the record did not show that the proper defendant's identity was easily ascertainable by Martin during the limitations period. Accordingly, the Court reversed the Court of Appeals. View "Martin v. Dematic" on Justia Law

In 2009, Maurice Clemmons shot and killed four Lakewood police officers. Clemmons contacted petitioners Eddie Davis and Letrecia Nelson shortly after the shootings. Based on their actions following that contact, petitioners were convicted of rendering criminal assistance and possessing a firearm. A divided Washington Supreme Court would have held that there was sufficient evidence presented at trial to support Davis' and Nelson's convictions for possession of a stolen firearm, and Davis' conviction for second degree unlawful possession of that firearm, but this was not the decision of the Court. The Court did hold that the aggravating factor found in RCW 9.94A.535(3)(r) could not justify an exceptional sentence for rendering criminal assistance as a matter of law. The result of three opinions of the Court for this case was to reversed the Court of Appeals and remanded for further proceedings. View "Washington v. Davis" on Justia Law