Justia Washington Supreme Court Opinion Summaries

In 1993, petitioner Lindsey Crumpton was convicted of five counts of first degree rape and one count of residential burglary. In 2011, he petitioned the court for post-conviction deoxyribonucleic acid (DNA) testing. The superior court denied this motion, saying he had not shown a '"likelihood that the DNA evidence would demonstrate his innocence on a more probable than not basis"' as is required by RCW 10.73.170(3). The Court of Appeals affirmed. The issue this case presented for the Supreme Court's review was the standard the court should use to decide a motion for post-conviction DNA testing and whether a court should presume DNA evidence would be favorable to the convicted individual when determining if it is likely the evidence would prove his or her innocence. The Court held that a court should use such a presumption. View "Washington v. Crumpton" on Justia Law

Petitioner Abraham MacDicken was arrested carrying a laptop bag and pushing a rolling duffel bag. He was suspected of armed robbery. The officers moved the bags a car's length away to search them. MacDicken argued that search violated his state and federal constitutional rights. The Supreme Court recently held that police may search an arrestee's person and possessions closely associated with the person at the time of arrest without violating constitutional rights; MacDicken argued the bags were not closely associated with him at the time of arrest to give police the right to search them without a warrant. The Supreme Court disagreed held the police conducted a valid search. View "Washington v. MacDicken" on Justia Law

A police detective spent five to ten minutes looking at a cell phone taken from Daniel Lee incident to his arrest for possession of heroin. The officer saw several text messages from appellant Jonathan Roden, responded to one of Roden's messages with a new message, and set up a drug deal. When Roden arrived to complete the deal, officers arrested. On appeal of his eventual conviction, Roden contended that the officer's conduct violated the state privacy act and the state and federal constitutions. Upon review, the Supreme Court agreed that the state privacy law was violated when the officer intercepted the private text message without Lee's or Roden's consent or warrant. Accordingly, the Court reversed the Court of Appeals' decision and Roden's conviction. View "Washington v. Roden" on Justia Law

A police detective read text messages on a cell phone police seized from Daniel Lee, who had been arrested for possession of heroin. Among other things, the detective read an incoming text message from Shawn Hinton, responded to it posing as Lee, and arranged a drug deal. Hinton was consequently arrested and charged with attempted possession of heroin. Hinton argued on appeal of his conviction that the detective's conduct violated his rights under the state and federal constitutions. Upon review, the Supreme Court agreed that Hinton's rights were violated when the officer intercepted the private text message without Lee's or Hinton's consent or warrant. Accordingly, the Court reversed the Court of Appeals' decision and Hinton's conviction. View "Washington v. Hinton" on Justia Law

The issue before the Supreme Court in this case was whether the Department of Ecology erred in determining that no environmental impact statement (EIS) was necessary for a proposed energy cogeneration project, and failed to adequately consider the effects of carbon dioxide emissions and demand for woody biomass from the state's forests. In addition, the issue on appeal centered on whether the project was exempt from the EIS requirement as part of an energy recovery facility that existed before January 1, 1989. After review, the Supreme Court concluded Ecology adequately reviewed the relevant information in determining that the project would not have significant impacts on the environment, and the project was exempt from the EIS requirement. View "PT Air Watchers v. Dep't of Ecology" on Justia Law

The Washington Department of Retirement Services (DRS) and the State of Washington appealed an order granting summary judgment to a class of public employee unions and unaffiliated employees and holding that the 2011 repeal of legislation granting future uniform cost of living adjustments (UCOLA) to the respondents' monthly pension payments was an unconstitutional impairment of the State's contractual obligation with its employees. The Supreme Court found that because the legislature reserved its right to repeal the pension rights at issue and the original enactment of UCOLA did not impair any existing contract rights of state employees. Accordingly, the Supreme Court reversed. View "Wash. Educ. Ass'n v. Dep't of Ret. Sys." on Justia Law

The issue this case presented to the Supreme Court was whether the Washington legislature's 2007 repeal of gain sharing-a pension enhancement provided in years of extraordinary investment return-unconstitutionally impaired the contract between the State and its employees. The Court held that the legislature reserved its right to repeal a benefit in the original enactment of that benefit and the enactment did not impair any preexisting contractual right. As to the employees' alternative argument, the Court held that the explanatory materials provided by the Department of Retirement Systems (DRS) do not rise to the level of making a promise or creating an inconsistent statement and thus reject the employees' contention that the state was estopped from repealing the gain-sharing benefit at issue in this case. Accordingly, the Court reversed the trial court's award of summary judgment to the employees. View "Wash. Educ. Ass'n v. Dep't of Ret. Sys." on Justia Law

In early 2013, Pierce County detained the 10 respondents in this case (all patients) under the Involuntary Treatment Act (ITA). In most cases, the respondents were initially held in hospital emergency rooms or in local acute care medical hospitals. None of these sites were certified as evaluation and treatment centers under the ITA. In all cases, the county, through one of its designated mental health providers, filed petitions to hold the respondents for up to 14 more days. Several of the involuntarily detained patients moved to dismiss these 14-day petitions on the grounds that they had not been, and believed they would not be, detained in a certified evaluation and treatment facility. A trial judge found that the patients' placement in uncertified treatment centers, a/k/a "psychiatric boarding," was unlawful. Pierce County appealed, but the Supreme Court agreed with the trial judge and affirmed. View "In Re Det. of D.W." on Justia Law

In this case, the trial court granted a new trial after Edwin Hawkins produced new evidence that supported his defense theory that he was framed for possessing stolen farm equipment. The Court of Appeals did not give that decision its proper deference. The Supreme Court reversed because the trial court did not abuse its wide discretion in awarding Hawkins a new trial. View "Washington v. Hawkins" on Justia Law

Plaintiffs worked as night janitors for subcontractors in various Puget Sound Fred Meyer grocery stores. They alleged that they regularly worked well over 40 hours per week without being paid either minimum wage or overtime as required by Washington's Minimum Wage Act (MWA). The issue this case presented to the Washington Supreme Court was whether Fred Meyer Stores Inc. and Expert Janitorial LLC were joint employers of the janitors for purposes of the Act. While the Supreme Court had never specifically held that the "joint employer" doctrine was a viable theory under the MWA, consistent with the interpretations of the federal Fair Labor Standards Act (FLSA), liability under minimum wage laws may extend to "joint employers" even when there is no formal employment relationship. The trial court dismissed the plaintiffs' joint employer claims against Fred Meyer and Expert, a middleman, at summary judgment. The Supreme Court found that summary judgment was improperly granted and remanded for further proceedings. View "Becerra Becerra v. Expert Janitorial, LLC" on Justia Law