Justia Washington Supreme Court Opinion Summaries

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

Petitioner Phillip Garcia Jr. appealed his convictions for kidnapping in the first degree, burglary in the second degree, and criminal trespass in the first degree. He argued that that the evidence was insufficient to support each of the alternative means of kidnapping presented to the jury, that the trial court violated his confrontation rights by limiting his cross-examination of an adverse witness, that the trial court erroneously admitted evidence of a prior crime of dishonesty, and that the prosecutor incorrectly defined "burglary" during closing arguments. Upon review of the trial court record, the Supreme Court reversed petitioner's convictions for kidnapping in the first degree because there was insufficient evidence to support that conviction. The Court reversed the conviction for burglary in the second degree because of prejudicial trial error. But the Court affirmed his conviction for criminal trespass in the first degree because the errors petitioner claimed were harmless. View "Washington v. Garcia" on Justia Law

The State prosecuted petitioner David Gower for sex crimes against his 17-year-old stepdaughter S.E.H. In accordance with ER 404(b) and RCW 10.58.090, the State offered evidence that petitioner had committed other similar crimes against two other alleged juvenile victims, C.M. (his biological daughter) and J.K. (another stepdaughter). In a pretrial evidentiary hearing on the admissibility of that evidence, the trial court ruled it was all inadmissible under ER 404(b). But the trial court acknowledged that admissibility of that evidence under RCW 10.58.090 was a separate question and concluded that although the evidence of other sex offenses was inadmissible under ER 404(b), the evidence of the prior crimes relating to C.M. was admissible under RCW 10.58.090. In 2009, between the statute's enactment arid subsequent invalidation in 2012, the trial court admitted evidence of petitioner's prior sex offenses against him at trial. He was ultimately convicted. Because that evidence was improperly admitted and considered by the trial judge in finding petitioner guilty, the Supreme Court reversed his conviction and remanded the case for a new trial. View "Washington v. Gower" on Justia Law