Justia Washington Supreme Court Opinion Summaries

KOMO-TV news reporter Tracv Vedder made three unsuccessful public records requests to the Seattle Police Department (SPD) relating to "dash-cam" videos taken by SPD officers. The Supreme Court concluded that two of the requests should have been granted. The Court found that the SPD complied with the Public Records Act when it declined Vedder's request for officer log sheets, but failed to comply when it failed to produce a list of retained videos. The case was remanded to the trial court for further proceedings. View "Fisher Broadcasting. v. City of Seattle" on Justia Law

The issue this case presented to the Supreme Court centered on the proper assignment of the burden of proof at a pretrial competency hearing following treatment designed to restore competency. The trial court placed the burden on respondent Blayne Coley to prove his incompetence. The Court of Appeals reversed, holding that the burden rested with the State to prove restoration of competency and that the trial court's mistake created structural error. Upon review of the matter, the Supreme Court reversed the Court of Appeals and held that the relevant statute, interpreted by its language, the context of the provision, the statutory scheme as a whole, and related provisions, placed the burden on the party contesting competency where, after an evaluation ordered under RCW 10.77.060, the individual has been evaluated as competent. Furthermore, the Court held that the trial court did not abuse its discretion by declining to rule on Coley's requests to proceed prose pending a competency determination, and that Coley's request after he was deemed competent to stand trial, and therefore eligible for self-representation, was equivocal. View "Washington v. Coley" on Justia Law

Robert Campbell quit his job as a school teacher in anticipation of accompanying his wife to Finland on her Fulbright grant. Campbell applied for unemployment benefits for the months between his resignation in June 2010 and his family's planned departure in February 2011. His request was denied because the Department of Employment Security determined that Campbell did not qualify for benefits as claimed under RCW 50.20.050(2)(b)(iii), known as the "quit to follow" provision. On appeal, the superior court reversed, but the Court of Appeals reinstated the agency action. The Supreme Court affirmed the Court of Appeals and held that Campbell's resignation from his job seven months before the planned relocation was not reasonable as contemplated by the statute. View "Campbell v. Dep't of Emp't Sec." on Justia Law

Appellants James Kumar, Ranveer Singh, Asegedew Gefe, and Abbas Kosymov brought a class action lawsuit against their employer, Gate Gourmet Inc., alleging two common law torts and two violations of Washington's Law Against Discrimination (WLAD). The lawsuit stemmed from Gate Gourmet's employee meal policy, which barred employees from bringing in their own food for lunch (for security reasons), leaving only employer-provided food for the employees to eat. According to plaintiffs, the policy forced them to work without food or eat food that violated their religious beliefs. The meals ostensibly consist of one vegetarian and one meat-based main dish. The employees alleged that Gate Gourmet used animal by-products in the "vegetarian" option, and despite switching to turkey for a meat-based option, the company reverted to using a beef/pork mixture in violation of others' religious dietary restrictions. The complaint, therefore, alleged that Gate Gourmet deceived "putative class members [to] unknowingly eat[ing] food forbidden by their beliefs," and that class members "have faced the choice of eating food forbidden by their sincerely held beliefs or not eating. Those that did consume meals, they argued, suffered offensive touching due to their contact with food prohibited by their beliefs, and suffered distress as a result." The trial court granted in full Gate Gourmet's CR 12(b)(6) motion to dismiss, finding that the WLAD contained no requirement that employers make reasonable accommodations for their employees' religious practices. The Washington Supreme Court granted direct review and reversed. The Court held that the WLAD created a cause of action for failure to reasonably accommodate an employee's religious practices. With regard to plaintiffs' tort claims, the Court found the trial court dismissed them at the pleading stage, and the tort claims went without analysis. "In light of this fact and in light of Washington's relatively liberal standard for stating a cognizable claim," the Court remanded the case back to the superior court for further proceedings. View "Kumar v. Gate Gourmet, Inc." on Justia Law

This case arose out of an incident of domestic violence committed by petitioner Edward Olsen against the mother of his children, Bonnie Devenny. Olsen broke into Devenny's house, poured gasoline on her while she was sleeping, and told her that she was going to die. Olsen had a history of threatening and committing acts of domestic violence against Devenny, including a California conviction for terrorist threats for which he pleaded no contest. During the California incident, Olsen allegedly wrapped duct tape around Devenny's legs and told her that he was going to kill her, cut her up into little pieces, and put the pieces in a plastic storage container. The issue this case presented to the Washington Supreme Court was Washington's treatment of foreign convictions for sentencing purposes in light of "Descamps v. United States" (133 S. Ct. 2276) (2013)). Olsen's offender score at sentencing was six and he received an exceptional sentence of 360 months. Olsen claimed that a foreign conviction for terrorist threats was not comparable to Washington's felony harassment and should not have been included in his offender score. The Court of Appeals affirmed Olsen's convictions and sentence. The Supreme Court affirmed the Court of Appeals. View "Washington v. Olsen" on Justia Law

Erick Jordan appealed the Court of Appeals' decision affirming his convictions and sentence for second degree murder with a firearm enhancement and first degree unlawful possession of a firearm. At issue was whether differences between self-defense standards in Washington and Texas barred a sentencing court from finding that manslaughter convictions in these states were legally comparable. The Washington Supreme Court held they did not and affirmed the lower court. View "Washington v. Jordan" on Justia Law

In 2008, Clinton Morgan was awaiting a civil commitment trial to determine if he was likely to engage in predatory acts of sexual violence if not confined to a secure facility. Defense counsel became concerned that Morgan (who had been diagnosed with schizophrenia) was exhibiting psychotic symptoms. Morgan's counsel requested a competency determination and sought an order for involuntary medication to control Morgan's delusions during trial. The trial judge determined that Morgan was incompetent, appointed a guardian ad litem to represent his interests, and ordered involuntary medication. His trial followed, and the jury unanimously found him to be a sexually violent predator. He was confined in the Special Commitment Center. Morgan appealed, arguing that he had due process rights to be competent during a sexually violent predator trial and arguing that a pretrial in-chambers conference violated his right to a public trial. Finding no grounds to disturb the trial court's decision, the Supreme Court affirmed his commitment. View "In re Det. of Morgan" on Justia Law

AllianceOne Receivables Management Inc. instituted a collections action against William Carl Lewis Jr. and then voluntarily dismissed it. Lewis claimed he was entitled to attorney fees as the "prevailing party" under RCW 4.84.250 and .270 since under RCW 4.84.270 a defendant is a prevailing party when the plaintiff "recovers nothing." The district court denied Lewis' fee request, holding that there is no prevailing party for the purposes of an award of attorney fees when the plaintiff voluntarily dismisses the action. Finding no reversible error, the Supreme Court affirmed. View "AllianceOne Receivables Mgmt., Inc. v. Lewis" on Justia Law

This case arose from the legal defense of Maribel Gomez against charges of manslaughter and homicide by abuse for the death of her son. She argued she received ineffective assistance of counsel under the Sixth Amendment to the United States Constitution in the preparation and presentation of her defense. Upon review of the gruesome facts surrounding the child's death and the Gomez's manslaughter trial, the Supreme Court concluded Gomez did not meet her burden of proving ineffective assistance of counsel: "[t]he trial court transcripts paint a picture of a supremely fair trial at which Gomez was represented by a highly competent attorney. Having received a fair trial with effective attorney assistance, the State was able to prove all elements of homicide by abuse." View "In re Pers. Restraint of Gomez" on Justia Law

The trial court excluded defendant Andre Franklin's proffered evidence that someone else committed the cyberstalking-related crimes with which he was charged. The Supreme Court reversed: "the United States Constitution bars the trial court from considering the strength or weakness of the State's case in deciding whether to exclude defense-proffered other suspect evidence. [. . .] our cases hold that if there is an adequate nexus between the alleged other suspect and the crime, such evidence should be admitted. The trial court violated both of these rules: it considered the strength of the State's case against the defendant and it applied a per se standard to exclude the other suspect evidence. Thus, its exclusion of the proffered other suspect evidence was error under both our case law and our constitution." View "Washington v. Franklin" on Justia Law