Justia Constitutional Law Opinion Summaries

Articles Posted in Washington Supreme Court

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Police were dispatched to petitioner Michael Boisselle's home after two anonymous 911 calls reported that a man named Mike shot and possibly killed someone at the residence. While responding to the calls, officers learned the residence was related to an ongoing missing person/homicide investigation. Unable to determine whether someone was alive inside the home, officers entered the residence and conducted a warrantless search, discovering evidence of a murder therein. Boisselle moved to suppress the evidence, arguing the officers' warrantless search was unlawful under article I, section 7 of the Washington Constitution. The trial court denied Boisselle's motion, concluding that the officers' search fell within the emergency aid function of the community caretaking exception to the warrant requirement. Boisselle was convicted by jury of second degree murder and second degree unlawful possession of a firearm. The Court of Appeals affirmed his convictions. The Washington Supreme Court found the officers’ warrantless search of Boisselle's home was a pretext for a criminal investigation because the officers had significant suspicions of criminal activity, the officers' entry was motivated by the desire to conduct an evidentiary search, and there was no present emergency. Accordingly, the search did not fall within the emergency aid function of the community caretaking exception, and thus violated article I, section 7. Therefore, the Court held the trial court’s findings of fact did not support its conclusions of law and the trial court erred in denying Boisselle's motion to suppress. The Court of Appeals’ judgment was reversed and the case remanded back to the trial court for further proceedings. View "Washington v. Boisselle" on Justia Law

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A.M. (juvenile) appealed an unpublished Court of Appeals decision affirming her conviction for possession of a controlled substance. She argued: (1) it was manifest constitutional error for the trial court to admit a detention center inventory form where she signed a sworn statement indicating that a backpack, which was discovered to contain methamphetamine, was her property because it violated her right against self-incrimination; and (2) the affirmative defense of unwitting possession was an unconstitutional burden-shifting scheme that violated her due process rights. After review, the Washington Supreme Court held the admission of the inventory form was manifest constitutional error because it violated her right against self-incrimination and warranted reversal because it was not harmless error. Because the Court found reversible constitutional error, it declined to consider A.M.'s due process argument. The case was remanded back to the trial court for further proceedings. View "Washington v. A.M." on Justia Law

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Four defendants’ cases were consolidated for review by the Washington Supreme Court. In each case, the defendant had been labeled a “persistent offender” under RCW 9.94A.570 and was sentenced. Under the Washington Persistent Offender Accountability Act (POAA), the third time a person is convicted of a “most serious offense,” they were sentenced to life imprisonment without the possibility of parole (the so-called “three strikes and you’re out” law). The question presented to the Supreme Court was whether it was constitutional to apply the POAA to people who were in their 30 or 40s when they committed their third strike, but were young adults when they committed their first strike. The Supreme Court held it was constitutional: Article I, section14 of the Washington Constitution did not require a categorical bar on sentences of life in prison without the possibility of parole for fully developed adult offenders who committed one of their prison strikes as young adults. Furthermore, the Court did not find the sentences each defendant received was grossly disproportionate to their respective crimes. View "Washington v. Moretti" on Justia Law

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In 2014, Matthew McCarthy approached a stranger's home under a mistaken belief that he would find his ex-wife inside. He forced his way in and pushed the occupant against the wall. He returned twice the next evening: the first time once again looking for his ex-wife and the second time looking for his cell phone. Out of these events, the State charged McCarthy with first-degree burglary predicated on assault.The State notified him that this was a most serious offense and that he was facing life in prison without parole due to his criminal history. Prior to McCarthy's arraignment, his public defender expressed her concerns to the court that regarding McCarthy's competency to stand trial. The trial court ordered a competency evaluation and stayed the proceedings. McCarthy objected to the initiation of competency proceedings against his will because he believed himself to be competent. McCarthy was diagnosed with bipolar disorder with nonbizarre delusions, and various substance abuse disorders. While the physician-evaluator initially found McCarthy had a detailed understanding of the legal proceedings, on second review McCarthy was deemed incompetent, and a 90-day restoration was ordered. At issue before the Washington Supreme Court was: (1) whether under RCW 10.77.060(1)(a), the trial court erred during trial, in not ordering a third competency hearing after a jury had previously found McCarthy competent; and (2) what deference, if any, is given to a trial court when it does not sua sponte order a competency hearing. The Washington Supreme Court reversed the Court of Appeals, finding the proper standard of review was abuse of discretion, and the trial court did not abuse its discretion when it did not sua sponte order a competency evaluation based on the evidence presented during the criminal proceedings. The matter was remanded for the appellate court to decide the remaining issues raised in McCarthy's personal restraint petition. View "Washington v. McCarthy" on Justia Law

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Widower, 82-year-old Leroy Bagnell met 57-year-old defendant Theresa Scanlan in a bar. At first she was introduced to Bagnell's adult children as a friend, later he began referring to her as his girlfriend. In 2014, police responded to a 911 hang-up call made from Bagnell's house. Scanlan answered the door. Police saw Bagnell at the top of the stairs in his underwear, head and forearm bleeding, and a "big, bloody, and bruised lump" on his leg. As a result of that contact, a domestic violence no contact order was issued prohibiting Scanlan from coming within 1,000 feet of Bagnell's house. Bagnell did not seek medical care for his injuries. Months after the no contact order, Bagnell's children checked on their father at the house: they found blood in the entryway, along the walls, and found shattered glass and ceramic on the kitchen floor. They discovered Bagnell in the family room severely bruised from head to toe. The children called 911. Scanlan was found in the garage underneath a blanket in her car with the doors locked. Scanlan was taken into custody; Bagnell was taken to the emergency room, where providers determined in addition to the extensive bruising, Bagnell had two broken fingers, and several skin tears on his legs and arms. Scanlan was charged with second degree assault, felony violation of a no contact order, unlawful imprisonment, and fourth degree assault. Neither Bagnell nor Scanlan testified at trial, but the court admitted several statements Bagnell made to his medical providers. The issue this case presented for the Washington Supreme Court's review centered on whether a crime victim's statements to his medical providers were testimonial, and if so, whether their admission at trial violated the defendant's right of confrontation under the Sixth Amendment. The Supreme Court held the victim's statements were nontestimonial in this case, because they were not made with the primary purpose of creating an out-of-court substitute for testimony. View "Washington v. Scanlan" on Justia Law

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Brendan Taylor was charged with felony violation of a no-contact order. Before trial, Taylor offered to stipulate to the fact that a domestic violence no-contact order was in place, and that he knew of the order. The trial court rejected the stipulation, and admitted the no-contact order into evidence. The trial court reasoned that Old Chief v. United States, 519 U.S. 172 (1997) did not apply to the admission of a domestic violence no-contact order. The jury convicted Taylor, but the Court of Appeals reversed, holding that Old Chief applied, and required the trial court exclude the no-contact order from evidence. In an issue of first impression, the Washington Supreme Court concluded Old Chief did not apply, and reversed the Court of Appeals. View "Washington v. Taylor" on Justia Law

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A jury convicted petitioner Tomas Berhe of murder and assault. After the trial, juror 6 came forward, alleging that racial bias during jury deliberations influenced the verdict. The trial court denied Berhe's motion for a new trial without an evidentiary hearing, instead relying solely on written declarations prepared with the aid of counsel. The Washington Supreme Court recognized that when allegations of juror misconduct arise after the verdict, trial courts have discretion to determine whether an evidentiary hearing is necessary. “However, there are limits to that discretion, particularly in cases of alleged racial bias that deprives a defendant of his or her constitutional right to a. fair trial by an impartial jury.” In this case, the Supreme Court determined the trial court: (1) did not exercise sufficient oversight of the process, allowing counsel to taint several jurors with inappropriate questions about their deliberations; and (2) the court did not conduct a sufficient inquiry before determining that an evidentiary hearing was unnecessary. The Supreme Court therefore vacated the trial court's order denying Berhe's motion for a new trial and remanded for further inquiry and other proceedings as necessary. View "Washington v. Berhe" on Justia Law

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A drunk driver hit and disabled another vehicle, then fled. A Good Samaritan stopped to help the struck vehicle; while helping, the Good Samaritan was fatally injured when a second vehicle did not see the disabled vehicle in time to avoid striking it, pushing the disabled vehicle into the Good Samaritan, ultimately killing him. The issue this case presented for the Washington Supreme Court's review was whether the drunk driver's acts were too attenuated from the Good Samaritan's death for criminal liability to attach. The Supreme Court concluded the drunk driver's (Joshua Frahm) acts were the legal cause of the Good Samaritan's death, because those acts were criminal, cause direct harm as well as risk of further harm, and occurred close in time and location to the ultimate harm that befell the Good Samaritan. Furthermore, the Court concluded the issue of intervening, superseding cause was proper for the jury to determine as a matter of actual cause using a reasonable foreseeability standard, and that the vehicular homicide conviction was supported by sufficient evidence. Frahm's conviction was affirmed. View "Washington v. Frahm" on Justia Law

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Seattle voters approved the "Democracy Voucher Program," intending to increase civic engagement. Recipients could give their vouchers to qualified municipal candidates, who could redeem those vouchers for campaign purposes. The city would find the program through property taxes. Mark Elster and Sarah Pynchon sued, arguing the taxes funding the program was unconstitutional. Because the program did not violate the First Amendment, the Washington Supreme Court affirmed. View "Elster v. City Of Seattle" on Justia Law

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Petitioner Shacon Barbee "was a pimp who made money from prostitutes working under his supervision." He was convicted of multiple crimes, including the sexual abuse of minors, leading organized crime, and theft. Barbee had two sentencing hearings: (1) an initial hearing in 2013; and (2) a resentencing on remand in 2017. The issue his case raised for the Washington Supreme Court's review was whether which sentencing hearing was to be used as the basis for restitution. RCW 9.94A.753(1) holds restitution had to be determined within 180 days of "the sentencing hearing." The Court of Appeals held in this case the operative "sentencing hearing" was the 2017 hearing. The Supreme Court concurred and affirmed the appellate court's judgment. View "Washington v. Barbee" on Justia Law