Justia Constitutional Law Opinion Summaries

The Benton County District Court ordered petitioner Briana Wakefield to pay $15 each month toward her outstanding legal financial obligations (LFOs). Wakefield was homeless, disabled, and indigent. Her only income was $710 in social security disability payments each month, and as a result, she struggled to meet her own basic needs. Wakefield and amici asked the Washington Supreme Court to reverse the district court's order and hold that the practice of strict LFO enforcement against homeless, disabled, and indigent people in Benton County violated state and federal statutes. Because the district court's order was contrary to both the law and the evidence in the record, the Supreme Court reversed: "Under state law, LFOs should be imposed only if an individual has a present or future ability to pay, and LFOs may be remitted when paying them would impose a manifest hardship on the person. . . . we order that her LFOs be remitted." View "City of Richland v. Wakefield" on Justia Law

The issue this case presented for the Supreme Court's review centered on the circumstances officers making a lawful arrest may seize a companion of the arrestee in the absence of reasonable suspicion to independently justify a "Terri" stop of the companion. The Court held that where officers have an objective rationale predicated on safety concerns to seize a companion to secure the scene of the arrest, article I, section 7 of the Washington State Constitution allowed for the seizure, so long as it remained reasonable in scope and duration. Based on this holding, the Court reversed the Court of Appeals and held that evidence of a gun taken from respondent Cody Flores during his brief seizure should not have been suppressed. View "Washington v. Flores" on Justia Law

In 2000, the Department of Retirement Systems (DRS) created a new option for eligible retirees in which the retiree could opt for a pension that would allow a surviving spouse to continue to receive monthly pension benefits at the same amount after the retiree's death. To make this pension actuarially equivalent in value to the previous pension, the DRS provided for a greater reduction in the retiree's monthly benefits. In 2010, the DRS adopted rules that modified the degree of the actuarial reduction. Appellant Tim Lenander challenged the changes to the reduction, arguing that the changes violated the statutory scheme and impaired his contract right to a lower reduction in his pension payment. The Supreme Court found Lenander's arguments unavailing, holding that the DRS acted within its authority in amending the survivor benefit actuarial reduction regulations as set forth under former WACs 415-02-380 (2010) and 415-103-215 (2010). In amending these regulations, the DRS did not violate the contract clause of article I, section 23 of the Washington Constitution. Consequently, the Court held that the DRS did not infringe on Lenander's right to an "actuarial equivalent" survivor benefit, and that Lenander did not suffer substantial impairment to his pension contract rights. View "Lenander v. Dep't of Retirement Sys." on Justia Law

Petitioner Michael Goss argued that the charging document the State used to accuse him of second degree child molestation failed to pass constitutional muster because it violated his right to know the "nature and cause of the accusation" made against him, and failed to give notice of every fact that increased any penalties he faced. Specifically, Goss contended the State's charging document failed to allege that the victim was "at least twelve years old," the lower limit of the age range for that degree of the crime. After review, the Supreme Court affirmed, holding that the fact that the victim was "at least twelve years old" was not an essential element of second degree child molestation, and that Goss had notice of every fact that exposed him to a greater penalty. View "Washington v. Goss" on Justia Law

Petitioner Adrian Sutlej Samalia fled on foot from a stolen car during a lawful traffic stop, leaving his cell phone behind in the vehicle. After Samalia successfully escaped, the police searched the cell phone without a warrant and made contact with one of the numbers stored in the cell phone. That contact led to Samalia's identification as the owner of the phone and driver of the stolen vehicle. The State used this evidence against Samalia at trial. Samalia contends that his right to be free from unreasonable searches was violated when the State introduced the identification evidence derived from the search of his cell phone. After review, the Washington Supreme Court held that although Samalia initially had a constitutionally protected privacy interest in the cell phone and its data, he abandoned that interest when he voluntarily left the cell phone in a stolen vehicle while fleeing from a lawful traffic stop. Accordingly, the Court affirmed the Court of Appeals. View "Washington v. Samalia" on Justia Law

A city of Lakewood police officer saw petitioner Robert Willis walk into the traffic lanes at Interstate 5's (I-5) northbound exit ramp on Gravelly Lake Drive. Willis carried a sign saying he was disabled and needed help. The officer issued Willis a criminal citation, not for walking into the traffic lane, blocking traffic, or disrupting pedestrian or vehicle progress, but for begging. Willis raised several challenges to the anti-begging ordinance under which he was charged (and later convicted). After review, the Washington Supreme Court found that Willis could challenge LMC 9A.04.020A(1) and (2) as facially overbroad regardless of his own conduct when cited. Because both provisions imposed a content-based speech restriction in a substantial number of traditional public forums, Willis' facial challenge succeeds. Thus, his conviction was reversed and the matter remanded for further proceedings. View "City of Lakewood v. Willis" on Justia Law

Two police officers were dispatched to defendant Sayiden Mohamed's residence to follow up on several 911 hang-up calls that had originated from the house. Upon speaking with him, the officers observed that defendant was intoxicated but determined that no further action was needed. Shortly after ending the initial contact, the officers received information that there was an outstanding warrant for the defendant's arrest. When the officers returned to carry out the arrest, the defendant became hostile and belligerent and resisted the officers' attempts to place him in the patrol car. While the officers were in the process of forcibly subduing him until backup arrived, defendant spit in both of the officers' faces. He continued to spit at the officers even after a spit mask was placed over his head. Once defendant was restrained, the officers were able to place him in the patrol car and take him to jail. Defendant was charged with two counts of third degree assault for spitting on the arresting officers. The issue this case presented for the Supreme Court's review was whether it was permissible to impeach a hearsay declarant with his or her prior convictions under certain circumstances. In this case, defendant did not testify and his own out-of-court statements were admitted into evidence through his expert witness' testimony. Defense counsel expressly declined a limiting instruction offered by the trial court regarding the purpose of defendant's statements. The State then cross-examined the expert witness with the defendant's previously admitted prior convictions pursuant to ER 806. Defendant contended that his out-of-court statements were not admitted for the truth of the matter asserted, barring impeachment pursuant to ER 806. Because defense counsel declined an instruction that would have limited the evidence to its proper purpose, the Supreme Court held that the statements were also offered for their truth and that impeachment of the defendant's credibility was therefore permissible pursuant to ER 806. Consequently, the Court reversed the Court of Appeals and reinstated the convictions. View "Washington v. Mohamed" on Justia Law

Petitioner Clark Stuhr was in the custody of Department of Corrections (DOC), serving two consecutive sentences imposed pursuant to the Sentencing Reform Act of 1981 (SRA). As penalties for Stuhr's serious disciplinary infractions, DOC revoked potentially available good conduct time for both of his sentences. Stuhr filed a personal restraint petition (PRP), arguing that this loss of potential good conduct time violated statutory and constitutional law. The Supreme Court disagreed and therefore denied relief. View "In re Pers. Restraint of Stuhr" on Justia Law

Baron Ashley Jr. appealed his conviction for unlawful imprisonment with domestic violence. At trial, the State introduced evidence of Ashley's prior acts of domestic violence against the victim pursuant to ER 404(b). The Washington Supreme Court held that the evidence was properly admitted for the purpose of establishing an element of the charged crime but that the trial court erred in admitting the evidence for the purpose of bolstering the witness's credibility. However, because the Supreme Court held that the error was harmless, it affirmed the Court of Appeals. View "Washington v. Ashley" on Justia Law

The State challenged a Court of Appeals decision reversing Clifford Porter's conviction for possession of a stolen motor vehicle. Pursuant to a search warrant, police discovered portions of a stolen vehicle on Porter's property. At the close of trial, the jury convicted Porter as charged. On appeal, Porter argued for the first time that his conviction should be overturned because the charging document was constitutionally deficient for failing to allege that Porter withheld or appropriated the vehicle from the true owner. Specifically, Porter argued that his conviction should be overturned because the charging document omitted an essential element of the offense of possession of a stolen motor vehicle: RCW 9A.56.140(1 )'s provision stating that possession means to "'withhold or appropriate [stolen property] to the use of any person other than the true owner or person entitled thereto."' The State contended the information need not include the "withhold or appropriate" language because it merely defined the essential element of possession and was not itself an essential element. The Supreme Court concluded the State had the better argument, and reversed the Court of Appeals' decision. View "Washington v. Porter" on Justia Law