Justia Constitutional Law Opinion Summaries

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

Jennifer Holmes and James Lindsay entered the home of Laurence Wilkey, Holmes's former boyfriend. They tied him up, beat him, and took a number of items from his home. The State charged Holmes and Lindsay with first degree robbery, burglary, kidnapping, assault, and firearm theft. Holmes and Lindsay argued that they did not intend to commit a felony but were instead repossessing things that Wilkey had originally stolen from Holmes. A jury convicted them on most, but not all, counts. On appeal, Holmes and Lindsay argued that the prosecutor's remarks, particularly during closing arguments, constituted misconduct that prejudiced both defendants. The Court of Appeals agreed that the prosecutor committed misconduct but split as to whether that misconduct caused prejudice. "[G]iven the magnitude of the problem and the lawyers' inability to control their conduct," the Supreme Court agreed with the Court of Appeals' dissent and reversed the trial court. View "Washington v. Lindsay" on Justia Law

The issue this case presented to the Supreme Court was whether Samuel Piatnitsky unequivocally invoked his right to remain silent when he told police investigating a murder that, "I don't want to talk right now" but that he would "write it down." The Court concluded that it was, "at best," an equivocal invocation of the right to remain silent, and thus, the trial judge did not err in admitting Piatnitsky' s written confession. View "Washington v. Piatnitsky" on Justia Law

Petitioner Cesar Trochez-Jimenez appealed his conviction for murder in the second degree, arguing the statements he made during custodial interrogation should have been suppressed because they were taken in violation of his Miranda rights. The case law petitioner cited on appeal held that prior to custodial interrogation, a suspect must be informed of his right to remain silent and right to counsel, and once the suspect invokes his right to counsel, no further interrogation about any offense by any authorities could be conducted until counsel was present or the suspect initiated communication. These cases, however, involved only domestic investigations regarding domestic crimes. At issue before the Supreme Court was whether the same rule applied when a suspect requests an attorney during an interrogation conducted outside the United States by foreign authorities regarding a foreign crime. Both the trial court and Court of Appeals said it did not. The Supreme Court agreed and affirmed. View "Washington v. Trochez-Jimenez" on Justia Law

Respondent-cross-petitioner J.C. Johnson was convicted of five crimes related to several days of ongoing domestic violence against his wife. A jury convicted Johnson for holding his wife “J.J.” under his control, allowing her only to leave their apartment when Johnson left, using his Rottweiler to restrain her movements, and keeping a knife and icepick near the bed to intimidate her. For three days, Johnson severely injured his wife by choking her, hitting her with rocks, and allowing the dog to bite her. J.J. managed to escape and receive treatment for her injuries. On appeal, Johnson argued: (1) the information for the unlawful imprisonment charges were insufficient because it did not include a definition of the word “restraint;” and (2) he received ineffective assistance of counsel when his trial lawyer proposed a definition of “reckless” in jury instructions that did not include charge-specific language when the “to convict” instruction included the specific language. The Court of Appeals overturned Johnson’s unlawful imprisonment conviction because the State omitted the definition of “restrain.” The appellate court agreed with Johnson that it was error to give a jury instruction on a generic definition of “reckless,” but that trial counsel was not ineffective for proposing it. The Supreme Court reversed on the “restraint” issue, holding that charging documents need only contain essential elements of a crime, not related definitions. With regard to the “reckless” issue, the Supreme Court affirmed the Court of Appeals, but for a different reason: it was not error to instruct a jury on the generic definition as long as the jury was given a “to convict” instruction that lists every element of the crime the State needs to prove in order to convict the defendant. View "Washington v. Johnson" on Justia Law

Chiwawa Communities Association appealed the trial court's grant of summary judgment to owners of homes in the Chiwawa River Pines community. Respondents Ross and Cindy Wilkinson asked the trial court to invalidate a 2011 amendment to the community covenants prohibiting rental of their homes for less than 30 days. The issue this case presented for the Supreme Court was whether short-term vacation rentals conflicted with the covenants in place prior to 2011, if the Association validly amended the covenants to prohibit them, and if the trial court erred by striking portions of the offered evidence. Upon review, the Court concluded that short-term rentals did not violate the covenants barring commercial use of the property or restricting lots to single-family residential use. Furthermore, the Court held the Association exceeded its power to amend the covenants when it prohibited short-term vacation rentals in 2011, and the trial court did not err by granting in part motions brought by the Wilkinsons to strike evidence. View "Wilkinson v. Chiwawa Cmtys. Ass'n" on Justia Law

While petitioner Mario Medina was awaiting retrial on charges of second degree murder, he was ordered to participate in two King County Community Center for Alternative Programs (CCAP): "CCAP Enhanced" and "CCAP Basic." Petitioner participated in these programs for approximately five years before his second trial resulted in a conviction. He argued that he was entitled, as a matter of both statutory and constitutional law, to credit for time served in the alternative programs. Both the trial court and the Court of Appeals rejected this argument. Finding no reversible error, the Supreme Court affirmed. View "Washington v. Medina" on Justia Law

The issue before the Supreme Court in this case centered on whether the "vested rights doctrine" applied to permit applications filed under plans and regulations that were later found to be noncompliant with the State Environmental Policy Act (SEPA). In 2006, BSRE Point Wells LP asked Snohomish County to amend its comprehensive plan and zoning regulations to allow for a mixed use/urban center designation and redevelopment of the Point Wells site. BSRE wanted to redevelop the property by adding over 3,000 housing units and over 100,000 square feet of commercial and retail space. The petitioners, Town of Woodway and Save Richmond Beach Inc., opposed the project. They argued that the area lacked the infrastructure needed to support an urban center, namely sufficient roads and public transit. These nearby communities did not want to "bear the burden of providing urban services to the site." Upon review, the Supreme Court concluded the vested rights doctrine did apply to the permit applications filed in this case: local land use plans and development regulations enacted under the Growth Management Act (GMA), chapter 36.70A RCW, are presumed valid upon adoption. Should a valid plan or regulation later be found to violate SEPA, the exclusive remedies provided by the GMA affect only future applications for development-not development rights that have already vested. In this case, BSRE Point Wells LP (BSRE) submitted complete applications for development permits before the local land use ordinances were found to be noncompliant with SEPA. BSRE's rights vested when it submitted its applications. A later finding of noncompliance did not affect BSRE's already vested rights. View "Town of Woodway v. Snohomish County" on Justia Law

The issue this case presented for the Supreme Court's review in this case was whether Ronald Mendes was "compelled" to waive his constitutional right not to testify as a witness in his own criminal case after the trial court refused to rule on whether the evidence presented during the State's case in chief entitled Mendes to a self-defense instruction. Mendes challenged his conviction for felony murder based on allegations that he shot and killed Danny Saylor after an altercation at Saylor's home. At trial, Mendes's theory of the case was that he acted in self-defense after Saylor came at him with a baseball bat. After the State rested, Mendes's counsel asked the court to make a preliminary ruling on whether enough evidence had been presented through the State's witnesses to warrant a self-defense instruction. The State objected, and the trial court declined to rule on Mendes's request. Mendes then testified on his own behalf. Mendes was convicted of felony murder. On appeal, Mendes argued that the trial court improperly compelled him to testify when it declined to rule on whether the State's evidence alone entitled him to a self-defense instruction. The Court of Appeals rejected this argument and held that Mendes was not entitled to an advisory ruling on jury instructions before the close of all the evidence and that Mendes's decision to testify was voluntary and tactical. Agreeing with the Court of Appeals, the Supreme Court affirmed. View "Washington v. Mendes" on Justia Law

Robert Kinnaman pleaded guilty to attempting to elude a pursuing police vehicle. He also agreed to a special finding that supported a sentence enhancement. At sentencing Kinnaman moved to withdraw his agreement to the sentencing enhancement only. The trial court denied the motion and sentenced Kinnaman. The Court of Appeals found the plea involuntary and indivisible and reversed, remanding the matter to the trial court for vacation of the entire plea. The Supreme Court disagreed with the appellate court's holding that the entire plea should be vacated; neither party sought that result. Therefore, the Supreme Court reversed the Court of Appeals and affirmed the trial court's order denying Kinnaman's motion to withdraw his agreement to the special finding. View "Washington v. Kinnaman" on Justia Law