Justia Constitutional Law Opinion Summaries

Petitioner Stephen Johnson was arrested and convicted for driving on a suspended license (in the third degree). His license had been suspended for failing to pay a traffic fine. Johnson appealed his DWLS 3rd conviction, arguing: (1) the former RCW 46.20.342(1)(c)(iv) (2008) did not proscribe his continuing to drive after the suspension of his license for failing to pay a traffic fine; or alternatively, (2) that because he was indigent, the suspension was invalid under the Fourteenth Amendment to the United States Constitution's due process and equal protection clauses, which required the State to inquire into his ability to pay the fine before suspending his license. Furthermore, Johnson argued the trial court erred by denying him counsel to fight these charges, and wanted reimbursement for attorney fees spent in his defense. The Supreme Court rejected Johnson's arguments on appeal, but remanded the case for further proceedings to determine Johnson's right to reimbursement for attorney fees. The plain meaning of former RCW 46.20.342(1 )( c )(iv) allows the State to convict a driver for DWLS 3rd where the underlying license suspension occurred for failure to pay a fine. Johnson was not constitutionally indigent, but statutorily so; on remand, the Supreme Court instructed the district court to enter an order designating Johnson either as (1) indigent or (2) indigent and able to contribute. If Johnson is able to contribute, the district court would have to enter an order determining the costs he should bear for his appeal. View "Washington v. Johnson" on Justia Law

Petitioner Sione Lui was charged with second degree murder. This case presented the issue of when the confrontation clause requires testimony from laboratory analysts who conduct tests on evidence. DNA test results were admitted into evidence at Petitioner's trial, and he challenged that admission as violation of his constitutional rights. The Supreme Court held that based on the trial court record, there was no violation of Petitioner's rights under the confrontation clause when DNA test results and temperature readings taken from the victim's body were admitted. However, Petitioner's confrontation rights were violated by the admission of the victim's postmortem toxicology results and several statements from the autopsy report. The Court deemed those admissions harmless. View "Washington v. Lui" on Justia Law

At issue before the Supreme Court in this case was the proper scope of the effective law enforcement exemption of the Public Records Act (PRA), chapter 42.56 RCW. The Seattle Police Department (SPD) used this exemption to justify withholding documents regarding the investigation of an altercation between petitioner Evan Sargent and an SPD officer. Sargent raised several challenges to the Court of Appeals decision which held that the exemption applied categorically to an investigation file where the prosecutor has declined to file charges and has referred the case back to the SPD for follow-up investigation and to information contained in an internal investigation file. Upon review of the matter, the Supreme Court held that the exemption does not apply categorically to the requested criminal investigation information or to the requested internal investigation information. Further, although the Supreme Court agreed with the Court of Appeals that the exemption does not apply categorically to witness identification, it held that remand on this issue was not warranted. The Court also agreed with the Court of Appeals that the SPD properly withheld Sargent's nonconviction information under the Washington State Criminal Records Privacy Act (CRPA), and that the Court of Appeals correctly remanded for reconsideration of penalties. The Supreme Court reversed the Court of Appeals in part, affirmed in part, and remanded the case to the trial court for reconsideration of the appropriate penalty. View "Sargent v. Seattle Police Dep't" on Justia Law

The State brought a paternity action in 2008 to establish the parentage of C.M.F. Respondent Jonathan Fairfax was adjudicated C.M.F.'s father. Petitioner Amanda Simpson was designated custodian. Fairfax petitioned the family court to establish a parenting plan for C.M.F. Trial began on two years later. After Mr. Fairfax completed his case, Simpson moved the court to dismiss the petition under CR 12(b)(6) on the grounds that Fairfax had filed the wrong petition and failed to establish that there was adequate cause to hold a modification hearing. The court denied the motion, finding that the parentage order was not a custody decree and that Simpson's motion was untimely. Simpson presented her case, and the court created a final parenting plan that had C.M.F. residing with Fairfax for the majority of the time and designated Fairfax the "custodian of the child solely for purposes of all other state and federal statutes…" Simpson appealed and the Court of Appeals affirmed the trial court. Because the superior court previously entered a parentage order that qualified as a custody decree, the Supreme Court reversed the decision of the Court of Appeals and remanded the case for further proceedings. View "In re Parentage of C.M.F." on Justia Law

The City of Seattle appealed an unpublished Court of Appeals decision that affirmed a $12.75 million verdict in favor of former Seattle fire fighter Mark Jones. Jones was injured when he fell fifteen feet through a station "pole hole." The City argued that the trial court erred by excluding three late-disclosed defense witnesses without first conducting the necessary inquiry under "Burnet v. Spokane Ambulance," (93 3 P .2d. 1036 (1997)) and by denying the City's motion to vacate the judgment on the basis of newly discovered evidence. After review, the Supreme Court found that though the trial court erred in excluding testimony by the late-disclosed witnesses, the Court agreed with both parties that the error was harmless. Further, the Court also found that the trial court did not abuse its discretion in denying the City's motion to vacate. Therefore the trial court was affirmed. View "Jones v. City of Seattle" on Justia Law

Respondent Tamara Frizzell borrowed $100,000 from petitioner Barbara Murray, secured by a deed of trust on Frizzell's home. Frizzell defaulted and a nonjudicial foreclosure sale was set. Before the sale, Frizzell sued Barbara and her husband Gregory Murray, alleging several claims, and filed a motion for an order to enjoin the sale. A judge stayed the sale, unless Frizzell made a payment of $25,000 into the court registry by the following morning. Frizzell failed to make the payment and the sale took place. The trial court then dismissed Frizzell's claims on summary judgment, stating her failure to enjoin the sale resulted in a waiver of her claims. The Court of Appeals reversed and remanded, determining it would be inequitable to conclude Frizzell waived her claims. After its review, the Supreme Court concluded that Frizzell waived her claims as to the foreclosure sale. The Court remanded her other claims to the trial court for consideration under RCW 61.24.127. View "Frizzell v. Murray" on Justia Law

The issue before the Supreme Court in this case was whether law enforcement officers must expressly advise a person of his or her right to refuse entry into a home (provide "Ferrier") warnings-when the officers seek to execute an arrest warrant. Under the facts of this case, the Supreme Court concluded that sheriffs deputies unlawfully entered Petitioner Dara Ruem's mobile home in an attempt to execute an arrest warrant for Ruem's brother, Chantha. The deputies lacked probable cause to believe Chantha was present, and Ruem revoked his initial consent to the entry. Thus, the evidence recovered from the search of the home was illegally obtained and unlawfully admitted. The Court held that Ferrier warnings were not required in this instance, though any consent obtained must be voluntary under the totality of the circumstances. View "Washington v. Ruem" on Justia Law

Appellant Roy Jorgenson was released on bond after a trial court judge found probable cause to believe he had shot someone. He was arrested with a handgun and an AR-15 rifle. Appellant was not at home at the time, nor was there any evidence that he was defending himself. He was convicted of violating RCW 9.41.040(2)(a)(iv). On appeal of his conviction, appellant argued that RCW 9.41.040(2)(a)(iv) violated his rights to bear arms under the federal and state constitutions. The Supreme Court deferred to the legislature's conclusion that when a trial judge finds probable cause to believe a defendant committed a serious offense, public safety justifies temporarily limiting that person's right to possess arms. The Court held that the statute was constitutional as applied to appellant and therefore affirmed his conviction. View "Washington v. Jorgenson" on Justia Law

Christopher Monfort was charged with one count of aggravated first degree murder for the death of a law enforcement officer. He filed a notice of special sentencing proceeding ("death penalty notice"). Monfort's defense moved to strike the notice on the basis that the county prosecutor considered the facts of the crime and lacked a factual basis for making a determination under the statute. The trial court denied the defense's motion on the first basis but granted it on the second. It stated that the county prosecutor had failed to exercise discretion as required by constitutional and statutory law. The State and defense moved for discretionary review. After considering the parties' arguments, the Supreme Court reversed the trial court, holding that a county prosecutor may consider the facts of the crime when deciding whether to file a death penalty notice, and the judiciary may review only whether a prosecutor has a "reason to believe that there are not sufficient mitigating circumstances" under RCW 10.95.040(1). View "Washington v. Monfort" on Justia Law

Petitioner Jerry Lain was sentenced to life under Washington's former indeterminate sentencing scheme. In 2010, the Indeterminate Sentencing Review Board found petitioner parolable, approved a release plan, and ordered parole with supervision. The governor revoked petitioner's parole. As a result, the Review Board tacked on 36 months to petitioner's minimum term of confinement. Petitioner challenged the revocation and additional term as-applied and facially, arguing that RCW 9.95.160 violated due process because it did not outline procedures for the governor to provide petitioner notice and an opportunity to be heard before the governor acted. The Supreme Court concluded the statute was constitutional on both its face and as applied to petitioner. View "In re Pers. Restraint of Lain" on Justia Law