The case involved Darold Stenson's personal restraint petition challenging his 1994 conviction for two counts of aggravated first degree murder and death sentence based on the murders of his wife and business partner. Stenson claimed the State violated due process by withholding until 2009 photographs and an FBI file with potentially exculpatory forensic evidence related to gunshot residue, blood spatter, and bullet lead analysis that was available at the time of trial. The Washington Supreme Court held that this nondisclosure violated Brady v. Maryland because the evidence was material and created a reasonable probability of a different outcome, undermining confidence in the verdict. As a result, the court reversed the convictions and death sentence and remanded for a new trial.
In State v. Abdulle, the defendant was charged with first degree theft and forgery after attempting to deposit stolen payroll checks; the key issue at trial was the admissibility of his custodial statement to police. The trial court admitted the statement after finding by a preponderance of the evidence that Abdulle had knowingly, intelligently, and voluntarily waived his Miranda rights, leading to his conviction. The Court of Appeals reversed under State v. Davis, which had required the state to produce corroborating testimony from all officers present or explain their absence. The Washington Supreme Court overruled Davis, concluding that later U.S. Supreme Court precedent establishes a preponderance standard for proving waiver and does not mandate corroboration, and therefore reinstated the convictions.
This case involved Brian Siers, who was convicted of second degree assault after stabbing two men, including one acting as a good Samaritan. The Court of Appeals had reversed the conviction on one count because the State failed to allege the aggravating factor in the charging document. The Washington Supreme Court granted review and held that aggravating factors are not essential elements of the crime and thus do not need to be included in the information. The court reasoned that since the charging document contained all essential elements and Siers received prior notice of the State's intent to seek an aggravated sentence, his due process rights were satisfied. Accordingly, the Supreme Court reversed the Court of Appeals and reinstated the conviction.
This case involved Mansour Heidari's personal restraint petition challenging his conviction for second degree child molestation on grounds that the evidence was insufficient to prove sexual contact, as the victim avoided any such contact. The Court of Appeals vacated the conviction and declined the State's request to direct entry of judgment on the lesser included offense of attempted second degree child molestation because the jury had not been instructed on that offense. The Washington Supreme Court affirmed, holding that under its precedent in State v. Green and RAP 12.2, an appellate court may direct a judgment on a lesser included offense only when the jury was explicitly instructed on it, as this ensures the jury necessarily found the required elements. The decision turned on the interpretation of appellate authority and the need to avoid prejudice to the defendant from modifying a verdict without jury consideration of the lesser charge.
In this case, Bobby Ray Thompson was convicted of first-degree rape in 1995 based on testimony from the victim and other evidence from the crime scene, though no DNA testing was performed at trial on semen samples. Years later, Thompson filed a motion for postconviction DNA testing under Washington law, which the trial court denied after considering his post-arrest statement to police claiming consensual sex, even though that statement had been ruled inadmissible and was never introduced at trial. The Court of Appeals reversed the denial, holding that the trial court improperly relied on the unadmitted statement, and the Washington Supreme Court affirmed that decision. The core reasoning was that only evidence actually admitted or properly before the court at trial or in the motion record could be considered in evaluating whether DNA testing would likely produce exculpatory results that would have changed the outcome.
The case involved homeowners who purchased homes from Quadrant Corporation and later sued Quadrant, its parent WRECO, and grandparent Weyerhaeuser for construction defects causing personal injuries, alleging various tort and contract claims including under the Consumer Protection Act. The purchase agreements contained broad arbitration clauses, and the superior court denied motions to compel arbitration, finding factual issues on whether the contracts were adhesive. The Washington Supreme Court affirmed the Court of Appeals' reversal, holding that questions of procedural unconscionability regarding the contract as a whole are for the arbitrator to decide, that the parents' claims must go to arbitration, and that the minor children's claims are also subject to arbitration under principles of equitable estoppel because they sought to enforce the contracts.
This case involved orchardists and a farm association challenging Douglas County's issuance of permits to the Washington State Parks and Recreation Commission for constructing a pedestrian and bicycle trail along the Columbia River on land zoned partly for commercial agriculture. The petitioners argued that the project violated the Growth Management Act (GMA) by allowing incompatible recreational development on agricultural resource lands and that the environmental review under SEPA was inadequate. The Supreme Court of Washington affirmed the lower courts' dismissal of the challenge, holding that the GMA petition was not filed within the required 60-day statute of limitations and that related prior decisions on the permits had become final. The court did not reach the substantive merits of the GMA compliance or land-use issues because of these procedural bars.
The case involved Martin Mellish's challenge under the Land Use Petition Act (LUPA) to Jefferson County's grant of a conditional use permit and variance allowing Frog Mountain Pet Care to expand its boarding facility on adjacent property. The central issue was whether Mellish's timely motion for reconsideration before the county hearing examiner tolled the 21-day deadline for filing his superior court petition, which was filed 50 days after the original decision but only 20 days after denial of reconsideration. The Washington Supreme Court reversed the Court of Appeals and held that the petition was timely, ruling that a motion for reconsideration renders the hearing examiner's initial decision non-final under LUPA's definition of a land use decision. The court reasoned that the statute's requirement of a final determination by the local jurisdiction's highest authority, combined with the practical effect of reconsideration motions, supports tolling until the motion is resolved, consistent with subsequent legislative clarification.
The case concerned James Eserjose's conviction for second degree burglary of a coffee shop, based in part on a confession he gave at a sheriff's office after deputies arrested him without a warrant at his parents' home. The arrest was unlawful because the deputies exceeded the limited consent given to enter the home by proceeding upstairs and making the arrest there. The trial court admitted the confession anyway and found Eserjose guilty on stipulated facts; the Washington Supreme Court affirmed. The court held that under New York v. Harris and parallel state analysis, a confession obtained at the station after an unlawful home arrest is admissible when supported by probable cause and not coerced.
The case concerned whether the due process clauses of the Fourteenth Amendment or the Washington Constitution require appointment of counsel for a child at an initial truancy hearing under RCW 28A.225.035. The Washington Supreme Court reversed the Court of Appeals and held that due process does not compel appointment of counsel at that stage. The court reasoned that the initial hearing is a civil proceeding focused on attendance orders rather than sanctions, that existing procedural protections and parental involvement suffice to mitigate risks of error, and that the legislature had not mandated counsel at this early point unlike in certain other juvenile matters. Later contempt proceedings, where counsel was provided, were distinguished from the initial petition hearing.
In State v. Martin, the defendant was convicted of three counts of first degree kidnapping and one count of second degree robbery after a trial in which the victim testified about being forced into her van and the defendant admitted entering the van but gave a different account of events and timing. The central issue was whether the prosecutor's cross-examination questions, which highlighted the defendant's access to police reports, witness statements, and prior testimony, violated article I, section 22 of the Washington Constitution by implying he tailored his testimony. The Washington Supreme Court affirmed the convictions, holding that the questions did not infringe on the defendant's constitutional rights because they were based on his access to discovery materials rather than solely on his presence at trial. The court distinguished this from federal precedent under the Sixth Amendment and rejected the need for independent state constitutional analysis beyond the federal standard in this context. The decision upheld the trial court's overruling of defense objections to the questioning.
The case involved Glenn Nichols's personal restraint petition challenging his convictions for possession of cocaine with intent to deliver and possession of marijuana, based on evidence obtained after Seattle police learned from a motel desk clerk that he was registered in a room linked to a controlled drug buy. Nichols argued that the officers' warrantless request for the motel registry information violated article I, section 7 of the Washington Constitution, citing precedent against random motel registry checks. The Washington Supreme Court affirmed the denial of the petition, holding that the officers' targeted inquiry was supported by individualized suspicion from an informant and therefore did not constitute an unconstitutional intrusion into private affairs. The court distinguished the facts from cases involving random or suspicionless checks, emphasizing that the registry search was part of an ongoing criminal investigation rather than a general search.
The case involved Timothy Hager's conviction for first degree rape of a child based on allegations from his stepdaughter P.B. regarding an incident when she was in third grade. After a detective testified that Hager was 'evasive' during questioning, in violation of a pretrial order, the trial court denied Hager's motion for a mistrial but instructed the jury to disregard the remark; Hager was convicted, and the Court of Appeals reversed, holding the comment incurably prejudiced the defense. The Washington Supreme Court reversed the Court of Appeals and reinstated the conviction, reasoning that the trial court did not abuse its discretion because the improper statement could be cured by the limiting instruction and did not require a new trial. The core issue centered on whether the detective's opinion testimony about the defendant's demeanor violated constitutional protections and warranted mistrial.
