The Washington State Association for Justice recorded a debate between Washington State Supreme Court Justice Sanders and attorney Charlie Wiggins. The debate is in five parts so click "continue reading" to see the remaining videos.
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The Court will hear four arguments today, as usual. (Docket, briefs)
Morning session (9:00 a.m.)
State v. Mitchell, No. 83169-6. This case hinges on the question of whether a child qualifies as a "dependent person" for purposes of the crime of criminal mistreatment.
Marilea Mitchell and her boyfriend were charged with criminal mistreatment after starving the boyfriend's son almost to death. The statute refers to mistreatment of “a child or a dependent person,” and Mitchell was charged with mistreatment of a “dependent person.” Mitchell claims that the boy was a child, not a dependent person, and thus she was wrongly convicted.
But Division One Court of Appeals held that the boy was both a child and a dependent person, and upheld the conviction.
State v. Ervin, No. 83244-7. Under the Sentencing Reform Act, Class C felonies can be scrubbed from an individual's offender score if the person lives crime-free in society for five years. The question in this case is whether incarceration during the five-year period interrupts the countdown.
James Ervin was convicted of felony violation of a no-contact order in 2006. He had committed two previous felonies in 1991 and 1994, as well as other crimes between 1994 and 2006. During one five-year stretch he was not convicted of any crimes, but he was incarcerated during that time for a parole violation.
Ervin argues the five-year stretch without any crimes should cause his previous felony convictions to be scrubbed. But the King County Superior Court and Division One Court of Appeals held that while Ervin was in prison he was not “in the community,” and his imprisonment interrupted the five-year period.
Afternoon session (1:30 p.m.)
Forbes v. American Building Maintenance Company West, No. 82950-1. Whether the plaintiff has to pay prejudgment interest on attorney fees to her attorney, and whether a settlement was properly modified.
Attorney Mary Schultz represented Cheryl Forbes in an employment discrimination suit against American Building Maintenance. Schultz won the trial and the first appeal. Schultz and Forbes had a falling out, and while the case was on appeal to the Supreme Court Forbes fired Schultz and accepted a settlement offer by ABM. ABM deposited the settlement money in the court registry until the court could decide how much Schultz was entitled to.
The trial court awarded prejudgment interest on the attorney's fees, and Forbes challenges this award on two grounds.
First, she argues the claim for fees was unliquidated because there was disagreement over which terms of the fee agreement applied. Division Three Court of Appeals held that the amount “could be calculated with precision” even though there was disagreement on which terms to use, and thus the claim was liquidated.
Second, Forbes argues that the money was not under her control because it was in the court registry. The appellate court held that since Forbes instructed the court clerk to invest the money for her benefit, she still had “use of” the money, and thus prejudgment interest is appropriate.
In addition to the interest issue, the appellate court modified the settlement amount to match the satisfaction of judgment document. Forbes claims that the satisfaction of judgment was incorrect.
State v. Ish, No. 83308-7. Generally speaking, prosecutors are not allowed to vouch for the credibility of a witness. This case concerns whether informing the jury that a witness agreed to a plea bargain requiring truthful testimony constitutes vouching for his credibility.
Nathaniel Ish murdered his girlfriend and was arrested and imprisoned prior to trial. While in prison he talked to David Otterson, his cell mate, about the murder. The state made a plea agreement with Otterson which, in part, required him to testify truthfully at Ish's trial.
While examining Otterson at trial, the prosecutor brought out the information that the plea agreement required Otterson to testify truthfully and that it could be revoked if Otterson breached it. Ish claims this was vouching for the witness, but Division Two Court of Appeals disagreed, since the prosecutor did not express a personal opinion about Otterson's credibility.
McCurry v. Chevy Chase Bank, No. 81896-7. When Chris and Anne McCurry paid off their mortgage with Chevy Chase Bank, the total amount as itemized by the Bank included a $20 fax fee and a $2 notary fee. After paying the full amount, they filed this class action lawsuit. The McCurrys allege breach of the terms of .jpg)
the deed of trust, unjust enrichment, and violation of the Washington Consumer Protection Act. The Bank responded by arguing that federal regulations preempt these state law claims. The King County Superior Court agreed and dismissed the McCurry's complaint; the Court of Appeals affirmed.
The Court today first addresses the standard necessary to grant a motion to dismiss for failure to state a claim. While federal courts have recently made it more difficult for plaintiffs to survive motions to dismiss, the State Supreme Court refuses to follow that course here. The majority notes that "[t]he appropriate forum for revising the Washington rules is the rule-making process."
The Court holds that the McCurry's state contract law claims, including the unjust enrichment claim, are not preempted by federal lending laws or regulations.
State contract law does not purport to impose requirements on loan-related fees; state contract law instead requires parties to adhere to the terms of their contracts. Forcing Chevy Chase to adhere to the terms of its contract only incidentally affects the loan-related fees....
The Court further holds that the Consumer Protection Act claim survives to the extent that it relates to misrepresentation of the contract terms, but that it is preempted if the allegation is that the Act "regulates how or when fax or notary fees (loan-related fees) can be charged...."
The majority opinion is written by Justice Sanders and joined by five other justices. It strongly takes to task the dissent, authored by Justice James Johnson and joined by Justices Charles Johnson and Susan Owens, alleging that "the dissent's novel interpretation of preemption would prevent Washington consumers from enforcing contracts against federal savings associations." (briefs and argument)
South Tacoma Way v. State, No. 82212-3 (briefs and argument). The State Department of Transportation (DOT) owned an alley that was abutted by property owned by several different owners. DOT determined the alley was surplus property and sold it to Sustainable Urban Development #1, LLC (Sustainable). DOT mistakenly believed that Sustainable was the only abutting property owner, and no notice of the sale was given to the other abutting property owners, as is required with multiple abutters.
After this sale was complete, South Tacoma Way, LLC (South Tacoma) entered negotiations to purchase one of the abutting properties, and also expressed interest in the alley, only to find out DOT had sold it to Sustainable. South Tacoma purchased the abutting property and then filed this lawsuit objecting to the Sustainable purchase. The trial court ruled in favor of DOT and Sustainable, concluding that although DOT did not comply with the applicable statute, the sale was not ultra vires (i.e., outside DOT’s powers) and Sustainable was a bona fide purchaser. The Court of Appeals reversed the trial court in South Tacoma’s favor.
Today the Supreme Court, with Justice Charles Johnson writing the 8-vote majority, reversed the Court of Appeals and upheld the sale to Sustainable. The court said that while ultra vires acts are performed with no legal authority and are void on the basis that no power to act existed, there is a difference where an act is committed without an agency’s power, though without strict procedural or statutory compliance. The court determined that DOT had authority to sell the property and had mistakenly followed the wrong statutory process. Additionally, the court said that Sustainable was a bona fide purchaser and that this doctrine would apply. In other words, the law provides that a good faith purchaser for value who is without actual or constructive notice of another’s interest in purchased real property has superior interest in that property.
Justice Richard Sanders dissented, arguing that DOT was without authority to sell the property without giving proper statutory notice to all abutting owners, and that to ignore this requirement eviscerates the statute. “This interpretation erases the notice requirement from the statute. From now on DOT can simply sell to whomever it chooses without notice to other abutting landowners, in violation of RCW 47.12.063(2)(g). What other statutory limitations can the State ignore?”
The Supreme Court will issue opinions in two cases tomorrow:
McCurry v. Chevy Chase Bank, No. 81896-7 (briefs and argument). Originating in King County Superior Court, this case concerns whether bank fees charged in relation to a Washington home loan are governed by the federal Home Owners Loan Act.
The McCurrys had a mortgage through Chevy Chase, which they fully paid off. When they did so, the bank charged them a $20 fax fee and a $2 notary fee before signing the house over to them. The McCurrys paid the fees and then filed a class action suit under state law against the bank for illegal fees. The trial court dismissed it because the state law is preempted by the federal Home Owners Loan Act. The McCurrys argue that the facts of the case don't fall under the federal law.
South Tacoma Way v. State, No. 82212-3 (briefs and argument).The State Department of Transportation (DOT) sold an alley to Sustainable Urban Development #1, LLC (Sustainable). DOT failed to notify other adjacent property owners as required by law. South Tacoma Way, LLC, which also owns property next to the alley, sued DOT and Sustainable to void the contract as an ultra vires act outside DOT's authority. The trial court held that DOT was authorized to sell the property and that the failure to give notice was merely a procedural error. The Court of Appeals (Div. 2) reversed, holding that DOT is only authorized to sell property after giving notice.
Today the court will hear four cases, two in the morning and two in the afternoon. (Docket, briefs)
Morning session (9:00 a.m.)
Anderson v. Akzo Nobel Coatings, Inc. No. 822646. This case concerns whether a defense of comparative negligence based on the way a woman worked while pregnant is impermissibly discriminatory, and whether the Frye test for expert witnesses is still appropriate.
Julie Anderson worked for the auto paint company Akzo Nobel Coatings, where she mixed paint as part of her job. Anderson continued her job after becoming pregnant, and gave birth to a son with brain damage. She believes the damage was caused by exposure to paint fumes, and sued Akzo for inadequate safety procedures.
At trial, Akzo raised a comparative fault defense based on the fact that Anderson continued to mix paint during her pregnancy, contrary to the advice of her supervisor. Anderson moved for summary judgment to dismiss the defense as discriminatory against her for working while pregnant. But the King County Superior Court allowed Akzo to present the defense.
Testimony by Anderson's expert witness was excluded under Frye v. United States (293 F. 1013), which requires scientific theories and methodologies to be “generally accepted in the scientific community” in order to be admissible. Anderson wants Washington to stop using the Frye test, and says that it was incorrectly applied.
Finally, the court dismissed a wrongful discharge claim by Anderson because she failed to pursue a statutory remedy.
State v. Meneses, No. 831726. Whether charging someone with both harassment and intimidation of a witness due to the same phone call is double jeopardy.
As part of a visiting dispute, Andre Meneses called his ex-girlfriend several times, cursing her and threatening to kill her. He was charged and convicted of multiple counts of telephone harassment and intimidating a witness.
The court instructed the jury that the defendant commits telephone harassment if he makes a telephone call with intent to harass someone. Meneses claims that this did not inform the jury that the intent to harass must be formed before the call is made, but the court disagreed.
The harassment and intimidation charges are based on the same phone call, which Meneses claims is double-jeopardy. But the court held the two crimes are different because each requires the state to prove a different purpose for the threat.
Meneses also asks the court to review the trial court's refusal to instruct the jury on the lesser included offenses of attempted intimidating a witness and witness tampering.
Afternoon session (1:30 p.m.)
School District Alliance for Adequate Funding of Special Education v. State, No. 829616. Whether the state's funding mechanism for special education violates the state constitution.
Article 9, Section 1 of the state constitution says, “[i]t is the paramount duty of the state to make ample provision for the education of all children residing within its borders.” The School District Alliance for Adequate Funding of Special Education challenged the constitutionality of Washington's special education funding system under Article 9 as inadequate to completely provide for the education of special needs students, requiring some districts to rely on levies for special education funding.
The court found several problems with the Alliance's accounting, and ruled that their arguments “do not establish beyond a reasonable doubt” that special education is under funded. Accordingly, both a Thurston County Superior Court and Division Two Court of Appeals found the funding statute to be constitutional.
State v. Webb, No. 831777. This case presents the question of whether the burden of proving a child witness incompetent to testify is on the party calling the witness.
Samuel Webb, a minor, was convicted of raping another minor. At trial, the court required Webb to prove that the victim was incompetent to testify. Webb failed to do so.
Webb appealed, claiming the burden should have been on the state to prove his victim's competency. Division One Court of Appeals agreed, but found that the state met its burden and upheld the conviction.
The state now appeals the appellate court's finding that the burden of proof as to a child witness's competency is on the party calling the witness.
In Re Discipline of Terry J. Preszler, No. 200,570-5. Attorney Terry Preszler represented a couple in a bankruptcy. He failed to navigate correctly some of the rules related to a personal injury settlement, and was not forthright when he discovered his mistakes. The Washington State Bar Association alleged 17 counts of misconduct by Preszler and the Association's Disciplinary Board found that he had violated five and recommended a three-year suspension from the practice of law. Preszler challenges the Board's determination on several issues.
The Court upholds the Board on most points and imposes the suspension. Justice Fairhurst writes for the majority and is joined by five other justices. Justice Sanders, joined by Justices Chambers and James Johnson, dissents and would give greater weight to the mitigating factors and reduce the suspension. (briefs and argument)
Kustura v. Department of Labor, No. 81478-3. Several 
persons with "limited English proficiency" appealed determinations by the Department of Labor and Industries, and included in their claims a demand that the Department provide them with interpreters for all interactions with the Department. RCW 2.43.040 grants persons with limited English proficiency the right to translation services paid for by taxpayers where the government has instituted a legal proceeding.
Here, the Court upholds the Court of Appeals, which determined that the Department did not initiate the proceedings. It further casts doubt on whether the Department's proceedings here qualify as legal proceedings under the RCW. Justice James Johnson authored the Court's opinion, in which six other justices concurred. Justice Chambers, joined by Justice Sanders, dissents. (briefs and argument)
State v. Grenning, No. 81449-0. Neil Grenning was charged with 72 sex crimes, including 20 counts of possession of child pornography related to pictures found on his computer hard drives. The trial judge, at the request of the prosecutors, issued a restrictive order preventing copies of the hard drives from being turned over to the defense, though the defense was provided with access to them. .png){kind=icon}
Potential defense expert witnesses apparently refused to investigate the hard drives without the ability to take them to their own computer laboratories, and the defense did not present an expert witness regarding the hard drives at trial.
Grenning was convicted on all but one of the charges, including all of the instances of child pornography, and sentenced to 117 years in prison. He appealed, challenging the limitations placed on the hard drive evidence. The Court of Appeals agreed with Grenning and ordered a new trial for the child pornography charges; the state appealed.
The Court here upholds the Court of Appeals. In an opinion by Justice Chambers and joined by five other justices, the Court finds that its decision in State v. Boyd, "which held that the defense was entitled to a mirror image copy of the defendant's computer hard drives," controls the outcome here. Justice Madsen, joined by Justices Alexander and James Johnson, dissent and "disagree with the majority's recitation of the facts, its legal analysis, and its result." (briefs and argument)
The Supreme Court will issue opinions in the following cases tomorrow:
In Re Discipline of Terry J. Preszler, No. 200,570-5 (briefs and argument). Whether the court should adopt or reject the Washington State Disciplinary Board’s recommendation that Terry J. Preszler be suspended from the practice of law for three years.
Kustura v. Department of Labor, No. 81478-3 (briefs and argument). The appellants challenged several decisions by the Department of Labor & Industries, all of which were decided in the Department’s favor by Division One Court of Appeals and consolidated on appeal to the Supreme Court. The question before the Court is whether L&I is constitutionally required to provide interpreters to persons with limited proficiency in English.
Kustura and the other appellants are all workers with limited English skills who had hearings before L&I. Interpreters were provided for some parts of the hearings, but not all, such as for communication with attorneys. Kustura claims this violated his due process rights. The Court of Appeals disagreed, determining that L&I is not required by statute to provide interpreters and finding no evidence of actual harm from the lack of interpreters.
State v. Grenning, No. 81449-0 (briefs and argument). This case concerns whether restricting the defense counsel’s access to hard drives that contained some of the evidence used against Neil Grenning meant that he was deprived of the “effective assistance of counsel.”
Grenning was charged with seventy-one counts of child rape, possession of child pornography and related crimes, including sexually abusing a child he babysat – “B.H.” Part of the state’s evidence against Grenning was content from his computer’s hard drives, which contained nearly 40,000 images of child pornography, including pictures of B.H.
Grenning’s counsel requested copies of the drives, but the court restricted him to accessing the drives in a secure location to prevent any spread of the pictures of B.H. The defense counsel argues that the restricted access prevented him from effectively representing Grenning. The Court of Appeals agreed, reversing twenty of the counts against Grenning.
With candidate filing week over, we now have a complete picture of this year’s races for seats on the Supreme Court of Washington.
Running for Position 1 are Justice Jim Johnson and challenger Stan Rumbaugh. Chief Justice Barbara Madsen is running unchallenged for Position 5. We previously reported that Justice Richard Sanders and Charlie Wiggins are running for Position 6, and another candidate has jumped into this race: Pierce County Superior Court Judge Bryan Chushcoff.
Because judicial offices are nonpartisan, the August 19 primary is a key date for judicial elections. If any candidate receives 50 percent of the primary vote, that candidate advances unchallenged to the general election.
Here at the Supreme Court of Washington Blog we will be reporting on each of these contested judicial races. Voting for judges is often difficult as candidates refrain from taking positions on specific public policy issues. The Supreme Court of Washington Blog will not endorse any candidate; our goal is to provide information about each candidate’s background, qualifications, and previous rulings (if available).
Just click on the “Judicial Elections” category to the left to read each article we’ve written about the various judicial races. You can also sort articles by individual candidate using the tags below.
The Supreme Court may issue opinions this week on Thursday. No arguments are scheduled.
Today the Supreme Court issued decisions in three cases.
In Re Discipline of Paul H. King, No. 200,681-7 (briefs). The Supreme Court adopted a Disciplinary Board recommendation to disbar Paul H. King for violating the Rules of Professional Conduct by representing a client while suspended from the practice of law. Justice James Johnson wrote the opinion, while Justice Richard Sanders concurred separately.
In re the Welfare of A.B., No. 80759-1 (briefs and argument). The Supreme Court overturned a trial court decision to terminate the parent-child relationship between Rogelio Salas and his daughter, A.B. The child was born in 2001 with cocaine in her system. The Department of Social Health Services (DSHS) removed A.B. from the custody of the mother and placed her in a foster home. The mother’s parental rights were terminated and the child was eventually placed in a home with a distant cousin of the mother. Having never been married to the mother, Salas was living in Las Vegas when A.B. was born. His paternity was confirmed but because of his own substance abuse history he was only granted visitation rights. He later completed a recovery program. The State eventually filed a petition for termination of parental rights which a trial court granted, though the court never entered a finding that Salas was an unfit parent.
The Supreme Court today rules that a parent has a due process right not to have the State terminate his or her relationship with a natural child in the absence of a finding that he or she, at the time of trial, is currently unfit to parent the child. The Court directed the trial court to supervise the “prompt but orderly” transfer of A.B. to Salas’ home unless the parties agree otherwise. The majority was written by Judge J. Dean Morgan, who served as justice pro tempore. Chief Justice Barbara Madsen concurred separately.
Justice Tom Chambers wrote a strong dissent. “The court’s order today also confounds me. A.B. is living with her family. She has been raised by her mother’s cousin almost since birth. Her mother’s cousin has also adopted A.B.’s younger half brother, who has lived with his eldest sister his entire life. The ‘prompt but orderly transfer’ ordered by the court today will wrench this child out of the only home she has ever known and deprive a brother of his sister. Even if the trial judge did err by following this court’s well settled case law, the proper remedy would be remand for further proceedings.”
(Parenthetically, I am surprised at the delay between oral argument and this decision. The case was argued on June 24, 2008. Given the profound impact this decision will have on a child's life, a two-year delay is an inordinate amount of time.)
State v. Nason, No. 82333-2 (briefs and argument). Spokane County has a policy of imposing jail time on offenders who fail to pay court costs. James Nason was convicted of burglary, sentenced to community service, and ordered to pay certain court costs. He did not pay, and the court subsequently modified his sentence to impose jail time. Nason argues this “auto-jail” provision violated his due process rights. The Supreme Court unanimously agreed, with Justice Mary Fairhurst writing the opinion. The Court held that before sanctions are imposed on an offender for failure to pay a legal financial obligation, the trial court must inquire into the offender’s ability to pay when sanctions are sought. “To the extent that an auto-jail provision calls for incarceration without a contemporaneous inquiry into the offender’s ability to pay, it is void. Because the trial court in this case sentenced Nason to 30 days in jail for failure to report to jail under the auto-jail provision, Nason needs to be resentenced.”
Today the Supreme Court will hear arguments in three cases (docket and briefs).
In the morning session:
State v. Sandoval, No. 82175-5. Valentin Sandoval was pled guilty to a third-degree rape conviction. He seeks to vacate this conviction by challenging his trial counsel's effectiveness, who misadvised him of the deportation consequences of pleading guilty. The Court of Appeals (Div. III) affirmed Sandoval's conviction and guilty plea.
State v. Eserjose, No. 82491-6. On direct review from Kitsap County Superior Court, James Eserjose argues he was illegally arrested in his home and transported to the police station, where he subsequently made incriminating statements. He argues that evidence obtained through an illegal arrest should be suppressed.
In the afternoon session:
City of Seattle v. The Hon. George W. Holifield, No. 83277-3. Respondents Matthew Jacob and Jacob Culley were each charged with driving while under the influence of alcohol. Each moved to suppress their breath test results because of alleged misconduct by Ann Marie Gordon, the former manager of the Washington State Toxicology Laboratory. The municipal court suppressed the breath test results and the city sought writ of review. The superior court denied the writ. On appeal, the Court of Appeals held the suppression of evidence was not proper and the city was entitled to a writ of review.
Tomorrow the Supreme Court will issue opinions in several cases.
In Re Discipline of Paul H. King, No. 200,681-7 (briefs). King appeals a disciplinary recommendation that he be disbarred.
In re the Dependency of A.L.S.B., No. 80759-1 (briefs and argument). Whether a court unconstitutionally terminated a father’s parental rights without finding him unfit? This case has been pending since June 2008.
State v. Nason, No. 82333-2 (briefs and argument). Whether Spokane County’s policy of imposing jail time on offenders who fail to pay court costs violates due process. James Nason was convicted of burglary, sentenced to community service, and ordered to pay certain court costs. He did not pay, and the court subsequently modified his sentence to impose jail time. Nason argues this violated his due process rights.
Pierce County trial attorney Stan Rumbaugh has announced he will challenge Justice Jim Johnson, who is running for reelection. The Bellingham Herald has the story here. State Representative Brendan Williams was also reported to be interested in the position but has yet to file candidate papers.
The Supreme Court accepted petitions for review in several cases during its conference last week.
Today the Court will hear four arguments. (Docket, briefs)
Morning session
In re Sandra Ferguson, No. 200719-8. This disciplinary hearing concerns an attorney who violated the Rules of Professional Conduct.
According to the findings of the disciplinary board, Sandra Ferguson appeared before a court ex parte and filed a motion for injunctive relief and an order of contempt, which was granted. She did not notify the opposing party, however, but misled the judge into believing she had. Her license was suspended for ninety days.
State v. Montano, No. 82855-8. The Court will hear argument on whether general threats to a police officer constitute an attempt to influence the officer's actions, an element in the crime of intimidating a public servant.
Jose Montano resisted arrest for assault and officers had to shock him twice before they could handcuff him. On the way to jail, Montano threatened the officer driving him with statements including “I know when you get off work, and I will be waiting for you,” “I'll kick your a**,” and “I know you are afraid, I can see it in your eyes.” Montano was charged with intimidating a public servant.
One element of the crime involves proving that the defendant intended to influence the servant's official actions. The trial court dismissed the charge against Montano because there was no evidence that he wanted to influence the officer's actions. The Division Three Court of Appeals reversed, however, holding that the jury could infer an intent to influence from Montano's statements.
Afternoon session
State v. Immelt, No. 83343-5. Is honking your car horn repeatedly in a neighborhood a protected form of speech?
Snohomish County Code prohibits horn honking for purposes other than public safety. Helen Immelt, angry at a neighbor, honked her horn in front of his house for about ten minutes just before 6:00 a.m. Police came and warned Immelt to stop honking. She claimed her horn was broken, but then honked several times as she drove away. The police caught and arrested her.
Snohomish County Code prohibits horn honking for purposes other than public safety. Immelt challenges this ordinance as a free speech violation. The court held that her honking was not “speech,” and thus not protected.
Burton v. Twin Commander Aircraft, No. 83030-4. Here the Court must determine whether Twin Commander is an airplane manufacturer under federal law. If so, then Burton's claim is likely barred by a federal statute of limitations.
Twin Commander Aircraft bought the “type certificate” for a particular model of aircraft from Gulfstream. The type certificate authorizes the owner to manufacture a particular model of aircraft, and requires them to support the aircraft. Twin Commander has never actually manufactured the aircraft in question, but does manufacture spare parts, issues safety bulletins and provides other support services
Twenty years ago one of the aircraft in question crashed. Kenneth Burton, personal representative of the victims, sued Twin Commander for damages resulting from the crash. The federal General Aviation Revitalization Act puts an 18-year statute of limitations on suits against the manufacturer of an aircraft. Twin Commander argues that this bars the plaintiffs' claim. Division One Court of Appeals ruled that Twin Commander has failed to prove that it is a “manufacturer” of the aircraft, however, and thus covered by the statute of limitations.
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