Today's arguments - January 11, 2011

On its first day back from the holiday break the Court will hear only three arguments, two in the morning and one in the afternoon. (Docket, briefs for first two cases, briefs for third case)

Morning session: (starting at 9:00 a.m.)

In re the Marriage of Daniel & Teresa Farmer, No. 83960-3. How to determine damages for wrongful sale of stock options by one spouse during a divorce.

Teresa and Daniel Farmer dissolved their marriage. Daniel had received some stock options through work, and half of these options were awarded to Teresa. However, Daniel exercised all of the options, both his and Teresa's.

Teresa was awarded damages based on expert testimony about the probable future value of the stock options. Daniel argues that the damages should be based on the value of the options at the time he exercised them, or within a reasonable time thereafter. Daniel lost at Division One Court of Appeals.

 Bank of America v. Owens, No. 84044-0. Whether a supplemental decree giving one spouse partial title to real estate in a divorce decree gives that spouse's claim priority over a bank lien.

J'Amy Owens and Kenneth Treiger purchased a piece of property while married, which later became Owens' separate property. Owens used the property as collateral for a loan from Bank of America.

Owens and Treiger divorced. The court issued a supplemental decree dividing the parties’ assets, ordering that the property be sold and half of the money given to Treiger. The court issued several other decrees awarding money to Treiger.

Then the bank attached the property because Owens had defaulted on the loan. Later, the bank filed a declaratory judgment action to determine who had first claim to the property. The bank argued the supplemental decree was not a final judgment, and so did not give Treiger a judgment lien, thus giving the bank's lien first priority. The Division One Court of Appeals disagreed, but did hold that two other orders were not judgments (and thus did not have priority).

Afternoon session: (starting at 1:30 p.m.)

In re the Dependency of Jenkins, No. 83516-1. Whether a defect in a dependency order can be cured at subsequent hearings.

K.N.J., a minor child, was taken to an Oregon hospital after relatives discovered that she had been severely abused by her parents. A dependency petition was filed by the state and ordered by a judge pro tempore. Normally both parties have to consent to the appointment of a judge pro tempore, but Michael Jenkins, the father of K.N.J., was not present at the hearing and his consent was entered by default. 

Later the state filed for termination of Michael's parental rights, and he moved to vacate the original dependency order due to lack of his consent. The state argued that one parent's consent was sufficient, and that the several subsequent dependency review hearings cured any jurisdictional defect in the first hearing. Division One Court of Appeals found that the original hearing was invalid, but that the subsequent hearings cured the defect.

New cases accepted for review

The Supreme Court granted several petitions for review last week.

  • Cary v. Mason County, No. 83937-9
  • In re Marriage of Farmer, No. 83960-3
  • State v. Hartzell & Tieskotter, No. 84017-2
  • State v. Kosewicz, No. 83682-5
  • State v. Perez-Valdez, No. 84003-2
  • Washington Imaging Services, LLC v. Wash. State Dept of Rev., No. 84101-2.
  • Harris v. Hon. Edsonya Charles, No. 83867-4.
  • Kitsap Alliance of Prop. Owners v. Cent. Puget Sound Growth Mgmt. Hearings Bd., No. 83883-6
  • State v. Posey, No. 82957-8
  • State v. Mullen, No. 83981-6
  • Personal Restraint Petition of Chad Alan Pierce, No. 83731-7
  • Personal Restraint Petition of Eric Sheridan Flint, No. 83815-1 


Cary v. Mason County, No. 83937-9. A group of property owners seek a declaration that a special assessment adopted by the Mason County Conservation District is an invalid and unconstitutional property tax. The superior court ruled in favor of the property owners, and the Court of Appeals (Div. 2) reversed. (Note: The publisher of this blog filed an amicus curiae brief in support of the property owners’ petition for review.)

In re Marriage of Farmer, No. 83960-3. Daniel Farmer and Teresa Farmer entered into a dissolution agreement under which Teresa would receive one half of some community stock. After entering the agreement, but before the final dissolution decree, Daniel sold all of the stock options and fraudulently concealed the fact that he had done so until after entry of the decree. The trial court vacated the stock option provisions of the decree and awarded Teresa damages based an expert’s calculation of damages based on the value of the stock options. Daniel challenges the trial court’s determination of damages.

State v. Hartzell & Tieskotter, No. 84017-2. The Supreme Court granted review on the firearm enhancement issue and remanded the case to the Court of Appeals in light of State v. Williams-Walker (2010).

State v. Kosewicz, No. 83682-5. Theodore Kosewicz was convicted for aggravated first degree murder, first degree kidnapping, and conspiracy to commit first degree kidnapping. The Court of Appeals (Div. 3) reversed the conviction for first degree kidnapping but affirmed the other convictions. The Supreme Court agreed only to hear the review the aggravating factor issue.

State v. Perez-Valdez, No. 84003-2. Alberto Perez-Valdez was convicted of second and third degree rape of a child. He appealed, arguing the trial court made several evidentiary errors, including allowing an investigator to testify that the alleged child victims were telling the truth.

Washington Imaging Services, LLC v. Wash. State Dep’t of Rev., No. 84101-2. Washington Imaging Services (WIS) collects funds from its patients and insurance companies and forwards the funds to Overlake Imaging Associates for radiological analysis. WIS did not pay business and operating taxes on these funds, concluding that the funds qualified under a “pass through” exemption that allows a business to exclude amounts it receives as an agent for a client from its taxable gross income. After an audit the Department of Revenue concluded WIS owed B & O tax for payments forwarded to Overlake Imaging. The trial court ruled for the Department of Revenue, but the Court of Appeals (Div. 2) reversed the ruling, holding that the pass through payments were not gross income and WIS should not pay B&O taxes on these amounts.

Harris v. Hon. Edsonya Charles, No. 83867-4. Joshua Harris was sentenced to 90 days in jail after pleading guilty to driving while license suspended in the third degree. He filed a writ of habeas corpus in King County Superior Court asking that the municipal court be ordered to give him credit for his time on electronic home monitoring. The Superior Court granted the writ. The Court of Appeals (Div. 1) reversed.

Kitsap Alliance of Prop. Owners v. Cent. Puget Sound Growth Mgmt. Hearings Bd., No. 83883-6. The Supreme Court ordered the Court of Appeals to review the constitutionality of House Bill 1653, enacted by the Washington Legislature this year. The legislation was in response to a Court of Appeals ruling which relied on the Supreme Court’s interpretation of state land use law as it then stood. House Bill 1653 amended land use law and purported to apply retroactively. For more on the case, see the Pacific Legal Foundation’s press release.

State v. Posey, No. 82957-8.

State v. Mullen, No. 83981-6. Lisa Mullen and Kevin Dean were convicted of stealing from their employer, Frontier Ford. After their trial Mullen and Dean discovered information from a related lawsuit that could have been useful in corroborating their defense at trial. They sought a new trial but the trial court and the Court of Appeals (Div. 1) both held the defendants could have obtained the evidence on their own, and that the evidence too speculative to be material.

Personal Restraint Petition of Chad Alan Pierce, No. 83731-7.

Personal Restraint Petition of Eric Sheridan Flint, No. 83815-1.