WEEKLY ROUNDUP FOR THE WEEKS OF MAY 12 & 19, 2025
Washington Supreme Court:
Informants – A 911 call is not the same as an “anonymous tip.” A 911 call from a bystander (meaning someone not connected with the events) giving a contemporaneous eyewitness report is part of the totality of the circumstances that establishes reliability. The caller’s basis of knowledge is a factor in assessing the tip’s reliability, but is not required. Wenatchee v. Stearns, No. 102680-3 (May 15, 2025).
Division I:
Commercial sex acts – The (human) Trafficking statute, RCW 9A.40.100, does not limit commercial sex acts to those between the victim and a third person, arranged by a seller. “Things of value” may be housing, food and monetary support received by the victim directly from the defendant. State v. Callahan, No. 86613-3-I (May 19, 2025).
Land use – A hearing examiner may approve a plat application that fails to strictly comply with the county’s comprehensive plan if the development regulations do not expressly require compliance with the comprehensive plan. Fall City Sustainable Growth v. King County, No. 86032-1-I (May 19, 2025).
Division III:
Prosecutorial error – A prosecutor may present evidence and arguments related to religion and culture when it is relevant. Here, evidence of the defendant and victim’s religion and culture was probative of the defendant’s motive for killing his ex-wife, who had apparently changed her behavior and beliefs in ways inconsistent with Iraqi Islamic cultural norms. State v. Darraji, No. 39421-2-III (May 22, 2025).
Foreign case of interest:
Search & seizure – An officer’s mistaken belief about a law violation can be an objectively reasonable basis for a traffic stop. United States v. Smith, No. 24-1006 (May 13, 2025).