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Case Law Updates Feb. 19-Mar. 4, 2025

Court of Appeals

State v. W.H, ___ Wn.App.2d ___, Div. II, No. 59094-8 (Mar. 4, 2025): CrR 8.3: Although the trial court has discretion to dismiss a case under CrR 8.3, dismissal with prejudice prior to: the expiration of speedy trial is an extraordinary remedy, and the court must first consider lesser alternatives.

In re B.H-W., ___ Wn.App.2d ___, No. 58595-2, Div. II (Mar. 3, 2025):Family Defense/Dependency/Alleged Biological Parent’s Standing: Alleged biological parents have standing to participate as a party in dependency proceedings.

State v. Bellerouche, ___ Wn.App.2d ___, No. 8488-9, Div. I (Mar 3, 2025 opinion was withdrawn, and new opinion was substituted on Mar 13, 2025 in order to reflect corrections in the transcriptions of some of the verbatim report of proceedings referenced in the dissent): ER 403,
Race based prosecutorial misconduct, Prosecutorial misconduct.

State v. M.V., ___ Wn.App.2d ___, No. 58853-6, Div. II (Feb. 25, 2025): Juvenile/Disposition: The trial court has authority to impose a disposition up to the statutory maximum sentence, not the high end of the standard range under the SRA.

State v. Tyson, ___ Wn.App.2d ___, No. 58888-9, Div. II (Feb. 25, 2025): Search/Seizure: Under the independent source doctrine, warrantless seizure of cell phone did not bar admission of evidence later searched and seized from the cellphone pursuant to a valid warrant.

State v. Solomon-Gibson, ___ Wn.App.2d ___, No. 58962-1, Div. II (Feb. 19, 2025): Sentencing/Juvenile Points: Trial court erred when it excluded prior juvenile adjudications from the offender score.