Blomstrom v. Tripp, 91642-0

Three defendants (Blomstrom, Button, Cooper) arrested for DUI were released with conditions requiring periodic random urinalysis; one had a prior out-of-state DUI and ignition-interlock issues, two had very high BACs but no prior DUI convictions.
Each defendant objected at first appearance; the district court nonetheless imposed urinalysis testing (twice or four times monthly) and abstention conditions under CrRLJ 3.2.
Petitioners sought statutory writs of review in superior court challenging the pretrial urinalysis conditions as violating CrRLJ 3.2, the Fourth Amendment, and article I, section 7 of the Washington Constitution; superior court denied the writs as unnecessary because of an available RALJ appeal.
The Washington Supreme Court granted discretionary review to decide (1) whether a statutory writ was available and (2) whether the urinalysis conditions violated state constitutional privacy protections.
The Court held (majority) that petitioners lacked an adequate remedy at law, were entitled to statutory writs, and that suspicionless urinalysis as a pretrial release condition violated article I, § 7; the court declined to adopt the federal special-needs exception for this context.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to statutory writ under RCW 7.16.040	Petitioners: no plain, speedy, adequate remedy; must obtain pretrial relief	State: RALJ direct appeal or motion to amend conditions in district court are adequate	Court: RALJ and in‑court motion are inadequate; statutory writ available pretrial
Standing to challenge ignition‑interlock device (IID)	Petitioners: Button briefly subject to IID and can challenge IID practice	State: no petitioner was subject to an IID at time of writ filing	Court: collective IID challenge lacked standing/mootness; confined review to urinalysis
Preservation of constitutional challenge	Petitioners: counsel cited Rose at first appearance—sufficient to preserve article I, § 7 challenge	State: constitutional claim not adequately raised below	Court: citation to Rose in context preserved the state‑privacy challenge
Constitutionality of suspicionless urinalysis under article I, § 7 and Fourth Amendment	Petitioners: urinalysis is a severe intrusion on bodily privacy; no statute or rule provided authority; privacy greater under state constitution	State: public safety and CrRLJ authority justify testing; urged federal special‑needs balancing	Court: article I, § 7 affords greater protection here; no statutory/court‑rule authority or special‑needs importation justified suspicionless random urinalysis; testing unconstitutional

City of Seattle v. Holifield, 170 Wn.2d 230 (2010) (standard for statutory writ review and when inferior tribunal acts illegally)
Commanda v. Cary, 143 Wn.2d 651 (2001) (postconviction remedies may make writ inappropriate; clarified limits of writ relief)
State v. Rose, 146 Wn. App. 439 (2008) (Court of Appeals decision addressing constitutionality of pretrial urinalysis)
State v. York, 163 Wn.2d 297 (2008) (heightened state constitutional protection for bodily functions; treated limits of special‑needs reasoning)
State v. Olsen, 189 Wn.2d 118 (2017) (upheld suspicionless urinalysis for probationers based on reduced privacy expectations and narrow tailoring)
State v. Gunwall, 106 Wn.2d 54 (1986) (factors for independent state constitutional analysis)
State v. Puapuaga, 164 Wn.2d 515 (2008) (addressed privacy expectations for persons in custody; discussed scope of Fourth vs. article I, § 7 analysis)
State v. Surge, 160 Wn.2d 65 (2007) (framework for analyzing article I, § 7 intrusions: private affairs and authority of law)