Jason L. Watson v. City of Spokane, 34025-2

On Nov. 13, 2014, Spokane police arrested Jason Watson for delivery of a controlled substance; Watson admitted some of the $13,000 in his home safe came from drug sales and police seized the cash under a search warrant.
On the same day Watson signed a notice of seizure (informing him of a 45-day administrative claim window) and signed a stipulation and release agreeing to forfeit the $13,000 to the City.
Watson, through counsel, submitted a written claim and was scheduled for a forfeiture hearing before the City hearing examiner; the City later moved to dismiss based on the stipulation.
Watson did not submit any affidavit or other evidence contesting the voluntariness or validity of his stipulation; the hearing examiner dismissed his claim under RCW 34.05.416 for lack of a genuine defense.
The superior court initially remanded but on further review affirmed the examiner’s dismissal; Watson appealed to the Court of Appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether hearing examiner had subject-matter jurisdiction over forfeiture claim	Watson: Superior court has exclusive original jurisdiction over disputes >$3,000, so examiner lacked jurisdiction	City: RCW 69.50.505 grants administrative hearing before agency/examiner; claimant may instead remove to court but must exhaust administrative remedy	Court: Examiner had authority under statute; exhaustion of administrative remedies required before seeking relief in superior court
Whether due process required an evidentiary (live) hearing to test voluntariness of stipulation	Watson: Examiner should have held an evidentiary hearing to determine if his stipulation was knowing, intelligent, and voluntary	City: Watson had opportunity to oppose dismissal and produced no affidavit/evidence; summary dismissal proper when no genuine issue of material fact	Court: No due process violation; summary dismissal was appropriate where Watson presented no factual evidence to create a triable issue

Boeing Co. v. Sierracin Corp., 108 Wn.2d 38 (1987) (subject-matter jurisdiction may be raised at any time)
Wesley v. Schneckloth, 55 Wn.2d 90 (1959) (judgment rendered by a court lacking jurisdiction is void)
Cost Management Servs., Inc. v. City of Lakewood, 178 Wn.2d 635 (2013) (exhaustion of administrative remedies may be required despite superior court's original jurisdiction)
ASARCO, Inc. v. Air Quality Coalition, 92 Wn.2d 685 (1979) (administrative agencies may employ summary procedures)
Mitchell v. W.T. Grant Co., 416 U.S. 600 (1974) (due process does not require evidentiary hearing where no genuine issue of material fact exists)
Rozner v. City of Bellevue, 56 Wn. App. 525 (1990) (civil forfeiture proceedings governed by APA procedures)
IGI Resources, Inc. v. City of Pasco, 180 Wn. App. 638 (2014) (administrative remedies must be exhausted before judicial action where local ordinance provides process)