Maziar v. Department of Corrections
349 P.3d 826
Wash.2015Background
- Scott Maziar, a DOC prison guard, was injured after a DOC ferry captain removed a chair; he sued the Washington State Department of Corrections under general maritime negligence law.
- Trial court initially granted summary judgment for DOC based on Industrial Insurance Act and sovereign immunity; the Court of Appeals reversed and remanded.
- On remand Maziar moved to strike his jury demand, arguing no jury right exists for maritime torts; the trial court granted the motion and the Court of Appeals affirmed on different grounds.
- The Court of Appeals held that while maritime torts generally permit jury trials in state court, the State itself lacks a constitutional or statutory jury right in civil tort actions.
- The Washington Supreme Court granted review to decide whether the State has a jury trial right in tort suits against it.
- The Supreme Court concluded the State has a statutory right to a jury in tort actions and reversed, remanding for a jury trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State has a jury trial right in tort actions against it | Maziar argued no jury right exists for maritime torts (moved to strike his jury demand) | State argued it does have statutory (and constitutional) jury rights in tort suits against it | The Court held the State has a statutory jury-trial right in tort actions and remanded for jury trial |
Key Cases Cited
- Anderson v. Dussault, 181 Wn.2d 360 (2014) (statutory construction standard; ascertain legislature intent)
- Dep’t of Ecology v. Campbell & Gwinn, 146 Wn.2d 1 (2002) (plain meaning rule; read statute with related statutes)
- Thurston County v. Gorton, 85 Wn.2d 133 (1975) (presumption legislature enacts laws with knowledge of existing law)
- Maziar v. Dep’t of Corr., 151 Wn. App. 850 (2009) (Court of Appeals reversed trial court summary judgment on immunity/Industrial Insurance issues)
- Maziar v. Dep’t of Corr., 180 Wn. App. 209 (2014) (Court of Appeals affirmed trial court on jury issue, concluding State lacks constitutional/statutory jury right)