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Sasha Sugaberry, V. Ywca Seattle
81580-6
| Wash. Ct. App. | Aug 9, 2021
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Background

  • Sugaberry entered YWCA Seattle's emergency domestic-violence shelter in September 2018 and completed intake, including signing a "Resident Rights and Responsibilities" form describing shelter rules (including a 10:00 p.m. curfew and a 24‑hour absence rule that authorizes removal of a resident from the daily room log and disposal of belongings left for more than 24 hours).
  • On October 18, 2018 Sugaberry left the shelter for an out‑of‑state trip and left personal property behind; she contends she had permission to leave her belongings, while YWCA staff say she was told not to leave property.
  • When Sugaberry did not return or contact staff within 24 hours, YWCA staff disposed of the items per their policy.
  • Sugaberry sued for conversion; at a bench trial the court heard testimony from Sugaberry, one of her witnesses, and three YWCA staff and admitted the intake form and staff case notes into evidence.
  • The trial court found the YWCA witnesses credible, concluded Sugaberry had been warned about the 24‑hour rule and had signed the policies, found no proof of the value of the lost items, and dismissed the conversion claim with prejudice; Sugaberry appealed.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Admissibility of exhibits Intake form and staff notes were fraudulent/inaccurate and should be excluded Exhibits were properly authenticated and plaintiff could cross‑examine Trial court did not abuse discretion in admitting the documents
Exclusion/limitation of witness testimony Marsha Armstrong and other testimony was improperly excluded Late disclosure and much of the proffered testimony was irrelevant to YWCA’s conduct Court limited irrelevant testimony but admitted relevant testimony (e.g., about Sugaberry’s luggage); no abuse of discretion
Motion to compel discovery / subpoenas Plaintiff was denied access to evidence and witnesses via subpoenas Discovery deadline had passed; court granted a trial subpoena but required plaintiff to effect service Denial of belated motion to compel was not an abuse of discretion under local discovery deadline rules
Conversion claim and damages / sufficiency of evidence YWCA converted belongings, had authorized storage, and damages exceed $50,000 Items were abandoned or left with implied consent under shelter policy; plaintiff offered no admissible proof of value Findings supported by substantial evidence; plaintiff failed to prove conversion or value; dismissal affirmed

Key Cases Cited

  • In re Marriage of Olson, 69 Wn. App. 621 (Wash. Ct. App. 1993) (pro se litigants held to same procedural standards as attorneys)
  • State v. Marintorres, 93 Wn. App. 442 (Wash. Ct. App. 1999) (failure to follow appellate rules may preclude review)
  • In re Parentage of J.H., 112 Wn. App. 486 (Wash. Ct. App. 2002) (admissibility reviewed for abuse of discretion)
  • Cowiche Canyon Conservancy v. Bosley, 118 Wn.2d 801 (Wash. 1992) (arguments lacking record citations or legal analysis need not be considered)
  • Merriman v. Cokeley, 168 Wn.2d 627 (Wash. 2010) (substantial‑evidence standard for findings of fact)
  • Clarke v. State Att’y Gen.'s Office, 133 Wn. App. 767 (Wash. Ct. App. 2006) (discovery rulings reviewed for abuse of discretion)
Read the full case

Case Details

Case Name: Sasha Sugaberry, V. Ywca Seattle
Court Name: Court of Appeals of Washington
Date Published: Aug 9, 2021
Docket Number: 81580-6
Court Abbreviation: Wash. Ct. App.