State v. Sykes
182 Wash. 2d 168
| Wash. | 2014Background
- Petitioner Adonijah Sykes entered King County’s adult drug diversion court after pleading to controlled-substance offenses and signed waivers agreeing to drug-court procedures.
- King County’s practice: closed staffings (judge, prosecutor, defense counsel, case manager) where participants are not present; staffings are unrecorded and followed by an open review hearing where the judge recounts staffing discussions and issues orders.
- After compliance problems, the State moved to terminate Sykes from the program; Sykes moved to rescind her drug-court waivers and vacate participation orders, arguing closed staffings violated article I, § 10 (the Washington open-courts provision).
- The trial court denied relief; the State conceded the constitutional question for merits review. The Supreme Court granted direct review. Amicus briefing from drug-court professionals was accepted.
- The lead opinion holds adult drug-court staffings are not presumptively open under article I, § 10 and leaves staffing openness to individual drug courts; the court remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument (Sykes) | Defendant's Argument (State / Drug Court) | Held |
|---|---|---|---|
| Whether article I, § 10 requires adult drug-court staffings to be presumptively open | Closed staffings taint subsequent proceedings; staffings are part of judicial decisionmaking and thus presumptively open | Drug-court staffings are functionally distinct, collaborative, and traditionally closed; openness would undermine treatment goals | No — article I, § 10 does not require staffings to be presumptively open; discretion left to individual drug courts |
| Whether historical practice (experience prong) supports openness | Analogizes staffings to pretrial filings and judicial records that have been open | Points to drug-court practice nationally and in WA where staffings are commonly closed; analogous to private scheduling/conference procedures | Experience prong favors non-openness: staffings have not historically been open in the drug-court context |
| Whether public access materially benefits the process (logic prong) | Public oversight promotes judicial accountability; staffings inform decisions and thus should be public | Public access would harm the collaborative, therapeutic team dynamic and reduce participant engagement and success | Logic prong favors closure: public access would diminish collaboration and participant-judge connection central to drug-court functioning |
| Remedy for an open-courts violation (raised in dissents) | Sykes sought vacatur of waivers and restoration of full trial rights or restart in the program | State declined invited-error defense to resolve the constitutional question on the merits; separate invited-error arguments asserted by dissent | Majority did not order relief on merits beyond remand; dissent would apply invited-error to bar Sykes’ claim if open-courts applied |
Key Cases Cited
- State v. Sublett, 176 Wn.2d 58 (2012) (adopted experience-and-logic test for article I, § 10 public-trial analysis)
- Bennett v. Smith Bundy Berman Britton, PS, 176 Wn.2d 303 (2013) (documents considered by the court are presumptively open)
- In re Det. of Morgan, 180 Wn.2d 312 (2014) (experience-and-logic framework applied to nontraditional proceedings)
- State v. Chen, 178 Wn.2d 350 (2013) (competency evaluations relied on by a judge are presumptively open; sealing requires individualized findings)
- State v. Lormor, 172 Wn.2d 85 (2011) (strong presumption that courts are open at all trial stages)
- State v. Nelson, 108 Wn.2d 491 (1987) (discussing traditional purposes of criminal penalties vs. alternatives such as drug courts)