Washington v. Fitzsimmons
449 U.S. 977
SCOTUS1980Check TreatmentSup. Ct. Wash. Motion of respondent for leave to proceed in forma pauperis and certiorari granted. Judgment vacated and case remanded to the Supreme Court of Washington to consider whether its judgment is based upon federal or state constitutional grounds, or both. See California v. Krivda, 409 U. S. 33 (1972).
