Jennifer Hart v. Erin Hawtin

CourtCourt of Appeals of Washington
DecidedApril 9, 2019
Docket50350-6
StatusUnpublished

This text of Jennifer Hart v. Erin Hawtin (Jennifer Hart v. Erin Hawtin) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jennifer Hart v. Erin Hawtin, (Wash. Ct. App. 2019).

Opinion

Filed Washington State Court of Appeals Division Two IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON April 9, 2019 DIVISION II JENNIFER LYNN HART, No. 50350-6-II

Respondent,

v.

ERIN FREEDOM HAWTIN, UNPUBLISHED OPINION

Appellant.

WORSWICK, J. — After a superior court commissioner issued a final order for protection

against Erin Hawtin, a superior court judge, who disagreed with the decision, sua sponte

convened two hearings, temporarily staying a portion of the final order (the April 6 order) and,

ultimately amending the final order for protection, including changing the commissioner’s

findings of fact (the April 14 order). Hawtin argues that (1) the judge lacked the judicial

authority to sua sponte issue either order, (2) the hearings violated his right to due process, (3)

the hearings caused the Domestic Violence Prevention Act1 (DVPA) to be unconstitutionally

applied to him, (4) the hearings violated his right to equal protection, (5) the hearings were a

prior restraint on his First Amendment rights, (6) the trial court erred in rejecting Hawtin’s

motion and affidavit of prejudice, and (7) the judge violated the Code of Judicial Conduct (CJC)

and should have recused herself.

Jennifer Hart argues that issues arising from the first hearing are moot.

We hold that (1) issues arising from the first hearing are not moot, (2) the judge acted

without judicial authority when she sua sponte issued both orders, and (3) the hearings violated

1 Chapter 26.50. RCW. No. 50350-6-II

Hawtin’s right to due process. We do not reach the remainder of Hawtin’s arguments.

Accordingly, we reverse the April 6 order and reverse and vacate the April 14 order.

FACTS

Jennifer Hart petitioned the Thurston County Superior Court for an order for protection

against her former boyfriend, Erin Hawtin.2 After a full evidentiary hearing, Commissioner Pro

Tem Kratz, entered a final order for protection against Hawtin on April 5, 2017. The final order

for protection had check boxes for the judicial officer to make findings regarding the relationship

of the parties. Commissioner Kratz checked the box finding that Hart and Hawtin had a “current

or former dating relationship,” and did not check the box that Hawtin was a “current or former

cohabitant as intimate partner.” Clerk’s Papers (CP) at 85. The order also stated that Hawtin

had committed domestic violence and represented a credible threat to Hart’s safety. As a result,

the order restrained Hawtin from causing harm to Hart through injury, assault, harassment,

threats, or stalking.

The final order also ordered Hawtin’s firearms be returned to him. During the hearing,

Commissioner Kratz stated:

I want to handle the issue about the fear of firearms that [Hart] is asserting. I don’t find that to be credible. The fact that [Hart was] going to buy a pistol for [Hawtin] and . . . [that Hart asked Hawtin] to help assemble an AR-2 . . . . I don’t believe that rings true that [Hart] is actually fearful of firearms in the possession of [Hawtin].

Verbatim Report of Proceedings (VRP) (April 5, 2017) at 119-20. The commissioner further

stated:

I am not putting any restrictions on [Hawtin] as far as firearms. ....

2 Hart petitioned for this domestic protection order on January 30, 2017, shortly after she was arrested for assaulting Hawtin on January 26, 2017.

2 No. 50350-6-II

There is a statute under the State of Washington that provides that if the court finds that there is a credible threat that a domestic violence abuser would use firearms, that I can authorize that they be surrendered to law enforcement and that his right to possess firearms would be terminated. I’m not finding that in this particular case.

VRP (April 5, 2017) at 125-27. This final order was to be in effect for one year.

The following morning, April 6, Hawtin’s attorney’s office received a call from the

Thurston County Superior Court stating that Hawtin and his attorney were to be present at a

hearing that afternoon regarding the final order. Judge Hirsch presided over this hearing. There,

Judge Hirsh stated that the clerk and another commissioner alerted her that there “is an error” in

Commissioner Kratz’s order. VRP (April 6, 2017) at 3.

Judge Hirsch, before permitting either party to make arguments, stated, “I am going to

allow the protection order to stay in place, but I’m going to issue a stay of the return of the

firearms.” VRP (April 6, 2017) at 4. She further stated that the order was in conflict with Hart’s

petition,

and given that the federal law doesn’t allow there to be firearms once a protection order is issued in certain circumstances—and there are some limitations in the state law—the Court felt that it was necessary for community safety purposes to be able to address it in this way. Obviously, it’s not the best way to have things be addressed, but given the potential issues, the Court on its own motion wanted it brought back today.

VRP (April 6, 2017) at 4-5.

Hawtin’s counsel objected to the procedure of the hearing, stating that the statutory

procedure for revision of a commissioner’s order was not being followed and that the hearing

violated due process. Judge Hirsch responded:

THE COURT: I understand all of that, counsel, and the reason that I’m setting it over is to give everybody an opportunity in weighing the—excuse me. I’m going to finish because I told you we’re just having a moment here. You’re raising quite valid and important points. The Court doesn’t have any ability today to address them. Given the safety issues that the Court believes

3 No. 50350-6-II

may potentially be at issue, in balance I think it’s an appropriate ruling. I’m happy to have you raise those arguments, but I’m going to stay the firearms return.

[HAWTIN’S COUNSEL]: May I finish my record?

THE COURT: You can do your record in writing. You’ve raised due process issues.

[HAWTIN’S COUNSEL]: And I also have a—

THE COURT: Counsel. You raised your due process issues. You can brief the issue for the Court. I’ll set it as soon as I—counsel, if you interrupt me one more time, we’re going to be having some issues. I’m going to stay the firearms provisions. I believe that there are community safety issues at risk. The due process issues and the other issues you raised, counsel, are important, but on balance the Court is going to keep its ruling with respect to the firearm issue only. The order that was entered otherwise is going to remain in place.

VRP (April 6, 2017) at 6-7.

Judge Hirsch then issued an order stating that the court had jurisdiction, that the court

believed the April 5 order may contain a scrivener’s error, that the return of Hawtin’s firearms

would be stayed, and that a hearing would be held on April 14, 2017 in front of Judge Hirsch.

On April 10, Hawtin filed a motion to correct a clerical mistake, or, in the alternative,

motion to reconsider with Commissioner Kratz. Hawtin argued that unchecking one of the boxes

would make clearer that Hawtin is allowed to retain his firearms. Hawtin also filed a motion and

affidavit of prejudice against Judge Hirsch. Then, based on that motion and affidavit, Hawtin

filed a pleading entitled “Objections to Hearing” regarding the hearing scheduled for April 14.

CP at 103.

On April 11, the superior court issued an order rejecting Hawtin’s motion and affidavit of

prejudice noting simply that an affidavit of prejudice “is not applicable at this time.” CP at 109.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mathews v. Eldridge
424 U.S. 319 (Supreme Court, 1976)
Carpenter v. Folkerts
627 P.2d 559 (Court of Appeals of Washington, 1981)
Swan v. Landgren
495 P.2d 1044 (Court of Appeals of Washington, 1972)
PRESIDENTIAL ESTATES APT. v. Barrett
917 P.2d 100 (Washington Supreme Court, 1996)
Sorenson v. City of Bellingham
496 P.2d 512 (Washington Supreme Court, 1972)
State v. Gentry
888 P.2d 1105 (Washington Supreme Court, 1995)
American Continental Ins. Co. v. Steen
91 P.3d 864 (Washington Supreme Court, 2004)
Robertson v. Robertson
54 P.3d 708 (Court of Appeals of Washington, 2002)
Estate of Stalkup v. Vancouver Clinic, Inc.
187 P.3d 291 (Court of Appeals of Washington, 2008)
Hough v. Stockbridge
76 P.3d 216 (Washington Supreme Court, 2003)
State v. Noah
9 P.3d 858 (Court of Appeals of Washington, 2000)
In RE JAIME v. Rhay
365 P.2d 772 (Washington Supreme Court, 1961)
Gourley v. Gourley
145 P.3d 1185 (Washington Supreme Court, 2006)
Blackmon v. Blackmon
230 P.3d 233 (Court of Appeals of Washington, 2010)
North Coast Electric Company v. Signal Electric, Inc.
373 P.3d 296 (Court of Appeals of Washington, 2016)
Presidential Estates Apartment Associates v. Barrett
917 P.2d 100 (Washington Supreme Court, 1996)
Hough v. Stockbridge
150 Wash. 2d 234 (Washington Supreme Court, 2003)
American Continental Insurance v. Steen
91 P.3d 864 (Washington Supreme Court, 2004)
Gourley v. Gourley
158 Wash. 2d 460 (Washington Supreme Court, 2006)
Lowy v. PeaceHealth
280 P.3d 1078 (Washington Supreme Court, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Jennifer Hart v. Erin Hawtin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jennifer-hart-v-erin-hawtin-washctapp-2019.