State Of Washington V. Faafetai Santisteban

CourtCourt of Appeals of Washington
DecidedJune 23, 2025
Docket87313-0
StatusUnpublished

This text of State Of Washington V. Faafetai Santisteban (State Of Washington V. Faafetai Santisteban) 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
State Of Washington V. Faafetai Santisteban, (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

STATE OF WASHINGTON, No. 87313-0-I Plaintiff, DIVISION ONE v. UNPUBLISHED OPINION FAAFETAI T. SANTISTEBAN,

Respondent,

THE DEPARTMENT OF SOCIAL AND HEALTH SERVICES, non-party ordered to pay for services,

Appellant.

BIRK, J. — In 1998, Faafetai Santisteban was committed to Western State

Hospital after being acquitted as not guilty by reason of insanity. Santisteban

petitioned the superior court for conditional release. The superior court granted

Santisteban’s petition and directed that she be released to an adult family home.

But, in addition, based on the agreement of Santisteban and the Snohomish

County prosecutor’s office, and without affording the state Department of Social

and Health Services (DSHS) notice and an opportunity to be heard, the superior

court ordered DSHS to fund services that DSHS disputes it had legal authority to

fund. We conclude the superior court did not obtain personal jurisdiction over

DSHS and thus could not order DSHS to fund Santisteban’s conditional release.

We further conclude the superior court did not have appellate jurisdiction to review No. 87313-0-I/2

an earlier DSHS determination of Santisteban’s eligibility for services. We reverse

and remand for proceedings consistent with this opinion.

I

Following a 1998 acquittal on criminal charges by reason of insanity,

Santisteban was ordered to the care and custody of DSHS for treatment at

Western State Hospital.

In November 2023, Santisteban submitted to DSHS an application for

conditional release. In December 2023, a division of DSHS, Home and Community

Services (HCS), made a determination that she was not functionally eligible for

long term care under the “Community First Choice Residential” program. HCS’s

notice provided information to appeal the eligibility decision if Santisteban

disagreed with the denial. The record is silent as to whether Santisteban appealed

HCS’s decision.

Santisteban petitioned the superior court for conditional release. The

superior court scheduled a contested hearing for September 26-27, 2024. On

September 18, 2024, Santisteban filed a criminal calendar note setting entry of a

proposed “agreed” order for Monday, September 23, 2024. Santisteban served

notice of the hearing on the Snohomish County deputy prosecutor. County

prosecutors represent the State in conditional release proceedings. RCW

10.77.150(3)(b). On Friday, September 20, 2024, Santisteban filed a

memorandum challenging DSHS’s release planning for Santisteban and objecting

to DSHS’s contesting the proposed order.

2 No. 87313-0-I/3

At the September 23, 2024 hearing, in addition to Santisteban and the

county prosecutor, an assistant attorney general appeared for DSHS. Santisteban

informed the superior court that the parties—Santisteban and the county

prosecutor’s office—did not disagree “on the ultimate issue under [RCW]

10.77.150. And that is with the conditions and the amount of supervision laid out

in the conditions of the proposed order, there’s not a dispute.” The parties

submitted an agreed proposed order of conditional release to the superior court

and requested the court enter it.

Through its counsel, DSHS indicated it was made aware of the hearing and

the agreed proposed order the Wednesday before the Monday hearing. DSHS

argued the proposed order directed it to pay for an adult family home that it had

already determined the patient was not eligible for, it was obligated under the

governing statute to pay for only inpatient care, and it was not statutorily obligated

to pay for Santisteban’s less restrictive care.

The superior court stated that DSHS had not moved to intervene under CR

24. The superior court ruled that “it’s abundantly clear from the materials that

[Santisteban] meets the criteria for a less restrictive alternative based on the

findings as outlined quite thoroughly in the proposed order.” In its order granting

Santisteban’s conditional release, the superior court ruled that “DSHS is

responsible for the cost of [Santisteban’s] continued commitment,” which the court

said “includes her conditional release to an adult family home, and ordered “DSHS

via HCS to pay for all aspects of [Santisteban’s] community living.” The superior

3 No. 87313-0-I/4

court left “the ultimate source of funding to the discretion of DSHS,” but found that

“[HCS] should pay the cost of all aspects of this conditional release order.” The

superior court based this on “the parties’ stipulation”—that is, Santisteban and the

county prosecutor’s stipulation—“that the HCS incorrectly found [Santisteban]

ineligible for that funding in the first place.” DSHS filed a notice of appeal, and it

filed a motion in this court to stay the challenged portions of the superior court’s

order. A commissioner of this court granted the stay.

In this court, DSHS argues that the superior court lacked personal

jurisdiction over it and so its directive to DSHS to pay for services must be

reversed. DSHS further argues that the superior court lacked appellate jurisdiction

to review the merits of HCS’s decision about Santisteban’s eligibility for long term

care benefits. And, on the merits, DSHS argues that the superior court’s order that

DSHS must fund Santisteban’s conditional release to an adult family services

home is contrary to the plain language of RCW 10.77.250.

RCW 10.77.250(1) states, “[T]he department shall be responsible for all

costs relating to the evaluation and inpatient treatment of persons committed to it

pursuant to any provisions of this chapter, and the logistical and supportive

services pertaining thereto except as otherwise provided by law.” (Emphasis

added.) DSHS argues that “inpatient treatment” means care other than in a less

restrictive alternative based on the statutory language throughout chapter 10.77

RCW. Indeed, under the community behavioral health services act (see RCW

71.24.011), the director of the Washington state health care authority is directed

4 No. 87313-0-I/5

to take numerous actions associated with making behavioral health services

available in the state. RCW 71.24.035(1)-(6). Among these responsibilities, the

legislature has directed the health care authority to require behavioral health

administrative services organizations and managed care organizations to provide

the services required as part of a less restrictive alternative either under the

involuntary treatment act (ITA), RCW 71.05.585, or as part of a conditional release

of a person acquitted by reason of insanity, RCW 10.77.175. See RCW

71.24.035(5)(l). DSHS argues that the legislature’s providing for the health care

authority to contract for these services further shows that DSHS’s statutory

responsibility is to pay for only the inpatient care of those acquitted by reason of

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