State of Washington v. Nicholas Taylor

427 P.3d 656
CourtCourt of Appeals of Washington
DecidedOctober 2, 2018
Docket35461-0
StatusPublished

This text of 427 P.3d 656 (State of Washington v. Nicholas Taylor) 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. Nicholas Taylor, 427 P.3d 656 (Wash. Ct. App. 2018).

Opinion

FILED OCTOBER 2, 2018 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

STATE OF WASHINGTON, ) No. 35461-0-III ) Respondent. ) ) v. ) PUBLISHED OPINION ) NICHOLAS TAYLOR, ) ) Petitioner. )

LAWRENCE-BERREY, C.J. — We are asked whether the City of Spokane’s (City)

adoption of RCW 46.61.502, driving under the influence (DUI), deprived the Spokane

County District Court of jurisdiction over DUIs committed within the City. We hold that

it did not. We affirm Nicholas Taylor’s DUI conviction.

FACTS

A trooper with the Washington State Patrol stopped Mr. Taylor for suspected DUI.

The stop occurred within the city limits of Spokane. Mr. Taylor failed various tests, and

the trooper arrested and cited him for violating RCW 46.61.502.

The State charged Mr. Taylor in Spokane County District Court for violating

RCW 46.61.502. The jury found Mr. Taylor guilty of DUI, and the district court judge No. 35461-0-III State v. Taylor

entered a judgment of conviction. Mr. Taylor appealed his conviction to Spokane County

Superior Court.

There, Mr. Taylor argued that the Spokane County District Court lacked subject

matter jurisdiction over his DUI case. His argument was predicated on the City enacting

Spokane Municipal Code § 16A.02.010, which adopted Title 308-330 WAC—the

Washington Model Traffic Ordinance (WMTO). Title 308-330 WAC adopts various

state statutes, including RCW 46.61.502. Mr. Taylor argued that the City’s adoption of

RCW 46.61.502 vested its municipal court with exclusive jurisdiction over all DUIs

committed within the City’s boundaries. The superior court rejected his argument and

affirmed his conviction.

Mr. Taylor sought discretionary review. We were persuaded that the issue was one

of first impression and granted his request. A panel of this court considered the issue

without oral argument.

ANALYSIS

Mr. Taylor challenges the subject matter jurisdiction of the Spokane County

District Court. A party may challenge the trial court’s subject matter jurisdiction for the

first time at any point in a proceeding, even on appeal. Cole v. Harveyland, LLC, 163

Wn. App. 199, 205, 258 P.3d 70 (2011). Whether a trial court had jurisdiction is a

2 No. 35461-0-III State v. Taylor

question of law that we review de novo. City of Spokane v. Spokane County, 158 Wn.2d

661, 681, 146 P.3d 893 (2006).

The meaning of a statute is also a question of law that we review de novo. Id. at

672. The primary goal of statutory construction is to discern and implement the

legislature’s intent. Id. at 673.

Where the meaning of statutory language is plain on its face, we must give effect to that plain meaning as an expression of legislative intent. In discerning the plain meaning of a provision, we consider the entire statute in which the provision is found, as well as related statutes or other provisions in the same act that disclose legislative intent.

Id. (citation omitted).

Under the Washington Constitution, the legislature has the sole authority to

prescribe the jurisdiction and powers of district and municipal courts. WASH. CONST.

art. IV, § 12; Exendine v. City of Sammamish, 127 Wn. App. 574, 580, 113 P.3d 494

(2005).

The legislature has given the district courts jurisdiction “[c]oncurrent with the

superior court[s] of all misdemeanors and gross misdemeanors committed in their

respective counties and of all violations of city ordinances.” RCW 3.66.060. If a city has

created a municipal court, violations of city ordinances must be prosecuted exclusively in

the municipal court. RCW 3.50.020; see also City of Spokane, 158 Wn.2d at 683

3 No. 35461-0-III State v. Taylor

(ordering open cases involving municipal code violations to be transferred from the

district court to the newly created municipal court).

Municipal courts “have . . . exclusive original criminal jurisdiction of all violations

of city ordinances duly adopted by the city . . . .” RCW 3.50.020 (emphasis added).

When a court has exclusive original jurisdiction, the relevant action must be filed in that

court. City of Spokane, 158 Wn.2d at 682 (quoting Ledgerwood v. Lansdowne, 120 Wn.

App. 414, 420, 85 P.3d 950 (2004)).

Mr. Taylor argues that the City’s adoption of RCW 46.61.502 precludes Spokane

County from exercising jurisdiction over DUIs occurring within the City’s boundaries.

We disagree.

The State charged Mr. Taylor with a gross misdemeanor in violation of

RCW 46.61.502. As noted previously, the legislature gave district courts concurrent

jurisdiction with superior courts of all misdemeanor and gross misdemeanor violations

occurring within their respective counties. It is undisputed that Mr. Taylor committed his

DUI in Spokane County.

Mr. Taylor fails to cite to a statute that would deprive the district court of its

jurisdiction in this matter. At best, he cites to RCW 3.50.020, which gives municipal

courts exclusive criminal jurisdiction over all violations of city ordinances.

4 No. 35461-0-III State v. Taylor

RCW 46.61.502 is not a city ordinance. Nor did RCW 46.61.502 become a city

ordinance by virtue of the City adopting it.

Mr. Taylor argues that allowing law enforcement to cite a criminal law violation as

a state law or a municipal law violation gives law enforcement too much discretion and

threatens the viability of municipal courts. We disagree.

Washington State Patrol troopers are authorized to enforce state laws.

RCW 43.43.030. They are not permitted to enforce local laws. 1957 Op. Att’y Gen. No.

115, 1957 WL 54007. County sheriffs and their deputies are authorized to enforce state

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Related

Whatcom County v. City of Bellingham
909 P.2d 1303 (Washington Supreme Court, 1996)
Cole v. HARVEYLAND, LLC
258 P.3d 70 (Court of Appeals of Washington, 2011)
City of Auburn v. Gauntt
274 P.3d 1033 (Washington Supreme Court, 2012)
Exendine v. City of Sammamish
113 P.3d 494 (Court of Appeals of Washington, 2005)
City of Spokane v. County of Spokane
146 P.3d 893 (Washington Supreme Court, 2006)
Ledgerwood v. Lansdowne
85 P.3d 950 (Court of Appeals of Washington, 2004)
City of Spokane v. Spokane County
158 Wash. 2d 661 (Washington Supreme Court, 2006)
Ledgerwood v. Lansdowne
120 Wash. App. 414 (Court of Appeals of Washington, 2004)
Exendine v. City of Sammamish
113 P.3d 494 (Court of Appeals of Washington, 2005)

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