State v. Kipp

CourtWashington Supreme Court
DecidedFebruary 6, 2014
Docket88083-2
StatusPublished

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

Bluebook
State v. Kipp, (Wash. 2014).

Opinion

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IN THE SUPREME COURT OF THE STATE OF WASHINGTON

STATE OF WASHINGTON, ) ) No. 88083-2 Respondent, ) ) v. ) EnBanc ) WILLIAM JOHN KIPP, JR., ) ) Petitioner. ) ) Filed FEB 0 6 2014

C. JOHNSON, J.-The central issue in this case is whether the trial court

erred in admitting into evidence a secretly recorded conversation between William

Kipp and his brother-in-law in violation of Washington's privacy act, chapter 9.73

RCW. Kipp was convicted of two counts of rape of a child and one count of child

molestation in the second degree. Part of the evidence presented at trial was a

recording of a conversation made without Kipp's knowledge or consent. Before

trial, Kipp moved to suppress the recording, relying on the privacy act. The trial

court ruled that the recording was not a private conversation and, therefore, not

subject to suppression. A jury found Kipp guilty and he appealed. In a split

decision, the Court of Appeals affirmed, holding that substantial evidence

supported the trial court's ruling. In reaching its conclusion, the Court of Appeals State v. Kipp, No . .88083-2 .·

rejected this court's precedent under State v. Clark, 129 Wn.2d 211, 916 P.2d 384

( 1996), which holds that when facts are undisputed, the question of whether a

particular communication is private is a matter of law reviewed de novo. The Court

of Appeals utilized an abuse of discretion standard on review. Kipp petitioned this

court for diseretionary review, which we granted. State v. Kipp, 171 Wn. App. 14,

286 P.3d 68 (2012), review granted, 176 Wn.2d 1024, 301 P.3d 1047 (2013). We

hold that for purposes of the privacy act, when facts are undisputed, the question of

whether a partkular communication is private is a matter of law reviewed de novo.

In this case, Kipp's conversation with his brother-in-law was private and therefore

should have been suppressed. We reverse and remand.

FACTS AND PROCEDURAL HISTORY

William Kipp was accused of sexually assaulting two of his nieces. He was

confronted by their father, Kipp's brother-in-law, who secretly recorded a

conversation onto a cassette tape. This conversation was reported to police. The

State charged Kipp, for the acts against one of his nieces, with two counts of

~econd degree rape of a child and one count of second degree child molestation.

Before trial, Kipp moved to suppress the recorded conversation under the

privacy act, chapter 9.73 RCW. The trial court declined to conduct an evidentiary

2 State v. Kipp, No. 88083-2

hearing and instead accepted the facts put forth by the parties. 1 The trial court also

listened to the recording~ which was a little over 10 minutes in duration, and

accepted the following undisputed facts: (1) Kipp did not know he was being

recorded, (2) the taped conversation is about 10 minutes long, (3) the conversation

took place in the upstairs kitchen of a private home, (4) the conversation was

between Kipp and his brother-in-law, (5) the topic of conversation was the

accusation that Kipp molested Joseph Tan's daughters, and (6) Kipp suggested

toward the end of the conversation that they talk about it further at a later time.

Based on these facts, the trial court concluded that the conversation between Kipp

and his brother-in-law was not a private conversation and therefore not subject to

suppression under the privacy act. The recorded conversation was admitted into

evidence at trial, and the court reporter transcribed the recording to the best of her

abilities. The court revisited the suppression motion after the State substituted the

original recording during trial. The court reaffirmed its earlier ruling. A jury found

Kipp guilty on all counts.

Kipp appealed. The Court of Appeals affirmed in a split decision, holding

that sufficient evidence supported the trial court's decision that the conversation

1 Although Kipp assigned error to the trial court's failure to conduct an evidentiary hearing in its briefing to the Court of Appeals, this issue is not before us on review. See Pet. for Review.

3 State v. Kipp, No. 88083-2

was not private. We granted Kipp's petition for discretionary review. The

American Civil Liberties Union of Washington filed a brief in support ofKipp's

argument.

ANALYSIS

The privacy act prohibits recording of any "[p ]rivate conversation, by any

device electronic or otherwise designed to record or transmit such conversation

regardless how the device is powered or actuated without first obtaining the

consent of all the persons engaged in the conversation." RCW 9.73.030(1)(b).

Evidence obtained in violation of the act is inadmissible for any purpose at trial.

RCW 9.73.050. It is undisputed that the conversation was recorded without Kipp's

permission. The only issue, then, is whether the conversation between Kipp and his

brother-in-law was "private."

Generally, the privacy act is implicated when one party records a

conversation without the other party's consent. Washington State's privacy act is

considered one of the most restrictive in the nation. State v. Townsend, 147 Wn.2d

666, 672, 57 P.3d 255 (2002) .

. "Our state has a long history of statutory protection of private

communications and conversations." Clark, 129 Wn.2d at 222.

Since 1909, the privacy act has protected sealed messages, letters, and telegrams from being opened or read by someone other than the intended recipient. RCW 9.73.010-.020. In 1967, the legislature

4 State v. Kipp, No. 88083·-2

amended the act in order to keep pace with the changing nature of electronic conimunications and in recognition of the fact that there was no law that prevented eavesdropping.

State v. Christensen, 153 Wn~2d 186, 198, 102 P.3d 789 (2004). "In 1977, the

[l]egislature permitted electronic recording of conversations with one party's

consent where law enforcement obtained an order from a judge or magistrate

fi.nding probable cause to believe that the nonconsenting party committed, was

engaged in, or is about to commit a felony." Clark, 129 Wn.2d at 222-23 (citing

RCW 9.73.090(2)). Again, in 1989, the legislature broadened the ability of law

enforcement officers to record private conversations and communications

concerning drug felonies. See RCW 9.73.090(5); Clark, 129 Wn.2d at 223.

T'he federal government and 49 states have enacted privacy or

eavesdropping statutes. Washington is 1 of only 11 states that require that all

parties to a private communication consent to its recording and disclosure. This

"all.-party consent" rule adds an additional layer of protection to the private

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