City of Tukwila v. Garrett

Summary

The Washington Supreme Court held that a Tukwila Municipal Court jury-selection process using jurors drawn from three ZIP codes that roughly approximated the city substantially complied with RCW 2.36.050. The court also held that an oral agreement authorized the King County Superior Court to provide jury-selection services for the municipal court. The court reversed the superior court and affirmed Garrett's conviction; a dissent would have found the jury-selection process and service agreement invalid.

Holdings

1. A municipal court jury pool selected from three ZIP codes that roughly approximated the court's electoral district substantially complied with RCW 2.36.050, even though the ZIP codes included areas outside the municipality and excluded some residents within the municipality.
2. Because the selection procedure substantially complied with RCW 2.36.050 and did not materially depart from statutory requirements, prejudice was not presumed; Garrett was required to establish actual prejudice and failed to do so.
3. An oral agreement between the Tukwila Municipal Court and King County Superior Court validly authorized the superior court to perform jury-selection and jury-summons services after the written agreement expired.
4. The jury-selection process did not violate article I, section 22 of the Washington Constitution or the Sixth Amendment because jurors were drawn from the area served by the municipal court and therefore from the county and district where the offense was charged.

Questions Presented

1. Whether selecting jurors from three ZIP codes that roughly approximated Tukwila's boundaries, but also included residents outside the city, substantially complied with RCW 2.36.050.
2. Whether the jury-selection process materially departed from statutory requirements so that prejudice should be presumed, or whether Garrett had to show actual prejudice.
3. Whether an oral agreement between Tukwila Municipal Court and King County Superior Court validly authorized the superior court to perform jury-management and jury-summons services after the written agreement expired.
4. Whether the jury-selection process violated Garrett's rights to an impartial jury under article I, section 22 of the Washington Constitution and the Sixth Amendment.
5. Whether Garrett could assert the rights of city residents or prospective jurors who were allegedly summoned to serve outside their municipality.

Disposition

reversed