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HeadsUp for Washington State: Court Opinions From Tuesday, May 12, 2015

Tuesday, May 12, 2015

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Division Two of the Court of Appeals filed 1 new published opinion and Division Three filed no new opinions on Tuesday, May 12, 2015:

Division Two:

Watkins v. Dep't of Licensing
No. 45327-4
(May 12, 2015)
2015 Wash. App. LEXIS 1004 (

2015 Wash. App. LEXIS 1004 (Lexis Advance)


Brief: In a case involving the revocation of driving privileges, a second officer's certified report met the requirements of former RCW 46.20.308(6)(e) (2012) by stating that there were reasonable grounds to believe the driver had been driving under the influence and that, after receipt of the warnings required by the implied consent statute, the driver refused to submit to a breath test. The second officer's report was sufficient to give the Department of Licensing jurisdiction to revoke the driver's privileges. The arresting officer's uncertified arrest report was admissible at the revocation hearing under former RCW 46.20.308. The admission of the uncertified arrest report did not deprive the driver of due process. 

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