Washington v. Meredith (Majority, Concurrence and Dissent)
Annotate this CaseIn 2018, Petitioner Zachery Meredith boarded a “Swift Blue Line” bus in Snohomish County. Swift buses used a “barrier-free payment-system[ ].” Snohomish County Sheriff’s Deputy Thomas Dalton and his partner were also on the Swift Blue Line that day, conducting fare enforcement pursuant to RCW 36.57A.235. In addition to the two deputies, a third officer was “in his patrol car, following [the bus] and acting as the back-up officer.” Meredith was already on the bus when Dalton and his partner boarded the bus; Dalton “never observed [Petitioner] getting on the bus without paying,” either in person or on video. In accordance with his “general practice,” Dalton requested “‘proof of payment or ORCA card’” from each passenger on the bus. On this particular day, Meredith was one of three individuals who “was not able to present proof of fare payment,” so “[u]pon reaching the next stop, Deputy Dalton detained [Meredith] outside at the bus platform.” Meredith “did not possess any identification documents,” but he gave the deputy a name and birth date, which turned out to be false. Rather than issuing a “civil infraction[ ]” for Meredith’s failure to provide proof of payment, the deputy “believed he had probable cause to arrest [Meredith] for theft in the third degree.” The officers ultimately learned he had two outstanding arrest warrants, for which Meredith was arrested and taken to jail. The State charged Meredith with a gross misdemeanor for making “a false or misleading material statement to a public servant.” Meredith unsuccessfully moved to suppress, contending the deputy lacked reasonable suspicion a crime had been committed. The issue presented for the Washington Supreme Court's review was whether Meredith was "disturbed in his private affairs" by the particular method of fare enforcement used here and, if so, whether this disturbance complied with article I, section 7 of the Washington Constitution. Based on the totality of the circumstances presented, a majority of the Court held Meredith was unlawfully seized. Thus, the Court of Appeals was reversed and the case remanded to the trial court for further proceedings.
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