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State v. Epler
Citations: 969 P.2d 498; 93 Wash. App. 520Docket: 16702-0-III
Court: Court of Appeals of Washington; January 5, 1999; Washington; State Appellate Court
Michael D. Epler faced a DUI charge in district court on June 14, 1996, but the trial ended in a mistrial due to jury deadlock. The State sought a new trial and introduced a new charge of reckless driving linked to the same incident. Epler moved to dismiss the reckless driving charge on double jeopardy grounds, which the State later voluntarily dismissed while retaining the DUI charge. Epler then filed a motion for dismissal with prejudice of the DUI charge, claiming the State's actions constituted prejudicial misconduct under CrRLJ 8.3(b) and violated mandatory joinder provisions of CrRLJ 4.3, alleging that the prosecution's actions had caused him significant prejudice. The district court denied Epler's motion, prompting him to petition the superior court for a writ of stay and review, asserting that the district court had committed a legal error. The superior court granted the writ and conducted a de novo hearing, during which Epler presented new evidence, including an affidavit from a defense witness who expressed reluctance to testify due to perceived vindictiveness from the State. The superior court ultimately dismissed the DUI charge with prejudice, and the State's motion for reconsideration was denied. On discretionary review, the key issue was whether the superior court had the authority to issue the writ of review. The court ruled that it did not have jurisdiction since Epler was not in custody, and the writ fell under statutory parameters rather than constitutional ones. The review also clarified that district court orders in criminal cases could be reviewed by the superior court through a statutory writ, as outlined in RCW 35.20.030. The Rules for Appeal of Decisions of Courts of Limited Jurisdiction (RALJ) do not apply to writ proceedings, which are governed by RCW 7.16. A superior court can grant a writ of review only if the district court exceeded its jurisdiction or acted illegally, and if there is no adequate remedy at law. In this case, both conditions are unmet: the district court acted within its jurisdiction, and there is an adequate remedy through appeal. Mr. Epler's affidavit did not assert lack of jurisdiction but merely claimed a legal error, which is insufficient for a writ. The court's subject matter jurisdiction means that an erroneous ruling does not equate to an act outside its jurisdiction. Discretionary rulings by the district court are not subject to extraordinary writs. Although some circumstances may strip a court of jurisdiction to deny a motion, those involve clear violations of constitutional provisions or court rules, which do not apply here as the ruling was discretionary. An appeal exists as a remedy, making a writ unnecessary, even if an interlocutory order cannot be directly appealed. Under RALJ, interlocutory orders can be reviewed in appeals from final judgments, and the denial of a CrRLJ 8.3(b) motion to dismiss is typically addressed in appeals from the final judgment. Thus, the superior court's decision is reversed.