WASHINGTON CASE LAW UPDATE

State v. Enlow: The Division Three Court of Appeals overturned David Enlow's conviction for manufacture of methamphetamine, holding that Mr. Enlow was not in direct or constructive possession of the truck in whose bed he was found hiding, and therefore was not in possession of the methamphetamine-making supplies also found in the bed of the truck.

State v. Schaller: The Division One Court of Appeals held that multiple requests to dismiss assigned counsel does not, without more, justify substitution of new counsel. Rather, the court held, there must be good cause to warrant substitution, such as a conflict of interest, an irreconcilable conflict, or a complete breakdown in communication between the defendant and counsel. The court found that the trial court in this case had sufficiently questioned the defendant regarding his communications with his attorneys, and had acted appropriately in finding that new counsel need not be appointed.