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GRANT COUNTY
COMMISSIONERS AGENDA MEETING REQUEST FORM
(Must be submitted to the Clerk of the Board by 12:00pm on Thursday)
REQUESTING DEPARTMENT. Commissioner's Office
REQUEST SUBMITTED BY: B Vasquez/R Kaylor
DATE:6/11/24
PHONE:2928
CONTACT PERSON ATTENDING ROUNDTABLE:13 Vasquez, R Kaylor
CONFIDENTIAL INFORMATION: DYES 11 NO
Request for the Chair to DocuSign the MOU with Department of Social and Health
Services (DSHS) and WA State for settlement in Pierce County Superior Ct
Cause No. 23-2-09161-8 involving competency concerns.
If necessary, was this document reviewed by accounting? 11 YES F] NO 0 N/A
If necessary, was this document reviewed by legal? ® YES D NO 11 N/A
DATE OF ACTION: DEFERRED OR CONTINUED TO:
APPROVE: DENIED ABSTAIN
a to j
D1:
D2:
D3:
4/23/24
WITHDRAWN:
RmAgreement / Contract
EIAP Vouchers
ElAppointment / Reappointment
EIARPA Related
El Bids / RFPs / Quotes Award
OBid Opening Scheduled
El Boards / Committees
El Budget
ElComputer Related
FlCounty Code
ElEmergency Purchase
ElEmployee Rel.
E Facilities Related
1-1 Financial
7 Funds
El Hearing
El Invoices / Purchase Orders
ElGrants — Fed/State/County
Ell -eases
7MOA /MOU
F]Minutes
ElOrdinances
[:]Out of State Travel
F Petty Cash
El Policies
R Proclamations
El Request for Purchase
n Resolution
ORecommendation
F-1 Professional Serv/Consultant
7Support Letter
E]Surplus Req.
F-1Tax Levies
FlThank You's
E]Tax Title Property
EIWSLCB
Request for the Chair to DocuSign the MOU with Department of Social and Health
Services (DSHS) and WA State for settlement in Pierce County Superior Ct
Cause No. 23-2-09161-8 involving competency concerns.
If necessary, was this document reviewed by accounting? 11 YES F] NO 0 N/A
If necessary, was this document reviewed by legal? ® YES D NO 11 N/A
DATE OF ACTION: DEFERRED OR CONTINUED TO:
APPROVE: DENIED ABSTAIN
a to j
D1:
D2:
D3:
4/23/24
WITHDRAWN:
K24-150
PROTECTED UNDER ER 408; CONFIDENTIAL; FOR SETTLEMENT PURPOSES
ONLY
MEMORANDUM OF UNDERSTANDING
State of Washington
And
Asotin County
HIickitat County
Chelan County
Lewis County
Clallam County
Lincoln County
Clark County
Okanogan County
Columbia County
Pacific County
Cowlitz County
Pierce County
Douglas County
Skagit County
Garfield County
Skamania County
Grant County
Snohomish County
Grays Harbor County
Spokane County
Island County
Stevens County
Jefferson County
Thurston County
King County
Whatcom County
Kitsap County
Yakima County
1 1 FRECEI IV ED
JUN 1 1 2024
GRANT COUNTY cOMMISSIONEF3S
I. PARTIES
The State of Washington and the Washington Department of Social and
Health Services (hereinafter "DSHS") (collectively hereinafter "the State"),
through its representatives, have met, conferred and entered into this Memorandum
of Understanding ("MOU") with the following Washington State Counties through
their representatives: Asotin County, Chelan County, Clallam County, Clark
County, Columbia County, Cowlitz County, Douglas County, Garfield County,
Grant County, Grays Harbor County, Island County, Jefferson County, King
County, Kitsap County, Klickitat County, Lewis County, Lincoln County,
Okanogan County, Pacific County, Pierce County, Skagit County, Skamania
County, Snohomish County, Spokane County, Stevens County, Thurston County,
Whatcom County, and Yakima County (hereinafter "Counties"). The State and the
Counties are hereinafter collectively referred to as the "Parties."
11. PURPOSES, OBJECTIVES, AND SCOPE
2.1. Following the commencement of litigation in the superior court,
remand by the federal court after removal by the State, and entry of a preliminary
injunction by the superior court, the Parties met and reached the accommodation
set forth herein. The Parties intend this MOU to resolve the issues raised by the
Counties in Pierce County Superior Court Cause Number 23-2-09161-8, and result
in dismissal without prejudice of that action.
2.2. The purpose of this MOU is to provide for: (1) the receipt and
evaluation of patients by the State referred there by court order under RCW
10.77.086(7); (2) advance notice by the State of release of committed persons
under RCW 71.05.425; and (3) coordination between the State and the Counties to
facilitate the operation of, and compliance with, state law, federal law, and federal
court orders.
2.3. This MOU represents an accommodation between the State and the
Counties to resolve a pending court action, but it is not a contract. The counties
enter into this MOU as governmental entities under the authority of their elected
Commissioners, or the legislative/executive authority provided by home rule
charter. Nothing in this agreement purports to bind separately elected officials
housed within the geographic boundaries of counties who are not within the
control of the county government, including judges and prosecutors, whose official
functions and discretionary acts are defined by statute and constitution. The State
and the Counties intend to work collaboratively and in good faith to accomplish the
objectives of this MOU.
4
IR. RECITALS
3.1 The State agrees to receive and evaluate civil conversion patients in
facilities operated or contracted by DSHS under RCW 10.77.086(7) when ordered
to do so by the superior court.
3.2. The State agrees to provide notice to county prosecutors and others as
directed under RCW 71.05.425 regarding release, transfer or leave granted to
committed patients.
3.4. The State understands that the Counties will use reasonable efforts to
accomplish the following, recognizing that these tasks fall within the purview of
separately elected officials who are neither parties to this agreement, nor subject to
County supervision in the performance of their official duties:
a. Provide the complete discovery packet, including documents,
audio and video evidence, as directed under RCW 10.77.075 in
a timely fashion, and consistent with the checklist attached as
Appendix A to this MOU; The Counties understand that
training on this subject is available to them on request, provided
by the Attorney General's Office.
b. Send DSHS orders dismissing criminal charges under RCW
10.77.Q86 as soon as possible after the order is entered by the
5
court but no later than the next business day following the
entrance of such an order; and
C. Respond to reasonable informational questions from DSHS,
and assist with the recovery of court documents and other
disclosable documents within the Counties' control, as needed.
3.5. While recognizing that this MOU does not impact or limit
prosecutorial and judicial discretion as previously recited, the Parties agree on
certain principles for moving forward relating to wise use of behavioral health
services, including the benefit of working collaboratively where appropriate to
facilitate the State's ability to: (1) make effective use of state hospital and other
behavioral health resources; (2) avoid overcrowding of such facilities; and (3)
maintain timely compliance with the federal and state requirements for
competency evaluation and restoration.
3.6. For the avoidance of doubt, the failure of any county to bring about
compliance with the provisions of this Sections 3.4 and 3.5 will not excuse the
State's obligations to receive and evaluate civil conversion patients under RCW
10.77.086(7) and Section 3.1 of this MOU.
lei
IV. GENERAL PROVISIONS
4.1. Nothing in this MOU expands, alters, amends or limits the rights,
authority, responsibilities, sovereignty, or jurisdiction of any party. The attorneys
executing this MOU are doing so on behalf of their client Counties, not on behalf
of any independent prosecuting attorney or judge elected in those Counties.
Nothing in this MOU should be construed as an admission of liability or fault by
Defendants or an admission by Plaintiffs of validity of defense asserted by
Defendants.
4.2. Nothing in this MOU is intended to create a right in any entity not a
party to this MOU nor shall any entity be considered athird-party beneficiary of
this MOU. This MOU is not intended to bind or affect any non -signatory party.
4.3. This constitutes the entire agreement regarding the subject matter of
this MOU. Any modification of this MOU must be in writing and agreed to by all
the parties.
4.4. All parties to this MOU intend to fully cooperate with all matters
relating to or arising out of this MOU.
4.5. This MOU maybe executed so that electronic signatures will be
accepted as originals.
6
V. AMENDMENT AND SEVERABILITY
5.1. The parties enter into this MOU voluntarily and in good faith. This
MOU shall be effective upon the signatures of the parties below. This MOU may
be amended or supplemented upon the mutual agreement of all of the parties to this
MOU. This MOU is severable from any contracts or agreements that are into under
this MOU.
VL TERMINATION OF MEMORANDUM
6.1. This MOU is intended to last for five years and will terminate
automatically after the expiration of five years after the date of the first signature to
this MOU. This MOU shall terminate on the written notice by any party to this
agreement, following notice to all parties, conference by all parties regarding the
party's or parties' reasons for seeking termination of this MOU, and mediation, if
mediation is requested by one or more of the parties.
VII. SIGNATURES
PACIFICA LAW GROUP LLP
/s/
Paul J. Lawrence, WSBA #13557
Ian D. Rogers, WSBA #46584
Shweta Jayawardhan, WSBA #58490
11912 d Avenue, Suite 2000
Seattle, WA 98 101
Attorneys for Plaintiff Washington
State Association of Counties
CURT LIEDKIE
Asotin County Prosecuting Attorney
/s/
Curt Liedkie, WSBA #30371
Prosecutor
P.O. Box 220
Asotin, WA 99402
Attorneys forAsotin County
RYAN JURVAKAINEN
Cowlitz County Prosecuting Attorney
/s/
David J. Berger, WSBA #48480
Deputy Prosecuting Attorney
312 SW 1st Ave.
Kelso, WA 98626
Attorneys for Cowlitz County
9
MARY ROBNETT
Pierce County Prosecuting Attorney
/s/
Marcus Miller, WSBA #27563
Deputy Prosecuting Attorney
930 Tacoma Ave. South, Ste. 946
Tacoma, WA 98402
Attorne for Pierce County
JONATHAN MEYER
Lewis County Prosecuting Attorney
/s/
David E. Bailey, WSBA #26070
Chief Civil Deputy Prosecuting
Attorney
345 West Main Street, 2nd Floor
Chehalis, WA, 98532
Attorneysfor Lewis County
ADAM WALSER
Lincoln County Prosecuting Attorney
/s/
Adam Walser, WSBA #50566
Prosecutor
450 Logan Street
Davenport, WA 99122
Attorneysfor Lincoln County
GORDON EDGAR
Douglas County Prosecuting Attorney
/s/
James T. Mitchell, WSBA #31031
Civil Deputy Prosecuting Attorney
P.O. Box 360
Waterville, WA 98858
Attorneys for Douglas County
KEVIN MCCRAE
Grant County Prosecuting Attorney
/s/
Rebekah M. Kaylor, WSBA #53257
Deputy Prosecuting Attorney
35 C Street NW
Ephrata, WA 98823
Attorneys for Giant County
NORMA TILLOTSON
Grays Harbor County Prosecuting
Attorney
/s/
Bryan Lane, WSBA # 18246
Deputy Prosecuting Attorney
102 West Broadway, Room 102
Montesano, WA 98563
Attorneysfor Grays Harbor County
MICHAEL ROTHMAN
Pacific County Prosecuting Attorney
/s/
Michael Rothman, WSBA #33048
Prosecutor
300 Memorial Drive
South Bend, WA 98586
Attorneysfor Pacific County
RICH WEYRICH
Skagit County Prosecuting Attorney
/s/
Erik Pedersen, WSBA #20015
Chief Civil Deputy Prosecuting
Attorney
605 South Third Street
Mount Vernon, WA 98273
Attorneysfor Skagit County
ADAM KICK
Skamania County Prosecuting Attorney
/s/
Adam Kick, WSBA #27525
Prosecutor
240 NW Vancouver Ave.
Stevenson, WA 98648
Attorneys for Skamania County
10
GREGORY M. BANKS
Island County Prosecuting Attorney
/S/
Gregory M. Banks, WSBA #22926
Prosecutor
I NE 7th Street
Coupeville, WA 98239
Attorneys fog Island County
JAMES KENNEDY
Jefferson County Prosecuting Attorney
/S/
Philip C. Hunsucker, WSBA #48692
Chief Civil Deputy Prosecuting
Attorney
1820 Jefferson St
Port Townsend, WA 98368
Attorneys for Jefferson County
LEESA MANION
King County Prosecuting Attorney
/S/
Andrea Vitalich, WSBA #25535
Senior Deputy Prosecuting Attorney
701 5th Avenue, Suite 600
Seattle, WA 98104
Attorneys for King County
JASON CUNNINGS
Snohomish County Prosecuting
Attorney
/S/
Bridget E. Casey, WSBA #30459
Chief Civil Deputy Prosecuting
Attorney
3000 Rockefeller Avenue, M/S 504
Everett, WA 98201
Attorneys fog^ Snohomish County
LARRY H. HASKELL
Spokane County Prosecuting Attorney
/S/
Christopher Anderson, WSBA #45361
Chief Civil Deputy Prosecuting
Attorney
100 W Mallon Ave
Spokane, WA 99260
Attorneys for Spokane County
JON TUNHEIM
Thurston County Prosecuting Attorney
/S/
Elizabeth Petrich, WSBA #18713
Deputy Prosecuting Attorney
2000 Lakeridge Drive SW
Olympia, WA 98502
Attorneys for Thurston County
11
CHAD M. ENRIGHT
Kitsap County Prosecuting Attorney
/S/
Katherine A. Cummings, WSBA
#51646
Deputy Prosecuting Attorney
614 Division Street, MS -35A
Port Orchard, WA 98366
Attorneys for Kitsap County
ERIC J. RICHEY
Whatcom County Prosecuting Attorney
/S/
Christopher Quinn, WSBA # 34695
Chief Civil Deputy Prosecuting
Attorney
311 Grand Ave., Suite 201
Bellingham, WA 98225
Attorneys fog Whatcom County
DAVID R. QUESNEL JOSEPH A. BRUSIC
Klickitat County Prosecuting Attorney Yakima County Prosecuting Attorney
/S/
David R. Quesnel, WSBA #38579
Prosecutor
205 S. Columbus Ave, Room 106
Goldendale, WA 98620
Attorneys for Klickitat County
ROBERT W. SEALBY
Chelan County Prosecuting Attorney
/S/
Robert W. Sealby, WSBA #21330
Prosecutor
P.O. Box 2596
Wenatchee, WA 98807
Attorneys fog Chelan County
/S/
Don L. Anderson, WSBA # 12445
Chief Civil Deputy Prosecuting
Attorney
128 North 2nd Street, Room 211
Yakima, WA 98901
Attorneys for Yakima County
TONY GOLIK
Clark County Prosecuting Attorney
12
/S/
Leslie Lopez, WSBA #46118
Chief Civil Prosecuting Attorney
PO Box 5000
Vancouver, WA 98666
Attorneys for Clark County
DALE SLACK MATT NEWBERG
Columbia County Prosecuting Attorney Garfield County Prosecuting Attorney
/s/
Dale Slack, WSBA # 38397
Prosecutor
215 E. Clay St.
Dayton, WA 99328
Attornevs.fioryColumbia County
ALBERT LIN
Okanogan County Prosecuting
Attorney
/s/
Esther Milner, WSBA # 33042
Chief Civil Prosecuting Attorney
237 Fourth Avenue N.
Okanogan, WA 98840
Attornevs,fioryOkanogan County
/s/
Matt Newberg, WSBA # 36674
Prosecutor
789 Main Street, PO Box 278
Pomeroy WA 99347
Attorneys fog Garfield County,
ERIKA GEORGE
Stevens County Prosecuting Attorney
/s/
Julie C. James, WSBA # 40655
Deputy Prosecuting Attorney
215 S. Oak, Room 110
Colville, WA 99114
Attorneysfor Stevens County
MARK B. NICHOLS
Clallam County Prosecuting Attorney
/s/
Mark B. Nichols, WSBA # 32848
Prosecutor
223 E 4th Street, Suite 11
Port Angeles, WA 98362
Attorneysfor Clallam County
13
Communication — Who needs to know about vour Felonv F1iD?
Western State Hospital WSH and ESH need to know what the Court is ordering of
(WSH) and Eastern State them and where the patient is currently. The sooner WSH
Hospital (ESH) and ESH know, the easier they can set up staff and prepare
for the evaluation.
ofmhscourtordersgdshs.wa.gov Heads up: If you email WSH or ESH when drafting the dismissal order
as a general heads up, they can have more time to get ready.
Mental Health Felony
Division (MHS)-Tumwater:
WshTeam(a�ATG. WA. GOV
v
Spokane Division (SPO):
For documents only:
sposhsunit@ATG.WA.GOV
For questions:
DawnT.Vidonigat .wa.gov;
Aaren.Carnliengatg.wa. ov;
Jared. Cordtsgat .wa. gov; and
Michael. Shenefeltg at . wa. gov
Your Jail or Detention
Facility
We are the representatives for WSH and ESH and we need
to know what a court has ordered so we can collaborate
with WSH and ESH effectively and timely.
Team Email: this email is monitored and we respond very promptly so
if you have questions please ask!
Please inform the Jail or Detention facility holding your
defendant so they know not to release them.
Warning: It is rare but j ails/facilities have released defendants before
transfer, which means WSH no longer has jurisdiction or authority over
your defendant.
Checklist of Documents — What to Whom, and When?
WHAT
WHOM
WHEN
Order of Dismissal
WSH or
Immediately
Note: Triple check the Evaluation period!!
p p
ESH
Hint: Do not wait
Restoration received — 72 Hours Eval
MHS orfor
a file stamped
No Restoration received = 124 Hours vatE.
SFO
copy just a
In case you need an Updated Dismissal Form
y p
Jail
judicial signature
J g
and date needed!
Information
Note: make sure felonies listed in the Order of
MHS or
Immediately
Dismissal match the Information.
SPO
Probable Cause
MHS or
Immediately
SPO
Evaluations — An prior evals for the defendant
Y p
MHS or
Immediately
SPO
Law Enforcement Reports and Documentation
p
MHS or
Immediately
SPO
Digital Evidence —photos, videos, etc
Note: we know these can be large
e and numerous so a
MHS or
As soon as
Dropbox, OneDrive, mailed thumb or CD works.
SPQossible
p
Certified Copy of Dismissal Order(s)
Note: This is our first exhibit and gives the Pierce
MHS or
As soon as
County Court jurisdiction over the Felony Flip so it
SPO
possible
must be certified.