I might understand better than you'd like to believe.
The issue: "Whether the encounter between Harrington and the police officers rose to an unconstitutional seizure prior to arrest, in violation of article I, section 7 of the Washington Constitution, requiring suppression of drugs found on his
person."
The standard of review: "Whether police have seized a person is a mixed question of law and fact."
WA law impacting decision: "“No person shall be disturbed in his private affairs, or his home invaded, without authority of law."
That is all there is, really:
http://www.leg.wa.gov/lawsandagencyrules/pages/constitution.aspx
The actions of the officers, in order:
1. Social contact
2. Arrival of second police officer
3. Request to remove hands from pockets
4. Request to frisk
Note, each action in the progression was legal at the time of the action, and in fact, remains legal following this ruling. That is an indicator that the ruling falls on the bad law side of the good law-bad law line.
To be clear, Washington officers may still request to frisk someone. Look for the SCOTUS to pounce should Washington come out interpreting this ruling other wise.
The court interpreted the chain of events as a sum, dubbed a progression of intrusion, which culminated in his seizure via their interpretation of state law. An interpretation I anticipate to be described in the future by reviewing authorities in terms such as as "strained," "muddled," "over-reaching," etc.
Having decreed it a seizure: "Because Harrington’s consent to the search was obtained through
exploitation of a prior illegal seizure, suppression of the evidence is required.
See Garvin, 166 Wn.2d at 254."
The conclusion: "Because an objectively reasonable person would not have felt free to
leave by the time the officer asked to frisk, Harrington was unconstitutionally
seized prior to arrest in violation of article I, section 7 of the Washington
Constitution."
I anticipate that the challenges to this ruling are only constrained by the imagination of prosecutors and the state and federal law enforcement officers who consult with them.
But in the mean time, prosecutors are no doubt revising their advise on how to get around this judicial obstacle, which will soon be pushed to the field, if it has not already happened. Yes, as a profession, we're advised by lawyers on what we may or may not do, under what circumstances, etc. In fact, no doubt the officers in this case were trained to do what they did, for the reasons that they did it. The internalization process is short, with folks in the trade being fairly adaptive, and my colleagues in Washington will move forward. An by moving forward, I'm pretty sure they won't be returning to their patrol cars per the court's expressed desire...
Re the officers actions: They were legal at the time they undertook them, and taken separately, remain legal for them to continue to undertake. In any event, there was no "slapping" of them involved.