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184 Washington opinions name it 2 courts 1950–2026 41 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Leda v. Whisnandgreen2 sentences2019Second, the Kobets misstate the requirements of RCW 59.18.380 when they assert that the commissioner erred by failing to swear in and examine Sergey Kobets at the show cause hearing The Kobets assert that the statute required the commissioner to examine Sergey Kobets under oath despite the fact that the Kobets never sought to have Sergey Kobets sworn in to testify at the hearing To the contrary, our decision in gte is clear that RCW 59.18.380 guarantees the opportunity to present evidence in support of viable defenses M, 150 Wn. 2019This ensures that a court can conduct a show cause hearing “in a sufficiently expeditious manner to accommodate its calendar while still preserving the defendant’s procedural rights.” Le_da, 150 Wn. | 8 | 13 |
Randy Reynolds & Assocs., Inc. v. Harmongreen2 sentences2025To obtain a writ of restitution, the “landlord must apply for an order for a show cause hearing.” Randy Reynolds, 193 Wn.2d at 157 . 2025App. 2d 248, 252-53, 491 P.3d 171 (2021) (explaining that after obtaining a writ of restitution, “the landlord is entitled to immediate possession of the property pending a final judgment”).5 “Whether or not the court issues a writ of restitution at the show cause hearing, if material factual issues exist, the court is required to enter an order directing the parties to proceed to trial on the complaint and answer.” Harmon, 193 Wn.2d at 157. | 6 | 13 |
In re the Detention of Petersengreen2 sentences2023At the show cause hearing, RCW 71.090(2)(a) establishes two ways for the trial court to determine that there is probable cause to proceed to an unconditional release trial: “(1) by deficiency in the proof submitted by the State, or (2) by sufficiency of proof by the [committed person].” In re Det. of Petersen, 145 Wn.2d 789, 798 , 42 P.3d 952 (2002). 2017Ed. 2d 694 (J. 983)). 9 In re Det. of Petersen, 145 Wn.2d 789, 796 , 42 P.3d 952 (2002) ('" [B]oth this court and the United States Supreme Court agree that the State must bear the burden of proof in involuntary civil commitment hearings, and, therefore, the trial court was correct in determining that due process requires that the burden of proof remain upon the State in the show cause hearing." (alteration in original) (quoting In re Det. of Turay, 139 Wn.2d 379, 424 , 986 P.2d 790 (J.999))). 15 In re Det. of Marcum (John), No. 92501-1 (Gordon McCloud, J., concurring) constitutionally require | 5 | 19 |
Detention of Petersen v. Stategreen2 sentences2023At the show cause hearing, RCW 71.090(2)(a) establishes two ways for the trial court to determine that there is probable cause to proceed to an unconditional release trial: “(1) by deficiency in the proof submitted by the State, or (2) by sufficiency of proof by the [committed person].” In re Det. of Petersen, 145 Wn.2d 789, 798 , 42 P.3d 952 (2002). 2017Ed. 2d 694 (J. 983)). 9 In re Det. of Petersen, 145 Wn.2d 789, 796 , 42 P.3d 952 (2002) ('" [B]oth this court and the United States Supreme Court agree that the State must bear the burden of proof in involuntary civil commitment hearings, and, therefore, the trial court was correct in determining that due process requires that the burden of proof remain upon the State in the show cause hearing." (alteration in original) (quoting In re Det. of Turay, 139 Wn.2d 379, 424 , 986 P.2d 790 (J.999))). 15 In re Det. of Marcum (John), No. 92501-1 (Gordon McCloud, J., concurring) constitutionally require | 5 | 18 |
West v. Gregoiregreen2 sentences2016West v. Gregoire, 184 Wn. 2016West v. Gregoire, 184 Wn. | 3 | 3 |
Faciszewski v. Browngreen2 sentences2025“A show cause hearing must be meaningful, as it is the first (and sometimes the only) step of the eviction process in 18 No. 40068-9-III HMD Enters., LLC v. Carter which the tenant is able to participate.” Faciszewski v. Brown, 187 Wn.2d 308, 321 , 386 P.3d 711 (2016). 2025“A show cause hearing must be meaningful, as it is the first (and sometimes the only) step of the eviction process in 18 No. 40068-9-III HMD Enters., LLC v. Carter which the tenant is able to participate.” Faciszewski v. Brown, 187 Wn.2d 308, 321 , 386 P.3d 711 (2016). | 2 | 11 |
Indigo Real Estate Services, Inc. v. Wadsworthgreen2 sentences2021Inc. v. Wadsworth, 169 Wn. 2016SMC 22.206.160(C)(l) (a court may issue an order evicting a residential tenant "only after the tenant has an opportunity in a show cause hearing to contest the eviction"). -7- Faciszewski, eta!. v. Brown, eta!., 92978-5 court may deny the landlord's motion and "enter an order directing the parties to proceed to trial." Id. | 2 | 5 |
IBF, LLC v. Heuftgreen2 sentences2025See IBF, LLC v. Heuft, 141 Wn. 2024See IBF, 141 Wn. | 2 | 2 |
| In re the Detention of M.W.green | 2 | 2 |
| Rabon v. City of Seattlegreen | 2 | 2 |
| Dean v. Fishing Co. of Alaska, Inc.green | 2 | 2 |
| Stephen Faciszewski Et Al., Respondents, v. Michael R. Brown Et Al., Appellantsgreen | 2 | 2 |
| Rabon v. City of Seattlegreen | 2 | 2 |
| In re the Disciplinary Proceeding Against DeRuizgreen | 2 | 2 |
| State v. Groppergreen | 2 | 2 |
| In re the Dependency of A.K.green | 2 | 2 |
| Stoulil v. Epsteingreen | 2 | 2 |
Carlstrom v. Hanlinegreen2 sentences2025A show cause hearing is a summary proceeding where the superior court evaluates the evidence presented by the parties and decides “ ‘the issue of possession pending a lawsuit.’ ” Id. (quoting Carlstrom v. Hanline, 98 Wn. 2025A show cause hearing is a summary proceeding where the superior court evaluates the evidence presented by the parties and decides “ ‘the issue of possession pending a lawsuit.’ ” Id. (quoting Carlstrom v. Hanline, 98 Wn. | 1 | 24 |
State v. McCuistiongreen2 sentences2019In the setting of committed sexually violent predators, the court annually conducts a show cause hearing to determine whether the individual is entitled to an “evidentiary hearing.” State v. McCuistion, 174 Wn.2d 369, 380 , 275 P.3d 1092 (2012). 2019In the setting of committed sexually violent predators, the court annually conducts a show cause hearing to determine whether the individual is entitled to an “evidentiary hearing.” State v. McCuistion, 174 Wn.2d 369, 380 , 275 P.3d 1092 (2012). | 1 | 16 |
In re the Detention of Ambersgreen2 sentences2015In re Det. of Ambers, 160 Wn.2d at 557 (2007); In re Det. of Petersen, 145 Wn.2d 789, 799 , 42 P.3d 952 (2002). 2011RCW 71.09.090(3)(a), (c); In re Ambers, 160 Wash.2d at 548-49 , 158 P.3d 1144 . ¶ 10 It is only if a detainee petitions for release without DSHS authorization that a show cause hearing is required under RCW 71.09.090(2)(a). | 1 | 4 |
Grieco v. Wilsongreen2 sentences2017E.A.T.W., 168 Wn.2d at 348 (“The primary purpose of this threshold requirement for adequate cause ... is, among other things, to prevent a useless hearing.” (citing In re Marriage of Lemke, 120 Wn. 2010E.A.T.W., 168 Wash.2d at 348 , 227 P.3d 1284 . | 1 | 3 |
| Nichole Payton v. Samantha Nelsongreen | 1 | 2 |
| Country Manor MHC, LLC v. Occupantgreen | 1 | 2 |
| Sargent v. Seattle Police Dept.green | 1 | 2 |
| Amie Garrand, V Robin P. Cornettgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In re the Detention of Petersen
green
2 sentences2021Peterson, 138 Wn.2d at 85-86 . 2008In re Det. of Petersen, 138 Wash.2d 70, 86 , 980 P.2d 1204 (1999). [7] Before and after May 2005, RCW 71.09.090(2)(c) contained language placing an evidentiary burden on an SVP: "If the court at the show cause hearing determines that either: (i) The state has failed to present prima facie evidence that the committed person continues to meet the definition of [an SVP] and that no proposed [LRA] is in the best interest of the person and conditions cannot be imposed that would adequately protect the community; or (ii) probable cause exists to believe that the person's condition has so changed tha | 7 | 2002–2021 |
In Re Detention of Elmore
green
2 sentences2020Michael McHatton cites In re Detention of Elmore, 162 Wn.2d 27, 37 , 168 P.3d 1285 (2007), a case in which the Washington Supreme Court ruled that the trial court improperly weighed evidence at the show cause hearing. 2015In In re Detention of Elmore, 162 Wn.2d 27, 39 , 168 P.3d 1285 (2007), our high court reversed the trial court’s denial of a full evidentiary hearing and remanded for the evidentiary hearing rather than another show cause hearing. ¶99 During my earlier review of the sexually violent predator statutes, I examined the burdens of proof that each side holds at a show cause hearing. | 5 | 2008–2020 |
In re the Detention of Elmore
green
2 sentences2020Michael McHatton cites In re Detention of Elmore, 162 Wn.2d 27, 37 , 168 P.3d 1285 (2007), a case in which the Washington Supreme Court ruled that the trial court improperly weighed evidence at the show cause hearing. 2015In In re Detention of Elmore, 162 Wn.2d 27, 39 , 168 P.3d 1285 (2007), our high court reversed the trial court’s denial of a full evidentiary hearing and remanded for the evidentiary hearing rather than another show cause hearing. ¶99 During my earlier review of the sexually violent predator statutes, I examined the burdens of proof that each side holds at a show cause hearing. | 5 | 2008–2020 |
In re the Detention of Turay
green
2 sentences2017Ed. 2d 694 (J. 983)). 9 In re Det. of Petersen, 145 Wn.2d 789, 796 , 42 P.3d 952 (2002) ('" [B]oth this court and the United States Supreme Court agree that the State must bear the burden of proof in involuntary civil commitment hearings, and, therefore, the trial court was correct in determining that due process requires that the burden of proof remain upon the State in the show cause hearing." (alteration in original) (quoting In re Det. of Turay, 139 Wn.2d 379, 424 , 986 P.2d 790 (J.999))). 15 In re Det. of Marcum (John), No. 92501-1 (Gordon McCloud, J., concurring) constitutionally require 2002Turay asked, for the first time, who bears the burden of proof at a former RCW 71.09.090(2) show cause hearing, and the Court clearly answered that the bearer of this burden is the State, not the prisoner. 3 The Court first recognized the precedent set by Foucha and Young, see Taray, 139 Wn.2d at 423-24 , and then unambiguously held: [B]oth this court and the United States Supreme Court agree that the State must bear the burden of proof in involuntary civil commitment hearings, and, therefore, the trial court was correct in determining that due process requires that the burden of proof remain | 5 | 2002–2017 |
In Re Detention of Petersen
green
2 sentences2011In re Det. of Petersen, 138 Wn.2d 70, 88-90 , 980 P.2d 1204 (1999). 2008In re Det. of Petersen, 138 Wash.2d 70, 86 , 980 P.2d 1204 (1999). [7] Before and after May 2005, RCW 71.09.090(2)(c) contained language placing an evidentiary burden on an SVP: "If the court at the show cause hearing determines that either: (i) The state has failed to present prima facie evidence that the committed person continues to meet the definition of [an SVP] and that no proposed [LRA] is in the best interest of the person and conditions cannot be imposed that would adequately protect the community; or (ii) probable cause exists to believe that the person's condition has so changed tha | 5 | 2002–2011 |
Otis Housing Ass'n v. Ha
green
2 sentences2025Notably, the court rejected the association’s argument that “it waived no rights because the show cause hearing in an unlawful detainer action is limited to resolving questions of possession and the judge lacked the authority to compel arbitration.” Id. 2013Id. at 585-86 . | 4 | 2013–2025 |
Meadow Park Garden Associates v. Canley
green
2 sentences2021App. 371, 374 , 773 P.2d 875 (1989). 4 No. 81547-4-I/5 But obtaining a writ of restitution at a show cause hearing “‘is not the final determination of the rights of the parties in an unlawful detainer action.’”10 And regardless of whether the landlord is successful in obtaining the writ of restitution, the statute permits the landlord to seek “other relief” as part of the unlawful detainer process, such as a final judgment for damages or termination of the tenant’s lease.11 The statute allows the landlord such “other relief” at the show cause hearing only “‘if it shall appear to the court that 2014But a decision on a party' s motion seeking a show cause hearing to determine the merits of the party' s claim is not appealable as a matter of right under RAP 2. 2( a). 10 Meadow Park Garden Assocs. v. Canley, 54 Wn. | 4 | 2000–2021 |
Housing Authority v. Pleasant
green
2 sentences2019Id.\ Pleasant, 126 Wn. 2012In Pleasant, we explained that, because “[t]he United States Housing Act requires that the tenancies be terminated only for ‘serious or repeated violation of the terms or conditions of the lease or for other good cause,’ ” the issue of whether these requirements are met cannot generally be summarily resolved at a show cause hearing. 126 Wn. | 4 | 2012–2019 |
In Re Detention of Turay
green
2 sentences2017Ed. 2d 694 (J. 983)). 9 In re Det. of Petersen, 145 Wn.2d 789, 796 , 42 P.3d 952 (2002) ('" [B]oth this court and the United States Supreme Court agree that the State must bear the burden of proof in involuntary civil commitment hearings, and, therefore, the trial court was correct in determining that due process requires that the burden of proof remain upon the State in the show cause hearing." (alteration in original) (quoting In re Det. of Turay, 139 Wn.2d 379, 424 , 986 P.2d 790 (J.999))). 15 In re Det. of Marcum (John), No. 92501-1 (Gordon McCloud, J., concurring) constitutionally require 2002Turay asked, for the first time, who bears the burden of proof at a former RCW 71.09.090(2) show cause hearing, and the Court clearly answered that the bearer of this burden is the State, not the prisoner. [3] The Court first recognized the precedent set by Foucha and Young, see Turay, 139 Wash.2d at 423 , 986 P.2d 790 , and then unambiguously held: [B]oth this court and the United States Supreme Court agree that the State must bear the burden of proof in involuntary civil commitment hearings, and, therefore, *957 the trial court was correct in determining that due process requires that the bu | 4 | 2002–2017 |
In Re Detention of Ambers
green
2 sentences2011RCW 71.09.090(3)(a), (c); In re Ambers, 160 Wash.2d at 548-49 , 158 P.3d 1144 . ¶ 10 It is only if a detainee petitions for release without DSHS authorization that a show cause hearing is required under RCW 71.09.090(2)(a). 2007Id. ¶ 8 At the show cause hearing, the trial court must determine whether the petitioner is entitled to a full hearing on the issue of unconditional release or transfer to an LRA. | 4 | 2007–2012 |
Young v. State
green
2 sentences2007Smith remained in custody. ¶10 In March 2004, this court decided the case of In re Detention of Young, 120 Wn. 2007Elmore contends that “[b]y accepting the opinion of the State’s expert concerning Elmore’s progress in treatment, the ‘trial court substituted its judgment for that of [the detainee’s] expert.’ ” Pet. for Review at 12 (quoting Young, 120 Wn. | 4 | 2007–2007 |
Housing Authority v. Silva
green
2 sentences2019Id. 2019Id. | 3 | 2018–2019 |
State v. Jacobson
neutral
2 sentences2018The trial court rejected Dr. Novick Brown's opinion because her "initial evaluation cites no facts that would support a finding that any change in Mr. Hegwald's condition has been brought about as the result of positive responses to continuing treatment."12 The trial court also found that Dr. Novick Brown's supplemental declaration "relies on the same data and facts as her evaluation, but 8 In re Det. of Elmore, 162 Wn. 2d 27, 37 , 168 P.3d 1285 (2007). 9 In re Det. of Jacobson, 120 Wn. 2010In re Det. of Jacobson, 120 Wn. | 3 | 2010–2018 |
Christensen v. Ellsworth
green
2 sentences2009Christensen v. Ellsworth, 162 Wash.2d 365, 372 , 173 P.3d 228 (2007). ¶ 28 A tenant who raises a viable legal defense, either in written submissions or during the show cause hearing, is entitled to testify in support of that defense. 2009Christensen v. Ellsworth, 162 Wn.2d 365, 372 , 173 P.3d 228 (2007). ¶28 A tenant who raises a viable legal defense, either in written submissions or during the show cause hearing, is entitled to testify in support of that defense. | 3 | 2009–2016 |
Wood v. Thurston County
green
2 sentences2016This court concluded that "Wood is not entitled to a trial on the factual issue the trial court resolved against him in the show cause hearing." 117 Wn. 2014Wood v. Thurston County, 117 Wn. | 3 | 2014–2016 |
Fox v. DEPT. OF SOCIAL & HEALTH SERVICES
green
2 sentences2012Id. ¶[12 Alternatively, if DSHS does not authorize such a petition, the court must set a show cause hearing unless the individual affirmatively waives the right to petition for unconditional discharge or conditional release to a less restrictive alternative. 2010App. 374, 398-400 , 158 P.3d 69 (2007), we determined that former RCW 71.09.090(4) did not violate due process because it did not prevent the petitioners from introducing actuarial or clinical data as evidence; instead, it prevented a finding of probable cause based solely on such evidence demonstrating a change in a single demographic factor. ¶32 Likewise, here the statute does not prevent McGary from introducing evidence of an erroneous paraphilia diagnosis at a show cause hearing; it prevents only a finding of probable cause based solely on evidence not constituting a change in mental condi | 3 | 2010–2012 |
In Re Young
red
2 sentences2007Id. at 760-61, 86 P.3d 810 . 2007Elmore contends that "[b]y accepting the opinion of the State's expert concerning Elmore's progress in treatment, the `trial court substituted its judgment for that of [the detainee's] expert.'" Pet. for Review at 12 (quoting Young, 120 Wash.App. at 759-60 , 86 P.3d 810 ). | 3 | 2007–2007 |
In Re the Marriage of James
green
2 sentences2025In re Marriage of James, 79 Wn. 2025James, 79 Wn. | 2 | 2024–2025 |
| In re the Detention of Anthony Rushton green | 2 | 2017–2023 |
| State Of Washington, V Kevin S. Robinson green | 2 | 2017–2021 |
| Srivastav v. United States green | 2 | 2018–2018 |
| In re the Personal Restraint of Meirhofer green | 2 | 2015–2018 |
| Holt v. Holt green | 2 | 2017–2017 |
| State v. Curry green | 2 | 1997–2016 |
| Munro v. Irwin neutral | 2 | 2015–2015 |
| Minnesota ex rel. Burleigh v. Johnson green | 2 | 2014–2014 |
| M.J.H. v. L.L.H. green | 2 | 2013–2013 |
| W.R.P. Lake Union Ltd. Partnership v. Exterior Services, Inc. green | 2 | 2011–2011 |
| S.D. Deacon Corp. v. Gaston Bros. Excavating green | 2 | 2011–2011 |
| In Re Disciplinary Proceeding Against Burtch green | 2 | 2009–2009 |
| Christensen v. Ellsworth green | 2 | 2009–2009 |
| Lake Washington School District No. 414 v. Mobile Modules Northwest, Inc. green | 2 | 2009–2009 |
| In Re the Disciplinary Proceeding Against Clark green | 2 | 2009–2009 |
| Bonamy v. City of Seattle green | 2 | 2009–2009 |
| State v. Winthrop green | 2 | 2008–2008 |
| National Cable & Telecommunications Ass'n v. Gulf Power Co. green | 2 | 2007–2007 |
| Hearst Corp. v. Hoppe green | 2 | 2007–2007 |
| In Re the Marriage of Parks green | 2 | 2006–2006 |
| John R. Hansen, Inc. v. Pacific International Corp. green | 2 | 2005–2005 |
| Matter of Marriage of Irwin green | 2 | 2004–2004 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.