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25 Washington opinions name it 2 courts 1898–2025 5 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 |
|---|---|---|
Hoover v. Pierce Countygreen2 sentences2013The DOT argues that the Wolfes’ inverse condemnation claim fails under the subsequent purchaser rule, citing Hoover v. Pierce County, 79 Wn. 2013App. at 433-34 . ¶16 To bypass this subsequent purchaser rule, “a new taking cause of action requires additional governmental action [6] causing a measurable decline in market value.” Hoover, 79 Wn. | 2 | 5 |
Miebach v. Colasurdogreen2 sentences2019Miebach, 102 Wn.2d at 176 (purchaser with 23 years of investment experience was not bona fide purchaser). 2010Compare Steward, 51 Wash.App. at 513 , 754 P.2d 150 (noting that the bona fide purchasers had little real estate investing experience at the time of the sale) and Miebach v. Colasurdo, 102 Wash.2d 170, 176 , 685 P.2d 1074 (1984) (holding that the purchaser with 23 years of investment experience was not a bona fide purchaser). | 2 | 2 |
Steward v. Goodgreen2 sentences2010Compare Steward, 51 Wash.App. at 513 , 754 P.2d 150 (noting that the bona fide purchasers had little real estate investing experience at the time of the sale) and Miebach v. Colasurdo, 102 Wash.2d 170, 176 , 685 P.2d 1074 (1984) (holding that the purchaser with 23 years of investment experience was not a bona fide purchaser). 2010Compare Steward, 51 Wn. | 2 | 2 |
Wolfe v. Department of Transportationgreen2 sentences2014The subsequent purchaser rule does not allow a purchaser who has bought property previously damaged by a government taking to bring a claim because " it is the original owner who suffers from the true harm" and the subsequent purchaser " pays a price that presumably reflects the diminished property value in light of this earlier taking." Wolfe v. Dep' t of Transp., 173 Wn. 2014And in Wolfe we applied the subsequent purchaser doctrine and dismissed an inverse condemnation claim based on plaintiffs' allegations that WSDOT' s improvement of a bridge in 1986 caused ongoing erosion to property which they purchased in 2003 and 2004. 173 Wn. | 1 | 3 |
Crystal Lotus Enterprises, Ltd. v. City of Shorelinegreen1 sentence2015See Crystal Lotus Enter., Ltd. v. City of Shoreline, 167 Wn. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Schaaf v. Highfield
green
2 sentences2007"As Schaaf already knew before he bought the house that it needed a new roof, he simply cannot blame the appraiser for failing to report the roof needed repair." Schaaf, 127 Wash.2d at 30 , 896 P.2d 665 . 2007“As Schaaf already knew before he bought the house that it needed a new roof, he simply cannot blame the appraiser for failing to report the roof needed repair.” Schaaf, 127 Wn.2d at 30 . | 2 | 2007–2007 |
Olson v. Trippel
green
2 sentences1999Olson v. Trippel, 77 Wash.App. 545, 550-51 , 893 P.2d 634 (1995) (the general rule is that a person purchasing real property may rely on the record title to the property, in the absence of facts sufficient to put the purchaser on inquiry). 1999App. 545, 550-51 , 893 P.2d 634 (1995) (the general rule is that a person purchasing real property may rely on the record title to the property, in the absence of facts sufficient to put the purchaser on inquiry). | 2 | 1999–1999 |
Avnet, Inc. v. Department of Revenue
green
1 sentence2025Id. at 62 . | 1 | 2025–2025 |
Lakey v. Puget Sound Energy, Inc.
green
1 sentence2022Id. | 1 | 2022–2022 |
Bay Industry, Inc. v. Jefferson County
green
2 sentences2015App. 239 , 653 P.2d 1355 (1982). 2015Because Williams Place insists that this action does not seek compensation for any taking prior to Jorstad family ownership, we need not discuss the subsequent purchaser doctrine or the presumption of prior compensation further. 28 No. 31681-5-III Williams Place v. State Further authority that legislative action vacating a road ordinarily terminates all rights of use by an abutting owner is provided by Bay Industry, Inc. v. Jefferson County, 33 Wn. | 1 | 2015–2015 |
Lidstrand v. Silvercrest Industries
green
1 sentence1992Cf. Lidstrand v. Silvercrest Indus., 28 Wn. | 1 | 1992–1992 |
Brodack v. Morsbach
neutral
2 sentences1937In Brodack v. Morsbach, 38 Wash. 72 , 80 P. 275 , it was held that, whether or not a contract for the sale of growing timber was a sale of an interest in' land, the timber nevertheless became personal property upon execution and delivery of the contract, and the only interest the purchaser had or could claim in the land was an implied license to enter and remove the timber. *22 “In France v. Deep River Logging Co., 79 Wash. 336 , 140 P. 361 , Ann. 1937In Brodack v. Morsbach, 38 Wash. 72 , 80 P. 275 , it was held that, whether or not a contract for the sale of growing timber was a sale of an interest in' land, the timber nevertheless became personal property upon execution and delivery of the contract, and the only interest the purchaser had or could claim in the land was an implied license to enter and remove the timber. *22 “In France v. Deep River Logging Co., 79 Wash. 336 , 140 P. 361 , Ann. | 1 | 1937–1937 |
France v. Deep River Logging Co.
green
2 sentences1937In Brodack v. Morsbach, 38 Wash. 72 , 80 P. 275 , it was held that, whether or not a contract for the sale of growing timber was a sale of an interest in' land, the timber nevertheless became personal property upon execution and delivery of the contract, and the only interest the purchaser had or could claim in the land was an implied license to enter and remove the timber. *22 “In France v. Deep River Logging Co., 79 Wash. 336 , 140 P. 361 , Ann. 1937In Brodack v. Morsbach, 38 Wash. 72 , 80 P. 275 , it was held that, whether or not a contract for the sale of growing timber was a sale of an interest in' land, the timber nevertheless became personal property upon execution and delivery of the contract, and the only interest the purchaser had or could claim in the land was an implied license to enter and remove the timber. *22 “In France v. Deep River Logging Co., 79 Wash. 336 , 140 P. 361 , Ann. | 1 | 1937–1937 |
Moore & Co. v. Burling
neutral
2 sentences1924When it is very large, that circumstance may be considered in connection with other circumstances in determining the question of the purchaser’s good faith; but unless the consideration be merely nominal, or so grossly inadequate as to lead to the conclusion that the purchase is made for the purpose of specula ting upon the chances of collection, it is not of itself sufficient to justify a finding of had faith.” In Moore & Co. v. Burling, 93 Wash. 217 , 160 Pac. 420 , it was said: “It is true he bought the mortgage for his company at a large discount; but this, while it might put the purchaser 1924When it is very large, that circumstance may be considered in connection with other circumstances in determining the question of the purchaser’s good faith; but unless the consideration be merely nominal, or so grossly inadequate as to lead to the conclusion that the purchase is made for the purpose of specula ting upon the chances of collection, it is not of itself sufficient to justify a finding of had faith.” In Moore & Co. v. Burling, 93 Wash. 217 , 160 Pac. 420 , it was said: “It is true he bought the mortgage for his company at a large discount; but this, while it might put the purchaser | 1 | 1924–1924 |
Fagan v. Walters
green
2 sentences1924The law stood in that situation until the case of Fagan v. Walters, 115 Wash. 454 , 197 Pac. 635 , which involved a highway over rural land, and there the court held that a covenant of warranty warrants against known as well as unknown defects and incumbrances, and that where an easement for a sixteen-foot right-of-way existed over the granted land, the grantee could recover damages for this breach of warranty. 1924The law stood in that situation until the case of Fagan v. Walters, 115 Wash. 454 , 197 Pac. 635 , which involved a highway over rural land, and there the court held that a covenant of warranty warrants against known as well as unknown defects and incumbrances, and that where an easement for a sixteen-foot right-of-way existed over the granted land, the grantee could recover damages for this breach of warranty. | 1 | 1924–1924 |
Hoyt v. Rothe
neutral
2 sentences1918Hoyt v. Rothe, 95 Wash. 369 , 163 Pac. 925 . 1918Hoyt v. Rothe, 95 Wash. 369 , 163 Pac. 925 . | 1 | 1918–1918 |
McNamara v. Jose
neutral
2 sentences1916McNamara v. Jose, 28 Wash. 461 , 68 Pac. 903 ; Citizens’ Bank v. Stewart, 22 Cal. App. 91 , 133 Pac. 337 ; Ham, v. Merritt, 150 Ky. 11 , 149 S. W. 1131 . 1916McNamara v. Jose, 28 Wash. 461 , 68 Pac. 903 ; Citizens’ Bank v. Stewart, 22 Cal. App. 91 , 133 Pac. 337 ; Ham, v. Merritt, 150 Ky. 11 , 149 S. W. 1131 . | 1 | 1916–1916 |
Citizens' Bank v. Stewart
neutral
2 sentences1916McNamara v. Jose, 28 Wash. 461 , 68 Pac. 903 ; Citizens’ Bank v. Stewart, 22 Cal. App. 91 , 133 Pac. 337 ; Ham, v. Merritt, 150 Ky. 11 , 149 S. W. 1131 . 1916McNamara v. Jose, 28 Wash. 461 , 68 Pac. 903 ; Citizens’ Bank v. Stewart, 22 Cal. App. 91 , 133 Pac. 337 ; Ham, v. Merritt, 150 Ky. 11 , 149 S. W. 1131 . | 1 | 1916–1916 |
Ham v. Merritt
neutral
2 sentences1916McNamara v. Jose, 28 Wash. 461 , 68 Pac. 903 ; Citizens’ Bank v. Stewart, 22 Cal. App. 91 , 133 Pac. 337 ; Ham, v. Merritt, 150 Ky. 11 , 149 S. W. 1131 . 1916McNamara v. Jose, 28 Wash. 461 , 68 Pac. 903 ; Citizens’ Bank v. Stewart, 22 Cal. App. 91 , 133 Pac. 337 ; Ham, v. Merritt, 150 Ky. 11 , 149 S. W. 1131 . | 1 | 1916–1916 |
Mallett v. Kaehler
green
1 sentence1898In Mallett v. Kaehler, 141 Ill. 70 ( 30 N. E. 549 ), a case where a vendee of two adjoining lots under an unrecorded contract leased them, and a person who lived on a lot adjoining the two had a harn extended partly on one of said two lots, it was held that the tenant’s possession of the two lots by means of his barn and his taking timber and grass from the lots was sufficient to put a subsequent purchaser on inquiry as to the vendee’s rights. | 1 | 1898–1898 |
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.