six Gunwall factors (Washington) · Go Syfert
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six Gunwall factors in Washington

25 Washington opinions name it 2 courts 1991–2021 1 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.

Followed or applied (6)

CaseFollowedCited
State v. Ortizgreen
wash · 1992 · cited in 2 Washington opinions naming this issue, 1999–1999
2 sentences

1999See State v. Ortiz, 119 Wn.2d 294, 302 , 831 P.2d 1060 (1992) (noting the six Gunwall factors must be addressed before we will undertake state constitutional analysis); Thorne, 129 Wn.2d at 770 (declining to consider application of state constitution where defendant failed to engage in Gunwall analysis).

1999See State v. Ortiz, 119 Wn.2d 294, 302 , 831 P.2d 1060 (1992) (noting the six Gunwall factors must be addressed before we will undertake state constitutional analysis); Thorne, 129 Wn.2d at 770 (declining to consider application of state constitution where defendant failed to engage in Gunwall analysis).

22
State v. Gunwallgreen
wash · 1986 · cited in 11 Washington opinions naming this issue, 1991–2021
2 sentences

2018See Gunwall, 106 Wash.2d at 67 , 720 P.2d 808 (explaining that the discussion of the fourth factor may pertain to the sixth factor). ¶ 25 The six Gunwall factors all direct us toward interpreting article I, section 14 more broadly than the Eighth Amendment.

2018See Gunwall, 106 Wash.2d at 67 , 720 P.2d 808 (explaining that the discussion of the fourth factor may pertain to the sixth factor). ¶ 25 The six Gunwall factors all direct us toward interpreting article I, section 14 more broadly than the Eighth Amendment.

111
Ramm v. City of Seattlegreen
washctapp · 1992 · cited in 2 Washington opinions naming this issue, 1998–2000
2 sentences

2000This argument was rejected in Ramm v. City of Seattle, 66 Wash.App. 15, 23-27 , 830 P.2d 395 , review denied, 120 Wash.2d 1018 , 844 P.2d 437 (1992), wherein the Court of Appeals held: Our examination of the six Gunwall factors persuades us that, on matters not involving search and seizure, Const. art. 1, § 7 affords no greater protection than the minimum protection afforded by the federal constitutional analysis.

2000This argument was rejected in Ramm v. City of Seattle, 66 Wash.App. 15, 23-27 , 830 P.2d 395 , review denied, 120 Wash.2d 1018 , 844 P.2d 437 (1992), wherein the Court of Appeals held: Our examination of the six Gunwall factors persuades us that, on matters not involving search and seizure, Const. art. 1, § 7 affords no greater protection than the minimum protection afforded by the federal constitutional analysis.

12
State v. Thornegreen
wash · 1996 · cited in 2 Washington opinions naming this issue, 1999–1999
2 sentences

1999See State v. Ortiz, 119 Wn.2d 294, 302 , 831 P.2d 1060 (1992) (noting the six Gunwall factors must be addressed before we will undertake state constitutional analysis); Thorne, 129 Wn.2d at 770 (declining to consider application of state constitution where defendant failed to engage in Gunwall analysis).

1999See State v. Ortiz, 119 Wash.2d 294, 302 , 831 P.2d 1060 (1992) (noting the six Gunwall factors must be addressed before we will undertake state constitutional analysis); Thorne, 129 Wash.2d at 770 , 921 P.2d 514 (declining to consider application of state constitution where defendant failed to engage in Gunwall analysis). [13] Although Gronquist asserted errors at the 657 hearing regarding two of the prior general infraction determinations, he admitted he had indeed been found guilty of the four general infractions within the necessary six-month period. 3-31-97 Hearing Transcript at 5-6. [1]

12
State v. Wetheredgreen
wash · 1988 · cited in 2 Washington opinions naming this issue, 1995–1996
2 sentences

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

12
Ford Motor Co. v. Barrettgreen
wash · 1990 · cited in 1 Washington opinions naming this issue, 1992–1992
2 sentences

1992See Ford Motor Co. v. Barrett, 115 Wn.2d 556, 568 , 800 P.2d 367 (1990).

1992See Ford Motor Co. v. Barrett, 115 Wn.2d 556, 568 , 800 P.2d 367 (1990).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (21)

CaseCitedYears
State v. Boland green
wash · 1990
2 sentences

2007The six Gunwall factors parallel interpretive inquiries made when determining “whether the state constitution ultimately provides greater protection than its corresponding federal provision.” Ino Ino, Inc. v. City of Bellevue, 132 Wn.2d 103, 115 , 937 P.2d 154 , 943 P.2d 1358 (1997) (citing State v. Boland, 115 Wn.2d 571, 575 , 800 P.2d 1112 (1990)). ¶17 This court previously determined that the privileges and immunities clause of the Washington Constitution “requires an independent constitutional analysis from the equal protection clause of the United States Constitution.” Grant County Fire P

2007The six Gunwall factors parallel interpretive inquiries made when determining “whether the state constitution ultimately provides greater protection than its corresponding federal provision.” Ino Ino, Inc. v. City of Bellevue, 132 Wn.2d 103, 115 , 937 P.2d 154 , 943 P.2d 1358 (1997) (citing State v. Boland, 115 Wn.2d 571, 575 , 800 P.2d 1112 (1990)). ¶17 This court previously determined that the privileges and immunities clause of the Washington Constitution “requires an independent constitutional analysis from the equal protection clause of the United States Constitution.” Grant County Fire P

41994–2007
State v. Spurgeon green
washctapp · 1991
2 sentences

2015The six Gunwall factors are: (1) the state provision's textual language; (2) significant differences between the federal and state texts; (3) state constitutional and common law history; (4) existing state law; (5) structural differences between the federal and state constitutions; and (6) matters of particular state interest or local concern. 106 Wn.2d at 61-62 . "[These factors] are to be used in evaluating a specific claim and not all ofthem will be relevant to every case." State v. Sourgeon. 63 Wn.

2015App. 503, 505 , 820 P.2d 960 (1991).12 The first and second factors weigh against an independent interpretation under the Washington Constitution.

32008–2015
Ino Ino, Inc. v. City of Bellevue green
wash · 1997
2 sentences

2007The six Gunwall factors parallel interpretive inquiries made when determining “whether the state constitution ultimately provides greater protection than its corresponding federal provision.” Ino Ino, Inc. v. City of Bellevue, 132 Wn.2d 103, 115 , 937 P.2d 154 , 943 P.2d 1358 (1997) (citing State v. Boland, 115 Wn.2d 571, 575 , 800 P.2d 1112 (1990)). ¶17 This court previously determined that the privileges and immunities clause of the Washington Constitution “requires an independent constitutional analysis from the equal protection clause of the United States Constitution.” Grant County Fire P

2007The six Gunwall factors parallel interpretive inquiries made when determining "whether the state constitution ultimately provides greater protection than its corresponding federal provision." Ino Ino, Inc. v. City of Bellevue, 132 Wash.2d 103, 115 , 937 P.2d 154 , 943 P.2d 1358 (1997) (citing State v. Boland, 115 Wash.2d 571, 575 , 800 P.2d 1112 (1990)). ¶ 13 This court previously determined that the privileges and immunities clause of the Washington Constitution "requires an independent constitutional analysis from the equal protection clause of the United States Constitution." [6] Grant Coun

22007–2007
Srcc v. Public Disclosure Com'n green
wash · 1997
2 sentences

2007The six Gunwall factors parallel interpretive inquiries made when determining “whether the state constitution ultimately provides greater protection than its corresponding federal provision.” Ino Ino, Inc. v. City of Bellevue, 132 Wn.2d 103, 115 , 937 P.2d 154 , 943 P.2d 1358 (1997) (citing State v. Boland, 115 Wn.2d 571, 575 , 800 P.2d 1112 (1990)). ¶17 This court previously determined that the privileges and immunities clause of the Washington Constitution “requires an independent constitutional analysis from the equal protection clause of the United States Constitution.” Grant County Fire P

2007The six Gunwall factors parallel interpretive inquiries made when determining "whether the state constitution ultimately provides greater protection than its corresponding federal provision." Ino Ino, Inc. v. City of Bellevue, 132 Wash.2d 103, 115 , 937 P.2d 154 , 943 P.2d 1358 (1997) (citing State v. Boland, 115 Wash.2d 571, 575 , 800 P.2d 1112 (1990)). ¶ 13 This court previously determined that the privileges and immunities clause of the Washington Constitution "requires an independent constitutional analysis from the equal protection clause of the United States Constitution." [6] Grant Coun

22007–2007
Ino Ino, Inc. v. City of Bellevue green
wash · 1997
2 sentences

2007The six Gunwall factors parallel interpretive inquiries made when determining “whether the state constitution ultimately provides greater protection than its corresponding federal provision.” Ino Ino, Inc. v. City of Bellevue, 132 Wn.2d 103, 115 , 937 P.2d 154 , 943 P.2d 1358 (1997) (citing State v. Boland, 115 Wn.2d 571, 575 , 800 P.2d 1112 (1990)). ¶17 This court previously determined that the privileges and immunities clause of the Washington Constitution “requires an independent constitutional analysis from the equal protection clause of the United States Constitution.” Grant County Fire P

2007The six Gunwall factors parallel interpretive inquiries made when determining "whether the state constitution ultimately provides greater protection than its corresponding federal provision." Ino Ino, Inc. v. City of Bellevue, 132 Wash.2d 103, 115 , 937 P.2d 154 , 943 P.2d 1358 (1997) (citing State v. Boland, 115 Wash.2d 571, 575 , 800 P.2d 1112 (1990)). ¶ 13 This court previously determined that the privileges and immunities clause of the Washington Constitution "requires an independent constitutional analysis from the equal protection clause of the United States Constitution." [6] Grant Coun

22007–2007
State v. Richman green
washctapp · 1997
2 sentences

2000Richman, 85 Wn.

2000Richman, 85 Wash.App. at 573-74 , 933 P.2d 1088 .

22000–2000
State v. Boiko green
washctapp · 2007
1 sentence

2021State v. Gunwall, 106 Wn.2d 54, 61-62 , 720 P.2d 808 (1986). 1 State v. Gunwall, 106 Wn.2d 54, 61-62 , 720 P.2d 808 (1986). 8 53921-7-II Article I, section 21 of the Washington State Constitution states that “the right of trial by jury shall remain inviolate.” Article I, section 22 states in relevant part, “In criminal prosecutions the accused shall have the right . . . to have a speedy public trial by an impartial jury of the county in which the offense is charged to have been committed.” Such right “requires a trial by an unbiased and unprejudiced jury, free of disqualifying jury misconduct.

12021–2021
Department of Social & Health Services v. Luak green
wash · 2012
2 sentences

2018In re Dependency of M.S.R., 174 Wash.2d 1 , 15-16, 271 P.3d 234 (2012).

2018In re Dependency of M.S.R., 174 Wash.2d 1 , 15-16, 271 P.3d 234 (2012).

12018–2018
State v. Benitez green
washctapp · 2013
1 sentence

2014The Trebilcocks' argument is inconsistent with our decision in State v. Benitez, 175 Wn.

12014–2014
State v. Thorne green
wash · 1996
1 sentence

1999See State v. Ortiz, 119 Wash.2d 294, 302 , 831 P.2d 1060 (1992) (noting the six Gunwall factors must be addressed before we will undertake state constitutional analysis); Thorne, 129 Wash.2d at 770 , 921 P.2d 514 (declining to consider application of state constitution where defendant failed to engage in Gunwall analysis). [13] Although Gronquist asserted errors at the 657 hearing regarding two of the prior general infraction determinations, he admitted he had indeed been found guilty of the four general infractions within the necessary six-month period. 3-31-97 Hearing Transcript at 5-6. [1]

11999–1999
State v. Stroud red
wash · 1986
2 sentences

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

11996–1996
State v. Maxfield green
wash · 1994
2 sentences

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

11996–1996
State v. Coe green
wash · 1984
2 sentences

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

11996–1996
State v. Young green
· 1994
2 sentences

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

1996He then states "If this court decides that the search of the sleeping compartment did not violate Mr. Johnson's Fourth Amendment rights, then it needs to decide whether the Washington Constitution offers more protection...." Br. of Appellant at 16. [45] State v. Coe, 101 Wash.2d 364, 373-74 , 679 P.2d 353 (1984); State v. Young, 123 Wash.2d 173, 178-79 , 867 P.2d 593 (1994). [46] 115 Wash.2d 571 , 800 P.2d 1112 (1990). [47] State v. Gunwall, 106 Wash.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). [48] Br. of Appellant at 16-25. [49] 106 Wash.2d 144, 152 , 720 P.2d 436 (1986). [50] Respondent

11996–1996
State v. Cisneros green
washctapp · 1992
1 sentence

1992Gun-wall, at 61-62. 4 "The State of Washington has a long history of extending strong protections to telephonic and other electronic communications." Gunwall, at 66. 5 58 Wn.2d 171 , 361 P.2d 739 (1961). 6 See RCW 9.73.030. 7 Jennen , at 174. 8 For example, RCW 9.73.030(1), enacted in 1967, provides, in part: "Except as otherwise provided in this chapter, it shall be unlawful for any individual, partnership, corporation, association, or the state of Washington, its agencies, and political subdivisions to intercept, or record any: "(a) Private communication transmitted by telephone ... without

11992–1992
United States v. White green
scotus · 1971
1 sentence

1992Ed. 2d 453 , 91 S. Ct. 1122 (1971). 2 106 Wn.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). 3 The six Gunwall factors are: (1) textual language, (2) differences in the text, (3) state constitutional and common law history, (4) preexisting state law, (5) structural differences, and (6) matters of particular state or local concern.

11992–1992
State v. Jennen green
wash · 1961
2 sentences

1992Gun-wall, at 61-62. 4 "The State of Washington has a long history of extending strong protections to telephonic and other electronic communications." Gunwall, at 66. 5 58 Wn.2d 171 , 361 P.2d 739 (1961). 6 See RCW 9.73.030. 7 Jennen , at 174. 8 For example, RCW 9.73.030(1), enacted in 1967, provides, in part: "Except as otherwise provided in this chapter, it shall be unlawful for any individual, partnership, corporation, association, or the state of Washington, its agencies, and political subdivisions to intercept, or record any: "(a) Private communication transmitted by telephone ... without

1992Gun-wall, at 61-62. 4 "The State of Washington has a long history of extending strong protections to telephonic and other electronic communications." Gunwall, at 66. 5 58 Wn.2d 171 , 361 P.2d 739 (1961). 6 See RCW 9.73.030. 7 Jennen , at 174. 8 For example, RCW 9.73.030(1), enacted in 1967, provides, in part: "Except as otherwise provided in this chapter, it shall be unlawful for any individual, partnership, corporation, association, or the state of Washington, its agencies, and political subdivisions to intercept, or record any: "(a) Private communication transmitted by telephone ... without

11992–1992
Rozner v. City of Bellevue green
wash · 1991
1 sentence

1991App. 567 , 648 P.2d 481 , review denied, 98 Wn.2d 1008 (1982). 6 106 Wn.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). 7 See, for example, Rozner, 116 Wn.2d at 352 , where our Supreme Court stated: "plaintiff fails to provide any specific discussion of the six Gunwall factors relied on by this court to determine whether the state constitution should be construed to grant broader rights than the federal constitution.

11991–1991
Crape v. Mount green
washctapp · 1982
1 sentence

1991App. 567 , 648 P.2d 481 , review denied, 98 Wn.2d 1008 (1982). 6 106 Wn.2d 54 , 720 P.2d 808 , 76 A.L.R.4th 517 (1986). 7 See, for example, Rozner, 116 Wn.2d at 352 , where our Supreme Court stated: "plaintiff fails to provide any specific discussion of the six Gunwall factors relied on by this court to determine whether the state constitution should be construed to grant broader rights than the federal constitution.

11991–1991
State v. Gwinner green
washctapp · 1990
1 sentence

1991In the past, the failure to present such a briefing has led this court to decline consideration of the issue." 8 59 Wn.

11991–1991
California v. Trombetta green
scotus · 1984
2 sentences

1991The six Gunwall factors are: (1) the text of the state provision; (2) differences in the texts of the federal and state provisions; (3) state constitutional history; (4) preexisting state law; (5) structural differences between the federal and state constitutions; (6) whether it is a matter of particular state or local concern. 5 As stated in Gunwall, at 62-63: "Thus, the foregoing six criteria are aimed at: (1) suggesting to counsel where briefing might appropriately be directed in cases wherein they are urging *506 independent state constitutional grounds; and (2) helping to insure that if t

1991The six Gunwall factors are: (1) the text of the state provision; (2) differences in the texts of the federal and state provisions; (3) state constitutional history; (4) preexisting state law; (5) structural differences between the federal and state constitutions; (6) whether it is a matter of particular state or local concern. 5 As stated in Gunwall, at 62-63: "Thus, the foregoing six criteria are aimed at: (1) suggesting to counsel where briefing might appropriately be directed in cases wherein they are urging *506 independent state constitutional grounds; and (2) helping to insure that if t

11991–1991

Statutes the citing opinions construe

WA § Wash. Rev. Code § 2.06.040 (5) WA § Wash. Rev. Code § 69.50.401 (4) WA § Wash. Rev. Code § 46.61.502 (3) WA § Wash. Rev. Code § 9.73.090 (3)

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.

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