subrogation claim in Washington

2009See Sign-O-Lite Signs, Inc. v. DeLaurenti Florists, Inc., 64 Wn.

2009See Sign-O-Lite Signs, Inc. v. DeLaurenti Florists, Inc., 64 Wash.App. 553 , 825 P.2d 714 (1992) (taking time away from business to respond to unfair or deceptive collection activity satisfies injury requirement when loss of business results). ¶ 60 Consistently with most other states, Washington requires a private CPA plaintiff to establish the deceptive act caused injury.

2007See Martin, 59 P.2d at 1142-44 (examining numerous equitable subrogation cases and classifying them into a traditional view and a modem view, depending on the plaintiffs knowledge). 10 A1924 Georgia Supreme Court opinion illustrates this mistrust: “This court has denied that subro gation is a benevolent doctrine, and that equity will apply it in any case which justice required, and this court has refused to follow the cases which were based on this theory of the doctrine of subrogation.” Citizens Mercantile Co. v. Easom, 158 Ga. 604 , 123 S.E. 883, 886 (1924); see also Kitchell v. Mudgett, 37

2007See Martin, 59 P.2d at 1142-44 (examining numerous equitable subrogation cases and classifying them into a traditional view and a modem view, depending on the plaintiffs knowledge). 10 A1924 Georgia Supreme Court opinion illustrates this mistrust: “This court has denied that subro gation is a benevolent doctrine, and that equity will apply it in any case which justice required, and this court has refused to follow the cases which were based on this theory of the doctrine of subrogation.” Citizens Mercantile Co. v. Easom, 158 Ga. 604 , 123 S.E. 883, 886 (1924); see also Kitchell v. Mudgett, 37

2007Id. at 734 (“ ‘In applying the doctrine of subrogation, no attention should be paid to technicalities which are not of an insuperable character, but the broad equities should always be sought out so far as possible.’ ” (internal quotation marks omitted) (quoting Barnes v. Cady, 232 F. 318, 325 (6th Cir. 1916)))). ¶26 In their early mistrust of the doctrine, courts would not allow any lender with either actual or constructive knowledge to seek equitable subrogation.

2007Id. at 734 ("`In applying the doctrine of subrogation, no attention should be paid to technicalities which are not of an insuperable character, but the broad equities should always be sought out so far as possible.'") (internal quotation marks omitted) (quoting Barnes v. Cady, 232 F. 318, 325 (6th Cir.1916)). ¶ 26 In their early mistrust of the doctrine, courts would not allow any lender with either actual or constructive knowledge to seek equitable subrogation.

2007Id. at 734 (“ ‘In applying the doctrine of subrogation, no attention should be paid to technicalities which are not of an insuperable character, but the broad equities should always be sought out so far as possible.’ ” (internal quotation marks omitted) (quoting Barnes v. Cady, 232 F. 318, 325 (6th Cir. 1916)))). ¶26 In their early mistrust of the doctrine, courts would not allow any lender with either actual or constructive knowledge to seek equitable subrogation.

2007Id. at 734 ("`In applying the doctrine of subrogation, no attention should be paid to technicalities which are not of an insuperable character, but the broad equities should always be sought out so far as possible.'") (internal quotation marks omitted) (quoting Barnes v. Cady, 232 F. 318, 325 (6th Cir.1916)). ¶ 26 In their early mistrust of the doctrine, courts would not allow any lender with either actual or constructive knowledge to seek equitable subrogation.

2007See Martin, 59 P.2d at 1142-44 (examining numerous equitable subrogation cases and classifying them into a traditional view and a modem view, depending on the plaintiffs knowledge). 10 A1924 Georgia Supreme Court opinion illustrates this mistrust: “This court has denied that subro gation is a benevolent doctrine, and that equity will apply it in any case which justice required, and this court has refused to follow the cases which were based on this theory of the doctrine of subrogation.” Citizens Mercantile Co. v. Easom, 158 Ga. 604 , 123 S.E. 883, 886 (1924); see also Kitchell v. Mudgett, 37

2007See Martin, 59 P.2d at 1142-44 (examining numerous equitable subrogation cases and classifying them into a traditional view and a modern view, depending on the plaintiff's knowledge). [10] A 1924 Georgia Supreme Court opinion illustrates this mistrust: "This court has denied that subrogation is a benevolent doctrine, and that equity will apply it in any case which justice required, and this court has refused *25 to follow the cases which were based on this theory of the doctrine of subrogation." Citizens' Mercantile Co. v. Easom, 158 Ga. 604 , 123 S.E. 883, 886 (1924); see also Kitchell v. Mud

2007See Martin, 59 P.2d at 1142-44 (examining numerous equitable subrogation cases and classifying them into a traditional view and a modem view, depending on the plaintiffs knowledge). 10 A1924 Georgia Supreme Court opinion illustrates this mistrust: “This court has denied that subro gation is a benevolent doctrine, and that equity will apply it in any case which justice required, and this court has refused to follow the cases which were based on this theory of the doctrine of subrogation.” Citizens Mercantile Co. v. Easom, 158 Ga. 604 , 123 S.E. 883, 886 (1924); see also Kitchell v. Mudgett, 37

2007See Martin, 59 P.2d at 1142-44 (examining numerous equitable subrogation cases and classifying them into a traditional view and a modern view, depending on the plaintiff's knowledge). [10] A 1924 Georgia Supreme Court opinion illustrates this mistrust: "This court has denied that subrogation is a benevolent doctrine, and that equity will apply it in any case which justice required, and this court has refused *25 to follow the cases which were based on this theory of the doctrine of subrogation." Citizens' Mercantile Co. v. Easom, 158 Ga. 604 , 123 S.E. 883, 886 (1924); see also Kitchell v. Mud

2024App. 945 . 38 Greenberg et al., v. Amazon.com, No. 101858-4 Amazon’s reliance on Panag is inapposite because that case dealt with whether the CPA applied to a collection agency’s allegedly deceptive efforts to collect on an insurance company’s subrogation claim against an underinsured motorist. 166 Wn.2d at 34, 47 .

2019In Panaq, the State Supreme Court considered whether the CPA applies to a collection agency's "allegedly deceptive efforts to collect on an insurance company's subrogation claim against an uninsured motorist." 166 Wn.2d at 34 .

2021See id.

2009Credit Corp., 2 Haw.App. 435, 444, 445 , 634 P.2d 111 (1981) (consumer-plaintiff's damages may include out-of-pocket expenses for a money order, gasoline, parking, and wear and tear on automobile that resulted from unfair business practice)). ¶ 73 In this case, unlike in Indoor Billboard, Demopolis, Crane, and Flores , the plaintiff alleged as injury the expenses incurred in dispelling her uncertainty about the legal ramifications of the subrogation claim, including out-of-pocket expenses for postage, parking, and consulting an attorney.

2009Credit Corp., 2 Haw.App. 435, 444, 445 , 634 P.2d 111 (1981) (consumer-plaintiff's damages may include out-of-pocket expenses for a money order, gasoline, parking, and wear and tear on automobile that resulted from unfair business practice)). ¶ 73 In this case, unlike in Indoor Billboard, Demopolis, Crane, and Flores , the plaintiff alleged as injury the expenses incurred in dispelling her uncertainty about the legal ramifications of the subrogation claim, including out-of-pocket expenses for postage, parking, and consulting an attorney.

1979Rock Springs Realty, Inc. v. Waid, supra at 278; Monterey Corp. v. Hart, 216 Va. 843 , 224 S.E.2d 142, 146 (1976).

1979Rock Springs Realty, Inc. v. Waid, supra at 278; Monterey Corp. v. Hart, 216 Va. 843 , 224 S.E.2d 142, 146 (1976).

1979Rock Springs Realty, Inc. v. Waid, supra at 278; Monterey Corp. v. Hart, 216 Va. 843 , 224 S.E.2d 142, 146 (1976).