comprehensive analysis in Washington

1970The difference between the two was noted in Bordeaux v. Ingersoll Rand Co., 71 Wn.2d 392, 395 , 429 P.2d 207 (1967): [R]es judicata is the more comprehensive doctrine, identifying a prior judgment arising out of the same cause of action between the same parties, whereas a collateral estoppel relates to and bars relitigation on a particular issue or determinative fact.

1970The difference between the two was noted in Bordeaux v. Ingersoll Rand Co., 71 Wn.2d 392, 395 , 429 P.2d 207 (1967): [R]es judicata is the more comprehensive doctrine, identifying a prior judgment arising out of the same cause of action between the same parties, whereas a collateral estoppel relates to and bars relitigation on a particular issue or determinative fact.

2013The closest this court has come to adopting a comprehensive framework to govern harmless error review was in Guloy , when we intended “to settle the question of what type of standard this court will use in its harmless error analysis” and with little discussion or explanation selected “ ‘the overwhelming untainted evidence’ ” test over “the contribution test.” 104 Wn.2d at 425-26 ; see also State v. Evans, 96 Wn.2d 1, 6-10 , 633 P.2d 83 (1981) (Brachtenbach, C.J., concurring) (discussing these two tests).

2013The closest this court has come to adopting a comprehensive framework to govern harmless error review was in Guloy, when we intended "to settle the question of what type of standard this court will use in its harmless error analysis," and with little discussion or explanation selected '"the overwhelming untainted evidence"' test over "the contribution test." 104 Wn.2d at 425-26 ; see also State v. Evans, 96 Wn.2d 1, 6-10 , 633 P.2d 83 (1981) (Brachtenbach, C.J., concurring) (discussing these two tests).

2010No. 458, 127 Wash.App. 526, 535-36 , 111 P.3d 1235 (2005), rev'd on other grounds, 162 Wash.2d 196 , 172 P.3d 329 (2007). ¶ 70 While several Washington cases have examined whether particular "writings" that are "prepared, owned, used, or retained" by government "relating to the conduct of government or the performance of any governmental or proprietary function," none articulates a comprehensive test or presents an analytical framework for making such a determination.

2010App. 526, 535-36 , 111 P.3d 1235 (2005), rev’d on other grounds, 162 Wn.2d 196 , 172 P.3d 329 (2007). ¶70 While several Washington cases have examined whether particular “writings” that are “prepared, owned, used, or retained” by government “relating to the conduct of government or the performance of any governmental or proprietary function,” none articulates a comprehensive test or presents an analytical framework for making such a determination.

2010No. 458, 127 Wash.App. 526, 535-36 , 111 P.3d 1235 (2005), rev'd on other grounds, 162 Wash.2d 196 , 172 P.3d 329 (2007). ¶ 70 While several Washington cases have examined whether particular "writings" that are "prepared, owned, used, or retained" by government "relating to the conduct of government or the performance of any governmental or proprietary function," none articulates a comprehensive test or presents an analytical framework for making such a determination.

2010App. 526, 535-36 , 111 P.3d 1235 (2005), rev’d on other grounds, 162 Wn.2d 196 , 172 P.3d 329 (2007). ¶70 While several Washington cases have examined whether particular “writings” that are “prepared, owned, used, or retained” by government “relating to the conduct of government or the performance of any governmental or proprietary function,” none articulates a comprehensive test or presents an analytical framework for making such a determination.

2010No. 458, 127 Wash.App. 526, 535-36 , 111 P.3d 1235 (2005), rev'd on other grounds, 162 Wash.2d 196 , 172 P.3d 329 (2007). ¶ 70 While several Washington cases have examined whether particular "writings" that are "prepared, owned, used, or retained" by government "relating to the conduct of government or the performance of any governmental or proprietary function," none articulates a comprehensive test or presents an analytical framework for making such a determination.

2010App. 526, 535-36 , 111 P.3d 1235 (2005), rev’d on other grounds, 162 Wn.2d 196 , 172 P.3d 329 (2007). ¶70 While several Washington cases have examined whether particular “writings” that are “prepared, owned, used, or retained” by government “relating to the conduct of government or the performance of any governmental or proprietary function,” none articulates a comprehensive test or presents an analytical framework for making such a determination.

2010Trujillo, 112 Wash.App. at 393 , 49 P.3d 935 .

2010Trujillo, 112 Wn.

2008In Prisk, 46 Wash.App. at 804 , 732 P.2d 1013 , this court determined that the city of Poulsbo satisfied its obligations under RCW 35.92.025 because the city "acted deliberately and only after consideration of a comprehensive analysis of the historical costs of the system." The Prisk court further noted that the city provided considerable expert opinion in support of the reasonableness of the charges.

2008In Prisk, 46 Wash.App. at 804 , 732 P.2d 1013 , this court determined that the city of Poulsbo satisfied its obligations under RCW 35.92.025 because the city "acted deliberately and only after consideration of a comprehensive analysis of the historical costs of the system." The Prisk court further noted that the city provided considerable expert opinion in support of the reasonableness of the charges.

1997We recently engaged in a more comprehensive analysis of Halper , in State v. McClendon, 131 Wn.2d 853 , 935 P.2d 1334 (1997), holding that the issuance of probationary drivers licenses is not punishment for double jeopardy purposes.

1997We recently engaged in a more comprehensive analysis of Halper, in State v. McClendon, 131 Wash.2d 853 , 935 P.2d 1334 (1997), holding that the issuance of probationary drivers licenses is not punishment for double jeopardy purposes.

1997We recently engaged in a more comprehensive analysis of Halper , in State v. McClendon, 131 Wn.2d 853 , 935 P.2d 1334 (1997), holding that the issuance of probationary drivers licenses is not punishment for double jeopardy purposes.

1997We recently engaged in a more comprehensive analysis of Halper, in State v. McClendon, 131 Wash.2d 853 , 935 P.2d 1334 (1997), holding that the issuance of probationary drivers licenses is not punishment for double jeopardy purposes.

1970But subsequent to the comprehensive analysis of our cases by Judge Tolman in Wong Kee Jun v. Seattle, 143 Wash. 479 , 255 Pac. 645 , 52 A.L.R. 625 (1927), supplemented by Judge Steinert’s scholarly discussion in Boitano v. Snoho-mish Cy., 11 Wn.2d 664, 120 P.2d 490 (1941), we have adhered fairly closely to the principles enunciated in those cases.

1970But subsequent to the comprehensive analysis of our cases by Judge Tolman in Wong Kee Jun v. Seattle, 143 Wash. 479 , 255 Pac. 645 , 52 A.L.R. 625 (1927), supplemented by Judge Steinert’s scholarly discussion in Boitano v. Snoho-mish Cy., 11 Wn.2d 664, 120 P.2d 490 (1941), we have adhered fairly closely to the principles enunciated in those cases.

1970But subsequent to the comprehensive analysis of our cases by Judge Tolman in Wong Kee Jun v. Seattle, 143 Wash. 479 , 255 Pac. 645 , 52 A.L.R. 625 (1927), supplemented by Judge Steinert’s scholarly discussion in Boitano v. Snoho-mish Cy., 11 Wn.2d 664, 120 P.2d 490 (1941), we have adhered fairly closely to the principles enunciated in those cases.

1970But subsequent to the comprehensive analysis of our cases by Judge Tolman in Wong Kee Jun v. Seattle, 143 Wash. 479 , 255 Pac. 645 , 52 A.L.R. 625 (1927), supplemented by Judge Steinert’s scholarly discussion in Boitano v. Snoho-mish Cy., 11 Wn.2d 664, 120 P.2d 490 (1941), we have adhered fairly closely to the principles enunciated in those cases.

2024State v. Anderson, 92 Wn.

2019The O'Cain opinion highlighted two principles that are *209 recognized and significant in Melendez-Diaz : (1) a defendant loses the right to confrontation if he or she does not object at trial and (2) states have the power to create their own rules that govern how a defendant may assert a confrontation clause violation. 4 See *1192 O'Cain, 169 Wash. App. at 236 -40 , 279 P.3d 926 . ¶40 In O'Cain , the court identified the applicable procedural rule in Washington to be ER 103.

2019The O'Cain opinion highlighted two principles that are *209 recognized and significant in Melendez-Diaz : (1) a defendant loses the right to confrontation if he or she does not object at trial and (2) states have the power to create their own rules that govern how a defendant may assert a confrontation clause violation. 4 See *1192 O'Cain, 169 Wash. App. at 236 -40 , 279 P.3d 926 . ¶40 In O'Cain , the court identified the applicable procedural rule in Washington to be ER 103.

2015App. 567, 577 , 137 P.3d 66 (2006).

2015RCW 13.40.450 reflects the legislature's general attempt "to provide a comprehensive framework addressing all aspects of how an offender is to be charged, prosecuted, and punished." State v. G.A.H., 133 Wn.

2010Trujillo, 112 Wash.App. at 393 , 49 P.3d 935 .

2010No. 458, 127 Wash.App. 526, 535-36 , 111 P.3d 1235 (2005), rev'd on other grounds, 162 Wash.2d 196 , 172 P.3d 329 (2007). ¶ 70 While several Washington cases have examined whether particular "writings" that are "prepared, owned, used, or retained" by government "relating to the conduct of government or the performance of any governmental or proprietary function," none articulates a comprehensive test or presents an analytical framework for making such a determination.

1977App. 722 , 537 P.2d 1067 (1975), deal explicity with search and seizure and when considered together present a comprehensive analysis of the principles affecting peace officers and their agents, when acting with or without a warrant.

1976Botton v. State, 69 Wn.2d 751 , 753 n.l, 420 P.2d 352 (1966). 2 For a comprehensive analysis of the rights of riparian owners to navigable waters and tidelands, see Harris v. Hylebos Indus, Inc., 81 Wn.2d 770 , 505 P.2d 457 (1973).

1976Botton v. State, 69 Wn.2d 751 , 753 n.l, 420 P.2d 352 (1966). 2 For a comprehensive analysis of the rights of riparian owners to navigable waters and tidelands, see Harris v. Hylebos Indus, Inc., 81 Wn.2d 770 , 505 P.2d 457 (1973).

1976Botton v. State, 69 Wn.2d 751 , 753 n.l, 420 P.2d 352 (1966). 2 For a comprehensive analysis of the rights of riparian owners to navigable waters and tidelands, see Harris v. Hylebos Indus, Inc., 81 Wn.2d 770 , 505 P.2d 457 (1973).

1976Botton v. State, 69 Wn.2d 751 , 753 n.l, 420 P.2d 352 (1966). 2 For a comprehensive analysis of the rights of riparian owners to navigable waters and tidelands, see Harris v. Hylebos Indus, Inc., 81 Wn.2d 770 , 505 P.2d 457 (1973).

1970This evidence was admitted solely for the purpose of showing a possible scheme or plan which might relate to the defendant’s intent or of the absence of mistake as to his actions of May 28, 1968, and to show a reason for the presence of the police at the hospital on that date, and is not to be considered by you for any other purpose.” 2 For a comprehensive analysis of Washington cases which have considered the admission of evidence of other crimes to show a common scheme or plan, etc., see State v. Whalon, 1 Wn.

1970App. 785 , 464 P.2d 730 (1970). 3 The case was presented on the appeal by the successor in office oí the prosecuting attorney who made the argument in question.