end inquiry (Washington) · Go Syfert
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end inquiry in Washington

23 Washington opinions name it 2 courts 1964–2026 11 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 (5)

CaseFollowedCited
State v. Arndtgreen
wash · 2019 · cited in 3 Washington opinions naming this issue, 2023–2026
2 sentences

2026As to the first step, “‘[i]f there is clear legislative intent to impose multiple punishments for the same act or conduct, this is the end of the inquiry and no double jeopardy exits.’” Ray, 5 Wn.3d at 364 (quoting Arndt, 194 Wn.2d at 816 ).

2025Arndt, 194 Wn.2d at 816. “‘If there is clear legislative intent to impose multiple punishments for the same act or conduct, this is the end of the inquiry and no double jeopardy violation exists.’” Id. (quoting State v. Kelley, 168 Wn.2d 72, 77 , 226 P.3d 773 (2010)).

13
Exxon Shipping Co. v. Bakergreen
scotus · 2008 · cited in 1 Washington opinions naming this issue, 2012–2012
2 sentences

2012In the first paragraph of the opinion, the issue is framed as "whether the award ... in this case is greater than maritime law should allow in the circumstances. " Exxon, 554 U.S. at 476 , 128 S.Ct. 2605 (emphasis added). ¶ 30 Toward the end of its analysis, the Court again, in the context of analyzing the spectrum of laws and cases establishing limits on punitive awards, observes "... the upper limit is not directed to cases like this one, where the tortious action was worse than negligent but less than malicious, ... the 3:1 ratio ... applies to awards in quite different cases involving ...

2012In the first paragraph of the opinion, the issue is framed as "whether the award ... in this case is greater than maritime law should allow in the circumstances. " Exxon, 554 U.S. at 476 , 128 S.Ct. 2605 (emphasis added). ¶ 30 Toward the end of its analysis, the Court again, in the context of analyzing the spectrum of laws and cases establishing limits on punitive awards, observes "... the upper limit is not directed to cases like this one, where the tortious action was worse than negligent but less than malicious, ... the 3:1 ratio ... applies to awards in quite different cases involving ...

11
Fisher Properties, Inc. v. Arden-Mayfair, Inc.green
wash · 1990 · cited in 1 Washington opinions naming this issue, 2012–2012
1 sentence

2012See Fisher, 115 Wn.2d at 374 (holding that use of remind term “determine” required the trial court to enter new findings and exercise discretion rather than simply recalculate). ¶16 Yet at the end of our analysis, we simply stated, “We then remand for the entry of appropriate findings of fact and conclusions of law to support the award of fees and costs attributable to the Kenagys’ claims related to securing a successful recovery.” Deep Water, 152 Wn.

11
Deep Water Brewing, LLC v. Fairway Resources Ltd.green
washctapp · 2009 · cited in 1 Washington opinions naming this issue, 2012–2012
1 sentence

2012See Fisher, 115 Wn.2d at 374 (holding that use of remind term “determine” required the trial court to enter new findings and exercise discretion rather than simply recalculate). ¶16 Yet at the end of our analysis, we simply stated, “We then remand for the entry of appropriate findings of fact and conclusions of law to support the award of fees and costs attributable to the Kenagys’ claims related to securing a successful recovery.” Deep Water, 152 Wn.

11
Xieng v. Peoples National Bankgreen
wash · 1993 · cited in 1 Washington opinions naming this issue, 2006–2006
2 sentences

2006Xieng v. Peoples Nat'l Bank of Wash., 120 Wash.2d 512, 522 , 844 P.2d 389 (1993) ("Once an employment discrimination case has been decided on the merits, any issues concerning the employer's burden merge into the ultimate disposition of the issue of discrimination made by the trier of fact."). ¶ 36 The authorities Ms. Barker cites on the good faith issue are not retaliation cases.

2006Xieng v. Peoples Nat'l Bank of Wash., 120 Wash.2d 512, 522 , 844 P.2d 389 (1993) ("Once an employment discrimination case has been decided on the merits, any issues concerning the employer's burden merge into the ultimate disposition of the issue of discrimination made by the trier of fact."). ¶ 36 The authorities Ms. Barker cites on the good faith issue are not retaliation cases.

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 (22)

CaseCitedYears
State v. Kelley green
wash · 2010
2 sentences

2025Arndt, 194 Wn.2d at 816. “‘If there is clear legislative intent to impose multiple punishments for the same act or conduct, this is the end of the inquiry and no double jeopardy violation exists.’” Id. (quoting State v. Kelley, 168 Wn.2d 72, 77 , 226 P.3d 773 (2010)).

2023If the legislature clearly intended to impose multiple punishments for the same conduct, “ ‘this is the end of the inquiry and no double jeopardy violation exists.’ ” Id. at 816 (quoting State v. Kelley, 168 Wn.2d 72, 77 , 226 P.3d 773 (2010)).

32020–2025
State v. Kelley green
wash · 2010
2 sentences

2025Arndt, 194 Wn.2d at 816. “‘If there is clear legislative intent to impose multiple punishments for the same act or conduct, this is the end of the inquiry and no double jeopardy violation exists.’” Id. (quoting State v. Kelley, 168 Wn.2d 72, 77 , 226 P.3d 773 (2010)).

2023If the legislature clearly intended to impose multiple punishments for the same conduct, “ ‘this is the end of the inquiry and no double jeopardy violation exists.’ ” Id. at 816 (quoting State v. Kelley, 168 Wn.2d 72, 77 , 226 P.3d 773 (2010)).

32020–2025
State v. Jenks green
wash · 2021
2 sentences

2024If unambiguous, a statute’s plain language “provides the beginning and the end of the analysis.” State v. Jenks, 197 Wn.2d 708, 714 , 487 P.3d 482 (2021).

2024If unambiguous, the plain language provides “the beginning and the end of the analysis.” Id. 11 The amendment has the effect of removing a person’s prior juvenile dispositions from use when calculating a person’s offender score for any subsequent adult convictions, except for juvenile adjudications of guilt for murder in the first degree, murder in the second degree, and class A felony sex offenses.

32024–2024
Beal v. City of Seattle green
wash · 1998
2 sentences

2010Beal for Martinez v. City of Seattle, 134 Wash.2d 769, 777 , 954 P.2d 237 (1998).

2010Beal v. City of Seattle, 134 Wn.2d 769, 777 , 954 P.2d 237 (1998).

22010–2010
Beal for Martinez v. City of Seattle green
wash · 1998
2 sentences

2010Beal for Martinez v. City of Seattle, 134 Wash.2d 769, 777 , 954 P.2d 237 (1998).

2010Beal v. City of Seattle, 134 Wn.2d 769, 777 , 954 P.2d 237 (1998).

22010–2010
State v. Ritchie green
wash · 1995
1 sentence

2026At the end of the hearing, the trial court discussed Sanchez’s silence and perceived lack of remorse and then immediately stated, “so that’s kind of the mindset that I have.” Id.

12026–2026
Brown v. United States green
scotus · 1973
1 sentence

2025At the end of the analysis, we will reverse “where there is any reasonable possibility that the use of inadmissible evidence was necessary to reach a guilty verdict.” Id.

12025–2025
State v. Brown green
wash · 1999
1 sentence

2023App. 2d 37 , 47-50, 493 P.3d 1220 (2021) (quoting State v. Brown, 139 Wn.2d 20, 28 , 983 P.2d 608 (1999), overruled in part on other grounds by State v. Houston-Sconiers, 188 Wn.2d 1, 21 , 391 P.3d 409 (2017)), review denied, 199 Wn.2d 1001 , 506 P.3d 1230 (2022). 20 Because RCW 9.94A.533(3) clearly expresses the legislature’s intent for multiple punishments from the same conduct, “ ‘this is the end of the inquiry and no double jeopardy violation exists.’ ” Arndt, 194 Wn.2d at 816 (quoting Kelley, 168 Wn.2d at 77 ).

12023–2023
State of Washington v. Anthony Laurence Wright green
washctapp · 2021
1 sentence

2023App. 2d 37 , 47-50, 493 P.3d 1220 (2021) (quoting State v. Brown, 139 Wn.2d 20, 28 , 983 P.2d 608 (1999), overruled in part on other grounds by State v. Houston-Sconiers, 188 Wn.2d 1, 21 , 391 P.3d 409 (2017)), review denied, 199 Wn.2d 1001 , 506 P.3d 1230 (2022). 20 Because RCW 9.94A.533(3) clearly expresses the legislature’s intent for multiple punishments from the same conduct, “ ‘this is the end of the inquiry and no double jeopardy violation exists.’ ” Arndt, 194 Wn.2d at 816 (quoting Kelley, 168 Wn.2d at 77 ).

12023–2023
Berger v. Sonneland green
wash · 2001
1 sentence

2023Liability in a medical malpractice action can be based on negligence too, but our precedent is clear that “the objective symptom requirement is not necessary to prove emotional distress damages under chapter 7.70 RCW.” Berger v. Sonneland, 144 Wn.2d 91, 113 , 26 P.3d 257 (2001) (emphasis added).

12023–2023
State v. Brown green
wash · 1999
1 sentence

2023App. 2d 37 , 47-50, 493 P.3d 1220 (2021) (quoting State v. Brown, 139 Wn.2d 20, 28 , 983 P.2d 608 (1999), overruled in part on other grounds by State v. Houston-Sconiers, 188 Wn.2d 1, 21 , 391 P.3d 409 (2017)), review denied, 199 Wn.2d 1001 , 506 P.3d 1230 (2022). 20 Because RCW 9.94A.533(3) clearly expresses the legislature’s intent for multiple punishments from the same conduct, “ ‘this is the end of the inquiry and no double jeopardy violation exists.’ ” Arndt, 194 Wn.2d at 816 (quoting Kelley, 168 Wn.2d at 77 ).

12023–2023
Berger v. Sonneland green
wash · 2001
1 sentence

2023Liability in a medical malpractice action can be based on negligence too, but our precedent is clear that “the objective symptom requirement is not necessary to prove emotional distress damages under chapter 7.70 RCW.” Berger v. Sonneland, 144 Wn.2d 91, 113 , 26 P.3d 257 (2001) (emphasis added).

12023–2023
State v. Houston-Sconiers green
wash · 2017
2 sentences

2023App. 2d 37 , 47-50, 493 P.3d 1220 (2021) (quoting State v. Brown, 139 Wn.2d 20, 28 , 983 P.2d 608 (1999), overruled in part on other grounds by State v. Houston-Sconiers, 188 Wn.2d 1, 21 , 391 P.3d 409 (2017)), review denied, 199 Wn.2d 1001 , 506 P.3d 1230 (2022). 20 Because RCW 9.94A.533(3) clearly expresses the legislature’s intent for multiple punishments from the same conduct, “ ‘this is the end of the inquiry and no double jeopardy violation exists.’ ” Arndt, 194 Wn.2d at 816 (quoting Kelley, 168 Wn.2d at 77 ).

2023App. 2d 37 , 47-50, 493 P.3d 1220 (2021) (quoting State v. Brown, 139 Wn.2d 20, 28 , 983 P.2d 608 (1999), overruled in part on other grounds by State v. Houston-Sconiers, 188 Wn.2d 1, 21 , 391 P.3d 409 (2017)), review denied, 199 Wn.2d 1001 , 506 P.3d 1230 (2022). 20 Because RCW 9.94A.533(3) clearly expresses the legislature’s intent for multiple punishments from the same conduct, “ ‘this is the end of the inquiry and no double jeopardy violation exists.’ ” Arndt, 194 Wn.2d at 816 (quoting Kelley, 168 Wn.2d at 77 ).

12023–2023
Department of Ecology v. Campbell & Gwinn, L.L.C. green
wash · 2002
1 sentence

2021Campbell & Gwinn, 146 Wn.2d at 9-12 .

12021–2021
City of Seattle v. Evans green
washctapp · 2014
2 sentences

2021The petition stated that “respondent has been advised that involuntary commitment pursuant to this 14-day petition will result in the loss of firearm rights.”13 Additionally, before the probable cause hearing began, the court advised J.H., “[I]f you decline to accept or seek voluntary treatment at this time; and at the end of this hearing, if I conclude that you need to be involuntarily detained for your own benefit, then that could result in your loss of firearm rights.”14 The court also urged J.H. to take a moment to 12 City of Seattle v. Evans, 182 Wn.

2021App. 188, 191 , 327 P.3d 1303 (2014). 13 CP at 18. 14 RP (Mar. 4, 2020) at 6. 5 No. 81294-7-I/6 confer with his counsel.

12021–2021
Westerman v. Cary green
wash · 1995
1 sentence

2020Westerman, 125 Wn.2d at 286-87 .

12020–2020
State v. Madarash green
washctapp · 2003
1 sentence

2020Archaga-Reyes was convicted under the assault prong of the no-contact order statute, RCW 26.50.110(4), which provides that “[amy assault that is a violation of an order issued under. . . chapter 10.99, . . . and that does not amount to assault in the first or second degree . . . is a class C felony. . . .“ As applicable here, an assault is “an intentional touching or striking of another person, with unlawful force, that is harmful or offensive regardless of whether any physical injury is done to the person.” ~ State v. Madarash, 116 Wn.

12020–2020
State v. Eike green
wash · 1967
1 sentence

2017Eike, 72 Wn.2d at 764 .

12017–2017
Shum v. Department of Labor & Industries green
washctapp · 1991
1 sentence

2016App. 405, 408 , 819 P.2d 399 (1991) (vacation of judgment is not proper under CR 60(b)(11) absent extraordinary circumstances relating to irregularities which are extraneous to the court's action or implicate the regularity of its proceedings). 6 Regardless, at the end of the hearing on his motion to vacate a void order, Eggum acknowledged he was the prevailing party: "[Yjou've denied the order.

12016–2016
State v. Vickers green
wash · 2002
1 sentence

2015Vickers. 148 Wn.2d at 118 .

12015–2015
State v. Mickens green
wash · 1962
2 sentences

1986On point is this court's decision in State v. Mickens, 61 Wn.2d 83 , 377 P.2d 240 (1962).

1986On point is this court's decision in State v. Mickens, 61 Wn.2d 83 , 377 P.2d 240 (1962).

11986–1986
Martin v. Aleinikoff green
wash · 1964
1 sentence

1964NOTES [*] Reported in 389 P. (2d) 422 . [1] In his opening statement to the court, plaintiffs' counsel said: "The evidence will show that the defendants in this case, in order to attract new customers, offered to sell fuel oil at prices less than those regularly established prices at which they are selling to the great bulk of their customers.

11964–1964

Statutes the citing opinions construe

WA § Wash. Rev. Code § 10.01.040 (5) WA § Wash. Rev. Code § 9.94A.345 (4) WA § Wash. Rev. Code § 9.94A.525 (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.

Where else courts name it

CA 194 (1897–2026) TX 146 (1894–2026) NY 101 (1848–2026) PA 69 (1837–2026) IL 65 (1927–2026) IN 54 (1881–2026) NJ 54 (1955–2026) MI 54 (1910–2026) GA 51 (1878–2024) FL 50 (1909–2026) OH 49 (1858–2026) MD 42 (1965–2026) CT 32 (1972–2026) MA 31 (1929–2026) DC 30 (1974–2026) IA 30 (1886–2025) NC 29 (1883–2026) CO 29 (1960–2026) LA 28 (1945–2024) OR 27 (1959–2026) AL 24 (1909–2025) WA 23 (1964–2026) AZ 22 (1959–2026) UT 22 (1997–2025) MS 21 (1945–2023) WI 20 (1954–2025) NM 19 (1985–2019) KY 18 (1905–2025) KS 18 (1907–2025) VA 15 (1919–2023) AR 13 (1917–2025) SC 12 (1952–2025) MN 12 (1909–2026) WV 11 (2010–2026) MO 11 (1913–2021) NE 10 (1939–2021) RI 10 (1905–2013) AK 10 (1969–2023) TN 9 (1976–2026) ID 9 (1923–2024) ND 8 (1960–2022) OK 8 (1971–2017) HI 8 (1998–2025) VT 7 (1977–2025) DE 7 (1913–2025) SD 6 (1959–2013) VI 5 (2005–2016) MT 5 (2002–2025) NV 4 (2018–2018) NH 3 (2004–2022) ME 3 (1983–2020) WY 3 (1961–2024)

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.

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