marital privilege (Washington) · Go Syfert
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marital privilege in Washington

23 Washington opinions name it 2 courts 1953–2018 0 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 (12)

CaseFollowedCited
State v. Charltongreen
wash · 1978 · cited in 3 Washington opinions naming this issue, 2004–2012
2 sentences

2012See Monday, 171 Wn.2d at 678-80 (racist arguments required reversal; no weighing of evidence by the court); Belgarde, 110 Wn.2d at 507-10 (inflammatory remarks associating defendant with an organization the prosecutor described as “ ‘deadly group of madmen’ ”; misconduct required reversal; no weighing of evidence by the court); Charlton, 90 Wn.2d at 664 (prosecutor commented on the defendant’s spouse’s failure to testify, despite the marital privilege, with the inference being that the defendant was concealing or withholding testimony; reversal required — jury might have been inclined to belie

2004Easter, 130 Wn.2d at 242 (officer’s testimony was “elicited to insinuate Easter’s guilt”); Charlton, 90 Wn.2d at 663 (“[T]he prosecutor endeavored to suggest. . . that petitioner was concealing or withholding testimony.”); Swan, 25 Wn.2d at 327 (“In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state.”); McGinty, 14 Wn.2d at 79 (holding the State’s questions regarding the timing of the marriage and fact that the State forced the defendant to invoke the marital privilege in front of the jury “tended to make it appear

23
Dean S. v. Frederick S.green
washctapp · 2006 · cited in 2 Washington opinions naming this issue, 2018–2018
2 sentences

2018See In re Parentage of C.S., 134 Wn.

2018See In re Parentage of C.S., 134 Wn.

22
State v. Swangreen
wash · 1946 · cited in 4 Washington opinions naming this issue, 1966–2004
2 sentences

2004Easter, 130 Wn.2d at 242 (officer’s testimony was “elicited to insinuate Easter’s guilt”); Charlton, 90 Wn.2d at 663 (“[T]he prosecutor endeavored to suggest. . . that petitioner was concealing or withholding testimony.”); Swan, 25 Wn.2d at 327 (“In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state.”); McGinty, 14 Wn.2d at 79 (holding the State’s questions regarding the timing of the marriage and fact that the State forced the defendant to invoke the marital privilege in front of the jury “tended to make it appear

2004Easter, 130 Wash.2d at 242 , 922 P.2d 1285 (officer's testimony was "elicited to insinuate Easter's guilt"); Charlton, 90 Wash.2d at 663 , 585 P.2d 142 ("[T]he prosecutor endeavored to suggest ... that petitioner was concealing or withholding testimony."); Swan, 25 Wash.2d at 327 , 171 P.2d 222 ("In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state."); McGinty, 14 Wash.2d at 79 , 126 P.2d 1086 (holding the State's questions regarding the timing of the marriage and fact that the State forced the defendant to invoke

14
State v. McGintygreen
wash · 1942 · cited in 3 Washington opinions naming this issue, 1978–2004
2 sentences

2004Easter, 130 Wn.2d at 242 (officer’s testimony was “elicited to insinuate Easter’s guilt”); Charlton, 90 Wn.2d at 663 (“[T]he prosecutor endeavored to suggest. . . that petitioner was concealing or withholding testimony.”); Swan, 25 Wn.2d at 327 (“In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state.”); McGinty, 14 Wn.2d at 79 (holding the State’s questions regarding the timing of the marriage and fact that the State forced the defendant to invoke the marital privilege in front of the jury “tended to make it appear

2004Easter, 130 Wash.2d at 242 , 922 P.2d 1285 (officer's testimony was "elicited to insinuate Easter's guilt"); Charlton, 90 Wash.2d at 663 , 585 P.2d 142 ("[T]he prosecutor endeavored to suggest ... that petitioner was concealing or withholding testimony."); Swan, 25 Wash.2d at 327 , 171 P.2d 222 ("In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state."); McGinty, 14 Wash.2d at 79 , 126 P.2d 1086 (holding the State's questions regarding the timing of the marriage and fact that the State forced the defendant to invoke

13
State v. Eastergreen
wash · 1996 · cited in 2 Washington opinions naming this issue, 2004–2004
2 sentences

2004Easter, 130 Wn.2d at 242 (officer’s testimony was “elicited to insinuate Easter’s guilt”); Charlton, 90 Wn.2d at 663 (“[T]he prosecutor endeavored to suggest. . . that petitioner was concealing or withholding testimony.”); Swan, 25 Wn.2d at 327 (“In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state.”); McGinty, 14 Wn.2d at 79 (holding the State’s questions regarding the timing of the marriage and fact that the State forced the defendant to invoke the marital privilege in front of the jury “tended to make it appear

2004Easter, 130 Wash.2d at 242 , 922 P.2d 1285 (officer's testimony was "elicited to insinuate Easter's guilt"); Charlton, 90 Wash.2d at 663 , 585 P.2d 142 ("[T]he prosecutor endeavored to suggest ... that petitioner was concealing or withholding testimony."); Swan, 25 Wash.2d at 327 , 171 P.2d 222 ("In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state."); McGinty, 14 Wash.2d at 79 , 126 P.2d 1086 (holding the State's questions regarding the timing of the marriage and fact that the State forced the defendant to invoke

12
State v. Waleczekgreen
wash · 1978 · cited in 2 Washington opinions naming this issue, 1987–1997
2 sentences

1987This exception reflects the Legislature's decision to subordinate the marital privilege to the "overriding and paramount legislative intent to protect children from physical and sexual abuse." State v. Waleczek, 90 Wn.2d 746, 751 , 585 P.2d 797 (1978); accord, State v. Bouchard, 31 Wn.

1987This exception reflects the Legislature's decision to subordinate the marital privilege to the "overriding and paramount legislative intent to protect children from physical and sexual abuse." State v. Waleczek, 90 Wn.2d 746, 751 , 585 P.2d 797 (1978); accord, State v. Bouchard, 31 Wn.

12
State v. Tannergreen
wash · 1959 · cited in 2 Washington opinions naming this issue, 1966–1978
2 sentences

1966Appellant relies on certain language in State v. Swan, 25 Wn.2d 319 , 171 P.2d 222 , and State v. Tanner, 54 Wn.2d 535 , 341 P.2d 869 , in which the protection given by the marital privilege was likened to the privilege against self-incrimination guaranteed by Const, art. 1, § 9.

1966Appellant relies on certain language in State v. Swan, 25 Wn.2d 319 , 171 P.2d 222 , and State v. Tanner, 54 Wn.2d 535 , 341 P.2d 869 , in which the protection given by the marital privilege was likened to the privilege against self-incrimination guaranteed by Const, art. 1, § 9.

12
State v. Belgardegreen
wash · 1988 · cited in 1 Washington opinions naming this issue, 2012–2012
1 sentence

2012See Monday, 171 Wn.2d at 678-80 (racist arguments required reversal; no weighing of evidence by the court); Belgarde, 110 Wn.2d at 507-10 (inflammatory remarks associating defendant with an organization the prosecutor described as “ ‘deadly group of madmen’ ”; misconduct required reversal; no weighing of evidence by the court); Charlton, 90 Wn.2d at 664 (prosecutor commented on the defendant’s spouse’s failure to testify, despite the marital privilege, with the inference being that the defendant was concealing or withholding testimony; reversal required — jury might have been inclined to belie

11
State v. Mondaygreen
wash · 2011 · cited in 1 Washington opinions naming this issue, 2012–2012
1 sentence

2012See Monday, 171 Wn.2d at 678-80 (racist arguments required reversal; no weighing of evidence by the court); Belgarde, 110 Wn.2d at 507-10 (inflammatory remarks associating defendant with an organization the prosecutor described as “ ‘deadly group of madmen’ ”; misconduct required reversal; no weighing of evidence by the court); Charlton, 90 Wn.2d at 664 (prosecutor commented on the defendant’s spouse’s failure to testify, despite the marital privilege, with the inference being that the defendant was concealing or withholding testimony; reversal required — jury might have been inclined to belie

11
State v. Bouchardgreen
washctapp · 1982 · cited in 1 Washington opinions naming this issue, 1987–1987
2 sentences

1987This exception reflects the Legislature's decision to subordinate the marital privilege to the "overriding and paramount legislative intent to protect children from physical and sexual abuse." State v. Waleczek, 90 Wn.2d 746, 751 , 585 P.2d 797 (1978); accord, State v. Bouchard, 31 Wn.

1987App. 381, 387 , 639 P.2d 761 , review denied, 97 Wn.2d 1021 (1982).

11
Seventh Elect Church in Israel v. Rogersgreen
washctapp · 1983 · cited in 1 Washington opinions naming this issue, 1984–1984
1 sentence

1984See Seventh Elect Church v. Rogers, 34 Wn.

11
State v. Bromleygreen
wash · 1967 · cited in 1 Washington opinions naming this issue, 1979–1979
2 sentences

1979See State v. Bromley, 72 Wn.2d 150 , 432 P.2d 568 (1967).

1979See State v. Bromley, 72 Wn.2d 150 , 432 P.2d 568 (1967).

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 (17)

CaseCitedYears
Crawford v. Washington green
scotus · 2004
2 sentences

2005Id. at 38 .

2005Id. at 38 , 124 S.Ct. 1354 .

22005–2005
State v. Clark green
wash · 1946
2 sentences

1958State v. Clark, 26 Wn. (2d) 160, 173 P. (2d) 189 (1946) .

1953State v. Clark, 26 Wn. (2d) 160, 173 P. (2d) 189 (1946).

21953–1958
State v. Modica green
wash · 2008
2 sentences

2014As the State argues, Blair has failed to 30 Modica. 164 Wn.2d at 88 . 31 Modica. 164 Wn.2d at 88 . 32 Modica. 164 Wn.2d at 88 . 33 Modica. 164 Wn.2d at 89 . 34 Modica. 164 Wn.2d at 89. 35 Modica. 164 Wn.2d at 89 n.1, 90. 19 No. 68971-1-1/20 establish a marital privilege because engaging in conversation in the presence of others vitiates a privilege.

2014As the State argues, Blair has failed to 30 Modica. 164 Wn.2d at 88 . 31 Modica. 164 Wn.2d at 88 . 32 Modica. 164 Wn.2d at 88 . 33 Modica. 164 Wn.2d at 89 . 34 Modica. 164 Wn.2d at 89. 35 Modica. 164 Wn.2d at 89 n.1, 90. 19 No. 68971-1-1/20 establish a marital privilege because engaging in conversation in the presence of others vitiates a privilege.

12014–2014
Sumpter v. National Grocery Co. neutral
wash · 1938
2 sentences

2004Easter, 130 Wash.2d at 242 , 922 P.2d 1285 (officer's testimony was "elicited to insinuate Easter's guilt"); Charlton, 90 Wash.2d at 663 , 585 P.2d 142 ("[T]he prosecutor endeavored to suggest ... that petitioner was concealing or withholding testimony."); Swan, 25 Wash.2d at 327 , 171 P.2d 222 ("In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state."); McGinty, 14 Wash.2d at 79 , 126 P.2d 1086 (holding the State's questions regarding the timing of the marriage and fact that the State forced the defendant to invoke

2004Easter, 130 Wash.2d at 242 , 922 P.2d 1285 (officer's testimony was "elicited to insinuate Easter's guilt"); Charlton, 90 Wash.2d at 663 , 585 P.2d 142 ("[T]he prosecutor endeavored to suggest ... that petitioner was concealing or withholding testimony."); Swan, 25 Wash.2d at 327 , 171 P.2d 222 ("In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state."); McGinty, 14 Wash.2d at 79 , 126 P.2d 1086 (holding the State's questions regarding the timing of the marriage and fact that the State forced the defendant to invoke

12004–2004
State v. Easter green
wash · 1996
1 sentence

2004Easter, 130 Wash.2d at 242 , 922 P.2d 1285 (officer's testimony was "elicited to insinuate Easter's guilt"); Charlton, 90 Wash.2d at 663 , 585 P.2d 142 ("[T]he prosecutor endeavored to suggest ... that petitioner was concealing or withholding testimony."); Swan, 25 Wash.2d at 327 , 171 P.2d 222 ("In effect [counsel for the State] told the jury that appellant was guilty of concealing evidence which would be helpful to the state."); McGinty, 14 Wash.2d at 79 , 126 P.2d 1086 (holding the State's questions regarding the timing of the marriage and fact that the State forced the defendant to invoke

12004–2004
State v. Burden green
wash · 1992
2 sentences

1997The marital privilege is contained in RCW 5.60.060(1), which provides that neither a husband nor a wife can testify for or against the other spouse without the spouse’s consent. 3 State v. Burden, 120 Wn.2d 371, 373-74 , 841 P.2d 758 (1992).

1997The marital privilege is contained in RCW 5.60.060(1), which provides that neither a husband nor a wife can testify for or against the other spouse without the spouse’s consent. 3 State v. Burden, 120 Wn.2d 371, 373-74 , 841 P.2d 758 (1992).

11997–1997
State v. Thornton green
wash · 1992
2 sentences

1997RCW 5.60.060(1); State v. Thornton, 119 Wn.2d 578, 580 , 835 P.2d 216 (1992); State v. Waleczek, 90 Wn.2d 746, 749 , 585 P.2d 797 (1978).

1997RCW 5.60.060(1); State v. Thornton, 119 Wn.2d 578, 580 , 835 P.2d 216 (1992); State v. Waleczek, 90 Wn.2d 746, 749 , 585 P.2d 797 (1978).

11997–1997
State v. Cory green
wash · 1963
1 sentence

1988In assessing the proper remedy, I have considered the case of State v. Cory, 62 Wash 2d 371, 382 P. 2d 1019 (1963) . . .

11988–1988
State v. Hermes green
wash · 1967
2 sentences

1983Thus, Priscilla Rogers must be sworn and answer all relevant questions within her personal knowledge which are not confidential communications, State v. Hermes, 71 Wn.2d 56, 58 , 426 P.2d 494 (1967), unless she can establish a clear danger of self-incrimination as to herself with respect to each question.

1983Thus, Priscilla Rogers must be sworn and answer all relevant questions within her personal knowledge which are not confidential communications, State v. Hermes, 71 Wn.2d 56, 58 , 426 P.2d 494 (1967), unless she can establish a clear danger of self-incrimination as to herself with respect to each question.

11983–1983
Frankenthal v. Solomonson neutral
wash · 1899
2 sentences

1983The court held the marital privilege inapplicable since such a construction would completely nullify the statute authorizing supplemental proceedings in aid of execution, which statute "expressly provides that a judgment debtor may be required to appear in court and answer concerning property which he unjustly refuses to apply towards the satisfaction of the judgment." Belknap , at 4; cf. Frankenthal v. Solomonson, 20 Wash. 460 , 55 P. 754 (1899) (holding that a husband, the judgment debtor, could not assert the marital privilege in a supplemental proceeding initiated solely against his wife t

1983The court held the marital privilege inapplicable since such a construction would completely nullify the statute authorizing supplemental proceedings in aid of execution, which statute "expressly provides that a judgment debtor may be required to appear in court and answer concerning property which he unjustly refuses to apply towards the satisfaction of the judgment." Belknap , at 4; cf. Frankenthal v. Solomonson, 20 Wash. 460 , 55 P. 754 (1899) (holding that a husband, the judgment debtor, could not assert the marital privilege in a supplemental proceeding initiated solely against his wife t

11983–1983
State v. Lounsbery green
wash · 1968
2 sentences

1982State v. Lounsbery, 74 Wn.2d 659, 663 , 445 P.2d 1017 (1968).

1982State v. Lounsbery, 74 Wn.2d 659, 663 , 445 P.2d 1017 (1968).

11982–1982
Yamauchi v. Department of Employment Security neutral
washctapp · 1981
2 sentences

1982Yamauchi v. Department of Employment Security, 28 Wn.

1982Yamauchi v. Department of Employment Security, 28 Wn.

11982–1982
State v. Gant green
washctapp · 1971
1 sentence

1978State v. McGinty, supra; State v. Tanner, supra; State v. Swan, 25 Wn.2d 319 , 171 P.2d 222 (1946); State v. Gant, 6 Wn.

11978–1978
State v. Osborne green
washctapp · 1977
1 sentence

1978This argument is based upon State v. Osborne, 18 Wn.

11978–1978
United States v. Harris green
scotus · 1971
1 sentence

1972Ed. 2d 723 , 91 S. Ct. 2075 (1971). 2 The letter testified to by Mrs. Hughes and the testimony of Harold Sheridan were not inadmissible under the marital privilege.

11972–1972
State v. Robbins green
wash · 1950
1 sentence

1953Stat., § 1214]. *506 The Washington rule regarding the marital privilege is as stated in State v. Snyder, 84 Wash. 485 , 147 Pac. 38 : “The divorced wife was a competent witness against the appellant, except as to communications made by one to the other during the marriage. . . . “ ‘Any communication,’ as mentioned in the statute, means confidential communications, or such as are induced by the marriage relation.” As to what are communications to which a divorced wife cannot testify against her husband, the court in State v. Robbins, 35 Wn. (2d) 389, 213 P. (2d) 310 , said: “However, there are

11953–1953
State v. Snyder green
wash · 1915
2 sentences

1953Stat., § 1214]. *506 The Washington rule regarding the marital privilege is as stated in State v. Snyder, 84 Wash. 485 , 147 Pac. 38 : “The divorced wife was a competent witness against the appellant, except as to communications made by one to the other during the marriage. . . . “ ‘Any communication,’ as mentioned in the statute, means confidential communications, or such as are induced by the marriage relation.” As to what are communications to which a divorced wife cannot testify against her husband, the court in State v. Robbins, 35 Wn. (2d) 389, 213 P. (2d) 310 , said: “However, there are

1953Stat., § 1214]. *506 The Washington rule regarding the marital privilege is as stated in State v. Snyder, 84 Wash. 485 , 147 Pac. 38 : “The divorced wife was a competent witness against the appellant, except as to communications made by one to the other during the marriage. . . . “ ‘Any communication,’ as mentioned in the statute, means confidential communications, or such as are induced by the marriage relation.” As to what are communications to which a divorced wife cannot testify against her husband, the court in State v. Robbins, 35 Wn. (2d) 389, 213 P. (2d) 310 , said: “However, there are

11953–1953

Statutes the citing opinions construe

WA § Wash. Rev. Code § 5.60.060 (14)

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 163 (1956–2026) NY 131 (1975–2025) NJ 71 (1967–2026) IL 57 (1979–2024) FL 45 (1976–2018) OH 40 (1985–2023) AL 38 (1978–2026) MN 34 (1961–2025) UT 34 (1995–2025) TN 27 (1978–2015) GA 24 (1983–2024) WA 23 (1953–2018) MO 23 (1979–2024) CO 22 (1981–2026) NC 20 (1995–2025) IN 20 (1975–2026) PA 20 (1935–2025) AZ 19 (1974–2018) WI 18 (1967–2024) TX 17 (1972–2022) MI 15 (1965–2023) MA 15 (1980–2025) DC 15 (1976–2015) CT 12 (1995–2023) KY 11 (1988–2022) MD 11 (1996–2021) VT 11 (1988–2026) VA 10 (1996–2016) KS 10 (1977–2023) OR 9 (1972–2023) IA 8 (1978–2025) ME 7 (1971–2022) LA 7 (2014–2024) WY 7 (1978–2008) OK 6 (1999–2006) NV 6 (1980–2020) NH 6 (1989–2006) MS 6 (2000–2025) AK 5 (1980–2018) ID 5 (1925–2009) RI 5 (1998–2017) NM 5 (2003–2022) SC 4 (2005–2018) HI 4 (2003–2026) ND 4 (1993–1997) WV 3 (1987–2018) SD 3 (1986–2003) VI 3 (1997–2025) MT 2 (1981–2021) DE 2 (1994–2018)

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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