essence claim (District of Columbia) · Go Syfert
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essence claim in District of Columbia

22 District of Columbia opinions name it 1 courts 1977–2024 1 in the last five years

The cases below were cited by District of Columbia 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 (11)

CaseFollowedCited
Henderson v. Snider Bros., Inc.green
dc · 1981 · cited in 5 District of Columbia opinions naming this issue, 1984–2018
2 sentences

2018The doctrine applies “[w]hen the parties are the same, and the essence of the claim and the evidence necessary to establish it are the same.” Id. at 484 .

2018The doctrine applies "[w]hen the parties are the same, and the essence of the claim and the evidence necessary to establish it are the same." Id. at 484 .

35
Oesby v. United Statesgreen
dc · 1977 · cited in 3 District of Columbia opinions naming this issue, 1979–1980
2 sentences

1980The test for a post-trial determination of whether a defendant’s Sixth Amendment right to the effective assistance of counsel has been violated is whether his “counsel was grossly incompetent and [whether] that counsel’s incompetence blotted out the essence of his defense.” Oesby v. United States, D.C.App., 398 A.2d 1, 4 (1979).

1980Under *503 Angarano a convicted defendant must show two things: “that counsel was grossly incompetent and that counsel’s incompetence blotted out the essence of his defense.” Oesby v. United States, D.C.App., 398 A.2d 1, 4 (1979).

23
Williams v. Gerstenfeldgreen
dc · 1986 · cited in 2 District of Columbia opinions naming this issue, 1990–2006
2 sentences

2006“It is the factual nucleus, not the theory upon which a plaintiff relies, which operates to constitute the cause of action for claim preclusion purposes.” Stutsman, 546 A.2d at 370 ; see also (Arthur) Williams v. Gerstenfeld, 514 A.2d 1172, 1179 (D.C.1986) (“It is irrelevant that the nature of the two proceedings is different; as long as the parties are the same, and the essence of the claim and evidence necessary to establish it are the same, res judicata applies.”).

1990It does not matter that the earlier and later proceedings differ in nature: “as long as the parties are the same, and the essence of the claim and evidence necessary to establish it are the same, res judicata applies.” Williams v. Gerstenfeld, 514 A.2d 1172, 1179 (D.C.1986) (citation omitted).

22
Calomiris v. Calomirisgreen
dc · 2010 · cited in 2 District of Columbia opinions naming this issue, 2018–2024
2 sentences

2024Whether a “present claim is the same” for purposes of res judicata, id., depends “not [on] the theory on which a plaintiff relies” but on whether the claims share “a common nucleus of facts,” Faulkner, 618 A.2d at 183 (internal quotation marks omitted); see also Whiting v. Wells Fargo Bank, N.A., 230 A.3d 916 , 927 (D.C. 2020) (“It does not matter that the earlier and later proceedings differ in nature: as long as . . . the essence of the claim and evidence necessary to establish it are the same . . . .” (internal quotation marks omitted)).

2018"In determining whether res judicata applies, we consider (1) whether the claim was adjudicated finally in the first action; (2) whether the present claim is the same as the claim which was raised or which might have been raised in the prior proceeding; and (3) whether the party against whom the plea is asserted was a party or in privity with a party in the prior case." Calomiris v. Calomiris , 3 A.3d 1186 , 1190 (D.C. 2010) (internal quotation marks and alterations omitted).

12
Faulkner v. Government Employees Insurance Co.green
dc · 1992 · cited in 1 District of Columbia opinions naming this issue, 2024–2024
1 sentence

2024Whether a “present claim is the same” for purposes of res judicata, id., depends “not [on] the theory on which a plaintiff relies” but on whether the claims share “a common nucleus of facts,” Faulkner, 618 A.2d at 183 (internal quotation marks omitted); see also Whiting v. Wells Fargo Bank, N.A., 230 A.3d 916 , 927 (D.C. 2020) (“It does not matter that the earlier and later proceedings differ in nature: as long as . . . the essence of the claim and evidence necessary to establish it are the same . . . .” (internal quotation marks omitted)).

11
Smith v. Jenkinsgreen
dc · 1989 · cited in 1 District of Columbia opinions naming this issue, 2024–2024
1 sentence

2024In other words, “a second action may be precluded on the ground that the same claim or cause of action was advanced in the first action even though a different source of law is involved,” Smith v. Jenkins, 562 A.2d 610, 614 (D.C. 1989) (quoting 18 Charles Alan Wright, Arthur R.

11
Ingram v. United Statesgreen
dc · 1991 · cited in 1 District of Columbia opinions naming this issue, 2003–2003
2 sentences

2003See, e.g., Ingram v. United States, 592 A.2d 992, 1005 (D.C.1991).

2003See, e.g., Ingram v. United States, 592 A.2d 992, 1005 (D.C.1991).

11
Ceco Corp. v. Colemangreen
dc · 1982 · cited in 1 District of Columbia opinions naming this issue, 1987–1987
2 sentences

1987In such circumstances, the fact that a third person does act improperly is not an intelligible reason for excusing the defendant.” Ross, supra, 78 U.S.App.D.C. at 219 , 139 F.2d at 16 ; accord, Gaither, supra, 131 U.S.App.D.C. at 221 , 404 F.2d at 221 ; see also Ceco, supra, 441 A.2d at 944 (“The negligent act of a third party will operate as a superseding cause of the plaintiff’s harm only where the original actor should not have anticipated that act.”).

1987In such circumstances, the fact that a third person does act improperly is not an intelligible reason for excusing the defendant.” Ross, supra, 78 U.S.App.D.C. at 219 , 139 F.2d at 16 ; accord, Gaither, supra, 131 U.S.App.D.C. at 221 , 404 F.2d at 221 ; see also Ceco, supra, 441 A.2d at 944 (“The negligent act of a third party will operate as a superseding cause of the plaintiff’s harm only where the original actor should not have anticipated that act.”).

11
Frederick O. Gaither v. Charles R. Myers and American Motorist Insurance Co., a Corporationgreen
cadc · 1968 · cited in 1 District of Columbia opinions naming this issue, 1987–1987
2 sentences

1987In such circumstances, the fact that a third person does act improperly is not an intelligible reason for excusing the defendant.” Ross, supra, 78 U.S.App.D.C. at 219 , 139 F.2d at 16 ; accord, Gaither, supra, 131 U.S.App.D.C. at 221 , 404 F.2d at 221 ; see also Ceco, supra, 441 A.2d at 944 (“The negligent act of a third party will operate as a superseding cause of the plaintiff’s harm only where the original actor should not have anticipated that act.”).

1987In such circumstances, the fact that a third person does act improperly is not an intelligible reason for excusing the defendant.” Ross, supra, 78 U.S.App.D.C. at 219 , 139 F.2d at 16 ; accord, Gaither, supra, 131 U.S.App.D.C. at 221 , 404 F.2d at 221 ; see also Ceco, supra, 441 A.2d at 944 (“The negligent act of a third party will operate as a superseding cause of the plaintiff’s harm only where the original actor should not have anticipated that act.”).

11
World Wide Imp. Car Co., Ltd. v. Savings Bk. of Baltimoregreen
mdctspecapp · 1979 · cited in 1 District of Columbia opinions naming this issue, 1981–1981
2 sentences

1981See World Wide Imported Car Co., Ltd. v. Savings Bank of Baltimore, 41 Md.App. 263, 270-72 , 396 A.2d 547, 551 (1979), quoting *485 Klein v. Whitehead, 40 Md.App. 1 , 389 A.2d 374 (1978).

1981See World Wide Imported Car Co., Ltd. v. Savings Bank of Baltimore, 41 Md.App. 263, 270-72 , 396 A.2d 547, 551 (1979), quoting *485 Klein v. Whitehead, 40 Md.App. 1 , 389 A.2d 374 (1978).

11
Klein v. Whiteheadgreen
mdctspecapp · 1978 · cited in 1 District of Columbia opinions naming this issue, 1981–1981
2 sentences

1981See World Wide Imported Car Co., Ltd. v. Savings Bank of Baltimore, 41 Md.App. 263, 270-72 , 396 A.2d 547, 551 (1979), quoting *485 Klein v. Whitehead, 40 Md.App. 1 , 389 A.2d 374 (1978).

1981See World Wide Imported Car Co., Ltd. v. Savings Bank of Baltimore, 41 Md.App. 263, 270-72 , 396 A.2d 547, 551 (1979), quoting *485 Klein v. Whitehead, 40 Md.App. 1 , 389 A.2d 374 (1978).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

CaseCitedYears
Angarano v. United States green
dc · 1974
2 sentences

1983Appellant’s motion was denied without a hearing on the grounds that (1) the claims of ineffective assistance of counsel did not meet the standards of Angarano v. United States, D.C.App., 312 A.2d 295 (1973), reh’g *824 denied, 329 A.2d 453 (1974), and (2) the submission of tape recorded instructions to the jury for use in its deliberations was proper as it had recently been expressly upheld in an unpublished opinion of this court.

1979Oesby *1244 v. United States, D.C.App., 398 A.2d 1 (1977); Woody v. United States, D.C.App., 369 A.2d 592 (1977); Angarano v. United States, D.CApp., 312 A.2d 395 (1973), petition for reconsideration denied, 329 A.2d 453 (1974) (en banc).

31979–1983
Angarano v. United States green
dc · 1973
2 sentences

1983Appellant’s motion was denied without a hearing on the grounds that (1) the claims of ineffective assistance of counsel did not meet the standards of Angarano v. United States, D.C.App., 312 A.2d 295 (1973), reh’g *824 denied, 329 A.2d 453 (1974), and (2) the submission of tape recorded instructions to the jury for use in its deliberations was proper as it had recently been expressly upheld in an unpublished opinion of this court.

1979App., 312 A.2d 295 (1973), rehearing en banc denied, 329 A.2d 453 (1974).

21979–1983
Washington Medical Center, Inc. v. Holle green
dc · 1990
1 sentence

2020“It does not matter that the earlier and later proceedings differ in nature: ‘as long as the parties are the same, and the essence of the claim and evidence necessary to establish it are the same, res judicata applies.’” Id.

12020–2020
Sinai v. Polinger Co. green
dc · 1985
1 sentence

2007“Here, the trial court’s instructions on contributory negligence ... encompassed [the very activity] that the defense assigned as evidence that [Ms. Jones] had assumed the risk.” Sinai, 498 A.2d at 526 .

12007–2007
Stutsman v. Kaiser Foundation Health Plan of Mid-Atlantic States, Inc. green
dc · 1988
1 sentence

2006“It is the factual nucleus, not the theory upon which a plaintiff relies, which operates to constitute the cause of action for claim preclusion purposes.” Stutsman, 546 A.2d at 370 ; see also (Arthur) Williams v. Gerstenfeld, 514 A.2d 1172, 1179 (D.C.1986) (“It is irrelevant that the nature of the two proceedings is different; as long as the parties are the same, and the essence of the claim and evidence necessary to establish it are the same, res judicata applies.”).

12006–2006
Vereen v. Clayborne green
dc · 1993
1 sentence

2005Vereen, 623 A.2d at 1194 .

12005–2005
Mitchell v. Forsyth green
scotus · 1985
2 sentences

2001The essence of an immunity from suit is “an entitlement not to stand trial or face the other burdens of litigation.” Mitchell, 472 U.S. at 526 , 105 S.Ct. 2806 .

2001The essence of an immunity from suit is “an entitlement not to stand trial or face the other burdens of litigation.” Mitchell, 472 U.S. at 526 , 105 S.Ct. 2806 .

12001–2001
Robinson v. Smith green
dc · 1996
1 sentence

1998We further observed that “the essence of the hearing examiner’s statements is that there were inconsistencies in petitioner’s story.” Id. at 486 n. 4.

11998–1998
Ross v. Hartman green
cadc · 1943
2 sentences

1987In such circumstances, the fact that a third person does act improperly is not an intelligible reason for excusing the defendant.” Ross, supra, 78 U.S.App.D.C. at 219 , 139 F.2d at 16 ; accord, Gaither, supra, 131 U.S.App.D.C. at 221 , 404 F.2d at 221 ; see also Ceco, supra, 441 A.2d at 944 (“The negligent act of a third party will operate as a superseding cause of the plaintiff’s harm only where the original actor should not have anticipated that act.”).

1987In such circumstances, the fact that a third person does act improperly is not an intelligible reason for excusing the defendant.” Ross, supra, 78 U.S.App.D.C. at 219 , 139 F.2d at 16 ; accord, Gaither, supra, 131 U.S.App.D.C. at 221 , 404 F.2d at 221 ; see also Ceco, supra, 441 A.2d at 944 (“The negligent act of a third party will operate as a superseding cause of the plaintiff’s harm only where the original actor should not have anticipated that act.”).

11987–1987
Richardson Adoption Case neutral
pa · 1973
1 sentence

1979Oesby *1244 v. United States, D.C.App., 398 A.2d 1 (1977); Woody v. United States, D.C.App., 369 A.2d 592 (1977); Angarano v. United States, D.CApp., 312 A.2d 395 (1973), petition for reconsideration denied, 329 A.2d 453 (1974) (en banc).

11979–1979
Woody v. United States green
dc · 1977
1 sentence

1979Oesby *1244 v. United States, D.C.App., 398 A.2d 1 (1977); Woody v. United States, D.C.App., 369 A.2d 592 (1977); Angarano v. United States, D.CApp., 312 A.2d 395 (1973), petition for reconsideration denied, 329 A.2d 453 (1974) (en banc).

11979–1979
McMann v. Richardson green
scotus · 1970
2 sentences

1977The right to effective assistance of counsel attaches before trial, McMann v. Richardson, 397 U.S. 759 , 771 n. 14, 90 S.Ct. 1441 , 25 L.Ed.2d 763 (1970), and extends through the post-trial proceedings; consequently, we examine trial counsel’s conduct chronologically from the time of the pretrial suppression hearing. 4 At that hearing, counsel called as a witness the owner of the car in which appellants were riding, apparently for the purpose of testifying that he saw no bullet holes in the windshield of the automobile.

1977The right to effective assistance of counsel attaches before trial, McMann v. Richardson, 397 U.S. 759 , 771 n. 14, 90 S.Ct. 1441 , 25 L.Ed.2d 763 (1970), and extends through the post-trial proceedings; consequently, we examine trial counsel’s conduct chronologically from the time of the pretrial suppression hearing. 4 At that hearing, counsel called as a witness the owner of the car in which appellants were riding, apparently for the purpose of testifying that he saw no bullet holes in the windshield of the automobile.

11977–1977

Statutes the citing opinions construe

DC § D.C. Code § 23-110 (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

PA 275 (1927–2026) IL 97 (1928–2026) CA 97 (1919–2025) NJ 95 (1937–2026) NY 83 (1908–2025) TX 75 (1941–2025) OH 43 (1901–2025) MI 41 (1936–2025) OR 39 (1899–2022) IN 34 (1932–2025) VA 32 (1896–2025) CT 31 (1933–2025) FL 31 (1961–2024) WA 30 (1913–2026) NC 27 (1931–2025) ME 26 (1995–2024) MD 25 (1968–2025) MA 24 (1960–2025) DC 22 (1977–2024) NE 20 (1895–2024) MO 19 (1941–2024) WI 19 (1909–2025) AZ 19 (1922–2026) WV 19 (1894–2024) GA 18 (1951–2016) NM 17 (1967–2016) AL 15 (1904–2004) LA 14 (1932–2015) NH 14 (1987–2015) CO 14 (1910–2026) DE 13 (1951–2024) IA 12 (1904–2023) MT 11 (1916–2005) TN 10 (1948–2022) KS 10 (1934–2023) KY 10 (1923–2025) VT 8 (1857–2023) RI 7 (1962–2026) AR 7 (1921–2005) ID 6 (1971–1991) OK 6 (1981–2013) AK 6 (1978–1997) MN 6 (1920–2019) HI 5 (1991–2009) WY 5 (1967–2007) SD 5 (1990–2011) PR 3 (1954–1957) MS 3 (1902–2019) UT 2 (1942–2015)

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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