need standard (Washington) · Go Syfert
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need standard in Washington

22 Washington opinions name it 2 courts 1944–2025 2 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 (10)

CaseFollowedCited
District of Columbia v. Hellergreen
scotus · 2008 · cited in 4 Washington opinions naming this issue, 2013–2025
2 sentences

2025Ed. 1206 (1939)), 628, 636. 3 Heller, 554 U.S. at 582 ; McDonald, 561 U.S. at 780 (plurality portion). 1 State v. Gator’s Customs Guns et al., No. 102940-3 (Gordon McCloud, J., dissenting) the highest in “the home, where the need for defense of self, family, and property is most acute.” Heller, 554 U.S. at 628 ; McDonald, 561 U.S. at 780 (plurality portion).

2025Ed. 1206 (1939)), 628, 636. 3 Heller, 554 U.S. at 582 ; McDonald, 561 U.S. at 780 (plurality portion). 1 State v. Gator’s Customs Guns et al., No. 102940-3 (Gordon McCloud, J., dissenting) the highest in “the home, where the need for defense of self, family, and property is most acute.” Heller, 554 U.S. at 628 ; McDonald, 561 U.S. at 780 (plurality portion).

14
Dunner v. McLaughlingreen
wash · 1984 · cited in 2 Washington opinions naming this issue, 2005–2005
2 sentences

2005As this court observed in Dunner , “[bjalanced against the individual’s liberty interest is the State’s legitimate interest under its parens patriae powers in providing care to its citizens who are unable, because of emotional disorders, to care for themselves,” along with the State’s interest under its police powers in “protecting] the community from the dangerous tendencies of some who are mentally ill.” 100 Wn.2d at 839 (emphasis added). ¶60 Responding to due process challenges by balancing the private and governmental interests, courts have recognized the need for a standard higher than th

2005As this court observed in Dunner , "[b]alanced against the individual's liberty interest is the State's legitimate interest under its parens patriae powers in providing care to its citizens who are unable, because of emotional disorders, to care for themselves," along with the State's interest under its police powers in " protect [ ing ] the community from the dangerous tendencies of some who are mentally ill." 100 Wash.2d at 839 , 676 P.2d 444 (emphasis added). ¶ 60 Responding to due process challenges by balancing the private and governmental interests, courts have recognized the need for a

12
McDonald v. City of Chicagogreen
scotus · 2010 · cited in 1 Washington opinions naming this issue, 2025–2025
2 sentences

2025Ed. 1206 (1939)), 628, 636. 3 Heller, 554 U.S. at 582 ; McDonald, 561 U.S. at 780 (plurality portion). 1 State v. Gator’s Customs Guns et al., No. 102940-3 (Gordon McCloud, J., dissenting) the highest in “the home, where the need for defense of self, family, and property is most acute.” Heller, 554 U.S. at 628 ; McDonald, 561 U.S. at 780 (plurality portion).

2025Ed. 1206 (1939)), 628, 636. 3 Heller, 554 U.S. at 582 ; McDonald, 561 U.S. at 780 (plurality portion). 1 State v. Gator’s Customs Guns et al., No. 102940-3 (Gordon McCloud, J., dissenting) the highest in “the home, where the need for defense of self, family, and property is most acute.” Heller, 554 U.S. at 628 ; McDonald, 561 U.S. at 780 (plurality portion).

11
State v. Jorgensongreen
wash · 2013 · cited in 1 Washington opinions naming this issue, 2021–2021
1 sentence

2021See Jorgenson, 179 Wn.2d at 158 (“Jorgenson also possessed the firearms while driving, rather than in the home, ‘where the need for defense of self, family, and property is most acute.’” (quoting Heller, 554 U.S. at 628 )); cf. Young v. State, ___ F.3d ___, 2021 WL 1114180 , at *35 (9th Cir. Mar. 24, 2021) (“Indeed, we can find no general right to carry arms into the public square for self-defense.”).

11
Gebser v. Lago Vista Independent School Districtgreen
scotus · 1998 · cited in 1 Washington opinions naming this issue, 2015–2015
1 sentence

2015Thus, in Gebser , the Court required “that ‘the receiving entity of federal funds [have] notice that it will be liable for a monetary award’ ” before it could be subjected to liability for damages. 524 U.S. at 287 (alteration in original) (quoting Franklin, 503 U.S. at 74 ).

11
Southern Railway Company v. Carl Talmadge Lanhamgreen
ca5 · 1969 · cited in 1 Washington opinions naming this issue, 2006–2006
1 sentence

2006COG cites to Southern Railway v. Lanham, 403 F.2d 119, 123 (5th Cir. 1968), in which a railroad’s own claims agent gathered witness statements within days of an accident.

11
Greenen v. Board of Accountancygreen
washctapp · 2005 · cited in 1 Washington opinions naming this issue, 2005–2005
1 sentence

2005See Greenen, 126 Wn.

11
State v. Williamsgreen
washctapp · 2001 · cited in 1 Washington opinions naming this issue, 2003–2003
1 sentence

2003See State v. Williams, 104 Wash.App. 516 , 17 P.3d 648 (2001) (holding that the trial court did not abuse its discretion in granting five continuances due to the deputy prosecutor's unavailability and the need for defense counsel to prepare).

11
State v. Williamsgreen
washctapp · 2001 · cited in 1 Washington opinions naming this issue, 2003–2003
1 sentence

2003See State v. Williams, 104 Wash.App. 516 , 17 P.3d 648 (2001) (holding that the trial court did not abuse its discretion in granting five continuances due to the deputy prosecutor's unavailability and the need for defense counsel to prepare).

11
Republic Gear Company v. Borg-Warner Corporationgreen
ca2 · 1967 · cited in 1 Washington opinions naming this issue, 1985–1985
2 sentences

1985Republic Gear Co. v. Borg-Warner Corp., 381 F.2d 551, 557 (2d Cir.1967); Alltmont v. United States, 177 F.2d 971 (3d Cir.1949), cert. denied, 339 U.S. 967 (1950).

1985Republic Gear Co. v. Borg-Warner Corp., 381 F.2d 551, 557 (2d Cir. 1967); Alltmont v. United States, 177 F.2d 971 (3d Cir. 1949), cert. denied, 339 U.S. 967 (1950).

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
Franklin v. Gwinnett County Public Schools green
scotus · 1992
2 sentences

2015Thus, in Gebser , the Court required “that ‘the receiving entity of federal funds [have] notice that it will be liable for a monetary award’ ” before it could be subjected to liability for damages. 524 U.S. at 287 (alteration in original) (quoting Franklin, 503 U.S. at 74 ).

2015Thus, in Gebser, the Court required "that 'the receiving entity of federal funds [have] notice that it will be liable for a monetary award'" before it could be subjected to liability for damages. 524 U.S. -36- No. 71419-8-1/37 at 287 (quoting Franklin, 503 U.S. at 74 ).

22015–2015
Guardians Assn. v. Civil Serv. Comm'n of New York City green
scotus · 1983
2 sentences

2015In fashioning a remedy for the implied private right of action for the recovery of money damages, the Court perceived the need for a standard that would ensure that recipients of federal funds would be held liable for money damages only upon receiving proper notice, given that “the receipt of federal funds under typical Spending Clause legislation is a consensual matter.” Guardians, 463 U.S. at 596 .

2015In fashioning a remedy for the implied private right of action for the recovery of money damages, the Court perceived the need for a standard that would ensure that recipients of federal funds would be held liable for money damages only upon receiving proper notice, given that "the receipt of federal funds under typical Spending Clause legislation is a consensual matter." Guardians, 463 U.S. at 596 .

22015–2015
State v. Brightman green
wash · 2005
2 sentences

2009This argument fails because a trial court's sua sponte decision to close public hearings triggers the need for a Bone-Club analysis. [4] E.g., Brightman, 155 Wash.2d at 511 , 122 P.3d 150 . ¶ 17 The State also argues that Heath waived her right to public hearings on the disputed issues.

2009This argument fails because a trial court’s sua sponte decision to close public hearings triggers the need for a Bone-Club analysis. 4 E.g., Brightman, 155 Wn.2d at 511 . ¶17 The State also argues that Heath waived her right to public hearings on the disputed issues.

22009–2009
Addington v. Texas green
scotus · 1979
2 sentences

2005In April 1979, the United States Supreme Court held that, in civil proceedings to commit an individual to a state mental hospital for an indefinite period of time, “the ‘clear and convincing’ standard ... is required to meet due process guarantees.” Addington v. Texas, 441 U.S. 418, 433 , 99 S. Ct. 1804 , 60 L.

2005In April 1979, the United States Supreme Court held that, in civil proceedings to commit an individual to a state mental hospital for an indefinite period of time, “the ‘clear and convincing’ standard ... is required to meet due process guarantees.” Addington v. Texas, 441 U.S. 418, 433 , 99 S. Ct. 1804 , 60 L.

22005–2005
Caetano v. Massachusetts green
scotus · 2016
1 sentence

2021And in Caetano, the Court did not rule on the constitutionality of the law banning stun guns; rather, it held that the lower court erred by concluding that stun guns were not constitutionally protected arms and remanded the issue. 136 S. Ct. 1027 .

12021–2021
Parkins v. Van Doren Sales, Inc. green
washctapp · 1986
1 sentence

2019App. 19, 27-29 , 724 P.2d 389 (1986). 23 No. 77235-0-1/24 alleged defects in the window's design and construction, the need for warnings related to the window, what consumers expect regarding a window, and causation.

12019–2019
Musselman v. DSHS neutral
washctapp · 2006
1 sentence

2017RCW 34.05.370(2).” Id.

12017–2017
State v. Brightman green
wash · 2005
1 sentence

2009This argument fails because a trial court's sua sponte decision to close public hearings triggers the need for a Bone-Club analysis. [4] E.g., Brightman, 155 Wash.2d at 511 , 122 P.3d 150 . ¶ 17 The State also argues that Heath waived her right to public hearings on the disputed issues.

12009–2009
State v. Platz green
washctapp · 1982
2 sentences

1999Police need not make a showing of absolute necessity; the need requirement is interpreted in a “common sense fashion.” State v. Platz, 33 Wn.

1999App. 345, 349-50 , 655 P.2d 710 (1982).

11999–1999
Park Hill Corp. v. Sharp green
washctapp · 1991
1 sentence

1997Judgment as a UFTA Remedy Christensen contends that the trial court erred in entering judgment against CGI, arguing that the only remedy available here is to void the offending transfers, citing Park Hill Corp. v. Don Sharp, Inc., 60 Wn.

11997–1997
Matter of Marriage of McDaniel neutral
washctapp · 1997
1 sentence

1997This section shall not be construed to require monthly substantiation of income. 2 In re Marriage of McDaniel, 87 Wn.

11997–1997
Heidebrink v. Moriwaki green
wash · 1985
1 sentence

1993(Citations omitted.) Heidebrink, 104 Wn.2d at 401 .

11993–1993
Alltmont v. United States green
ca3 · 1950
2 sentences

1985Republic Gear Co. v. Borg-Warner Corp., 381 F.2d 551, 557 (2d Cir.1967); Alltmont v. United States, 177 F.2d 971 (3d Cir.1949), cert. denied, 339 U.S. 967 (1950).

1985Republic Gear Co. v. Borg-Warner Corp., 381 F.2d 551, 557 (2d Cir. 1967); Alltmont v. United States, 177 F.2d 971 (3d Cir. 1949), cert. denied, 339 U.S. 967 (1950).

11985–1985
Commissioner v. Busch's Kredit Jewelry Co. green
scotus · 1950
2 sentences

1985Republic Gear Co. v. Borg-Warner Corp., 381 F.2d 551, 557 (2d Cir.1967); Alltmont v. United States, 177 F.2d 971 (3d Cir.1949), cert. denied, 339 U.S. 967 (1950).

1985Republic Gear Co. v. Borg-Warner Corp., 381 F.2d 551, 557 (2d Cir. 1967); Alltmont v. United States, 177 F.2d 971 (3d Cir. 1949), cert. denied, 339 U.S. 967 (1950).

11985–1985
Escobedo v. Illinois green
scotus · 1964
1 sentence

1976Ed. 2d 977 , 84 S. Ct. 1758 (1964), the court held that the investigative process becomes accusatorial and the need for warnings is triggered at the moment the inquiry “focuses” on an accused in custody and the questioning is intended to. elicit incriminating statements.

11976–1976
Miranda v. Arizona green
scotus · 1966
2 sentences

1976The decision in Miranda v. Arizona, 384 U.S. 436 , 16 L.

1976The decision in Miranda v. Arizona, 384 U.S. 436 , 16 L.

11976–1976
Shelley v. Norman neutral
wash · 1921
2 sentences

1944Shelley v. Norman, 114 Wash. 381 , 195 Pac. 243 .

1944Shelley v. Norman, 114 Wash. 381 , 195 Pac. 243 .

11944–1944

Statutes the citing opinions construe

WA § Wash. Rev. Code § 34.05.570 (4) USC § 18u.s.c.922 (3) WA § Wash. Rev. Code § 9.41.010 (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

NY 128 (1919–2026) CA 103 (1953–2025) TX 87 (1978–2025) IL 67 (1955–2025) OH 50 (1988–2026) LA 49 (1956–2023) NJ 49 (1960–2026) FL 45 (1973–2019) PA 43 (1951–2024) CT 35 (1973–2024) MI 30 (1970–2025) DC 29 (1978–2024) MA 29 (1895–2025) IN 24 (1976–2020) OR 23 (1985–2025) WA 22 (1944–2025) MO 21 (1982–2024) CO 21 (1984–2025) MD 19 (1988–2024) IA 19 (1960–2025) WI 18 (1975–2023) TN 16 (1978–2024) NM 15 (1980–2023) NC 14 (1982–2025) DE 13 (1990–2025) AZ 13 (1968–2024) KS 12 (1980–2025) ID 11 (1972–2021) MS 9 (1980–2017) WV 9 (1975–2017) VA 9 (1967–2013) AK 9 (1982–2025) NH 9 (1979–2018) AL 9 (1994–2016) GA 9 (1925–2025) RI 8 (1979–2010) SC 8 (2007–2011) ME 8 (1978–2025) MN 7 (1966–2024) UT 7 (1995–2022) KY 7 (1985–2025) HI 6 (2000–2020) WY 6 (1966–2006) VT 5 (1991–2018) OK 5 (1988–2023) NE 4 (1998–2022) NV 4 (2016–2017) MT 4 (1989–2015) AR 4 (1982–2020) SD 2 (2005–2025) ND 2 (1979–1983)

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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