negligent supervision claim in Washington

21 Washington opinions name it 2 courts 1990–2025 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 (19)

Case	Followed	Cited
Niece v. Elmview Group Homegreen wash · 1997 · cited in 6 Washington opinions naming this issue, 2002–2018 2 sentences 2018Niece, 131 Wash.2d at 51 -52 , 929 P.2d 420 . ¶ 40 Here, Anderson appears to confuse the standard for a negligent supervision claim with the standard for a vicarious liability claim. 2018The dissent collapses the elements required for a negligent supervision claim and a negligent protection claim-the very danger that we recognized in Niece . 131 Wash.2d at 52 , 929 P.2d 420 ("The same evidence that would establish [the employer's] negligence under a broad theory of negligent supervision will also establish its negligence in failing to protect [a victim] from all foreseeable harms. [The] cause of action for negligent supervision thus collapses into [the] negligence claim based on [the employer's] breach of its special relationship duty of care.").	4	6
Petersen v. Stategreen wash · 1983 · cited in 4 Washington opinions naming this issue, 2002–2003 2 sentences 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 , 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 ,	3	4
Niece v. Elmview Group Homegreen wash · 1997 · cited in 5 Washington opinions naming this issue, 2002–2018 2 sentences 2018Niece, 131 Wash.2d at 51 -52 , 929 P.2d 420 . ¶ 40 Here, Anderson appears to confuse the standard for a negligent supervision claim with the standard for a vicarious liability claim. 2018We declined to address the merits of the plaintiff's negligent supervision claim because her broad theory of negligent supervision "also establishe[d] ... negligence in failing to protect [the plaintiff] from all foreseeable harms." Id.	1	5
Taggart v. Stategreen wash · 1992 · cited in 4 Washington opinions naming this issue, 2002–2003 2 sentences 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 , 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 ,	1	4
Bell v. Stategreen wash · 2002 · cited in 3 Washington opinions naming this issue, 2003–2003 2 sentences 2003Even if a negligent supervision claim exists in the first-time offender/community supervision context, no instruction informed the jury in this case of the appropriate legal cause standard clarified in Bell: “[a] plaintiff in a negligent parole supervision action must show not only inadequate supervision, but must also carry the burden to demonstrate the damage sustained by the plaintiff would have been avoided but for the inadequate supervision.” 147 Wn.2d at 179 (emphasis added). 2003Even if a negligent supervision claim exists in the first-time offender/community supervision context, no instruction informed the jury in this case of the appropriate legal cause standard clarified in Bell: "[a] plaintiff in a negligent parole supervision action must show not only inadequate supervision, but must also carry the burden to demonstrate the damage sustained by the plaintiff would have been avoided but for the inadequate supervision." 147 Wash.2d at 179 , 52 P.3d *1285 503 (emphasis added).	1	3
Peck v. Siaugreen washctapp · 1992 · cited in 2 Washington opinions naming this issue, 2002–2018 2 sentences 2018See, e.g., Thompson v. Everett Clinic, 71 Wash. App. 548 , 860 P.2d 1054 (1993), review denied 123 Wash.2d 1027 , 877 P.2d 694 (1994) ; Peck, 65 Wash. App. 285 , 827 P.2d 1108 . ¶ 49 This rule does not give "a free pass" to school districts when different employees cause harm to students. 2018See, e.g., Thompson v. Everett Clinic, 71 Wash. App. 548 , 860 P.2d 1054 (1993), review denied 123 Wash.2d 1027 , 877 P.2d 694 (1994) ; Peck, 65 Wash. App. 285 , 827 P.2d 1108 . ¶ 49 This rule does not give "a free pass" to school districts when different employees cause harm to students.	1	2
Doe v. Evansgreen fladistctapp · 1998 · cited in 2 Washington opinions naming this issue, 2002–2002 2 sentences 2002See Doe v. Evans, 718 So. 2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis. 2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court’s decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop, 1997 ME 63 , 692 A.2d 441 (holding negligent supervision claim against church barred by First Amendment). 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 ,	1	2
L.L.N. v. Claudergreen wis · 1997 · cited in 2 Washington opinions naming this issue, 2002–2002 2 sentences 2002See Doe v. Evans, 718 So. 2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis. 2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court’s decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop, 1997 ME 63 , 692 A.2d 441 (holding negligent supervision claim against church barred by First Amendment). 2002See Doe v. Evans, 718 So. 2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis. 2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court’s decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop, 1997 ME 63 , 692 A.2d 441 (holding negligent supervision claim against church barred by First Amendment).	1	2
C.J.C. v. Corporation of Catholic Bishopgreen wash · 1999 · cited in 2 Washington opinions naming this issue, 2002–2002 2 sentences 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 , 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 ,	1	2
Thompson v. Everett Clinicgreen washctapp · 1993 · cited in 1 Washington opinions naming this issue, 2018–2018 2 sentences 2018See, e.g., Thompson v. Everett Clinic, 71 Wash. App. 548 , 860 P.2d 1054 (1993), review denied 123 Wash.2d 1027 , 877 P.2d 694 (1994) ; Peck, 65 Wash. App. 285 , 827 P.2d 1108 . ¶ 49 This rule does not give "a free pass" to school districts when different employees cause harm to students. 2018See, e.g., Thompson v. Everett Clinic, 71 Wash. App. 548 , 860 P.2d 1054 (1993), review denied 123 Wash.2d 1027 , 877 P.2d 694 (1994) ; Peck, 65 Wash. App. 285 , 827 P.2d 1108 . ¶ 49 This rule does not give "a free pass" to school districts when different employees cause harm to students.	1	1
Gilliam v. Department of Social & Health Servicesgreen washctapp · 1998 · cited in 1 Washington opinions naming this issue, 2011–2011 1 sentence 2011See Niece, 131 Wn.2d at 48 . 89 Wn.	1	1
Carlsen v. Wackenhut Corporationgreen washctapp · 1994 · cited in 1 Washington opinions naming this issue, 2002–2002 2 sentences 2002Compare Carlsen v. Wackenhut Corp., 73 Wash.App. 247, 256 , 868 P.2d 882 , review denied, 124 Wash.2d 1022 , 881 P.2d 255 (1994) (employer liable for security guard's attempted rape if employer knew of or should have known of guard's violent propensities and nevertheless conferred position of authority and responsibility), with Peck v. Siau, 65 Wash.App. 285, 289, 292-94 , 827 P.2d 1108 , review denied, 120 Wash.2d 1005 , 838 P.2d 1142 (1992) (school not liable for teacher's off campus sexual assault of student where it did not know, nor reasonably should have known, of the risk posed by teach 2002Compare Carlsen v. Wackenhut Corp., 73 Wash.App. 247, 256 , 868 P.2d 882 , review denied, 124 Wash.2d 1022 , 881 P.2d 255 (1994) (employer liable for security guard's attempted rape if employer knew of or should have known of guard's violent propensities and nevertheless conferred position of authority and responsibility), with Peck v. Siau, 65 Wash.App. 285, 289, 292-94 , 827 P.2d 1108 , review denied, 120 Wash.2d 1005 , 838 P.2d 1142 (1992) (school not liable for teacher's off campus sexual assault of student where it did not know, nor reasonably should have known, of the risk posed by teach	1	1
In Re Halversongreen wash · 2000 · cited in 1 Washington opinions naming this issue, 2002–2002	1	1
In re the Disciplinary Proceeding against Halversongreen wash · 2000 · cited in 1 Washington opinions naming this issue, 2002–2002 1 sentence 2002Compare Carlsen v. Wackenhut Corp., 73 Wash.App. 247, 256 , 868 P.2d 882 , review denied, 124 Wash.2d 1022 , 881 P.2d 255 (1994) (employer liable for security guard's attempted rape if employer knew of or should have known of guard's violent propensities and nevertheless conferred position of authority and responsibility), with Peck v. Siau, 65 Wash.App. 285, 289, 292-94 , 827 P.2d 1108 , review denied, 120 Wash.2d 1005 , 838 P.2d 1142 (1992) (school not liable for teacher's off campus sexual assault of student where it did not know, nor reasonably should have known, of the risk posed by teach	1	1
CJC v. Corporation of Catholic Bishopgreen wash · 1999 · cited in 1 Washington opinions naming this issue, 2002–2002	1	1
Shepard v. Mielkegreen washctapp · 1994 · cited in 1 Washington opinions naming this issue, 2002–2002 2 sentences 2002Compare Carlsen v. Wackenhut Corp., 73 Wash.App. 247, 256 , 868 P.2d 882 , review denied, 124 Wash.2d 1022 , 881 P.2d 255 (1994) (employer liable for security guard's attempted rape if employer knew of or should have known of guard's violent propensities and nevertheless conferred position of authority and responsibility), with Peck v. Siau, 65 Wash.App. 285, 289, 292-94 , 827 P.2d 1108 , review denied, 120 Wash.2d 1005 , 838 P.2d 1142 (1992) (school not liable for teacher's off campus sexual assault of student where it did not know, nor reasonably should have known, of the risk posed by teach 2002Compare Carlsen v. Wackenhut Corp., 73 Wash.App. 247, 256 , 868 P.2d 882 , review denied, 124 Wash.2d 1022 , 881 P.2d 255 (1994) (employer liable for security guard's attempted rape if employer knew of or should have known of guard's violent propensities and nevertheless conferred position of authority and responsibility), with Peck v. Siau, 65 Wash.App. 285, 289, 292-94 , 827 P.2d 1108 , review denied, 120 Wash.2d 1005 , 838 P.2d 1142 (1992) (school not liable for teacher's off campus sexual assault of student where it did not know, nor reasonably should have known, of the risk posed by teach	1	1
American Home Assurance Co. v. Cohengreen wash · 1994 · cited in 1 Washington opinions naming this issue, 2002–2002	1	1
Norton v. Paynegreen · 1929 · cited in 1 Washington opinions naming this issue, 1991–1991	1	1
BC Tire Corp. v. GTE Directories Corp.green washctapp · 1986 · cited in 1 Washington opinions naming this issue, 1990–1990	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (20)

Case	Cited	Years
Wheeler v. Catholic Archdiocese green washctapp · 1992 2 sentences 2000Id. at 566-68 . 2000Id. at 566-68 , 829 P.2d 196 .	3	1994–2000
Swanson v. Roman Catholic Bishop of Portland green me · 1997 2 sentences 2002See Doe v. Evans, 718 So. 2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis. 2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court’s decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop, 1997 ME 63 , 692 A.2d 441 (holding negligent supervision claim against church barred by First Amendment). 2002See Doe v. Evans, 718 So. 2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis. 2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court’s decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop, 1997 ME 63 , 692 A.2d 441 (holding negligent supervision claim against church barred by First Amendment).	2	2002–2002
LaPlant v. Snohomish County green washctapp · 2011 2 sentences 2025The court first noted that a negligent supervision claim “requires a plaintiff to show that an employee acted outside the scope of [their] employment.” Id. at 479 . 2025“But when an employee commits negligence within the scope of employment, a different theory of liability—vicarious liability—applies.” Id. at 479-80 .	1	2025–2025
Bishop v. State green washctapp · 1995 1 sentence 2024Clerk’s Papers 16 (emphasis added). 9 Second, regarding LaBounty’s defamation claim, the District notes that she does not identify with specificity any particular statement, and it points to evidence the performance evaluation was not false, including Sewright’s declaration and attached exhibits that establish LaBounty was not present at her assigned class during the 2018-19 school year on numerous occasions. 10 Finally, in defense to LaBounty’s claim of outrage, the District argues that an employer does not owe a duty to provide its employees with a stress-free work environment, citing Bishop	1	2024–2024
Segaline v. Department of Labor & Industries green washctapp · 2013 1 sentence 2017Segaline v. Dep't of Labor & Indus., 176 Wn.	1	2017–2017
Joyce v. Department of Corrections green wash · 2005 1 sentence 2016The court held DOC “assume [s] the duty of supervising an offender’s conduct” and “has the ability to take steps to ensure, as a condition of release, that the offender complies with the conditions of release.” Joyce, 155 Wn.2d at 316 . ¶37 Here, the undisputed facts show that the Browns did not know or could not reasonably have known the essential elements of the negligent supervision claim against DOC until February 2012.	1	2016–2016
Rodriguez v. Perez green washctapp · 2000 1 sentence 2014Rodriguez v. Perez, 99 Wn.	1	2014–2014
Briggs v. Nova Services green washctapp · 2006 1 sentence 2014Briggs v. Nova, 135 Wn.	1	2014–2014
Briggs v. Nova Services green wash · 2009 1 sentence 2011App. 955, 966-67 , 147 P.3d 616 (2006) (“A negligent supervision claim requires showing: (1) an employee acted outside the scope of his or her employment; (2) the employee presented a risk of harm to other employees; (3) the employer knew, or should have known in the exercise of reasonable care, that the employee posed a risk to others; and (4) that the employer’s failure to supervise was the proximate cause of injuries to other employees.”), aff’d, 166 Wn.2d 794 , 213 P.3d 910 (2009).	1	2011–2011
Briggs v. Nova Services green wash · 2009 1 sentence 2011App. 955, 966-67 , 147 P.3d 616 (2006) (“A negligent supervision claim requires showing: (1) an employee acted outside the scope of his or her employment; (2) the employee presented a risk of harm to other employees; (3) the employer knew, or should have known in the exercise of reasonable care, that the employee posed a risk to others; and (4) that the employer’s failure to supervise was the proximate cause of injuries to other employees.”), aff’d, 166 Wn.2d 794 , 213 P.3d 910 (2009).	1	2011–2011
Briggs v. Nova Services green washctapp · 2006 1 sentence 2011App. 955, 966-67 , 147 P.3d 616 (2006) (“A negligent supervision claim requires showing: (1) an employee acted outside the scope of his or her employment; (2) the employee presented a risk of harm to other employees; (3) the employer knew, or should have known in the exercise of reasonable care, that the employee posed a risk to others; and (4) that the employer’s failure to supervise was the proximate cause of injuries to other employees.”), aff’d, 166 Wn.2d 794 , 213 P.3d 910 (2009).	1	2011–2011
La Lone v. Smith green wash · 1951 2 sentences 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 , 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 ,	1	2002–2002
Miller v. U.S. Bank green washctapp · 1994 2 sentences 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 , 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 ,	1	2002–2002
cluster 750720 green ca5 · 1998 2 sentences 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 , 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 ,	1	2002–2002
Germain v. Pullman Baptist Church green washctapp · 1999	1	2002–2002
Bivin v. Wright green illappct · 1995	1	2002–2002
Mains Farm Homeowners Ass'n v. Worthington green · 1993 2 sentences 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 , 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 ,	1	2002–2002
Jones v. Wolf green scotus · 1979 2 sentences 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 , 2002Thomas L.Rev. 31, 43-45. [15] See Doe v. Evans, 718 So.2d 286 (1998) (surveying cases addressing negligent supervision claims and the First Amendment); L.L.N. v. Clauder, 209 Wis.2d 674 , 563 N.W.2d 434 (1997) (reversing a lower court's decision on whether the First Amendment was a bar to a negligent supervision claim); Swanson v. Roman Catholic Bishop of Portland, 692 A.2d 441 (1997) (holding negligent supervision claim against church barred by First Amendment). [16] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [17] C.J.C., 138 Wash.2d at 720 , 985 P.2d 262 . [18] C.J.C., 138 Wash.2d at 727 ,	1	2002–2002
Carey v. Reeve green washctapp · 1989	1	1991–1991
Eldredge v. Kamp Kachess Youth Services, Inc. green wash · 1978	1	1991–1991

Statutes the citing opinions construe

USC § 42u.s.c.1983 (4) WA § Wash. Rev. Code § 49.60.180 (4) WA § Wash. Rev. Code § 49.60.210 (4) WA § Wash. Rev. Code § 5.40.050 (4) WA § Wash. Rev. Code § 69.50.204 (3) WA § Wash. Rev. Code § 69.50.206 (3) WA § Wash. Rev. Code § 7.70.040 (3) WA § Wash. Rev. Code § 70.54.350 (3) WA § Wash. Rev. Code § 9.92.060 (3) WA § Wash. Rev. Code § 9.94A.030 (3) WA § Wash. Rev. Code § 9.94A.650 (3) WA § Wash. Rev. Code § 9A.36.031 (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 43 (1978–2026) WA 21 (1990–2025) IL 18 (1996–2024) WI 15 (1996–2025) OH 14 (1999–2024) MO 14 (2000–2025) CA 10 (1996–2025) IA 10 (2002–2024) AL 9 (1984–2011) TX 8 (2002–2024) GA 8 (1999–2020) ME 8 (2002–2019) KY 8 (2011–2026) MA 8 (1997–2021) FL 7 (1988–2023) LA 6 (2007–2022) WV 6 (2016–2025) OR 6 (1999–2022) PA 6 (2000–2016) VT 6 (2005–2025) MN 5 (1982–2016) NJ 4 (1994–2019) UT 4 (1994–2025) ID 4 (2000–2006) CO 4 (1995–2022) NM 4 (1997–2023) SC 4 (2005–2023) IN 4 (1997–2014) AZ 4 (2003–2018) CT 4 (1999–2015) DC 3 (2003–2015) NC 3 (2015–2020) WY 3 (2012–2025) MI 2 (1986–2001) AR 2 (2003–2006) DE 2 (2018–2024)

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.

← Caselaw search · G Cite Topics · Brief Check

Your account

Appearance