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19 Washington opinions name it 2 courts 1983–2025 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.
| Case | Followed | Cited |
|---|---|---|
In re the Personal Restraint of Callgreen2 sentences2003See Call, 144 Wn.2d at 328 , in which the Supreme Court rejected the State’s invited error argument and considered Call’s petition, noting, “Because there was no apparent affirmative action by Respondent which contributed to the inadvertent error, we conclude he did not invite it.” Call, 144 Wn.2d at 329 . 2003See Call, 144 Wn.2d at 328 , in which the Supreme Court rejected the State’s invited error argument and considered Call’s petition, noting, “Because there was no apparent affirmative action by Respondent which contributed to the inadvertent error, we conclude he did not invite it.” Call, 144 Wn.2d at 329 . | 2 | 4 |
State v. Sweetgreen2 sentences2007See, e.g., Sweet, 90 Wash.2d at 287 , 581 P.2d 579 . [5] It follows that we do not embrace an inadvertent waiver without notice. 2007See, e.g., Sweet, 90 Wn.2d at 287 . 5 It follows that we do not embrace an inadvertent waiver without notice. | 2 | 2 |
In the Matter of Estate of Fostergreen2 sentences2022An inadvertent error in failing to disclose is considered willful because “‘willful’ violation means a violation without a reasonable excuse.”13 Carlson v. Lake Chelan Cmty. Hosp., 116 Wn. App. 718, 737 , 75 P.3d 533 (2003) (internal quotation marks omitted) (quoting In re Estate of Foster, 55 Wn. App. 545, 548 , 779 P.2d 272 (1989)). 13 Carlson concerned sanctions for discovery abuse under CR 26 and CR 37 rather than a CR 60(b)(4) motion to vacate based on discovery misconduct. 116 Wn. App. at 737 . 2022An inadvertent error in failing to disclose is considered willful because “‘willful’ violation means a violation without a reasonable excuse.”13 Carlson v. Lake Chelan Cmty. Hosp., 116 Wn. App. 718, 737 , 75 P.3d 533 (2003) (internal quotation marks omitted) (quoting In re Estate of Foster, 55 Wn. App. 545, 548 , 779 P.2d 272 (1989)). 13 Carlson concerned sanctions for discovery abuse under CR 26 and CR 37 rather than a CR 60(b)(4) motion to vacate based on discovery misconduct. 116 Wn. App. at 737 . | 1 | 6 |
Carlson v. Lake Chelan Community Hospitalgreen2 sentences2022An inadvertent error in failing to disclose is considered willful because “‘willful’ violation means a violation without a reasonable excuse.”13 Carlson v. Lake Chelan Cmty. Hosp., 116 Wn. App. 718, 737 , 75 P.3d 533 (2003) (internal quotation marks omitted) (quoting In re Estate of Foster, 55 Wn. App. 545, 548 , 779 P.2d 272 (1989)). 13 Carlson concerned sanctions for discovery abuse under CR 26 and CR 37 rather than a CR 60(b)(4) motion to vacate based on discovery misconduct. 116 Wn. App. at 737 . 2022An inadvertent error in failing to disclose is considered willful because “‘willful’ violation means a violation without a reasonable excuse.”13 Carlson v. Lake Chelan Cmty. Hosp., 116 Wn. App. 718, 737 , 75 P.3d 533 (2003) (internal quotation marks omitted) (quoting In re Estate of Foster, 55 Wn. App. 545, 548 , 779 P.2d 272 (1989)). 13 Carlson concerned sanctions for discovery abuse under CR 26 and CR 37 rather than a CR 60(b)(4) motion to vacate based on discovery misconduct. 116 Wn. App. at 737 . | 1 | 4 |
Carlson v. Lake Chelan Cmty. Hosp.green1 sentence2004See Roberson v. Perez, 119 Wash.App. 928 , 83 P.3d 1026 (2004). [2] Since these documents and other cited in this opinion were filed under seal, the court will not set forth in detail their contents here. [3] According to the City, this motion did not cite CR 60 as its basis, but we note that it is titled, "Plaintiffs' Motion to Vacate the Verdicts in Favor of Perez, Badgley and the City of Wenatchee with Respect to the Plaintiffs' 42 U.S.C. § 1983 Claims." CP at 2285. [4] CP at 2464. [5] Indeed, this court in Carlson, stated that "even an inadvertent error in failing to disclose an expert has | 1 | 1 |
Roberson v. Perezgreen2 sentences2004See Roberson v. Perez, 119 Wash.App. 928 , 83 P.3d 1026 (2004). [2] Since these documents and other cited in this opinion were filed under seal, the court will not set forth in detail their contents here. [3] According to the City, this motion did not cite CR 60 as its basis, but we note that it is titled, "Plaintiffs' Motion to Vacate the Verdicts in Favor of Perez, Badgley and the City of Wenatchee with Respect to the Plaintiffs' 42 U.S.C. § 1983 Claims." CP at 2285. [4] CP at 2464. [5] Indeed, this court in Carlson, stated that "even an inadvertent error in failing to disclose an expert has 2004See Roberson v. Perez, 119 Wash.App. 928 , 83 P.3d 1026 (2004). [2] Since these documents and other cited in this opinion were filed under seal, the court will not set forth in detail their contents here. [3] According to the City, this motion did not cite CR 60 as its basis, but we note that it is titled, "Plaintiffs' Motion to Vacate the Verdicts in Favor of Perez, Badgley and the City of Wenatchee with Respect to the Plaintiffs' 42 U.S.C. § 1983 Claims." CP at 2285. [4] CP at 2464. [5] Indeed, this court in Carlson, stated that "even an inadvertent error in failing to disclose an expert has | 1 | 1 |
In re the Personal Restraint of Thompsongreen1 sentence2002See also In re Personal Restraint of Thompson, 141 Wash.2d 712, 723-24 , 10 P.3d 380 (2000) (invited error doctrine requires some affirmative, knowing, and voluntary action by the defendant to set up the error). | 1 | 1 |
Personal Restraint of Thompsongreen1 sentence2002See also In re Personal Restraint of Thompson, 141 Wash.2d 712, 723-24 , 10 P.3d 380 (2000) (invited error doctrine requires some affirmative, knowing, and voluntary action by the defendant to set up the error). | 1 | 1 |
Jackson v. Standard Oil Co. of Californiagreen2 sentences1997App. 83, 95 , 505 P.2d 139 (1972), review denied, 82 Wn.2d 1001 (1973). 1997Because the inadvertent error could have been clarified without submitting a brief, we deny Tri-City’s request for attorney fees. 4 This general rule is now subject to so many exceptions that "it can now be said to be 'general’ only in the sense that it is applied where no good reason is found for departing from it.” Restatement (Second) of Torts § 409 cmt. b (1965); see Jackson v. Standard Oil Co., 8 Wn. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Gammon v. Clark Equipment Co.
green
2 sentences2003Co., 38 Wash.App. 274, 280 , 686 P.2d 1102 (1984), aff'd, 104 Wash.2d 613 , 707 P.2d 685 (1985)). 2003Co., 38 Wn. | 2 | 2003–2003 |
City of Seattle v. Klein
green
2 sentences2025“It follows that we do not embrace an inadvertent waiver without notice.” City of Seattle v. Klein, 161 Wn.2d 554, 560 , 166 P.3d 1149 (2007). 2025“It follows that we do not embrace an inadvertent waiver without notice.” City of Seattle v. Klein, 161 Wn.2d 554, 560 , 166 P.3d 1149 (2007). | 1 | 2025–2025 |
State v. Kells
green
2 sentences2025For the State to “affirmatively prove[]” a defendant waived their right to appeal, the State must show that the defendant understood that they had the “‘right to appeal and chose not to exercise it.’” Id. at 561; State v. Cater, 186 Wn. App. 384, 392 , 345 P.3d 843 (2015) (quoting State v. Kells, 134 Wn.2d 309, 315 , 949 P.2d 818 (1998)). 2025For the State to “affirmatively prove[]” a defendant waived their right to appeal, the State must show that the defendant understood that they had the “‘right to appeal and chose not to exercise it.’” Id. at 561; State v. Cater, 186 Wn. App. 384, 392 , 345 P.3d 843 (2015) (quoting State v. Kells, 134 Wn.2d 309, 315 , 949 P.2d 818 (1998)). | 1 | 2025–2025 |
State v. Cater
green
2 sentences2025For the State to “affirmatively prove[]” a defendant waived their right to appeal, the State must show that the defendant understood that they had the “‘right to appeal and chose not to exercise it.’” Id. at 561; State v. Cater, 186 Wn. App. 384, 392 , 345 P.3d 843 (2015) (quoting State v. Kells, 134 Wn.2d 309, 315 , 949 P.2d 818 (1998)). 2025For the State to “affirmatively prove[]” a defendant waived their right to appeal, the State must show that the defendant understood that they had the “‘right to appeal and chose not to exercise it.’” Id. at 561; State v. Cater, 186 Wn. App. 384, 392 , 345 P.3d 843 (2015) (quoting State v. Kells, 134 Wn.2d 309, 315 , 949 P.2d 818 (1998)). | 1 | 2025–2025 |
Roberson v. Perez
green
1 sentence2022Roberson cites to Carlson in a discussion of discovery misconduct under CR 37 and CR 60(b)(4) motions. 123 Wn. App. at 332-33 . | 1 | 2022–2022 |
Washington State Physicians Insurance Exchange & Ass'n v. Fisons Corp.
green
1 sentence2015Inadvertence is not a defense; "the Fisons decision set the standards for discovery sanctions under CR 26(g) and made it clear that 'intent need not be shown before sanctions are mandated.'" Mayer, 156 Wn.2d at 689 (quoting Fisons, 122 Wn.2d at 345 ). "[E]ven an inadvertent error in failing to disclose [evidence] has been deemed willful as a 'willful violation means a violation without a reasonable excuse.'" Carlson v. Lake Chelan Cmty. Hosp., 116 Wn. | 1 | 2015–2015 |
Mayer v. Sto Industries, Inc.
green
1 sentence2015Inadvertence is not a defense; "the Fisons decision set the standards for discovery sanctions under CR 26(g) and made it clear that 'intent need not be shown before sanctions are mandated.'" Mayer, 156 Wn.2d at 689 (quoting Fisons, 122 Wn.2d at 345 ). "[E]ven an inadvertent error in failing to disclose [evidence] has been deemed willful as a 'willful violation means a violation without a reasonable excuse.'" Carlson v. Lake Chelan Cmty. Hosp., 116 Wn. | 1 | 2015–2015 |
Trask v. Butler
green
2 sentences2015Federal and state laws and regulations, as well as the American Institute of Certified Public Accountants Code of Professional Conduct (AICPA Code), define the duties of certified public accountants.9 The AICPA Code states that accountant members have the obligation to serve the public interest10 and "should perform all professional responsibilities with the highest sense of integrity," which "can accommodate the inadvertent error and the honest difference of opinion [but] cannot accommodate deceit or subordination of principle." "Integrity also requires a member to observe the principles of o 2015Federal and state laws and regulations, as well as the American Institute of Certified Public Accountants Code of Professional Conduct (AICPA Code), define the duties of certified public accountants.9 The AICPA Code states that accountant members have the obligation to serve the public interest10 and "should perform all professional responsibilities with the highest sense of integrity," which "can accommodate the inadvertent error and the honest difference of opinion [but] cannot accommodate deceit or subordination of principle." "Integrity also requires a member to observe the principles of o | 1 | 2015–2015 |
State v. Davis
green
1 sentence2015We note that in State v. Davis, we did not remand to enter a written order or note dismissal of counts on the judgment. 176 Wn. | 1 | 2015–2015 |
Gammon v. Clark Equipment Co.
green
2 sentences2003Co., 38 Wash.App. 274, 280 , 686 P.2d 1102 (1984), aff'd, 104 Wash.2d 613 , 707 P.2d 685 (1985)). 2003Co., 38 Wash.App. 274, 280 , 686 P.2d 1102 (1984), aff'd, 104 Wash.2d 613 , 707 P.2d 685 (1985)). | 1 | 2003–2003 |
State v. Souza
green
1 sentence1999Souza, 60 Wn. | 1 | 1999–1999 |
Falk v. KEENE CORPORATION
green
1 sentence1989Falk v. Keene Corp., 53 Wn. | 1 | 1989–1989 |
State v. Taylor
green
2 sentences1983He further argues the Legislature's failure to provide that the 1981 amendment of RCW 9A.20.020 was to become effective in 1984 was an inadvertent error, citing State v. Taylor, 97 Wn.2d 724 , 649 P.2d 633 (1982). 1983He further argues the Legislature's failure to provide that the 1981 amendment of RCW 9A.20.020 was to become effective in 1984 was an inadvertent error, citing State v. Taylor, 97 Wn.2d 724 , 649 P.2d 633 (1982). | 1 | 1983–1983 |
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.
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.