reliance requirement (Washington) · Go Syfert
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reliance requirement in Washington

18 Washington opinions name it 2 courts 1986–2026 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 (7)

CaseFollowedCited
In Re Disciplinary Proceeding Against Eggergreen
wash · 2004 · cited in 2 Washington opinions naming this issue, 2006–2006
2 sentences

2006See Standards std. 4.64 (“Admonition is generally appropriate when a lawyer engages in an isolated instance of negligence in failing to provide a client with accurate or complete information, and causes little or no actual or potential injury to the client.”). 14 However, in doing so, we remain mindful that we have previously stated that the presumptive sanctions set forth in Standards generally “makes it clear that suspension is the appropriate sanction where an attorney acted with knowledge.” In re Disciplinary Proceeding Against Egger, 152 Wn.2d 393, 416 , 98 P.3d 477 (2004); see also Stand

2006See STANDARDS std. 4.64 ("Admonition is generally appropriate when a lawyer engages in an isolated instance of negligence in failing to provide a client with accurate or complete information, and causes little or no actual or potential injury to the client."). [14] However, in doing so, we remain *967 mindful that we have previously stated that the presumptive sanctions set forth in Standards generally "makes it clear that suspension is the appropriate sanction where an attorney acted with knowledge." In re Disciplinary Proceeding Against Egger, 152 Wash.2d 393, 416 , 98 P.3d 477 (2004); see a

22
In re the Disciplinary Proceeding Against Eggergreen
wash · 2004 · cited in 2 Washington opinions naming this issue, 2006–2006
2 sentences

2006See Standards std. 4.64 (“Admonition is generally appropriate when a lawyer engages in an isolated instance of negligence in failing to provide a client with accurate or complete information, and causes little or no actual or potential injury to the client.”). 14 However, in doing so, we remain mindful that we have previously stated that the presumptive sanctions set forth in Standards generally “makes it clear that suspension is the appropriate sanction where an attorney acted with knowledge.” In re Disciplinary Proceeding Against Egger, 152 Wn.2d 393, 416 , 98 P.3d 477 (2004); see also Stand

2006See STANDARDS std. 4.64 ("Admonition is generally appropriate when a lawyer engages in an isolated instance of negligence in failing to provide a client with accurate or complete information, and causes little or no actual or potential injury to the client."). [14] However, in doing so, we remain *967 mindful that we have previously stated that the presumptive sanctions set forth in Standards generally "makes it clear that suspension is the appropriate sanction where an attorney acted with knowledge." In re Disciplinary Proceeding Against Egger, 152 Wash.2d 393, 416 , 98 P.3d 477 (2004); see a

22
Siekawitch v. Washington Beef Producers, Inc.green
washctapp · 1990 · cited in 2 Washington opinions naming this issue, 2001–2001
2 sentences

2001See id. at 202-04, 978 P.2d 568 (discussing Siekawitch v. Wash. Beef Producers, Inc., 58 Wash.App. 454 , 793 P.2d 994 (1990); Klontz v. Puget Sound Power & Light Co., 90 Wash. App. 186 , 951 P.2d 280 (1998); Shaw v. Housing Auth. of Walla Walla, 75 Wash. App. 755 , 880 P.2d 1006 (1994); Bott v. Rockwell Int'l, 80 Wash.App. 326 , 908 P.2d 909 (1996); Wlasiuk v. Whirlpool Corp., 81 Wash.App. 163 , 914 P.2d 102 (1996)).

2001See, id. at 202-04 (discussing Siekawitch v. Wash. Beef Producers, Inc., 58 Wn.

22
Shermer v. Bakergreen
washctapp · 1970 · cited in 2 Washington opinions naming this issue, 2017–2019
2 sentences

2019See id. at 857-58 .

2017And the supreme court has subsequently denied review in cases from this court that have held reasonable reliance an essential element of RCW 21.20.010 claims.25 As we stated in 24 Wade, 915 F.2d at 1332 . 25 Shermer v. Baker, 2 Wn.

12
Bulman v. Safeway, Inc.green
washctapp · 1999 · cited in 2 Washington opinions naming this issue, 2001–2001
2 sentences

2001It found that "[t]hese cases reveal no clear line of analysis as to the reliance requirement of *1176 Thompson . " 96 Wash.App. at 204 , 978 P.2d 568 .

2001It found that “[t]hese cases reveal no clear line of analysis as to the reliance requirement of Thompson.” 96 Wn.

12
Hines v. Data Line Systems, Inc.green
wash · 1990 · cited in 1 Washington opinions naming this issue, 2019–2019
2 sentences

2019See id. 14 Federal Home Loan v. Credit Suisse, No. 95420-8 Federal Home Loan v. Barclays, No. 95436-4 We reaffirmed that Hines did not create a reliance requirement in subsequent cases.

2019In Go2Net, we repeated that "[s]imply put, a seller's 'violation [of the Securities Act] is in the misrepresentation itself.'" 158 Wn.2d at 253 (quoting Hines, 114 Wn.2d at 135 ).

11
Yoder v. Honeywell Inc.green
cod · 1995 · cited in 1 Washington opinions naming this issue, 2017–2017
1 sentence

2017See Yoder v. Honeywell Inc., 900 F. Supp. 240, 245 (D.

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 (20)

CaseCitedYears
State v. Sublett green
wash · 2012
2 sentences

2015State v. Sublett, 176 Wn.2d 58, 72-73 , 292 P.3d 715 (2012) (plurality opinion).

2015State v. Sublett, 176 Wn.2d 58, 72-73 , 292 P.3d 715 (2012) (plurality opinion).

22015–2015
Washington State Physicians Insurance Exchange & Ass'n v. Fisons Corp. green
wash · 1993
2 sentences

2007But Schmidt's description is compatible with the definition of "`proximate cause'" in WPI 15.01 because it effectively concluded that, but for the defendant's inflated appraisal, the plaintiffs would not have made the investment. ¶ 55 Fisons involved a physician who brought a claim against a drug company alleging that the drug company had engaged in unfair or deceptive act or practices by failing to warn the physician of the dangers related to a drug he prescribed to his patients. 122 Wash.2d at 311 , 858 P.2d 1054 .

2007But Schmidt’s description is compatible with the definition of “ ‘proximate cause’ ” in WPI 15.01 because it effectively concluded that, but for the defendant’s inflated appraisal, the plaintiffs would not have made the investment. ¶55 Fisons involved a physician who brought a claim against a drug company alleging that the drug company had engaged in unfair or deceptive act or practices by failing to warn the physician of the dangers related to a drug he prescribed to his patients. 122 Wn.2d at 311 .

22007–2007
Robinson v. Avis Rent A Car System, Inc. green
washctapp · 2001
2 sentences

2007However, Robinson involved a failure to disclose, not an affirmative misrepresentation, so it does not support Integra's argument. 106 Wash.App. at 119 , 22 P.3d 818 . ¶ 51 WSTLA and the AG suggest that Hangman Ridge replaced the reliance/inducement requirement with a proximate cause standard.

2007However, Robinson involved a failure to disclose, not an affirmative misrepresentation, so it does not support Integra’s argument. 106 Wn.

22007–2007
State v. McNeal green
washctapp · 2008
1 sentence

2026App. 777, 786-7 , 175 P.3d 1139 (2008) (holding that case ceased to be final upon vacation of a sentence and remand for resentencing). 11 No. 39242-2-III State v. Tellvik However, at Tellvik’s second resentencing hearing, the trial court noted a reliance on its analysis from the original resentencing hearing.

12026–2026
Cavell v. Hughes green
washctapp · 1981
1 sentence

2025However, the trial court’s findings about Hothi’s motives were relevant to whether he was acting in bad faith, as Cavell shows, and bad faith is relevant to the trial court’s conclusion that Sapphire breached the covenant of good faith and fair dealing. 29 Wn.

12025–2025
Cedar Grove Composting, Inc. v. City of Marysville green
washctapp · 2015
1 sentence

2020Cedar Grove, 188 Wn.

12020–2020
Stoneridge Investment Partners, LLC v. Scientific-Atlanta, Inc. green
scotus · 2008
2 sentences

2019Partners, LLC v. Scientific-Atlanta, Inc., 552 U.S. 148, 157 , 128 S. Ct. 761 , 169 L.

2019Partners, LLC v. Scientific-Atlanta, Inc., 552 U.S. 148, 157 , 128 S. Ct. 761 , 169 L.

12019–2019
Margaret Rublee, Et Ano. v. Carrier Corp. green
washctapp · 2017
2 sentences

2018For this reason, we reject the actual reliance test, which requires proof that the purchaser or user " 'actually and reasonably relied upon the reputed "apparent manufacturer's" trademark, reputation, or assurances of product quality, in purchasing the defective product at issue.' " Rublee , 199 Wash. App. at 377 , 398 P.3d 1247 (quoting Stein , 228 Md.

2018For this reason, we reject the actual reliance test, which requires proof that the purchaser or user " 'actually and reasonably relied upon the reputed "apparent manufacturer's" trademark, reputation, or assurances of product quality, in purchasing the defective product at issue.' " Rublee , 199 Wash. App. at 377 , 398 P.3d 1247 (quoting Stein , 228 Md.

12018–2018
Stein v. Pfizer Inc. green
mdctspecapp · 2016
2 sentences

2018For this reason, we reject the actual reliance test, which requires proof that the purchaser or user " 'actually and reasonably relied upon the reputed "apparent manufacturer's" trademark, reputation, or assurances of product quality, in purchasing the defective product at issue.' " Rublee , 199 Wash. App. at 377 , 398 P.3d 1247 (quoting Stein , 228 Md.

2018App. at 102 , 137 A.3d 279 ).

12018–2018
Curtis K. Wade Joan Vertlieb Sharon Svare Robert Svare John Starkovick Johanna Starkovick Richard Stainslaw Roger-Olympic Corp. v. Skipper's, Inc. green
ca9 · 1990
1 sentence

2017And the supreme court has subsequently denied review in cases from this court that have held reasonable reliance an essential element of RCW 21.20.010 claims.25 As we stated in 24 Wade, 915 F.2d at 1332 . 25 Shermer v. Baker, 2 Wn.

12017–2017
Clausing v. DeHart green
wash · 1973
2 sentences

2017It is particularly noteworthy that since Washington courts began recognizing a reliance requirement in 1970,20 the legislature has amended the 15 Clausing v. DeHart, 83 Wn.2d 70, 72 , 515 P.2d 982 (1973).

2017It is particularly noteworthy that since Washington courts began recognizing a reliance requirement in 1970,20 the legislature has amended the 15 Clausing v. DeHart, 83 Wn.2d 70, 72 , 515 P.2d 982 (1973).

12017–2017
Guarino v. Interactive Objects, Inc. green
washctapp · 2004
1 sentence

2017Guarino v. Interactive Obiects, Inc., 122 Wn.

12017–2017
Robinson v. Avis Rent a Car System, Inc. green
washctapp · 2001
1 sentence

2007However, Robinson involved a failure to disclose, not an affirmative misrepresentation, so it does not support Integra's argument. 106 Wash.App. at 119 , 22 P.3d 818 . ¶ 51 WSTLA and the AG suggest that Hangman Ridge replaced the reliance/inducement requirement with a proximate cause standard.

12007–2007
Wlasiuk v. Whirlpool Corp. green
washctapp · 1996
1 sentence

2001See id. at 202-04, 978 P.2d 568 (discussing Siekawitch v. Wash. Beef Producers, Inc., 58 Wash.App. 454 , 793 P.2d 994 (1990); Klontz v. Puget Sound Power & Light Co., 90 Wash. App. 186 , 951 P.2d 280 (1998); Shaw v. Housing Auth. of Walla Walla, 75 Wash. App. 755 , 880 P.2d 1006 (1994); Bott v. Rockwell Int'l, 80 Wash.App. 326 , 908 P.2d 909 (1996); Wlasiuk v. Whirlpool Corp., 81 Wash.App. 163 , 914 P.2d 102 (1996)).

12001–2001
Bott v. Rockwell International green
washctapp · 1996
1 sentence

2001See id. at 202-04, 978 P.2d 568 (discussing Siekawitch v. Wash. Beef Producers, Inc., 58 Wash.App. 454 , 793 P.2d 994 (1990); Klontz v. Puget Sound Power & Light Co., 90 Wash. App. 186 , 951 P.2d 280 (1998); Shaw v. Housing Auth. of Walla Walla, 75 Wash. App. 755 , 880 P.2d 1006 (1994); Bott v. Rockwell Int'l, 80 Wash.App. 326 , 908 P.2d 909 (1996); Wlasiuk v. Whirlpool Corp., 81 Wash.App. 163 , 914 P.2d 102 (1996)).

12001–2001
Klontz v. Puget Sound Power & Light Co. green
washctapp · 1998
2 sentences

2001See id. at 202-04, 978 P.2d 568 (discussing Siekawitch v. Wash. Beef Producers, Inc., 58 Wash.App. 454 , 793 P.2d 994 (1990); Klontz v. Puget Sound Power & Light Co., 90 Wash. App. 186 , 951 P.2d 280 (1998); Shaw v. Housing Auth. of Walla Walla, 75 Wash. App. 755 , 880 P.2d 1006 (1994); Bott v. Rockwell Int'l, 80 Wash.App. 326 , 908 P.2d 909 (1996); Wlasiuk v. Whirlpool Corp., 81 Wash.App. 163 , 914 P.2d 102 (1996)).

2001See id. at 202-04, 978 P.2d 568 (discussing Siekawitch v. Wash. Beef Producers, Inc., 58 Wash.App. 454 , 793 P.2d 994 (1990); Klontz v. Puget Sound Power & Light Co., 90 Wash. App. 186 , 951 P.2d 280 (1998); Shaw v. Housing Auth. of Walla Walla, 75 Wash. App. 755 , 880 P.2d 1006 (1994); Bott v. Rockwell Int'l, 80 Wash.App. 326 , 908 P.2d 909 (1996); Wlasiuk v. Whirlpool Corp., 81 Wash.App. 163 , 914 P.2d 102 (1996)).

12001–2001
Shaw v. Housing Authority green
washctapp · 1994
2 sentences

2001See id. at 202-04, 978 P.2d 568 (discussing Siekawitch v. Wash. Beef Producers, Inc., 58 Wash.App. 454 , 793 P.2d 994 (1990); Klontz v. Puget Sound Power & Light Co., 90 Wash. App. 186 , 951 P.2d 280 (1998); Shaw v. Housing Auth. of Walla Walla, 75 Wash. App. 755 , 880 P.2d 1006 (1994); Bott v. Rockwell Int'l, 80 Wash.App. 326 , 908 P.2d 909 (1996); Wlasiuk v. Whirlpool Corp., 81 Wash.App. 163 , 914 P.2d 102 (1996)).

2001See id. at 202-04, 978 P.2d 568 (discussing Siekawitch v. Wash. Beef Producers, Inc., 58 Wash.App. 454 , 793 P.2d 994 (1990); Klontz v. Puget Sound Power & Light Co., 90 Wash. App. 186 , 951 P.2d 280 (1998); Shaw v. Housing Auth. of Walla Walla, 75 Wash. App. 755 , 880 P.2d 1006 (1994); Bott v. Rockwell Int'l, 80 Wash.App. 326 , 908 P.2d 909 (1996); Wlasiuk v. Whirlpool Corp., 81 Wash.App. 163 , 914 P.2d 102 (1996)).

12001–2001
Wlasiuk v. Whirlpool Corp. green
washctapp · 1996
1 sentence

2001See id. at 202-04, 978 P.2d 568 (discussing Siekawitch v. Wash. Beef Producers, Inc., 58 Wash.App. 454 , 793 P.2d 994 (1990); Klontz v. Puget Sound Power & Light Co., 90 Wash. App. 186 , 951 P.2d 280 (1998); Shaw v. Housing Auth. of Walla Walla, 75 Wash. App. 755 , 880 P.2d 1006 (1994); Bott v. Rockwell Int'l, 80 Wash.App. 326 , 908 P.2d 909 (1996); Wlasiuk v. Whirlpool Corp., 81 Wash.App. 163 , 914 P.2d 102 (1996)).

12001–2001
State v. Strauss green
wash · 1992
1 sentence

1999Strauss, 119 Wn.2d at 421 ; Strauss, slip op. at 2.

11999–1999
State v. Dictado green
wash · 1984
2 sentences

1986Our Supreme Court has not yet answered the question of whether rough notes are discoverable as of right, State v. Dictado, 102 Wn.2d 277, 298 , 687 P.2d 172 (1984), but we need not reach that issue here.

1986Our Supreme Court has not yet answered the question of whether rough notes are discoverable as of right, State v. Dictado, 102 Wn.2d 277, 298 , 687 P.2d 172 (1984), but we need not reach that issue here.

11986–1986

Statutes the citing opinions construe

WA § Wash. Rev. Code § 21.20.010 (3) WA § Wash. Rev. Code § 21.20.430 (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

CA 75 (1964–2026) NY 30 (1906–2025) IL 26 (1977–2024) PA 23 (1980–2025) TX 18 (1978–2022) WA 18 (1986–2026) AL 16 (1991–2025) CT 15 (1995–2024) MA 14 (1960–2025) MD 14 (1969–2024) FL 14 (1973–2020) NJ 12 (1981–2022) WI 11 (1985–2025) MI 9 (1978–2024) UT 8 (1995–2026) GA 8 (1978–2026) OH 8 (1966–2018) AZ 7 (1973–2020) DC 7 (1979–2022) LA 7 (1985–2017) VT 6 (1967–2018) NM 6 (2000–2021) NC 6 (1986–2020) ID 6 (1979–2021) NE 5 (1988–2024) AK 5 (1976–1989) OR 5 (2001–2012) MN 5 (1971–2017) CO 5 (1994–2026) TN 4 (1995–2014) NV 4 (1957–2014) IA 4 (2006–2018) WV 4 (1980–2017) RI 4 (2002–2023) IN 4 (1978–2023) VA 4 (2008–2018) MO 3 (1966–2017) KS 3 (1972–2008) MS 2 (2007–2007) HI 2 (1996–2017) KY 2 (2011–2026) SC 2 (2000–2011) SD 2 (2004–2009) VI 2 (2009–2011) ME 2 (2007–2012) ND 2 (1976–2018) NH 2 (1997–2005)

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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