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17 Washington opinions name it 2 courts 1994–2025 4 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 |
|---|---|---|
State v. Kirkmangreen2 sentences2025Kirkman, 159 Wn.2d at 935 (internal quotation marks omitted). 2021RAP 2.5(a)(3); Kirkman, 159 Wn.2d at 926 . | 1 | 2 |
In re Termination of Parental Rights to M.A.S.C.green1 sentence2025This court should limit its review of the trial court’s termination of the mother’s parental rights to the errors and issues that she identified in her appeal. 8 Of course, the mother was “not required to prove that DCYF's offers of services were not understandable; it [i]s DCYF's burden to prove that they were.” M.A.S.C., 197 Wn.2d at 703. 9 “A party may raise a claim of error which was not raised by the party in the trial court if another party on the same side of the case has raised the claim of error in the trial court.” RAP 2.5(a). 6 No. 86993-1-I/7 To the extent the majority opinion inst | 1 | 1 |
State Of Washington, Resp. v. Alan J. Sinclair Ii, App.27green1 sentence2017See Sinclair, 192 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 |
|---|---|---|
State v. O'Hara
green
2 sentences2025However, a party may raise an error for the first time on appeal if “‘(1) the error is manifest and (2) the error is truly of constitutional dimension.’” State v. J.W.M., 1 Wn.3d 58 , 90, 524 P.3d 596 (2023) (quoting O’Hara, 167 Wn.2d at 98 ); RAP 2.5(a)(3). 2017However, a party may raise a claim of error for the first time on appeal if it is a "manifest error affecting a constitutional right." RAP 2.5(a)(3); State v. O'Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009). | 3 | 2017–2025 |
State v. O'HARA
green
2 sentences2020App. 172, 185-86 , 267 P.3d 454 (2011) (quoting State v. O’Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009)). 4 Grimes, 165 Wn. 2017However, a party may raise a claim of error for the first time on appeal if it is a "manifest error affecting a constitutional right." RAP 2.5(a)(3); State v. O'Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009). | 2 | 2017–2020 |
State v. Grimes
green
2 sentences2020App. 172, 185-86 , 267 P.3d 454 (2011) (quoting State v. O’Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009)). 4 Grimes, 165 Wn. 2020Generally, this court will not consider issues raised for the first time on appeal. 1 But, a party may raise an error for the first time on appeal if it concerns a manifest error affecting a constitutional right. 2 “The defendant has the initial burden of showing that (1) the error was ‘truly of constitutional dimension’ and (2) the error was ‘manifest.’” 3 “A defendant cannot simply assert that an error occurred at trial and label the error ‘constitutional.’” 4 “The defendant must identify a constitutional error and show how, in the context of the trial, the alleged error actually affected th | 2 | 2013–2020 |
In Re Dependency of Grove
green
2 sentences2019Generally, there is a right to counsel in civil cases only when a civil litigant’s “physical liberty is threatened” or a “fundamental liberty interest . . . is at risk.” In re Dependency of Grove, 127 Wn.2d 221, 237 , 897 P.2d 1252 (1995). 2019Generally, there is a right to counsel in civil cases only when a civil litigant’s “physical liberty is threatened” or a “fundamental liberty interest . . . is at risk.” In re Dependency of Grove, 127 Wn.2d 221, 237 , 897 P.2d 1252 (1995). | 1 | 2019–2019 |
State v. Chapin
green
2 sentences2018He provides no reason this court should consider the argument despite 31 State v. Chapin, 118 Wn.2d 681, 688 , 826 P.2d 194 (1992). -14- No. 75716-4-1/ 15 the general rule that the appellate court may refuse to consider a claim of error not raised in the trial court.32 A party may raise a claim of manifest error affecting a constitutional right for the first time on appeal. 2018He provides no reason this court should consider the argument despite 31 State v. Chapin, 118 Wn.2d 681, 688 , 826 P.2d 194 (1992). -14- No. 75716-4-1/ 15 the general rule that the appellate court may refuse to consider a claim of error not raised in the trial court.32 A party may raise a claim of manifest error affecting a constitutional right for the first time on appeal. | 1 | 2018–2018 |
Conner v. Universal Utilities
green
2 sentences2018“It is consistent with RAP 2.5(a) for a party to raise the issue of denial of procedural due process in a civil case at the appellate level for the first time.” Conner v. Universal Utils., 105 Wn.2d 168, 171 , 712 P.2d 849 (1986) (citing Esmieu v. Schrag, 88 Wn.2d 490, 497 , 563 P.2d 203 (1977)). 2018“It is consistent with RAP 2.5(a) for a party to raise the issue of denial of procedural due process in a civil case at the appellate level for the first time.” Conner v. Universal Utils., 105 Wn.2d 168, 171 , 712 P.2d 849 (1986) (citing Esmieu v. Schrag, 88 Wn.2d 490, 497 , 563 P.2d 203 (1977)). | 1 | 2018–2018 |
Esmieu v. Schrag
green
2 sentences2018“It is consistent with RAP 2.5(a) for a party to raise the issue of denial of procedural due process in a civil case at the appellate level for the first time.” Conner v. Universal Utils., 105 Wn.2d 168, 171 , 712 P.2d 849 (1986) (citing Esmieu v. Schrag, 88 Wn.2d 490, 497 , 563 P.2d 203 (1977)). 2018“It is consistent with RAP 2.5(a) for a party to raise the issue of denial of procedural due process in a civil case at the appellate level for the first time.” Conner v. Universal Utils., 105 Wn.2d 168, 171 , 712 P.2d 849 (1986) (citing Esmieu v. Schrag, 88 Wn.2d 490, 497 , 563 P.2d 203 (1977)). | 1 | 2018–2018 |
State Ex Rel. Carroll v. Junker
green
2 sentences2017Carroll v. Junker, 79 Wn.2d 12, 26 , 482 P.2d 775 (1971)). 2017Carroll v. Junker, 79 Wn.2d 12, 26 , 482 P.2d 775 (1971)). | 1 | 2017–2017 |
State v. Downing
green
1 sentence2017Under RAP 2.5(a), a party may raise a claim of error on appeal "if another party on the same side of the case has raised the claim of error in the trial court." 26 No. 72753-2-1/27 unreasonable, or exercised on untenable grounds, or for untenable reasons.'" State v. Downing, 151 Wn.2d 265, 272 , 87 P.3d 1169 (2004)10 (quoting State ex rel. | 1 | 2017–2017 |
State v. Downing
green
1 sentence2017Under RAP 2.5(a), a party may raise a claim of error on appeal "if another party on the same side of the case has raised the claim of error in the trial court." 26 No. 72753-2-1/27 unreasonable, or exercised on untenable grounds, or for untenable reasons.'" State v. Downing, 151 Wn.2d 265, 272 , 87 P.3d 1169 (2004)10 (quoting State ex rel. | 1 | 2017–2017 |
State v. Rose
green
1 sentence2017Here, Cooper stated the basis for his objection by citing to Rose, 146 Wn. | 1 | 2017–2017 |
State v. McCabe
neutral
1 sentence2017McCabe, 161 Wn. | 1 | 2017–2017 |
In Re the Marriage of Hall
green
1 sentence2016A party may raise a claim of error which was not raised by the party in the trial court if another party on the same side of the case has raised the claim of error in the trial court. 15 See Hall, 103 Wn.2d at 243-44 . 16 Hall, 103Wn.2dat244. | 1 | 2016–2016 |
Waters v. Churchill
green
2 sentences1999Because of the conclusions we reach in this case we do not address that assignment of error. [57] White, 131 Wash.2d at 11 , 929 P.2d 396 (citing Waters v. Churchill, 511 U.S. 661, 668 , 114 S.Ct. 1878 , 128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 384-85 , 107 S.Ct. 2891 , 97 L.Ed.2d 315 (1987). [58] White, 131 Wash.2d at 14 , 929 P.2d 396 (emphasis omitted) (citing Binkley, 114 Wash.2d at 383 , 787 P.2d 1366 ). [59] White, 131 Wash.2d at 16 , 929 P.2d 396 . 1999Because of the conclusions we reach in this case we do not address that assignment of error. [57] White, 131 Wash.2d at 11 , 929 P.2d 396 (citing Waters v. Churchill, 511 U.S. 661, 668 , 114 S.Ct. 1878 , 128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 384-85 , 107 S.Ct. 2891 , 97 L.Ed.2d 315 (1987). [58] White, 131 Wash.2d at 14 , 929 P.2d 396 (emphasis omitted) (citing Binkley, 114 Wash.2d at 383 , 787 P.2d 1366 ). [59] White, 131 Wash.2d at 16 , 929 P.2d 396 . | 1 | 1999–1999 |
White v. State
green
1 sentence1999Because of the conclusions we reach in this case we do not address that assignment of error. [57] White, 131 Wash.2d at 11 , 929 P.2d 396 (citing Waters v. Churchill, 511 U.S. 661, 668 , 114 S.Ct. 1878 , 128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 384-85 , 107 S.Ct. 2891 , 97 L.Ed.2d 315 (1987). [58] White, 131 Wash.2d at 14 , 929 P.2d 396 (emphasis omitted) (citing Binkley, 114 Wash.2d at 383 , 787 P.2d 1366 ). [59] White, 131 Wash.2d at 16 , 929 P.2d 396 . | 1 | 1999–1999 |
White v. State
green
2 sentences1999Because of the conclusions we reach in this case we do not address that assignment of error. [57] White, 131 Wash.2d at 11 , 929 P.2d 396 (citing Waters v. Churchill, 511 U.S. 661, 668 , 114 S.Ct. 1878 , 128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 384-85 , 107 S.Ct. 2891 , 97 L.Ed.2d 315 (1987). [58] White, 131 Wash.2d at 14 , 929 P.2d 396 (emphasis omitted) (citing Binkley, 114 Wash.2d at 383 , 787 P.2d 1366 ). [59] White, 131 Wash.2d at 16 , 929 P.2d 396 . 1999Because of the conclusions we reach in this case we do not address that assignment of error. [57] White, 131 Wash.2d at 11 , 929 P.2d 396 (citing Waters v. Churchill, 511 U.S. 661, 668 , 114 S.Ct. 1878 , 128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 384-85 , 107 S.Ct. 2891 , 97 L.Ed.2d 315 (1987). [58] White, 131 Wash.2d at 14 , 929 P.2d 396 (emphasis omitted) (citing Binkley, 114 Wash.2d at 383 , 787 P.2d 1366 ). [59] White, 131 Wash.2d at 16 , 929 P.2d 396 . | 1 | 1999–1999 |
Binkley v. City of Tacoma
green
2 sentences1999Because of the conclusions we reach in this case we do not address that assignment of error. [57] White, 131 Wash.2d at 11 , 929 P.2d 396 (citing Waters v. Churchill, 511 U.S. 661, 668 , 114 S.Ct. 1878 , 128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 384-85 , 107 S.Ct. 2891 , 97 L.Ed.2d 315 (1987). [58] White, 131 Wash.2d at 14 , 929 P.2d 396 (emphasis omitted) (citing Binkley, 114 Wash.2d at 383 , 787 P.2d 1366 ). [59] White, 131 Wash.2d at 16 , 929 P.2d 396 . 1999Because of the conclusions we reach in this case we do not address that assignment of error. [57] White, 131 Wash.2d at 11 , 929 P.2d 396 (citing Waters v. Churchill, 511 U.S. 661, 668 , 114 S.Ct. 1878 , 128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 384-85 , 107 S.Ct. 2891 , 97 L.Ed.2d 315 (1987). [58] White, 131 Wash.2d at 14 , 929 P.2d 396 (emphasis omitted) (citing Binkley, 114 Wash.2d at 383 , 787 P.2d 1366 ). [59] White, 131 Wash.2d at 16 , 929 P.2d 396 . | 1 | 1999–1999 |
Rankin v. McPherson
green
2 sentences1999Because of the conclusions we reach in this case we do not address that assignment of error. [57] White, 131 Wash.2d at 11 , 929 P.2d 396 (citing Waters v. Churchill, 511 U.S. 661, 668 , 114 S.Ct. 1878 , 128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 384-85 , 107 S.Ct. 2891 , 97 L.Ed.2d 315 (1987). [58] White, 131 Wash.2d at 14 , 929 P.2d 396 (emphasis omitted) (citing Binkley, 114 Wash.2d at 383 , 787 P.2d 1366 ). [59] White, 131 Wash.2d at 16 , 929 P.2d 396 . 1999Because of the conclusions we reach in this case we do not address that assignment of error. [57] White, 131 Wash.2d at 11 , 929 P.2d 396 (citing Waters v. Churchill, 511 U.S. 661, 668 , 114 S.Ct. 1878 , 128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 384-85 , 107 S.Ct. 2891 , 97 L.Ed.2d 315 (1987). [58] White, 131 Wash.2d at 14 , 929 P.2d 396 (emphasis omitted) (citing Binkley, 114 Wash.2d at 383 , 787 P.2d 1366 ). [59] White, 131 Wash.2d at 16 , 929 P.2d 396 . | 1 | 1999–1999 |
Matter of Personal Restraint of Riley
green
2 sentences1994"The sixth amendment to the United States Constitution guarantees a criminal defendant the right 'to have the assistance of counsel for his defense.’ U.S. Const, amend. 6.[ 2 ] The right to counsel means the right to the effective assistance of counsel.” (Footnote omitted.) In re Riley, 122 Wn.2d 772, 779-80 , 863 P.2d 554 (1993). 1994"The sixth amendment to the United States Constitution guarantees a criminal defendant the right 'to have the assistance of counsel for his defense.’ U.S. Const, amend. 6.[ 2 ] The right to counsel means the right to the effective assistance of counsel.” (Footnote omitted.) In re Riley, 122 Wn.2d 772, 779-80 , 863 P.2d 554 (1993). | 1 | 1994–1994 |
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.