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16 District of Columbia opinions name it 1 courts 1993–2025 6 in the last five years
The cases below were cited by District of Columbia 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 |
|---|---|---|
Purcell v. District Attorney for Suffolk Districtgreen1 sentence2025As explained above, the dissent does not disagree that some threats may be unprivileged because they do not meet the existing 117 test for privileged communications, but that in no way supports the majority’s categorical exception. 42 42 The majority dismisses cases cited by Mr. Moore and PDS as amicus where threatening statements have been deemed protected by the attorney-client privilege—see, e.g., Purcell v. District Attorney, 676 N.E.2d 436, 438, 441 (Mass. 1997); Newman v. State, 863 A.2d 321, 330-36 (Md. 2004); In re Grand Jury Investigation, 902 N.E.2d 929, 930-34 (Mass. 2009); State v. | 1 | 1 |
In re Grand Jury Investigationgreen1 sentence2025As explained above, the dissent does not disagree that some threats may be unprivileged because they do not meet the existing 117 test for privileged communications, but that in no way supports the majority’s categorical exception. 42 42 The majority dismisses cases cited by Mr. Moore and PDS as amicus where threatening statements have been deemed protected by the attorney-client privilege—see, e.g., Purcell v. District Attorney, 676 N.E.2d 436, 438, 441 (Mass. 1997); Newman v. State, 863 A.2d 321, 330-36 (Md. 2004); In re Grand Jury Investigation, 902 N.E.2d 929, 930-34 (Mass. 2009); State v. | 1 | 1 |
Newman v. Stategreen1 sentence2025As explained above, the dissent does not disagree that some threats may be unprivileged because they do not meet the existing 117 test for privileged communications, but that in no way supports the majority’s categorical exception. 42 42 The majority dismisses cases cited by Mr. Moore and PDS as amicus where threatening statements have been deemed protected by the attorney-client privilege—see, e.g., Purcell v. District Attorney, 676 N.E.2d 436, 438, 441 (Mass. 1997); Newman v. State, 863 A.2d 321, 330-36 (Md. 2004); In re Grand Jury Investigation, 902 N.E.2d 929, 930-34 (Mass. 2009); State v. | 1 | 1 |
Lee Carrell v. United States (Revised Version)green1 sentence2024See Carrell v. United States, 165 A.3d 314, 317 (D.C. 2017) (en banc) (“We now hold that the government must prove the defendant’s mens rea to utter the words as a threat, and that it may do so by establishing that the defendant acted with the purpose to threaten or with knowledge 13 A. Instructional Error The gravamen of Mr. Keerikkattil’s first claim on appeal—at least if interpreted generously—appears to be that the trial court erred by not instructing the jury that it must find beyond a reasonable doubt that his conduct was either nonexpressive conduct or conduct that fell within the narro | 1 | 1 |
Kraft v. Kraftgreen1 sentence2024See Kraft v. Kraft, 155 A.2d 910, 913 (D.C. 1959) 50 (“It is well to remember that significance is given to broad and general statements of law only by comparing the facts from which they arise with those facts to which they supposedly apply.”). | 1 | 1 |
United States v. Alvarezgreen1 sentence2024Cf. United States v. Alvarez, 567 U.S. 709, 718-19 (2012) (plurality opinion) (discussing some of the contours of the categorical exception for defamation). | 1 | 1 |
Arkansas Game & Fish Commission v. United Statesgreen2 sentences2024The Court instead “reject[ed] a categorical bar to temporary- flooding takings claims,” id. at 36 , explaining that “[t]he sentence in question was composed to summarize the flooding cases the Court had encountered up to that point, which had unexceptionally involved permanent, rather than temporary, government-induced flooding,” id. at 35 . 2024The Court instead “reject[ed] a categorical bar to temporary- flooding takings claims,” id. at 36 , explaining that “[t]he sentence in question was composed to summarize the flooding cases the Court had encountered up to that point, which had unexceptionally involved permanent, rather than temporary, government-induced flooding,” id. at 35 . | 1 | 1 |
Council on American Islamic Relations v. Ballengergreen1 sentence2023See id. at 666 . | 1 | 1 |
In Re ZCgreen1 sentence2021See 813 A.2d at 203 (discussing the lack of reputational harm and concluding that “[a]ccordingly, the mother lacks standing to prosecute her appeal”); see also In re M.L., 28 A.3d 520 , 531 n.22 (D.C. 2011) (relying on In re Z.C. for the principle that an appellant who cannot secure “any remedial benefit from a decision by this court” lacks standing to bring an appeal (internal quotation marks omitted)). | 1 | 1 |
In Re Mlgreen1 sentence2021See 813 A.2d at 203 (discussing the lack of reputational harm and concluding that “[a]ccordingly, the mother lacks standing to prosecute her appeal”); see also In re M.L., 28 A.3d 520 , 531 n.22 (D.C. 2011) (relying on In re Z.C. for the principle that an appellant who cannot secure “any remedial benefit from a decision by this court” lacks standing to bring an appeal (internal quotation marks omitted)). | 1 | 1 |
Hampleton v. United Statesgreen1 sentence2013May 16, 2013) (merger of two counts of threats required where appellant’s threat to kill "all y’all” was "one act directed at an undifferentiated group of victims”); Hargraves v. United States, 62 A.3d 107 , 121 n. 50 (D.C.2013) (Fisher, J., joining the majority) (specifically noting that the fact ”[t]hat the predicate offenses had different victims does not preclude merger on the facts of this case”); and Hampleton v. United States, 10 A.3d 137, 146 (D.C.2010) (Fisher, J.) (merging multiple convictions for possession of a firearm during the commission of a crime of violence that stemmed from | 1 | 1 |
Atkins v. Swimwest Family Fitness Centergreen1 sentence2007See id. at 340-42 (waiver was "overly broad and all-inclusive,” the word “negligence” was not included, the provision was not “sufficiently highlight[ed],” and there was "no opportunity to bargain”). | 1 | 1 |
United States v. Steven Boldgreen1 sentence1996The Court, however, did not “adopt a categorical rule requiring the corroboration of predictive information as a precondition to reliance on anonymous tips.” United States v. Clipper, 297 U.S.App.D.C. 372, 377 , 973 F.2d 944, 949 (1992), cert. denied, 506 U.S. 1070 , 113 S.Ct. 1025 , 122 L.Ed.2d 171 (1993); see also Cauthen, 592 A.2d at 1025 (“White establishes no mandatory condition that a tip predict future activity to be rehable”); United States v. (Anthony) Johnson, 64 F.3d 1120, 1125 (8th Cir.1995) (White “does not create a rule requiring that a tip predict future action”); United States | 1 | 1 |
United States v. Anthony Philip Johnson, United States of America v. Chico A. Tillmongreen1 sentence1996The Court, however, did not “adopt a categorical rule requiring the corroboration of predictive information as a precondition to reliance on anonymous tips.” United States v. Clipper, 297 U.S.App.D.C. 372, 377 , 973 F.2d 944, 949 (1992), cert. denied, 506 U.S. 1070 , 113 S.Ct. 1025 , 122 L.Ed.2d 171 (1993); see also Cauthen, 592 A.2d at 1025 (“White establishes no mandatory condition that a tip predict future activity to be rehable”); United States v. (Anthony) Johnson, 64 F.3d 1120, 1125 (8th Cir.1995) (White “does not create a rule requiring that a tip predict future action”); United States | 1 | 1 |
United States v. Oliver L. Gibsongreen1 sentence1996The Court, however, did not “adopt a categorical rule requiring the corroboration of predictive information as a precondition to reliance on anonymous tips.” United States v. Clipper, 297 U.S.App.D.C. 372, 377 , 973 F.2d 944, 949 (1992), cert. denied, 506 U.S. 1070 , 113 S.Ct. 1025 , 122 L.Ed.2d 171 (1993); see also Cauthen, 592 A.2d at 1025 (“White establishes no mandatory condition that a tip predict future activity to be rehable”); United States v. (Anthony) Johnson, 64 F.3d 1120, 1125 (8th Cir.1995) (White “does not create a rule requiring that a tip predict future action”); United States | 1 | 1 |
Alabama v. Whitegreen2 sentences1996Rather, the Court continued to rely on the “totality of the circumstances” where “the whole picture ... must be taken into account when evaluating whether there is reasonable suspicion.” White, 496 U.S. at 330 , 110 S.Ct. at 2416 (internal quotations and citations omitted). 1996Rather, the Court continued to rely on the “totality of the circumstances” where “the whole picture ... must be taken into account when evaluating whether there is reasonable suspicion.” White, 496 U.S. at 330 , 110 S.Ct. at 2416 (internal quotations and citations omitted). | 1 | 1 |
Cauthen v. United Statesgreen1 sentence1996The Court, however, did not “adopt a categorical rule requiring the corroboration of predictive information as a precondition to reliance on anonymous tips.” United States v. Clipper, 297 U.S.App.D.C. 372, 377 , 973 F.2d 944, 949 (1992), cert. denied, 506 U.S. 1070 , 113 S.Ct. 1025 , 122 L.Ed.2d 171 (1993); see also Cauthen, 592 A.2d at 1025 (“White establishes no mandatory condition that a tip predict future activity to be rehable”); United States v. (Anthony) Johnson, 64 F.3d 1120, 1125 (8th Cir.1995) (White “does not create a rule requiring that a tip predict future action”); United States | 1 | 1 |
United States v. Ronald T. Clippergreen2 sentences1996The Court, however, did not “adopt a categorical rule requiring the corroboration of predictive information as a precondition to reliance on anonymous tips.” United States v. Clipper, 297 U.S.App.D.C. 372, 377 , 973 F.2d 944, 949 (1992), cert. denied, 506 U.S. 1070 , 113 S.Ct. 1025 , 122 L.Ed.2d 171 (1993); see also Cauthen, 592 A.2d at 1025 (“White establishes no mandatory condition that a tip predict future activity to be rehable”); United States v. (Anthony) Johnson, 64 F.3d 1120, 1125 (8th Cir.1995) (White “does not create a rule requiring that a tip predict future action”); United States 1996The Court, however, did not “adopt a categorical rule requiring the corroboration of predictive information as a precondition to reliance on anonymous tips.” United States v. Clipper, 297 U.S.App.D.C. 372, 377 , 973 F.2d 944, 949 (1992), cert. denied, 506 U.S. 1070 , 113 S.Ct. 1025 , 122 L.Ed.2d 171 (1993); see also Cauthen, 592 A.2d at 1025 (“White establishes no mandatory condition that a tip predict future activity to be rehable”); United States v. (Anthony) Johnson, 64 F.3d 1120, 1125 (8th Cir.1995) (White “does not create a rule requiring that a tip predict future action”); United States | 1 | 1 |
| James v. Illinoisgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in District of Columbia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Penn Central Transportation Co. v. New York City
green
1 sentence2024Co. v. New York City, 438 U.S. 104 (1978). 13 We disagree. | 1 | 2024–2024 |
Snowder v. District of Columbia
green
1 sentence2013Snowder itself did not apply a categorical rule, but went on to determine, based upon the particular facts of that case, that the damages claimed there were unliquidated: “While some appellants paid certain amounts (which might not be the full extent of their damages, as they sought compensatory damages), others lost their cars entirely, and the value of the cars is uncertain.” Snowder, 949 A.2d at 601 . | 1 | 2013–2013 |
Miller v. Alabama
green
1 sentence2013Lastly, Miller , the most recent decision in the categorical exception line, adopts Graham’s rule that “youth matters in determining the appropriateness of a lifetime of incarceration without the possibility of parole.” Miller, supra, 132 S.Ct. at 2465 . | 1 | 2013–2013 |
District of Columbia v. World Fire & Marine Ins.
green
1 sentence2013The court noted, that is, that “[n]o initial liability was either admitted or provided,” that the D.C. commissioners were under no obligation to approve the claim for damages, that “their right to compromise claims is discretionary,” and that the commissioners could have refused to pay the claim at all or “offered only partial settlement.” Id. | 1 | 2013–2013 |
Kittle v. United States
green
1 sentence2013Preliminarily, had Hanna announced such a categorical rule, it should have precluded merger in recent decisions like Kittle v. United States, 09-CF-1586, 2013 WL 2102150 , at *13 n. 15 (D.C. | 1 | 2013–2013 |
Hargraves v. United States
green
1 sentence2013May 16, 2013) (merger of two counts of threats required where appellant’s threat to kill "all y’all” was "one act directed at an undifferentiated group of victims”); Hargraves v. United States, 62 A.3d 107 , 121 n. 50 (D.C.2013) (Fisher, J., joining the majority) (specifically noting that the fact ”[t]hat the predicate offenses had different victims does not preclude merger on the facts of this case”); and Hampleton v. United States, 10 A.3d 137, 146 (D.C.2010) (Fisher, J.) (merging multiple convictions for possession of a firearm during the commission of a crime of violence that stemmed from | 1 | 2013–2013 |
Riley v. United States
green
2 sentences2010Cf. Riley v. United States, 923 A.2d 868, 884 , 885 n. 17 (D.C.2007). 2010Cf. Riley v. United States, 923 A.2d 868, 884 , 885 n. 17 (D.C.2007). | 1 | 2010–2010 |
Zafiro v. United States
green
2 sentences2005When the risk of prejudice is high, a [trial] court is more likely to determine that separate trials are necessary .... ” Zafiro, 506 U.S. at 539 , 113 S.Ct. 933 . 2005When the risk of prejudice is high, a [trial] court is more likely to determine that separate trials are necessary .... ” Zafiro, 506 U.S. at 539 , 113 S.Ct. 933 . | 1 | 2005–2005 |
Glorious Food, Inc. v. Georgetown Prospect Place Associates
green
1 sentence1997In both instances, the court relied solely upon this court’s decision in Glorious Food v. Georgetown Prospect Place Assocs., 648 A.2d 946 (D.C.1994), which in turn relied on Beach v. United States, 466 A.2d 862 (D.C.1988) (per curiam), for the categorical rule that the same person may not testify both as an expert and as a fact witness in the same proceeding. 1 Just recently, however, this court overruled Beach insofar as it declared a per se ban on dual lay and expert testimony by a single witness. | 1 | 1997–1997 |
Eason v. United States
green
1 sentence1997Instead the court com mitted “to the trial court’s discretion in each ease whether the danger of jury confusion can be neutralized by lesser measures than exclusion of dual testimony altogether.” Eason v. United States, No. 95-CF-4, slip op. at 2, - A.2d -, - ( 1997 WL 471486 ) (D.C. | 1 | 1997–1997 |
Beach v. United States
green
1 sentence1997In both instances, the court relied solely upon this court’s decision in Glorious Food v. Georgetown Prospect Place Assocs., 648 A.2d 946 (D.C.1994), which in turn relied on Beach v. United States, 466 A.2d 862 (D.C.1988) (per curiam), for the categorical rule that the same person may not testify both as an expert and as a fact witness in the same proceeding. 1 Just recently, however, this court overruled Beach insofar as it declared a per se ban on dual lay and expert testimony by a single witness. | 1 | 1997–1997 |
| Williamson v. United States green | 1 | 1996–1996 |
| Pogany v. United States green | 1 | 1996–1996 |
Currie v. United States
green
1 sentence1996The Court, however, did not “adopt a categorical rule requiring the corroboration of predictive information as a precondition to reliance on anonymous tips.” United States v. Clipper, 297 U.S.App.D.C. 372, 377 , 973 F.2d 944, 949 (1992), cert. denied, 506 U.S. 1070 , 113 S.Ct. 1025 , 122 L.Ed.2d 171 (1993); see also Cauthen, 592 A.2d at 1025 (“White establishes no mandatory condition that a tip predict future activity to be rehable”); United States v. (Anthony) Johnson, 64 F.3d 1120, 1125 (8th Cir.1995) (White “does not create a rule requiring that a tip predict future action”); United States | 1 | 1996–1996 |
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.