15 Washington opinions name it 2 courts 1955–2015 0 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 Estate of Chafeygreen2 sentences2004However, in Campbell, it appears that the will presented to the court included the testator’s signature and a signed attestation clause. 7 47 Wn.2d at 614-15 ; see In re Estate of Chafey, 167 Wash. 185, 189 , 8 P.2d 959 (1932) (stating that an attestation clause with a genuine signature of the testator is prima facie evidence of the will’s execution); see also In re Estate of Alfaro, 301 Ill. 2004However, in Campbell, it appears that the will presented to the court included the testator’s signature and a signed attestation clause. 7 47 Wn.2d at 614-15 ; see In re Estate of Chafey, 167 Wash. 185, 189 , 8 P.2d 959 (1932) (stating that an attestation clause with a genuine signature of the testator is prima facie evidence of the will’s execution); see also In re Estate of Alfaro, 301 Ill. | 2 | 3 |
In Re Estate of Alfarogreen2 sentences2004However, in Campbell, it appears that the will presented to the court included the testator’s signature and a signed attestation clause. 7 47 Wn.2d at 614-15 ; see In re Estate of Chafey, 167 Wash. 185, 189 , 8 P.2d 959 (1932) (stating that an attestation clause with a genuine signature of the testator is prima facie evidence of the will’s execution); see also In re Estate of Alfaro, 301 Ill. 2004However, in Campbell, it appears that the will presented to the court included the testator's signature and a signed attestation clause. [7] 47 Wash.2d at 614-15 , 288 P.2d 852 ; see In re Estate of Chafey, 167 Wash. 185, 189 , 8 P.2d 959 (1932) (stating that an attestation clause with a genuine signature of the testator is prima facie evidence of the will's execution); see also In re Estate of Alfaro, 301 Ill.App.3d 500, 504 , 234 Ill.Dec. 759 , 703 N.E.2d 620 (1998) (stating that an attestation clause with genuine signatures on the instrument is prima facie evidence that the will was properl | 2 | 2 |
Estate of Campbell v. Bergegreen2 sentences2004However, in Campbell, it appears that the will presented to the court included the testator’s signature and a signed attestation clause. 7 47 Wn.2d at 614-15 ; see In re Estate of Chafey, 167 Wash. 185, 189 , 8 P.2d 959 (1932) (stating that an attestation clause with a genuine signature of the testator is prima facie evidence of the will’s execution); see also In re Estate of Alfaro, 301 Ill. 2004However, in Campbell, it appears that the will presented to the court included the testator's signature and a signed attestation clause. [7] 47 Wash.2d at 614-15 , 288 P.2d 852 ; see In re Estate of Chafey, 167 Wash. 185, 189 , 8 P.2d 959 (1932) (stating that an attestation clause with a genuine signature of the testator is prima facie evidence of the will's execution); see also In re Estate of Alfaro, 301 Ill.App.3d 500, 504 , 234 Ill.Dec. 759 , 703 N.E.2d 620 (1998) (stating that an attestation clause with genuine signatures on the instrument is prima facie evidence that the will was properl | 1 | 4 |
Fircrest Supply, Inc. v. Plummergreen2 sentences2006App. 384 , 634 P.2d 891 (1981) (lien claim substantially complied with RCW 60.04.091 although the claimant did not sign the lien because the notary’s signature following the claimant’s typed name indicated that the claimant verified the claim in the notary’s presence). 3 But no Washington court has ruled on who may sign the attestation clause on the claimant’s behalf. ¶20 The Williamses argue that the attestation requirement is meaningless if we broadly construe the phrase “some person authorized to act on his or her behalf.” In their view, the legislature obviously intended that someone who h 2006App. 384 , 634 P.2d 891 (1981) (lien claim substantially complied with RCW 60.04.091 although the claimant did not sign the lien because the notary’s signature following the claimant’s typed name indicated that the claimant verified the claim in the notary’s presence). 3 But no Washington court has ruled on who may sign the attestation clause on the claimant’s behalf. ¶20 The Williamses argue that the attestation requirement is meaningless if we broadly construe the phrase “some person authorized to act on his or her behalf.” In their view, the legislature obviously intended that someone who h | 1 | 2 |
Lumberman's of Washington, Inc. v. Barnhardtgreen2 sentences2006See Lumberman's, Inc., 89 Wash.App. 283 , 949 P.2d 382 (lien claim invalid where the claimant signed the lien notice but failed to sign the attestation clause); Flag Constr., 109 Wash.App. 286 , 34 P.3d 1250 (lien claim invalid where claimant signed the lien, a notary signed the verification, but the claimant did not sign the verification); compare with Fircrest Supply, Inc. v. Plummer, 30 Wash.App. 384 , 634 P.2d 891 (1981) (lien claim substantially complied with RCW 60.04.091 although the claimant did not sign the lien because the notary's signature following the claimant's typed name indica 2006See Lumberman's, Inc., 89 Wash.App. 283 , 949 P.2d 382 (lien claim invalid where the claimant signed the lien notice but failed to sign the attestation clause); Flag Constr., 109 Wash.App. 286 , 34 P.3d 1250 (lien claim invalid where claimant signed the lien, a notary signed the verification, but the claimant did not sign the verification); compare with Fircrest Supply, Inc. v. Plummer, 30 Wash.App. 384 , 634 P.2d 891 (1981) (lien claim substantially complied with RCW 60.04.091 although the claimant did not sign the lien because the notary's signature following the claimant's typed name indica | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Williams v. Athletic Field, Inc.
green
2 sentences2015App. 434, 444 , 228 P. 3d 1297 ( 2010) ( holding that an attestation clause signed by an employee of the lien filing service company did not satisfy the lien statute' s requirement of corporate acknowledgement). 2 No. 42845 -8 -II Consolidated wi No. 44995 -1 - II subsequently overturned the case upon which the trial court had relied in granting summary judgment to Anchor Bank.2 The parties stipulated to an order vacating the summary judgment in Anchor Bank' s favor, and a bench trial followed between Shelcon and Anchor Bank. 2015App. 434, 444 , 228 P.3d 1297 (2010) (holding that an attestation clause signed by an employee of the lien filing service company did not satisfy the lien statute’s requirement of corporate acknowledgement). | 2 | 2015–2015 |
Ben Holt Industries, Inc. v. Milne
green
2 sentences2010Ben Holt, 36 Wash.App. at 472 , 675 P.2d 1256 . ¶ 24 Here, the elements of corporate acknowledgment are not satisfied by the attestation clause signed by Rebecca Southern. 2010Ben Holt, 36 Wash.App. at 472 , 675 P.2d 1256 . ¶ 24 Here, the elements of corporate acknowledgment are not satisfied by the attestation clause signed by Rebecca Southern. | 2 | 2010–2010 |
City of Bothell v. Gutschmidt
green
2 sentences2008In support of their motion, the Owenses relied on City of Bothell v. Gutschmidt, 78 Wash.App. 654 , 898 P.2d 864 (1995) and argued that the attestation requirement of RCW 35A.12.130 must be met for an ordinance to be validly enacted. ¶ 8 The Chelan County District Court held a hearing on the motion. 2008App. 654 , 898 P.2d 864 (1995) and argued that the attestation requirement of RCW 35A.12.130 must be met for an ordinance to be validly enacted. ¶8 The Chelan County District Court held a hearing on the motion. | 2 | 2008–2008 |
Flag Construction Co. v. Olympic Boulevard Partners
neutral
2 sentences2006See Lumberman's, Inc., 89 Wash.App. 283 , 949 P.2d 382 (lien claim invalid where the claimant signed the lien notice but failed to sign the attestation clause); Flag Constr., 109 Wash.App. 286 , 34 P.3d 1250 (lien claim invalid where claimant signed the lien, a notary signed the verification, but the claimant did not sign the verification); compare with Fircrest Supply, Inc. v. Plummer, 30 Wash.App. 384 , 634 P.2d 891 (1981) (lien claim substantially complied with RCW 60.04.091 although the claimant did not sign the lien because the notary's signature following the claimant's typed name indica 2006App. 283 (lien claim invalid where the claimant signed the lien notice but failed to sign the attestation clause); Flag Constr., 109 Wn. | 2 | 2006–2006 |
Sunderland v. Allstate Indemnity Co.
green
2 sentences2002We also made a passing reference to the attestation requirement for MAR 7.1 service-by-mail in Sunderland, 100 Wn. 2002Thus, the April 30 certification complied with CR 5(b)(1) and MAR 7.1(a)." Carpenter, 97 Wash.App. at 990 n. 6, 988 P.2d 1009 . [4] We also made a passing reference to the attestation requirement for MAR 7.1 service-by-mail in Sunderland, 100 Wash.App. at 328 , 995 P.2d 614 : [T]he CR 5(b)(2)(B) attestation requirement for service by mail also applies to service by delivery and requires a sworn statement by the messenger that service did in fact occur; and that proof of service must be done by attestation in light of [the] Nevers policy of strict compliance. [5] The trial court found that the | 2 | 2002–2002 |
Williams v. ATHLETIC FIELD, INC.
green
2 sentences2015Williams v. Athletic Field, Inc., 172 Wn.2d 683, 698 , 261 P.3d 109 (2011) (holding that a claim of lien following the lien statute’s sample form is valid even in the absence of a proper corporate acknowledgement). 2015Williams v. Athletic Field, Inc., 172 Wn.2d 683, 698 , 261 P.3d 109 (2011) (holding that a claim of lien following the lien statute’s sample form is valid even in the absence of a proper corporate acknowledgement). | 1 | 2015–2015 |
Intermountain Elec., Inc. v. GAT BROS. CONST., INC.
green
1 sentence2006Intermountain, 115 Wash.App. at 394 , 62 P.3d 548 . ¶ 25 Whether RCW 60.04.091 permits any authorized agent to sign the attestation clause, rather than only the claimant or the claimant's attorney, is an issue of first impression subject to legitimate dispute. | 1 | 2006–2006 |
Flag Const. Co., Inc. v. Olympic Blvd.
neutral
1 sentence2006See Lumberman's, Inc., 89 Wash.App. 283 , 949 P.2d 382 (lien claim invalid where the claimant signed the lien notice but failed to sign the attestation clause); Flag Constr., 109 Wash.App. 286 , 34 P.3d 1250 (lien claim invalid where claimant signed the lien, a notary signed the verification, but the claimant did not sign the verification); compare with Fircrest Supply, Inc. v. Plummer, 30 Wash.App. 384 , 634 P.2d 891 (1981) (lien claim substantially complied with RCW 60.04.091 although the claimant did not sign the lien because the notary's signature following the claimant's typed name indica | 1 | 2006–2006 |
Intermountain Electric, Inc. v. G-A-T Bros. Construction, Inc.
green
1 sentence2006Intermountain, 115 Wash.App. at 394 , 62 P.3d 548 . ¶ 25 Whether RCW 60.04.091 permits any authorized agent to sign the attestation clause, rather than only the claimant or the claimant's attorney, is an issue of first impression subject to legitimate dispute. | 1 | 2006–2006 |
Carpenter v. Elway
green
2 sentences2002Thus, the April 30 certification complied with CR 5(b)(1) and MAR 7.1(a)." Carpenter, 97 Wash.App. at 990 n. 6, 988 P.2d 1009 . [4] We also made a passing reference to the attestation requirement for MAR 7.1 service-by-mail in Sunderland, 100 Wash.App. at 328 , 995 P.2d 614 : [T]he CR 5(b)(2)(B) attestation requirement for service by mail also applies to service by delivery and requires a sworn statement by the messenger that service did in fact occur; and that proof of service must be done by attestation in light of [the] Nevers policy of strict compliance. [5] The trial court found that the 2002Thus, the April 30 certification complied with CR 5(b)(1) and MAR 7.1(a)." Carpenter, 97 Wash.App. at 990 n. 6, 988 P.2d 1009 . [4] We also made a passing reference to the attestation requirement for MAR 7.1 service-by-mail in Sunderland, 100 Wash.App. at 328 , 995 P.2d 614 : [T]he CR 5(b)(2)(B) attestation requirement for service by mail also applies to service by delivery and requires a sworn statement by the messenger that service did in fact occur; and that proof of service must be done by attestation in light of [the] Nevers policy of strict compliance. [5] The trial court found that the | 1 | 2002–2002 |
Sunderland v. ALLSTATE INDEMN. CO.
green
1 sentence2002Thus, the April 30 certification complied with CR 5(b)(1) and MAR 7.1(a)." Carpenter, 97 Wash.App. at 990 n. 6, 988 P.2d 1009 . [4] We also made a passing reference to the attestation requirement for MAR 7.1 service-by-mail in Sunderland, 100 Wash.App. at 328 , 995 P.2d 614 : [T]he CR 5(b)(2)(B) attestation requirement for service by mail also applies to service by delivery and requires a sworn statement by the messenger that service did in fact occur; and that proof of service must be done by attestation in light of [the] Nevers policy of strict compliance. [5] The trial court found that the | 1 | 2002–2002 |
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.