compulsory process clause in Washington

15 Washington opinions name it 2 courts 1981–2025 3 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 (14)

Case	Followed	Cited
Rock v. Arkansasgreen scotus · 1987 · cited in 5 Washington opinions naming this issue, 1996–1999 2 sentences 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	5
State v. Thomasgreen wash · 1996 · cited in 3 Washington opinions naming this issue, 1999–1999 2 sentences 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	3
Taylor v. Illinoisgreen scotus · 1988 · cited in 2 Washington opinions naming this issue, 2012–2021 2 sentences 2021Ed. 2d 798 (1988),] which permits exclusion of defense witness testimony as a sanction for discovery violations”). 60 Id. at 882-83 (citing Taylor, 484 U.S. at 415 n.19). 61See Taylor, 484 U.S. at 410 (explaining the compulsory process clause “provides the defendant with a sword that may be employed to rebut the prosecution’s case” and is utilized only upon “the defendant’s initiative”). 17 No. 78071-9-I/18 and disclose the report under CrRLJ 4.7(d), and it failed to do so. 2021Ed. 2d 798 (1988),] which permits exclusion of defense witness testimony as a sanction for discovery violations”). 60 Id. at 882-83 (citing Taylor, 484 U.S. at 415 n.19). 61See Taylor, 484 U.S. at 410 (explaining the compulsory process clause “provides the defendant with a sword that may be employed to rebut the prosecution’s case” and is utilized only upon “the defendant’s initiative”). 17 No. 78071-9-I/18 and disclose the report under CrRLJ 4.7(d), and it failed to do so.	1	2
State v. Thomasgreen wash · 1996 · cited in 2 Washington opinions naming this issue, 1999–1999 2 sentences 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	2
cluster 521018green ca8 · 1989 · cited in 1 Washington opinions naming this issue, 2023–2023 2 sentences 2023The Eighth Circuit Court of Appeals has held that a criminal defendant’s rights under the compulsory process clause of the Sixth Amendment require the Valenzuela- Bernal showing that the testimony of the proposed witnesses is favorable and material. 18 No. 38604-0-III State v. Young Perry v. Lockhart, 871 F.2d 1384, 1386-87 (8th Cir. 1989); accord Wright v. Lockhart, 914 F.2d 1093, 1098 (8th Cir. 1990) (holding that the omitted evidence must be evaluated in the “context of the entire record,” quoting Valenzuela-Bernal’s reliance on language from Agurs). 2023In Perry, the State conceded that the state trial court’s ruling denying Perry’s request for a court order compelling the presence of several witnesses had been erroneous. 871 F.2d at 1387 .	1	1
James C. Wright v. A.L. Lockhart, Director, Arkansas Department of Correctiongreen ca8 · 1990 · cited in 1 Washington opinions naming this issue, 2023–2023 1 sentence 2023The Eighth Circuit Court of Appeals has held that a criminal defendant’s rights under the compulsory process clause of the Sixth Amendment require the Valenzuela- Bernal showing that the testimony of the proposed witnesses is favorable and material. 18 No. 38604-0-III State v. Young Perry v. Lockhart, 871 F.2d 1384, 1386-87 (8th Cir. 1989); accord Wright v. Lockhart, 914 F.2d 1093, 1098 (8th Cir. 1990) (holding that the omitted evidence must be evaluated in the “context of the entire record,” quoting Valenzuela-Bernal’s reliance on language from Agurs).	1	1
Tachibana v. Stategreen haw · 1995 · cited in 1 Washington opinions naming this issue, 1999–1999 2 sentences 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1
People v. Romangreen nysupct · 1997 · cited in 1 Washington opinions naming this issue, 1999–1999 2 sentences 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1
State v. Robinsongreen washctapp · 1998 · cited in 1 Washington opinions naming this issue, 1999–1999 2 sentences 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1
United States v. Eddie Edwardsgreen ca9 · 1990 · cited in 1 Washington opinions naming this issue, 1999–1999 2 sentences 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1
State v. Robinsongreen washctapp · 1997 · cited in 1 Washington opinions naming this issue, 1999–1999 2 sentences 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1
Medina-Quiroga v. United Statesgreen scotus · 1990 · cited in 1 Washington opinions naming this issue, 1999–1999 1 sentence 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1
Marrero v. United Statesgreen scotus · 1990 · cited in 1 Washington opinions naming this issue, 1999–1999 1 sentence 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1
Sumlin v. United Statesgreen scotus · 1990 · cited in 1 Washington opinions naming this issue, 1999–1999 1 sentence 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (14)

Case	Cited	Years
Holmes v. South Carolina green scotus · 2006 2 sentences 2020Whether rooted in the compulsory process clause of the Sixth Amendment or the due process clause of the Fourteenth Amendment, the United States Constitution guarantees a criminal defendant” ‘a meaningful opportunity to present a complete defense.’” Holmes v. South Carolina, 547 U.S. 319, 324 , 126 S. Ct. 1727 , 164 L. 2020Whether rooted in the compulsory process clause of the Sixth Amendment or the due process clause of the Fourteenth Amendment, the United States Constitution guarantees a criminal defendant” ‘a meaningful opportunity to present a complete defense.’” Holmes v. South Carolina, 547 U.S. 319, 324 , 126 S. Ct. 1727 , 164 L.	4	2015–2025
Crane v. Kentucky green scotus · 1986 2 sentences 2020Ed. 2d 503 (2006)14 (quoting Crane v. Kentucky, 476 U.S. 683, 690 , 106 S. Ct. 2142 , 90 L. 2020Ed. 2d 503 (2006)14 (quoting Crane v. Kentucky, 476 U.S. 683, 690 , 106 S. Ct. 2142 , 90 L.	3	2015–2020
United States v. Valenzuela-Bernal green scotus · 1982 2 sentences 2015The right to compulsory process is not absolute. “[M]ore than the mere absence of testimony is necessary to establish a violation of the right.” United States v. Valenzuela-Bernal, 458 U.S. 858, 867 , 102 S. Ct. 3440 , 73 L. 2013The failure to comply with the transport order under those circumstances, in my view, could raise issues under the compulsory process clause of the Sixth Amendment to the United States Constitution or the due process clause of the Fourteenth Amendment by analogy to cases such as United States v. Valenzuela -Bernal, 458 U. . 858, 102 S. Ct. 3440 , 73 L.Ed. 2d S 1193 (1982).Although Valenzuela -Bernal involved federal deportation of potential witnesses in a federal prosecution, its rationale could reach situations where but for noncompliance with a state court order, a potentially exculpatory wi	2	2013–2015
State v. Gunwall green wash · 1986 2 sentences 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	2	1998–1999
Alaska Steamship Co. v. Petterson green scotus · 1954 1 sentence 2021Ed. 2d 798 (1988),] which permits exclusion of defense witness testimony as a sanction for discovery violations”). 60 Id. at 882-83 (citing Taylor, 484 U.S. at 415 n.19). 61See Taylor, 484 U.S. at 410 (explaining the compulsory process clause “provides the defendant with a sword that may be employed to rebut the prosecution’s case” and is utilized only upon “the defendant’s initiative”). 17 No. 78071-9-I/18 and disclose the report under CrRLJ 4.7(d), and it failed to do so.	1	2021–2021
State v. Jones green wash · 2010 1 sentence 2015State v. Jones, 168 Wn.2d 713, 719 , 230 P.3d 576 (2010). ¶61 Whether rooted in the compulsory process clause of the Sixth Amendment or the due process clause of the Fourteenth Amendment, the United States Constitution guarantees a criminal defendant “ ‘a meaningful opportunity to present a complete defense.’” Holmes v. South Carolina, 547 U.S. 319, 324 , 126 S. Ct. 1727 , 164 L.	1	2015–2015
State v. Ramos green wash · 2010 1 sentence 2015State v. Jones, 168 Wn.2d 713, 719 , 230 P.3d 576 (2010). ¶61 Whether rooted in the compulsory process clause of the Sixth Amendment or the due process clause of the Fourteenth Amendment, the United States Constitution guarantees a criminal defendant “ ‘a meaningful opportunity to present a complete defense.’” Holmes v. South Carolina, 547 U.S. 319, 324 , 126 S. Ct. 1727 , 164 L.	1	2015–2015
Brown v. Artuz green scotus · 1998 1 sentence 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1999–1999
State v. Taylor green washctapp · 1981 2 sentences 1999After all, "[p]retrial hearings are but mechanical devices designed to effectuate substantive rights and remedies." State v. Taylor, 30 Wash.App. 89, 93 , 632 P.2d 892 (citing State v. Wilson, 28 Wash.App. 821 , 626 P.2d 998 , review denied, 96 Wash.2d 1022 (1981)), review denied, 96 Wash.2d 1012 (1981). 1999After all, "[p]retrial hearings are but mechanical devices designed to effectuate substantive rights and remedies." State v. Taylor, 30 Wash.App. 89, 93 , 632 P.2d 892 (citing State v. Wilson, 28 Wash.App. 821 , 626 P.2d 998 , review denied, 96 Wash.2d 1022 (1981)), review denied, 96 Wash.2d 1012 (1981).	1	1999–1999
State v. Copeland green wash · 1996 1 sentence 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1999–1999
James Brown v. Christopher Artuz green ca2 · 1997 1 sentence 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1999–1999
State v. Copeland green wash · 1996 1 sentence 1999NOTES [1] RCW 9.94A.030(23), (27) and RCW 9.94A.120(4). [2] State v. Copeland, 130 Wash.2d 244, 294 , 922 P.2d 1304 (1996). [3] This section provides that a criminal defendant has the right "to testify in his own behalf." [4] Rock v. Arkansas, 483 U.S. 44, 49, 51-53 , 107 S.Ct. 2704 , 97 L.Ed.2d 37 (1987) (stating that the right has been derived from the fourteenth amendment's due process clause, the compulsory process clause of the sixth amendment, and as a necessary corollary to the fifth amendment's privilege against self-incrimination). [5] State v. Gunwall, 106 Wash.2d 54, 61-62 , 720 P.2	1	1999–1999
State v. Wilson green washctapp · 1981 1 sentence 1999After all, "[p]retrial hearings are but mechanical devices designed to effectuate substantive rights and remedies." State v. Taylor, 30 Wash.App. 89, 93 , 632 P.2d 892 (citing State v. Wilson, 28 Wash.App. 821 , 626 P.2d 998 , review denied, 96 Wash.2d 1022 (1981)), review denied, 96 Wash.2d 1012 (1981).	1	1999–1999
State v. Geer green washctapp · 1975 1 sentence 1981We repeated in Blum what we first observed in State v. Geer, 13 Wn.	1	1981–1981

Where else courts name it

CA 21 (1982–2025) OR 17 (1954–2022) WA 15 (1981–2025) IL 14 (1981–2014) TX 12 (1983–2022) LA 11 (1981–2017) CT 11 (1989–2025) MA 11 (1978–2015) MD 10 (1983–2017) PA 8 (1979–1992) WI 8 (1989–2025) ID 8 (1985–2024) CO 7 (1986–2004) WV 6 (1987–2020) IN 6 (2006–2011) NH 6 (1978–1997) AZ 5 (1988–2024) WY 5 (1990–2017) NC 5 (1983–2025) NJ 5 (1978–1990) FL 4 (1984–2025) NM 3 (1988–1990) HI 3 (1980–2013) NV 3 (1989–2016) OK 3 (1992–2020) VA 3 (1996–2002) RI 2 (1989–1995) MO 2 (1994–1997) MS 2 (2007–2007) DE 2 (1984–1986) ND 2 (1982–1992) MI 2 (1982–1986) DC 2 (1986–1987) AK 2 (1977–2008) ME 2 (2000–2003) NE 2 (1993–2020)

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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