15 Washington opinions name it 2 courts 2006–2025 5 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 the Truancy of Perkinsgreen2 sentences2011While it is true that the initial hearing with which we are here concerned must precede a contempt hearing, the "mere possibility that an order in a hearing may later serve as the predicate for a contempt adjudication is not enough to entitle an indigent party therein to free legal assistance." Tetro v. Tetro, 86 Wash.2d 252 , 255 n. 1, 544 P.2d 17 (1975); see also In re Truancy of Perkins, 93 Wash.App. 590 , 969 P.2d 1101 (concluding that children are not entitled to appointed counsel at the initial truancy hearing), review denied, 138 Wash.2d 1003 , 984 P.2d 1033 (1999). 2011While it is true that the initial hearing with which we are here concerned must precede a contempt hearing, the “mere possibility that an order in a hearing may later serve as the predicate for a contempt adjudication is not enough to entitle an indigent party therein to free legal assistance.” Tetro v. Tetro, 86 Wn.2d 252 , 255 n.1, 544 P.2d 17 (1975); see also In re Truancy of Perkins, 93 Wn. | 2 | 2 |
In re of J.R.H.green2 sentences2011See In re J.R.H., 83 Wash.App. 613, 616 , 922 P.2d 206 (1996) (court order cannot be collaterally attacked in contempt proceedings as *585 contempt judgment will stand even if order violated was erroneous or later ruled invalid). 2011See In re J.R.H., 83 Wn. | 2 | 2 |
Perkins v. Stategreen2 sentences2011While it is true that the initial hearing with which we are here concerned must precede a contempt hearing, the "mere possibility that an order in a hearing may later serve as the predicate for a contempt adjudication is not enough to entitle an indigent party therein to free legal assistance." Tetro v. Tetro, 86 Wash.2d 252 , 255 n. 1, 544 P.2d 17 (1975); see also In re Truancy of Perkins, 93 Wash.App. 590 , 969 P.2d 1101 (concluding that children are not entitled to appointed counsel at the initial truancy hearing), review denied, 138 Wash.2d 1003 , 984 P.2d 1033 (1999). 2011App. 590 , 969 P.2d 1101 (concluding that children are not entitled to appointed counsel at the initial truancy hearing), review denied, 138 Wn.2d 1003 , 984 P.2d 1033 (1999). | 1 | 2 |
Matter of Marriage of Sterngreen1 sentence2017See CR 52(a)(2)(B); see also Stern, 68 Wn. | 1 | 1 |
In Re the Personal Restraint of Kinggreen2 sentences2015See King v. Dep' t ofSoc. & Health Servs., 110 Wn.2d 793, 797 , 756 P. 2d 1303 ( 1988) ( intentional disobedience of lawful court order is contempt). 2015See King v. Dep' t ofSoc. & Health Servs., 110 Wn.2d 793, 797 , 756 P. 2d 1303 ( 1988) ( intentional disobedience of lawful court order is contempt). | 1 | 1 |
Matter of Jrhgreen1 sentence2011See In re J.R.H., 83 Wash.App. 613, 616 , 922 P.2d 206 (1996) (court order cannot be collaterally attacked in contempt proceedings as *585 contempt judgment will stand even if order violated was erroneous or later ruled invalid). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Tetro v. Tetro
green
2 sentences2025RIGHT TO ASSIGNED COUNSEL Ms. Cramer contends the trial court abused its discretion when it failed to advise her of her constitutional right to be represented by an attorney at public expense at the contempt hearing. “[W]herever a contempt adjudication may result in incarceration, the person accused of contempt must be provided with state-paid counsel if he or she is unable to afford private representation.” Tetro v. Tetro, 86 Wn.2d 252, 255 , 544 P.2d 17 (1975). 2025RIGHT TO ASSIGNED COUNSEL Ms. Cramer contends the trial court abused its discretion when it failed to advise her of her constitutional right to be represented by an attorney at public expense at the contempt hearing. “[W]herever a contempt adjudication may result in incarceration, the person accused of contempt must be provided with state-paid counsel if he or she is unable to afford private representation.” Tetro v. Tetro, 86 Wn.2d 252, 255 , 544 P.2d 17 (1975). | 3 | 2011–2025 |
In re the Marriage of Eklund
green
2 sentences2020In re Marriage of Eklund, 143 Wn. 2019In re Marriage of Eklund, 143 Wn. | 2 | 2019–2020 |
State v. Hatten
green
1 sentence2021Hatten, 70 Wn.2d at 621 . | 1 | 2021–2021 |
Roe v. Snyder
neutral
1 sentence2021“It was evidence of an independent fact, not touched by any evidence at the trial, but bearing directly and vitally upon the main issue.” Snyder, 100 Wash. at 315 . 15 No. 37037-2-III Thomason v. Stennes At the contempt hearing in this case, the Stenneses offered Bert’s will and Mike’s testimony about Mr. Thomason’s keenness for the Stennes property as circumstantial evidence of a scheme to have the Stenneses evicted. | 1 | 2021–2021 |
Folsom v. County of Spokane
green
1 sentence2021Sean asks us to review an August 2019 writ of 23 While “[r]econsideration of an identical legal issue in a subsequent appeal of the same case will be granted where the holding of the prior appeal is clearly erroneous and the application of the [law of the case] doctrine would result in manifest injustice,” Folsom, 111 Wn.2d at 264 , Sean fails to show that Kuhlmeyer I was clearly erroneous or that manifest injustice results from applying the doctrine. 24 Sean’s briefing alludes to a December 2019 subpoena duces tecum for medical records, but that document is not in the record. 11 No. 81002-2-I | 1 | 2021–2021 |
Joy v. Kaiser Aluminum & Chemical Corp.
green
1 sentence2021App. 909, 911 , 816 P.2d 90 (1991)). 27See Report of Proceedings (RP) (Jan. 29, 2020) at 13 (Kosnoff’s counsel explaining he had no objection to holding the contempt hearing, “[o]ther than our objections on subject matter jurisdiction”). 28 Rabbage, 5 Wn. | 1 | 2021–2021 |
Cowiche Canyon Conservancy v. Bosley
green
2 sentences2017Cowiche Canvon Conservancy v. Boslev, 118 Wn.2d 801, 809 , 828 P.2d 549 (1992). -6- No. 74221-3-1/7 Because the trial court had the authority to hold the contempt hearing and did not misinterpret the parenting plan, its contempt order was not a manifest abuse of discretion. 2017Cowiche Canvon Conservancy v. Boslev, 118 Wn.2d 801, 809 , 828 P.2d 549 (1992). -6- No. 74221-3-1/7 Because the trial court had the authority to hold the contempt hearing and did not misinterpret the parenting plan, its contempt order was not a manifest abuse of discretion. | 1 | 2017–2017 |
In re the Marriage of Mansour
green
1 sentence2016Tiffany cites to In re Marriage of Mansour, 126 Wn. | 1 | 2016–2016 |
Moreman v. Butcher
green
2 sentences2014Moreman v. Butcher, 126 Wn.2d 36, 40 , 891 P.2d 725 7 KCLCR 16(b)(5) reads: "A judge presiding over a settlement conference shall be disqualified from acting as the trial judge in the matter, unless all parties agree in writing that he/she should so act." 8 Neither party designated the transcript of the contempt hearing as part of the record on appeal. 17 No. 69426-0-1/18 (1995). 2014Moreman v. Butcher, 126 Wn.2d 36, 40 , 891 P.2d 725 7 KCLCR 16(b)(5) reads: "A judge presiding over a settlement conference shall be disqualified from acting as the trial judge in the matter, unless all parties agree in writing that he/she should so act." 8 Neither party designated the transcript of the contempt hearing as part of the record on appeal. 17 No. 69426-0-1/18 (1995). | 1 | 2014–2014 |
Rhinevault v. Rhinevault
green
2 sentences2006Shafer v. Bloomer, 94 Wash.App. 246, 253 , 973 P.2d 1062 (1999); Rhinevault, 91 Wash.App. at 695 , 959 P.2d 687 ; In re Marriage of Wulfsberg, 42 Wash.App. 627 , 713 P.2d 132 (1986). [7] In addition, during the contempt hearing the commissioner made statements suggesting that she was concerned with deterrence: "[W]hen you don't support the children, even if you do follow these beliefs right into the jailhouse, if nothing else, the other folks in this courtroom will get the idea that people have to support kids." RP (May 16, 2005) at 11. [8] The commissioner stated, "If within the 30 days, the 2006Shafer v. Bloomer, 94 Wash.App. 246, 253 , 973 P.2d 1062 (1999); Rhinevault, 91 Wash.App. at 695 , 959 P.2d 687 ; In re Marriage of Wulfsberg, 42 Wash.App. 627 , 713 P.2d 132 (1986). [7] In addition, during the contempt hearing the commissioner made statements suggesting that she was concerned with deterrence: "[W]hen you don't support the children, even if you do follow these beliefs right into the jailhouse, if nothing else, the other folks in this courtroom will get the idea that people have to support kids." RP (May 16, 2005) at 11. [8] The commissioner stated, "If within the 30 days, the | 1 | 2006–2006 |
State v. Bloomer
neutral
1 sentence2006Shafer v. Bloomer, 94 Wash.App. 246, 253 , 973 P.2d 1062 (1999); Rhinevault, 91 Wash.App. at 695 , 959 P.2d 687 ; In re Marriage of Wulfsberg, 42 Wash.App. 627 , 713 P.2d 132 (1986). [7] In addition, during the contempt hearing the commissioner made statements suggesting that she was concerned with deterrence: "[W]hen you don't support the children, even if you do follow these beliefs right into the jailhouse, if nothing else, the other folks in this courtroom will get the idea that people have to support kids." RP (May 16, 2005) at 11. [8] The commissioner stated, "If within the 30 days, the | 1 | 2006–2006 |
State Ex Rel. Shafer v. Bloomer
neutral
1 sentence2006Shafer v. Bloomer, 94 Wash.App. 246, 253 , 973 P.2d 1062 (1999); Rhinevault, 91 Wash.App. at 695 , 959 P.2d 687 ; In re Marriage of Wulfsberg, 42 Wash.App. 627 , 713 P.2d 132 (1986). [7] In addition, during the contempt hearing the commissioner made statements suggesting that she was concerned with deterrence: "[W]hen you don't support the children, even if you do follow these beliefs right into the jailhouse, if nothing else, the other folks in this courtroom will get the idea that people have to support kids." RP (May 16, 2005) at 11. [8] The commissioner stated, "If within the 30 days, the | 1 | 2006–2006 |
In re the Marriage of Wulfsberg
green
2 sentences2006Shafer v. Bloomer, 94 Wash.App. 246, 253 , 973 P.2d 1062 (1999); Rhinevault, 91 Wash.App. at 695 , 959 P.2d 687 ; In re Marriage of Wulfsberg, 42 Wash.App. 627 , 713 P.2d 132 (1986). [7] In addition, during the contempt hearing the commissioner made statements suggesting that she was concerned with deterrence: "[W]hen you don't support the children, even if you do follow these beliefs right into the jailhouse, if nothing else, the other folks in this courtroom will get the idea that people have to support kids." RP (May 16, 2005) at 11. [8] The commissioner stated, "If within the 30 days, the 2006Shafer v. Bloomer, 94 Wash.App. 246, 253 , 973 P.2d 1062 (1999); Rhinevault, 91 Wash.App. at 695 , 959 P.2d 687 ; In re Marriage of Wulfsberg, 42 Wash.App. 627 , 713 P.2d 132 (1986). [7] In addition, during the contempt hearing the commissioner made statements suggesting that she was concerned with deterrence: "[W]hen you don't support the children, even if you do follow these beliefs right into the jailhouse, if nothing else, the other folks in this courtroom will get the idea that people have to support kids." RP (May 16, 2005) at 11. [8] The commissioner stated, "If within the 30 days, the | 1 | 2006–2006 |
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.