15 Washington opinions name it 2 courts 1982–2025 2 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 |
|---|---|---|
United States v. Hinojosagreen2 sentences2014The court explained that there was no need to extend the Edwards prohibition to encompass foreign interrogations where the reasoning for the Edwards rule does not apply, particularly when "a request for counsel made in connection with a foreign investigation may result only from the American suspect's unfamiliarity with the foreign legal system and does not necessarily mean that the suspect is unwilling to talk to an American investigator until he has been provided counsel." !d.; accord United States v. Hinojosa, 33 M.J. 353, 355 (C.M.A. 1991) (reasoning that "appellant's request for an attorn 2014The court explained that there was no need to extend the Edwards prohibition to encompass foreign interrogations where the reasoning for the Edwards rule does not apply, particularly when “a request for counsel made in connection with a foreign investigation may result only from the American suspect’s unfamiliarity with the foreign legal system and does not necessarily mean that the suspect is unwilling to talk to an American investigator until he has been provided counsel.” Id.; accord United States v. Hinojosa, 33 M.J. 353, 355 (C.M.A. 1991) (reasoning that “appellant’s request for an attorn | 2 | 2 |
State v. Dunawaygreen2 sentences2023Drawing from Dunaway, the court in Lewis applied the Edwards’ factors and held that “[b]ecause the four violations of the Uniform Controlled Substances Act by the defendant were carried out on separate dates and Lewis formed a separate objective criminal intent to execute each act, his crimes were not ‘same criminal conduct.’” Id. at 303 (emphasis added). 15 No. 100570-9 Madsen, J., dissenting As to the first element under Dunaway, Lewis’ criminal intent, as objectively viewed, changed from one crime to the next because he formed a different intent between each delivery. 2023As to the second element, “[Lewis’] acts were not part of a single criminal conduct because the commission of one drug deal did not further the commission of the other drug deals, and they were not part of a recognizable scheme or plan.” Id. at 302 . | 1 | 1 |
State v. Griergreen1 sentence2012See Grier, 171 Wn.2d at 42 . | 1 | 1 |
State v. Salinasgreen1 sentence2012See Salinas, 119 Wn.2d at 201 . | 1 | 1 |
Desist v. United Statesgreen2 sentences1983See Desist v. United States, 394 U.S. 244 , 22 L.Ed.2d 248 , 89 S.Ct. 1030 (1969); State v. Barton, 93 Wn.2d 615 , 611 P.2d 789 (1980). [1, 2] Had our decision in Edwards been the equivalent of a "new" procedural rule, a traditional retroactivity analysis might be appropriate; [3] however, the Court of Appeals in Darden misconstrued Edwards . 1983See Desist v. United States, 394 U.S. 244 , 22 L.Ed.2d 248 , 89 S.Ct. 1030 (1969); State v. Barton, 93 Wn.2d 615 , 611 P.2d 789 (1980). [1, 2] Had our decision in Edwards been the equivalent of a "new" procedural rule, a traditional retroactivity analysis might be appropriate; [3] however, the Court of Appeals in Darden misconstrued Edwards . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Arizona v. Roberson
green
2 sentences2013Id. at 484-85 . ¶16 In Arizona v. Roberson, the United States Supreme Court extended the Edwards rule to custodial interrogation in a separate investigation. 486 U.S. 675, 677 , 108 S. Ct. 2093 , 100 L. 2013Id. at 484-85 . ¶16 In Arizona v. Roberson, the United States Supreme Court extended the Edwards rule to custodial interrogation in a separate investigation. 486 U.S. 675, 677 , 108 S. Ct. 2093 , 100 L. | 5 | 1989–2014 |
Edwards v. Arizona
green
2 sentences2013Id. at 484-85 . ¶16 In Arizona v. Roberson, the United States Supreme Court extended the Edwards rule to custodial interrogation in a separate investigation. 486 U.S. 675, 677 , 108 S. Ct. 2093 , 100 L. 2013Id. at 484-85 . ¶16 In Arizona v. Roberson, the United States Supreme Court extended the Edwards rule to custodial interrogation in a separate investigation. 486 U.S. 675, 677 , 108 S. Ct. 2093 , 100 L. | 2 | 1989–2013 |
Davis v. United States
green
2 sentences2007Davis, 512 U.S. at 459-60 . 2007Davis, 512 U.S. at 459-60 . | 2 | 2007–2007 |
Quinn v. Cherry Lane Auto Plaza, Inc.
green
1 sentence2025However, “an appellate court is simply not permitted to reweigh the evidence and come to a contrary finding.” Quinn v. Cherry Lane Auto Plaza, Inc., 153 Wn. | 1 | 2025–2025 |
State v. Edwards
green
2 sentences2023Id. at 214-15 (citing Edwards, 45 Wn. 2023Id. at 214-15 (citing Edwards, 45 Wn. | 1 | 2023–2023 |
Maryland v. Shatzer
green
2 sentences2018But, in Maryland v. Shatzer, the United States Supreme Court held that the Edwards rule does not apply to a break in custody lasting 14 days or more. 559 U.S. 98, 110 , 130 S. Ct. 1213 , 175 L. 2018But, in Maryland v. Shatzer, the United States Supreme Court held that the Edwards rule does not apply to a break in custody lasting 14 days or more. 559 U.S. 98, 110 , 130 S. Ct. 1213 , 175 L. | 1 | 2018–2018 |
United States v. Santistevan
green
2 sentences2018Relying on United States v. Santistevan, 701 F.3d 1289 (10th Cir. 2012), Halfhill argues that he invoked his Miranda rights during his second interrogation 10 No. 77246-5-I/li when he specifically referred to his earlier invocation of rights. 2018Relying on United States v. Santistevan, 701 F.3d 1289 (10th Cir. 2012), Halfhill argues that he invoked his Miranda rights during his second interrogation 10 No. 77246-5-I/li when he specifically referred to his earlier invocation of rights. | 1 | 2018–2018 |
United States v. Pedro Angel Gomez
green
1 sentence2014United States v. Thomas, 521 F. App' x. 878, 882 -83 ( 11th Cir. 2013) ( statement obtained 20 minutes after Edwards violation involuntary as a matter of law); United States v. Gomez, 927 F. 2d 1530 , 1538- 39 ( 11th Cir. 1991) ( statement obtained less than a few minutes after Edwards violation involuntary as a matter of law). | 1 | 2014–2014 |
Noel v. Cole
green
2 sentences1984In Noel v. Cole, 98 Wn.2d 375 , 655 P.2d 245 (1982), the court most recently affirmed the Edwards analysis. 1984In Noel v. Cole, 98 Wn.2d 375 , 655 P.2d 245 (1982), the court most recently affirmed the Edwards analysis. | 1 | 1984–1984 |
Finch v. Matthews
green
2 sentences1984The Edwards rule was further explained in Finch v. Matthews, 74 Wn.2d 161 , 443 P.2d 833 (1968). 1984The Edwards rule was further explained in Finch v. Matthews, 74 Wn.2d 161 , 443 P.2d 833 (1968). | 1 | 1984–1984 |
State v. Barton
green
2 sentences1983See Desist v. United States, 394 U.S. 244 , 22 L.Ed.2d 248 , 89 S.Ct. 1030 (1969); State v. Barton, 93 Wn.2d 615 , 611 P.2d 789 (1980). [1, 2] Had our decision in Edwards been the equivalent of a "new" procedural rule, a traditional retroactivity analysis might be appropriate; [3] however, the Court of Appeals in Darden misconstrued Edwards . 1983See Desist v. United States, 394 U.S. 244 , 22 L.Ed.2d 248 , 89 S.Ct. 1030 (1969); State v. Barton, 93 Wn.2d 615 , 611 P.2d 789 (1980). [1, 2] Had our decision in Edwards been the equivalent of a "new" procedural rule, a traditional retroactivity analysis might be appropriate; [3] however, the Court of Appeals in Darden misconstrued Edwards . | 1 | 1983–1983 |
State v. Schapiro
green
2 sentences1982We believe the administration of justice and integrity of the judicial process *897 would be damaged by dismissing convictions because the State failed to anticipate a decision which we said in State v. Schapiro, 28 Wn. 1982We believe the administration of justice and integrity of the judicial process *897 would be damaged by dismissing convictions because the State failed to anticipate a decision which we said in State v. Schapiro, 28 Wn. | 1 | 1982–1982 |
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.