purely objective test (Washington) · Go Syfert
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purely objective test in Washington

15 Washington opinions name it 1 courts 1997–2019 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.

Followed or applied (6)

CaseFollowedCited
State v. Younggreen
wash · 1998 · cited in 5 Washington opinions naming this issue, 2001–2019
2 sentences

2019Subsequently, our Supreme Court rejected the application of this test to article I, section 7 seizure analysis, instead applying a purely objective standard, Young, 135 Wn.2d at 509-11 , which focuses not on whether the subject perceived that he or she was being ordered to restrict his or her movement but, 3 "In a challenge to the validity of a Terry stop, article 1, section 7 generally tracks the Fourth Amendment analysis." State v. Z.U.E., 183 Wn.2d 610, 617 , 352 P.3d 796 (2015). -9- No. 77720-3-1/10 rather, on whether the officer's words and actions would have conveyed that meaning to a re

2018The Washington Constitution, the Young court announced, requires application of a purely objective standard, 135 Wn.2d at 509-11 ,focusing not on whether the suspect subjectively perceived that he or she was being ordered to restrict his or her movements but, rather, on whether the officer's words and actions would have conveyed that meaning to a reasonable person. 135 Wn.2d at 506 .5 5"The 'purely objective' standard articulated in young rejected the Fourth Amendment seizure test, which contains a subjective element.

25
State v. Ladsongreen
wash · 1999 · cited in 3 Washington opinions naming this issue, 2003–2008
2 sentences

2008Id. ¶17 The State argues that, because the trial court found that Sergeant Dresker was credible in his testimony that he did not follow the van hoping to find a legal reason to stop it and his subjective intent was to stop the van and cite the driver for not having his headlights on, Sergeant Dresker’s testimony about his own subjective intent is dispositive. 1 We disagree. ¶18 In Ladson, the Washington Supreme Court rejected the purely objective test for pretext stops because “an objective test may not fully answer the critical inquiry: Was the officer conducting a pretextual traffic stop or

2008Id. ¶17 The State argues that, because the trial court found that Sergeant Dresker was credible in his testimony that he did not follow the van hoping to find a legal reason to stop it and his subjective intent was to stop the van and cite the driver for not having his headlights on, Sergeant Dresker’s testimony about his own subjective intent is dispositive. 1 We disagree. ¶18 In Ladson, the Washington Supreme Court rejected the purely objective test for pretext stops because “an objective test may not fully answer the critical inquiry: Was the officer conducting a pretextual traffic stop or

23
State v. Chapingreen
washctapp · 1994 · cited in 5 Washington opinions naming this issue, 1999–2008
2 sentences

2008Id. ¶17 The State argues that, because the trial court found that Sergeant Dresker was credible in his testimony that he did not follow the van hoping to find a legal reason to stop it and his subjective intent was to stop the van and cite the driver for not having his headlights on, Sergeant Dresker’s testimony about his own subjective intent is dispositive. 1 We disagree. ¶18 In Ladson, the Washington Supreme Court rejected the purely objective test for pretext stops because “an objective test may not fully answer the critical inquiry: Was the officer conducting a pretextual traffic stop or

2008Id. ¶ 17 The State argues that, because the trial court found that Sergeant Dresker was credible in his testimony that he did not follow the van hoping to find a legal reason to stop it and his subjective intent was to stop the van and cite the driver for not having his headlights on, Sergeant Dresker's testimony about his own subjective intent is dispositive. [1] We disagree. ¶ 18 In Ladson, the Washington Supreme Court rejected the purely objective test for pretext stops because "an objective test may not fully answer the critical inquiry: Was the officer conducting a pretextual traffic stop

15
California v. Hodari D.green
scotus · 1991 · cited in 1 Washington opinions naming this issue, 2018–2018
2 sentences

2018See California v. Hodari D., 499 U.S. 621, 626 , 111 S. Ct. 1547 , 113 L.

2018See California v. Hodari D., 499 U.S. 621, 626 , 111 S. Ct. 1547 , 113 L.

11
State v. Younggreen
wash · 1998 · cited in 1 Washington opinions naming this issue, 2001–2001
2 sentences

2001See Young, 135 Wash.2d at 501 , 957 P.2d 681 ; see also id. at 514, 957 P.2d 681 (concluding that the shining of a spotlight alone, "without additional indicia of authority," does not constitute a seizure).

2001See Young, 135 Wash.2d at 501 , 957 P.2d 681 ; see also id. at 514, 957 P.2d 681 (concluding that the shining of a spotlight alone, "without additional indicia of authority," does not constitute a seizure).

11
Whren v. United Statesgreen
scotus · 1996 · cited in 1 Washington opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Whren v. United States, 517 U.S. 806 , 116 S. Ct. 1769, 1774 , 135 L.

1997See, e.g., Whren v. United States, 517 U.S. 806 , 116 S. Ct. 1769, 1774 , 135 L.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
State v. Ladson green
wash · 1999
2 sentences

2008Id. ¶ 17 The State argues that, because the trial court found that Sergeant Dresker was credible in his testimony that he did not follow the van hoping to find a legal reason to stop it and his subjective intent was to stop the van and cite the driver for not having his headlights on, Sergeant Dresker's testimony about his own subjective intent is dispositive. [1] We disagree. ¶ 18 In Ladson, the Washington Supreme Court rejected the purely objective test for pretext stops because "an objective test may not fully answer the critical inquiry: Was the officer conducting a pretextual traffic stop

2008Id. ¶ 17 The State argues that, because the trial court found that Sergeant Dresker was credible in his testimony that he did not follow the van hoping to find a legal reason to stop it and his subjective intent was to stop the van and cite the driver for not having his headlights on, Sergeant Dresker's testimony about his own subjective intent is dispositive. [1] We disagree. ¶ 18 In Ladson, the Washington Supreme Court rejected the purely objective test for pretext stops because "an objective test may not fully answer the critical inquiry: Was the officer conducting a pretextual traffic stop

22003–2008
Department of Labor & Industries v. Avundes green
wash · 2000
2 sentences

2006Avundes, 140 Wash.2d at 289-90 , 996 P.2d 593 .

2006Avundes, 140 Wn.2d at 289-90 .

22006–2006
State v. Z.U.E. green
wash · 2015
2 sentences

2019Subsequently, our Supreme Court rejected the application of this test to article I, section 7 seizure analysis, instead applying a purely objective standard, Young, 135 Wn.2d at 509-11 , which focuses not on whether the subject perceived that he or she was being ordered to restrict his or her movement but, 3 "In a challenge to the validity of a Terry stop, article 1, section 7 generally tracks the Fourth Amendment analysis." State v. Z.U.E., 183 Wn.2d 610, 617 , 352 P.3d 796 (2015). -9- No. 77720-3-1/10 rather, on whether the officer's words and actions would have conveyed that meaning to a re

2019Subsequently, our Supreme Court rejected the application of this test to article I, section 7 seizure analysis, instead applying a purely objective standard, Young, 135 Wn.2d at 509-11 , which focuses not on whether the subject perceived that he or she was being ordered to restrict his or her movement but, 3 "In a challenge to the validity of a Terry stop, article 1, section 7 generally tracks the Fourth Amendment analysis." State v. Z.U.E., 183 Wn.2d 610, 617 , 352 P.3d 796 (2015). -9- No. 77720-3-1/10 rather, on whether the officer's words and actions would have conveyed that meaning to a re

12019–2019
State v. Bliss green
washctapp · 2009
1 sentence

2013State v. Bliss, 153 Wn.App. 197, 203 , 222 P. d 3 107 (2009).To facilitate our review,the trial court is required to enter written findings of fact and conclusions of law at the conclusion of a suppression hearing.

12013–2013
United States v. Mendenhall green
scotus · 1980
2 sentences

2013State v. Young, 135 Wn. d 498, 501, 957 P. d 681 (1998). 2 2 Circumstances that are likely to result in a seizure include "the threatening presence of several officers, the display of a weapon by an officer, some physical touching of the person of the citizen, or the use of language or tone of voice indicating that compliance with the officer's request might be compelled." Young, 135 Wri.2d at 512 (quoting United States v. Mendenhall, 446 U. . 544, 554, 100 S. Ct. 1870 , 64 L.

2013State v. Young, 135 Wn. d 498, 501, 957 P. d 681 (1998). 2 2 Circumstances that are likely to result in a seizure include "the threatening presence of several officers, the display of a weapon by an officer, some physical touching of the person of the citizen, or the use of language or tone of voice indicating that compliance with the officer's request might be compelled." Young, 135 Wri.2d at 512 (quoting United States v. Mendenhall, 446 U. . 544, 554, 100 S. Ct. 1870 , 64 L.

12013–2013
Dept. of Labor and Industries v. AVUDES green
wash · 2000
1 sentence

2006Avundes, 140 Wash.2d at 289-90 , 996 P.2d 593 .

12006–2006
State v. Loewen green
wash · 1982
1 sentence

1997Id.; Loewen, 97 Wn.2d at 568 .

11997–1997

Statutes the citing opinions construe

WA § Wash. Rev. Code § 46.20.342 (4)

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.

Where else courts name it

CA 22 (1984–2026) WA 15 (1997–2019) LA 12 (2006–2023) TX 8 (2001–2021) VA 5 (1997–2026) AL 4 (1991–2005) CT 3 (1993–2003) AZ 3 (2010–2017) NM 2 (2000–2005) MA 2 (1984–1995) IA 2 (1992–1995) PA 2 (1992–2012) MI 2 (1995–2020) NY 2 (1995–1998)

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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