writing requirement (Washington) · Go Syfert
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writing requirement in Washington

15 Washington opinions name it 1 courts 1982–2019 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 (5)

CaseFollowedCited
Zimmerman v. Kytegreen
washctapp · 1988 · cited in 2 Washington opinions naming this issue, 2009–2009
2 sentences

2009See Zimmerman v. Kyte, 53 Wash.App. 11, 17-18 , 765 P.2d 905 (1988).

2009See Zimmerman v. Kyte, 53 Wn.

22
State v. Harrisgreen
· 1992 · cited in 1 Washington opinions naming this issue, 2012–2012
1 sentence

2012See Harris, 66 Wn.

11
United States v. Ruth M. Andersongreen
ca3 · 1983 · cited in 1 Washington opinions naming this issue, 1983–1983
1 sentence

1983See United States v. Anderson, 704 F.2d 117 (3d Cir. 1983); United States v. Martin, 704 F.2d 267 (6th Cir. 1983); United States v. *146 Scott, 583 F.2d 362 (7th Cir. 1978). 3 These decisions are persuasive because the writing requirement applied in the federal courts is virtually identical to CrR 6.1(a) in both language and purpose.

11
United States v. Eric Charles Martin, A/K/A Mickey Milton Arringtongreen
ca6 · 1983 · cited in 1 Washington opinions naming this issue, 1983–1983
2 sentences

1983See United States v. Anderson, 704 F.2d 117 (3d Cir. 1983); United States v. Martin, 704 F.2d 267 (6th Cir. 1983); United States v. *146 Scott, 583 F.2d 362 (7th Cir. 1978). 3 These decisions are persuasive because the writing requirement applied in the federal courts is virtually identical to CrR 6.1(a) in both language and purpose.

1983P. 23(a), which imposes a writing requirement almost identical to CrR 6.1(a), "is designed to impress the defendant with the gravity of the right relinquished and provide the best evidence of the defendant's voluntary consent." (Italics ours.) United States v. Martin, 704 F.2d 267, 271 (6th Cir. 1983). 3 The Seventh Circuit, however, has adopted a colloquy requirement pursuant to its supervisory power.

11
Klehn v. Territory of Washingtongreen
wash · 1889 · cited in 1 Washington opinions naming this issue, 1982–1982
1 sentence

1982Cf. Community Sav. & Loan Ass'n v. Fisher, 409 S.W.2d 546 (Tex. 1966); see also Hazard v. Maxon, 1 Wash. Terr. 584 (1878) (under the original statute governing interest rates only the legal rate of interest could be recovered on a contract which was so ambiguous as to render it uncertain whether more than such rate was stipulated for).

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 (17)

CaseCitedYears
Topline Equipment, Inc. v. Stan Witty Land, Inc. green
washctapp · 1982
2 sentences

2015In Topline Equip., Inc. v. Stan Witty Land, Inc., we examined the writing requirement of RCW 19. 52. 010, and held that the writing must specify the interest rate sought, or at least provide information sufficient to calculate the interest rate. 31 Wn.

2015In Topline Equipment, Inc. v. Stan Witty Land, Inc., we examined the writing requirement of RCW 19.52.010, and held that the writing must specify the interest rate sought, or at least provide information sufficient to calculate the interest rate. 31 Wn.

22015–2015
McIndoe v. Department of Labor & Industries green
wash · 2001
2 sentences

2008RCW 51.12.010; McIndoe v. Dep’t of Labor & Indus., 144 Wn.2d 252, 256-57 , 26 P.3d 903 (2001). ¶41 Consistent with this view, although a writing is required for claim filing, our Supreme Court has held that the filings of injured workers should be viewed liberally.

2008RCW 51.12.010; McIndoe v. Dep't. of Labor & Indus., 144 Wash.2d 252, 256-57 , 26 P.3d 903 (2001). ¶ 41 Consistent with this view, although a writing is required for claim filing, our Supreme Court has held that the filings of injured workers should be viewed liberally.

22008–2008
McIndoe v. Department of Labor green
wash · 2001
2 sentences

2008RCW 51.12.010; McIndoe v. Dep’t of Labor & Indus., 144 Wn.2d 252, 256-57 , 26 P.3d 903 (2001). ¶41 Consistent with this view, although a writing is required for claim filing, our Supreme Court has held that the filings of injured workers should be viewed liberally.

2008RCW 51.12.010; McIndoe v. Dep't. of Labor & Indus., 144 Wash.2d 252, 256-57 , 26 P.3d 903 (2001). ¶ 41 Consistent with this view, although a writing is required for claim filing, our Supreme Court has held that the filings of injured workers should be viewed liberally.

22008–2008
Kloss v. Honeywell, Inc. green
washctapp · 1995
2 sentences

2001This statement flows from case law cited on page 1004. "[E]x parte writings are sufficient to bring a contract within the 6 year statute of limitations if the writing contains all of the elements of a contract." Kloss, 77 Wash.App. at 298 , 890 P.2d 480 (citing the dissent in Evans v. Yakima Valley Grape Growers Ass'n, 52 Wash.2d 634, 644 , 328 P.2d 671 (1958)).

2001This statement flows from case law cited on page 561. “[E]x parte writings are sufficient to bring a contract within the 6-year statute of limitations if the writing contains all of the elements of a contract.” Kloss, 77 Wn.

22001–2001
Powers v. Hastings green
washctapp · 1978
2 sentences

2019Third, in support of its argument that David’s trial testimony satisfies the writing requirement, HMD cites Powers v. Hastings, 20 Wn.

2019App. 837, 846 , 582 P.2d 897 (1978), aff’d on other grounds, 93 Wn.2d 709 , 612 P.2d 371 (1980).

12019–2019
Powers v. Hastings green
wash · 1980
2 sentences

2019App. 837, 846 , 582 P.2d 897 (1978), aff’d on other grounds, 93 Wn.2d 709 , 612 P.2d 371 (1980).

2019App. 837, 846 , 582 P.2d 897 (1978), aff’d on other grounds, 93 Wn.2d 709 , 612 P.2d 371 (1980).

12019–2019
Hamlin v. Flick neutral
wash · 1924
2 sentences

2019Hamlin v. Flick, 130 Wash. 126, 130 , 226 P. 484 (1924). 64 No. 34443-6-III In re Marriage of Carlson No writing confirms the 2003 and 2007 loans to South 80 Orchards.

2019Hamlin v. Flick, 130 Wash. 126, 130 , 226 P. 484 (1924). 64 No. 34443-6-III In re Marriage of Carlson No writing confirms the 2003 and 2007 loans to South 80 Orchards.

12019–2019
Mrc Receivables Corp. v. Zion green
washctapp · 2009
1 sentence

2011MRC Receivables Corp. v. Zion, 152 Wn.

12011–2011
Clements v. Travelers Indemnity Co. green
wash · 1993
2 sentences

2009The insured must decline coverage by an "affirmative and conscious act." Clements, 121 Wash.2d at 254 , 850 P.2d 1298 . ¶ 20 Division One of this court has specifically rejected the contention that "writings prepared by the insured's broker may not serve to waive UIM coverage." Galbraith, 78 Wash.App. at 531 , 897 P.2d 417 . "`[T]here is nothing in Washington's UIM statute or our case law precluding an agent from acting on behalf of an insured in rejecting UIM coverage.'" Id. (quoting Weir, 63 Wash.App. at 191 , 816 P.2d 1278 ). ¶ 21 Moreover, cases in which the writing requirement was not sat

2009The insured must decline coverage by an "affirmative and conscious act." Clements, 121 Wash.2d at 254 , 850 P.2d 1298 . ¶ 20 Division One of this court has specifically rejected the contention that "writings prepared by the insured's broker may not serve to waive UIM coverage." Galbraith, 78 Wash.App. at 531 , 897 P.2d 417 . "`[T]here is nothing in Washington's UIM statute or our case law precluding an agent from acting on behalf of an insured in rejecting UIM coverage.'" Id. (quoting Weir, 63 Wash.App. at 191 , 816 P.2d 1278 ). ¶ 21 Moreover, cases in which the writing requirement was not sat

12009–2009
Galbraith v. National Union Fire Insurance Co. of Pittsburgh green
washctapp · 1995
2 sentences

2009The insured must decline coverage by an "affirmative and conscious act." Clements, 121 Wash.2d at 254 , 850 P.2d 1298 . ¶ 20 Division One of this court has specifically rejected the contention that "writings prepared by the insured's broker may not serve to waive UIM coverage." Galbraith, 78 Wash.App. at 531 , 897 P.2d 417 . "`[T]here is nothing in Washington's UIM statute or our case law precluding an agent from acting on behalf of an insured in rejecting UIM coverage.'" Id. (quoting Weir, 63 Wash.App. at 191 , 816 P.2d 1278 ). ¶ 21 Moreover, cases in which the writing requirement was not sat

2009The insured must decline coverage by an "affirmative and conscious act." Clements, 121 Wash.2d at 254 , 850 P.2d 1298 . ¶ 20 Division One of this court has specifically rejected the contention that "writings prepared by the insured's broker may not serve to waive UIM coverage." Galbraith, 78 Wash.App. at 531 , 897 P.2d 417 . "`[T]here is nothing in Washington's UIM statute or our case law precluding an agent from acting on behalf of an insured in rejecting UIM coverage.'" Id. (quoting Weir, 63 Wash.App. at 191 , 816 P.2d 1278 ). ¶ 21 Moreover, cases in which the writing requirement was not sat

12009–2009
Weir v. American Motorists Insurance neutral
washctapp · 1991
2 sentences

2009The insured must decline coverage by an "affirmative and conscious act." Clements, 121 Wash.2d at 254 , 850 P.2d 1298 . ¶ 20 Division One of this court has specifically rejected the contention that "writings prepared by the insured's broker may not serve to waive UIM coverage." Galbraith, 78 Wash.App. at 531 , 897 P.2d 417 . "`[T]here is nothing in Washington's UIM statute or our case law precluding an agent from acting on behalf of an insured in rejecting UIM coverage.'" Id. (quoting Weir, 63 Wash.App. at 191 , 816 P.2d 1278 ). ¶ 21 Moreover, cases in which the writing requirement was not sat

2009The insured must decline coverage by an "affirmative and conscious act." Clements, 121 Wash.2d at 254 , 850 P.2d 1298 . ¶ 20 Division One of this court has specifically rejected the contention that "writings prepared by the insured's broker may not serve to waive UIM coverage." Galbraith, 78 Wash.App. at 531 , 897 P.2d 417 . "`[T]here is nothing in Washington's UIM statute or our case law precluding an agent from acting on behalf of an insured in rejecting UIM coverage.'" Id. (quoting Weir, 63 Wash.App. at 191 , 816 P.2d 1278 ). ¶ 21 Moreover, cases in which the writing requirement was not sat

12009–2009
Evans v. YAKIMA ETC. ASS'N. green
wash · 1958
2 sentences

2001This statement flows from case law cited on page 1004. "[E]x parte writings are sufficient to bring a contract within the 6 year statute of limitations if the writing contains all of the elements of a contract." Kloss, 77 Wash.App. at 298 , 890 P.2d 480 (citing the dissent in Evans v. Yakima Valley Grape Growers Ass'n, 52 Wash.2d 634, 644 , 328 P.2d 671 (1958)).

2001This statement flows from case law cited on page 1004. "[E]x parte writings are sufficient to bring a contract within the 6 year statute of limitations if the writing contains all of the elements of a contract." Kloss, 77 Wash.App. at 298 , 890 P.2d 480 (citing the dissent in Evans v. Yakima Valley Grape Growers Ass'n, 52 Wash.2d 634, 644 , 328 P.2d 671 (1958)).

12001–2001
State v. Downs green
washctapp · 1983
2 sentences

1991Indeed, the purpose of the writing requirement is to ensure that a waiver is knowing, voluntary and intelligent. *559 State v. Downs, 36 Wn.

1991App. 143, 145 , 672 P.2d 416 (1983), review denied, 100 Wn.2d 1040 (1984). 3 Here, not only did Lund sign a written waiver, but Lund's counsel stated in court that Lund waived his right to trial by jury, Lund orally stated to the court that he waived his right to trial by jury, and the trial judge engaged in an extended colloquy with Lund regarding the effects of the waiver.

11991–1991
United States v. Manuel Delgado green
ca7 · 1981
1 sentence

1983United States v. Delgado, 635 F.2d 889 (7th Cir. 1981).

11983–1983
State v. Bray green
washctapp · 1979
1 sentence

1983Wicke , at 642; State v. Bray, 23 Wn.

11983–1983
United States v. James Scott green
ca7 · 1978
1 sentence

1983See United States v. Anderson, 704 F.2d 117 (3d Cir. 1983); United States v. Martin, 704 F.2d 267 (6th Cir. 1983); United States v. *146 Scott, 583 F.2d 362 (7th Cir. 1978). 3 These decisions are persuasive because the writing requirement applied in the federal courts is virtually identical to CrR 6.1(a) in both language and purpose.

11983–1983
Community Savings and Loan Association v. Fisher green
tex · 1966
1 sentence

1982Cf. Community Sav. & Loan Ass'n v. Fisher, 409 S.W.2d 546 (Tex. 1966); see also Hazard v. Maxon, 1 Wash. Terr. 584 (1878) (under the original statute governing interest rates only the legal rate of interest could be recovered on a contract which was so ambiguous as to render it uncertain whether more than such rate was stipulated for).

11982–1982

Statutes the citing opinions construe

WA § Wash. Rev. Code § 4.16.040 (4) WA § Wash. Rev. Code § 4.08.080 (3) WA § Wash. Rev. Code § 4.16.080 (3) WA § Wash. Rev. Code § 4.84.330 (3)

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

IL 43 (1977–2026) NY 42 (1897–2017) CA 39 (1915–2023) LA 38 (1971–2025) IN 34 (1990–2025) TX 33 (1915–2026) MI 21 (1983–2025) GA 16 (1929–2026) WA 15 (1982–2019) PA 15 (1919–2025) MO 15 (1980–2025) NJ 10 (1979–2024) UT 10 (1998–2023) FL 9 (1978–2026) VA 9 (1991–2024) CT 9 (1994–2019) AR 8 (1942–2015) SC 7 (2007–2022) MA 7 (1959–2020) TN 7 (1956–2026) OH 7 (1989–2025) WY 6 (1981–2019) IA 6 (1988–2016) NM 6 (1985–2011) KY 6 (1915–2025) RI 6 (1969–2012) MD 5 (1976–2025) NV 5 (1983–2012) KS 5 (1975–2007) ID 5 (1993–2019) ND 5 (1980–2021) AZ 4 (1975–2018) MN 4 (1988–2009) MS 4 (1978–2007) HI 4 (2001–2020) ME 4 (2004–2022) MT 4 (2003–2009) SD 3 (2005–2026) DC 3 (1993–2011) AL 3 (1967–1986) VT 2 (1922–1986) WV 2 (1893–1997) DE 2 (2014–2019) OR 2 (1984–1999) WI 2 (2006–2006) NC 2 (2000–2019) OK 2 (1994–2016)

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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