Williams analysis (District of Columbia) · Go Syfert
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Williams analysis in District of Columbia

14 District of Columbia opinions name it 1 courts 1977–2024 1 in the last five years

The cases below were cited by District of Columbia 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 (17)

CaseFollowedCited
Gregory Trotter & Ernest Pee v. United Statesgreen
dc · 2015 · cited in 2 District of Columbia opinions naming this issue, 2018–2018
2 sentences

2018Accordingly, the trial court’s decision not to grant Williams’s motion for a mistrial due to the government’s opening statement was proper, especially because “a mistrial is a severe remedy . . . one to be taken only in circumstances manifesting a necessity therefor.” Trotter v. United States, 121 A.3d 40, 53 (D.C. 2015) (brackets, footnote, and internal quotation marks omitted).

2018Accordingly, the trial court’s decision not to grant Williams’s motion for a mistrial due to the government’s opening statement was proper, especially because “a mistrial is a severe remedy ... one to be taken only in circumstances manifesting a necessity therefor.” Trotter v. United States, 121 A.3d 40, 53 (D.C. 2015) (brackets, footnote, and internal quotation marks omitted).

22
Wade v. District of Columbiagreen
dc · 1973 · cited in 1 District of Columbia opinions naming this issue, 2024–2024
1 sentence

2024The District likewise skips over this analysis in its brief and simply asserts that “an official acting within the scope of . . . her official duties is protected from suits for civil damages resulting from a ‘mistake of fact occurring in the exercise of [her] . . . discretion.’” But, as explained above, if Ms. Williams’s site visit was a ministerial act, it is not covered by absolute official immunity. 12 The 12 In support of its argument that the Superior Court’s “qualified immunity analysis for the [Gordons’] Fourth Amendment claim effectively resolved Ms. Williams’s immunity for the [Gordo

11
Leasure v. United Statesgreen
dc · 1983 · cited in 1 District of Columbia opinions naming this issue, 2018–2018
1 sentence

2018The photograph was admitted into evidence, and as the trial court noted, the photograph was used by the prosecutor to show the high power of the AK-47 to infer appellants’ intent to kill. 62 See Jones v. United States, 27 A.3d 1130, 1142 (D.C. 2011) (“The admission of photographs is within the sound discretion of the trial judge.”) (citations and internal quotation marks omitted); see also Leasure v. United States, 458 A.2d 726 , 728 n.2 (D.C. 1983) (holding that the trial court did not abuse its discretion in admitting photographs of the murder victim, as they had probative value in confirmin

11
Jones v. United Statesgreen
dc · 2011 · cited in 1 District of Columbia opinions naming this issue, 2018–2018
1 sentence

2018The photograph was admitted into evidence, and as the trial court noted, the photograph was used by the prosecutor to show the high power of the AK-47 to infer appellants’ intent to kill. 62 See Jones v. United States, 27 A.3d 1130, 1142 (D.C. 2011) (“The admission of photographs is within the sound discretion of the trial judge.”) (citations and internal quotation marks omitted); see also Leasure v. United States, 458 A.2d 726 , 728 n.2 (D.C. 1983) (holding that the trial court did not abuse its discretion in admitting photographs of the murder victim, as they had probative value in confirmin

11
Kerrigan v. Britches of Georgetowne, Inc.green
dc · 1997 · cited in 1 District of Columbia opinions naming this issue, 2010–2010
2 sentences

2010Williams’s claim is more akin to the intentional infliction of emotional distress claim that we dismissed in Kerrigan v. Britches of Georgetowne, Inc., 705 A.2d 624, 628 (D.C.1997), where we held that allegations that an employer manufactured evidence to establish a claim of sexual harassment against an employee, demoted him, and leaked the information to other employees did not "rise to the level of outrageous conduct” necessary to state a claim for intentional infliction of emotional distress.

2010Id. (quoting Best, 484 A.2d at 986 ).

11
Phillips v. County of Alleghenygreen
ca3 · 2008 · cited in 1 District of Columbia opinions naming this issue, 2010–2010
1 sentence

2010We think the subset of “senior” District officials who would have been “displeased with [Williams’s particular] allegations ... and ... testimony” 9 is not so large that Williams’s claim should be foreclosed before any discovery has been conducted. 10 What is called for at the motion to dismiss stage is simply “ ‘enough facts to raise a reasonable expectation that discovery will reveal evidence of the necessary element.” Phillips v. County of Allegheny, 515 F.3d 224, 234 (3d Cir.2008) (quoting Bell Atl.

11
United States v. Everett A. Williamsgreen
cadc · 1985 · cited in 1 District of Columbia opinions naming this issue, 2010–2010
2 sentences

2010Id.; see also United States v. Williams, 244 U.S.App.D.C. 20, 21 , 754 F.2d 1001, 1002 (1985) (remand required on trial court’s denial of Williams’ motion to suppress evidence seized when he was arrested for violating the District of Columbia disorderly conduct statute, where record was susceptible to the reading that the misdemeanor had not occurred in the officers’ presence, which would invalidate the arrest under District of Columbia law).

2010Id.; see also United States v. Williams, 244 U.S.App.D.C. 20, 21 , 754 F.2d 1001, 1002 (1985) (remand required on trial court’s denial of Williams’ motion to suppress evidence seized when he was arrested for violating the District of Columbia disorderly conduct statute, where record was susceptible to the reading that the misdemeanor had not occurred in the officers’ presence, which would invalidate the arrest under District of Columbia law).

11
Hsu v. United Statesgreen
dc · 1978 · cited in 1 District of Columbia opinions naming this issue, 2000–2000
1 sentence

2000Rule 7(c) of the Superior Court Rules of Criminal Procedure requires that the indictment shall contain “a plain, concise and definite written statement of the essential facts constituting the crime charged.” This “eschews emphasis on technical requirements and deficiencies, casting some of the burden on a defendant to pursue additional details, if needed, by way of a bill of particulars.” Hsu v. United States, 392 A.2d 972, 977 (D.C.1978).

11
Ridge v. Police & Firefighters Retirement & Relief Boardgreen
dc · 1986 · cited in 1 District of Columbia opinions naming this issue, 1997–1997
1 sentence

1997Accordingly, says the company, because the prehearing conference order provided no notice that the hearing examiner might award compensation for a scheduled injury, the company had every expectation that the only issue would be Williams’ claim for an unscheduled injury. ‘We have held that ‘[i]n general, an individual is entitled to fair and adequate notice of administrative proceedings that will affect his [or her] rights, in order that he [or she] may have an opportunity to defend his [or her] position.’ ” Ridge v. Police & Firefighters Retirement and Relief Bd., 511 A.2d 418, 424 (D.C.1986)

11
Carroll v. District of Columbia Department of Employment Servicesgreen
dc · 1985 · cited in 1 District of Columbia opinions naming this issue, 1997–1997
1 sentence

1997Accordingly, says the company, because the prehearing conference order provided no notice that the hearing examiner might award compensation for a scheduled injury, the company had every expectation that the only issue would be Williams’ claim for an unscheduled injury. ‘We have held that ‘[i]n general, an individual is entitled to fair and adequate notice of administrative proceedings that will affect his [or her] rights, in order that he [or she] may have an opportunity to defend his [or her] position.’ ” Ridge v. Police & Firefighters Retirement and Relief Bd., 511 A.2d 418, 424 (D.C.1986)

11
Abia-Okon v. District of Columbia Contract Appeals Boardgreen
dc · 1994 · cited in 1 District of Columbia opinions naming this issue, 1997–1997
1 sentence

1997We have observed, moreover, that this notice guarantee has its “ ‘roots in constitutional due process.’ ” Abia-Okon v. District of Columbia Contract Appeals Bd., 647 A.2d 79, 84 (D.C.1994) (quoting Ammerman v. District of Columbia Rental Accommodations Comm’n, 375 A.2d 1060, 1062 (D.C.1977)).

11
Ammerman v. District of Columbia Rental Accommodations Commissiongreen
dc · 1977 · cited in 1 District of Columbia opinions naming this issue, 1997–1997
1 sentence

1997We have observed, moreover, that this notice guarantee has its “ ‘roots in constitutional due process.’ ” Abia-Okon v. District of Columbia Contract Appeals Bd., 647 A.2d 79, 84 (D.C.1994) (quoting Ammerman v. District of Columbia Rental Accommodations Comm’n, 375 A.2d 1060, 1062 (D.C.1977)).

11
Asuncion v. Columbia Hospital for Womengreen
dc · 1986 · cited in 1 District of Columbia opinions naming this issue, 1997–1997
1 sentence

1997Under the pre-Williams standard, while the physical injury need not be substantial in order to recover, “there nonetheless must be at least some physical injury.” Asuncion v. Columbia Hosp. for Women, 514 A.2d 1187, 1189 (D.C.1986).

11
International Society for Krishna Consciousness, Inc. v. Leegreen
scotus · 1992 · cited in 1 District of Columbia opinions naming this issue, 1996–1996
2 sentences

1996In International Soc’y for Krishna Consciousness v. Lee, 505 U.S. 672 , 112 S.Ct. 2701 , 120 L.Ed.2d 541 (1992), a case involving a non-profit religious corporation, the Supreme Court of the United States said: “It is uncontested that the solicitation at issue in this case [contributions at airport terminals] is a form of protected speech under the First Amendment.” 505 U.S. at 677 , 112 S.Ct. at 2704 (referencing Heffron v. International Soc’y for Krishna Consciousness, Inc., 452 U.S. 640 , 101 S.Ct. 2559 , 69 L.Ed.2d 298 (1981) and United States v. Kokinda, 497 U.S. 720 , 110 S.Ct. 3115 , 11

1996In International Soc’y for Krishna Consciousness v. Lee, 505 U.S. 672 , 112 S.Ct. 2701 , 120 L.Ed.2d 541 (1992), a case involving a non-profit religious corporation, the Supreme Court of the United States said: “It is uncontested that the solicitation at issue in this case [contributions at airport terminals] is a form of protected speech under the First Amendment.” 505 U.S. at 677 , 112 S.Ct. at 2704 (referencing Heffron v. International Soc’y for Krishna Consciousness, Inc., 452 U.S. 640 , 101 S.Ct. 2559 , 69 L.Ed.2d 298 (1981) and United States v. Kokinda, 497 U.S. 720 , 110 S.Ct. 3115 , 11

11
Speight v. United Statesgreen
dc · 1989 · cited in 1 District of Columbia opinions naming this issue, 1996–1996
1 sentence

1996At no time did [Officer Godinez] see the defendant acting in an aggressive manner.” Notwithstanding the characterization of the hearing testimony by Mr. Williams and the District, the trial judge had the authority to “conduct [his] review either upon the written summary of the evidence presented by the parties or after listening to the tape or reading the transcript of the proceedings before the commissioner.” Speight v. United States, 558 A.2d 357, 359-60 (D.C.1989).

11
MATTER OF DeLOATCHgreen
dc · 1987 · cited in 1 District of Columbia opinions naming this issue, 1988–1988
2 sentences

1988See In re DeLoatch, 532 A.2d 1343 (D.C.1987), wherein we declined to follow the Williams analysis when the trial court failed to conduct a hearing within 24 hours of appellant’s request, as required by § 21-525.

1988See In re DeLoatch, 532 A.2d 1343 (D.C.1987), wherein we declined to follow the Williams analysis when the trial court failed to conduct a hearing within 24 hours of appellant’s request, as required by § 21-525.

11
Rosenberg v. District of Columbiagreen
dc · 1949 · cited in 1 District of Columbia opinions naming this issue, 1977–1977
2 sentences

1977See Rosenberg v. District of Columbia, D.C.Mun.App., 66 A.2d 489, 490-91 (1949).

1977See Rosenberg v. District of Columbia, D.C.Mun.App., 66 A.2d 489, 490-91 (1949).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
Bell Atlantic Corp. v. Twombly green
scotus · 2007
2 sentences

2010Corp. v. Twombly, 550 U.S. 544, 556 , 127 S.Ct. 1955 , 167 L.Ed.2d 929 (2007)).

2010Corp. v. Twombly, 550 U.S. 544, 556 , 127 S.Ct. 1955 , 167 L.Ed.2d 929 (2007)).

12010–2010
Howard University v. Best green
dc · 1984
1 sentence

2010Id. (quoting Best, 484 A.2d at 986 ).

12010–2010
Chapman v. California red
scotus · 1967
2 sentences

2004Due to the fact that the court in the prior trial had already ruled against the defendants’ objections to admission of the plea statements, we are persuaded that the trial court’s general adoption of its prior rulings and Williams' prior notice to adopt the motions of his co-defendants was sufficient to preserve Williams’ objection; thus we review the admission of the plea statements under the standard set forth in Chapman, supra, 386 U.S. at 24 , 87 S.Ct. 824 . 8 .

2004Due to the fact that the court in the prior trial had already ruled against the defendants’ objections to admission of the plea statements, we are persuaded that the trial court’s general adoption of its prior rulings and Williams' prior notice to adopt the motions of his co-defendants was sufficient to preserve Williams’ objection; thus we review the admission of the plea statements under the standard set forth in Chapman, supra, 386 U.S. at 24 , 87 S.Ct. 824 . 8 .

12004–2004
Lee v. United States green
dc · 1991
2 sentences

2000The government filed an opposition to the second motion in which it argued, inter alia, that Williams’ claim was precluded by Lee v. United States, 597 A.2d 1333 (D.C.1991).

2000This court had held in Lee , on essentially identical facts, that “the Constitution does not ... require the appointment of counsel for post-conviction *207 proceedings,” and that the defendant therefore “cannot prevail on a claim that his counsel was constitutionally ineffective in relation to that motion.” Id. at 1334 .

12000–2000
United States v. Kokinda green
scotus · 1990
2 sentences

1996In International Soc’y for Krishna Consciousness v. Lee, 505 U.S. 672 , 112 S.Ct. 2701 , 120 L.Ed.2d 541 (1992), a case involving a non-profit religious corporation, the Supreme Court of the United States said: “It is uncontested that the solicitation at issue in this case [contributions at airport terminals] is a form of protected speech under the First Amendment.” 505 U.S. at 677 , 112 S.Ct. at 2704 (referencing Heffron v. International Soc’y for Krishna Consciousness, Inc., 452 U.S. 640 , 101 S.Ct. 2559 , 69 L.Ed.2d 298 (1981) and United States v. Kokinda, 497 U.S. 720 , 110 S.Ct. 3115 , 11

1996In International Soc’y for Krishna Consciousness v. Lee, 505 U.S. 672 , 112 S.Ct. 2701 , 120 L.Ed.2d 541 (1992), a case involving a non-profit religious corporation, the Supreme Court of the United States said: “It is uncontested that the solicitation at issue in this case [contributions at airport terminals] is a form of protected speech under the First Amendment.” 505 U.S. at 677 , 112 S.Ct. at 2704 (referencing Heffron v. International Soc’y for Krishna Consciousness, Inc., 452 U.S. 640 , 101 S.Ct. 2559 , 69 L.Ed.2d 298 (1981) and United States v. Kokinda, 497 U.S. 720 , 110 S.Ct. 3115 , 11

11996–1996
Heffron v. International Society for Krishna Consciousness, Inc. green
scotus · 1981
2 sentences

1996In International Soc’y for Krishna Consciousness v. Lee, 505 U.S. 672 , 112 S.Ct. 2701 , 120 L.Ed.2d 541 (1992), a case involving a non-profit religious corporation, the Supreme Court of the United States said: “It is uncontested that the solicitation at issue in this case [contributions at airport terminals] is a form of protected speech under the First Amendment.” 505 U.S. at 677 , 112 S.Ct. at 2704 (referencing Heffron v. International Soc’y for Krishna Consciousness, Inc., 452 U.S. 640 , 101 S.Ct. 2559 , 69 L.Ed.2d 298 (1981) and United States v. Kokinda, 497 U.S. 720 , 110 S.Ct. 3115 , 11

1996In International Soc’y for Krishna Consciousness v. Lee, 505 U.S. 672 , 112 S.Ct. 2701 , 120 L.Ed.2d 541 (1992), a case involving a non-profit religious corporation, the Supreme Court of the United States said: “It is uncontested that the solicitation at issue in this case [contributions at airport terminals] is a form of protected speech under the First Amendment.” 505 U.S. at 677 , 112 S.Ct. at 2704 (referencing Heffron v. International Soc’y for Krishna Consciousness, Inc., 452 U.S. 640 , 101 S.Ct. 2559 , 69 L.Ed.2d 298 (1981) and United States v. Kokinda, 497 U.S. 720 , 110 S.Ct. 3115 , 11

11996–1996
Barbara J. MacKey v. United States of America green
cadc · 1993
2 sentences

1994Remarking that “[t]he District of Columbia’s recovery rule for negligently inflicted emotional distress is as clear as it is stringent,” the Mackey court correctly observed that this court “has decisively expressed its hostility to broadening the scope of the Williams rule.” Id. at 427, 8 F.3d at 831 , citing Cauman v. George Washington University, supra. We note that in Mackey the Court of Appeals, in affirming the trial court’s judgment on the negligent interference claim, rejected the appellee’s argument that this court had “repudiated” Steagall in District of Columbia v. Smith, supra. See

1994Remarking that “[t]he District of Columbia’s recovery rule for negligently inflicted emotional distress is as clear as it is stringent,” the Mackey court correctly observed that this court “has decisively expressed its hostility to broadening the scope of the Williams rule.” Id. at 427, 8 F.3d at 831 , citing Cauman v. George Washington University, supra. We note that in Mackey the Court of Appeals, in affirming the trial court’s judgment on the negligent interference claim, rejected the appellee’s argument that this court had “repudiated” Steagall in District of Columbia v. Smith, supra. See

11994–1994
District of Columbia v. Smith green
dc · 1981
2 sentences

1994We note that in Mackey the Court of Appeals, in affirming the trial court's judgment on the negligent interference claim, rejected the appellee's argument that this court had "repudiated" Steagall in District of Columbia v. Smith, supra .

1994We note that in Mackey the Court of Appeals, in affirming the trial court's judgment on the negligent interference claim, rejected the appellee's argument that this court had "repudiated" Steagall in District of Columbia v. Smith, supra .

11994–1994
Matter of Blair green
dc · 1986
2 sentences

1988The fact that the appellant then waived the hearing did not save him from the Williams result, as he had hoped it would; we still ruled that the court’s ex parte determination of probable cause for further detention under D.C.Code § 21-523 & -524 remedied the imperfection of the initial application. 482 A.2d at 373 . 3 Nor are we persuaded by appellant’s reliance on In re Blair, 510 A.2d 1048 (D.C. 1986).

1988The fact that the appellant then waived the hearing did not save him from the Williams result, as he had hoped it would; we still ruled that the court’s ex parte determination of probable cause for further detention under D.C.Code § 21-523 & -524 remedied the imperfection of the initial application. 482 A.2d at 373 . 3 Nor are we persuaded by appellant’s reliance on In re Blair, 510 A.2d 1048 (D.C. 1986).

11988–1988
In Re Morris green
dc · 1984
2 sentences

1988But we applied the Williams analysis in Morris, supra, where an application was challenged before a requested hearing took place. 482 A.2d at 370 .

1988But we applied the Williams analysis in Morris, supra, where an application was challenged before a requested hearing took place. 482 A.2d at 370 .

11988–1988

Statutes the citing opinions construe

DC § D.C. Code § 23-110 (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

FL 418 (1933–2026) CA 142 (1959–2026) GA 133 (1981–2026) TX 104 (1970–2025) IL 88 (1988–2026) CT 88 (2003–2025) OH 85 (1997–2026) PA 76 (1948–2026) MS 54 (1990–2024) AL 38 (1985–2025) WA 38 (1980–2026) IN 36 (1894–2023) VA 24 (1987–2026) MO 23 (1973–2025) LA 19 (1983–2025) NE 17 (1983–2024) TN 17 (1981–2026) AZ 17 (1985–2025) WI 17 (1998–2025) KS 16 (1983–2024) MD 15 (1975–2022) DC 14 (1977–2024) MN 14 (1967–2025) SC 13 (2015–2025) MI 13 (1966–2020) AR 13 (1974–2024) MT 13 (1973–2017) DE 12 (1970–2026) NC 12 (1983–2025) NY 11 (1974–2026) NM 10 (1976–2024) NJ 10 (1967–2022) AK 10 (1983–2023) CO 9 (1994–2026) UT 8 (1999–2019) ME 8 (2001–2024) MA 7 (1981–2013) NV 7 (1983–2021) ID 7 (1974–2018) OK 7 (1987–2018) WY 6 (1980–2026) ND 6 (1987–2025) WV 5 (1980–2017) IA 4 (1996–2020) NH 3 (1998–2011) HI 3 (2007–2020) VI 2 (2011–2016) VT 2 (1985–2019) KY 2 (2020–2023) SD 2 (2006–2008)

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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