election waiver (Oregon) · Go Syfert
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election waiver in Oregon

14 Oregon opinions name it 2 courts 1947–2017 0 in the last five years

The cases below were cited by Oregon 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 (2)

CaseFollowedCited
Dika v. Department of Insurance & Financegreen
or · 1991 · cited in 1 Oregon opinions naming this issue, 2015–2015
2 sentences

2015ORS 742.502(2)(b) (emphases added); see Dika v. Dept. of Ins. & Finance, 312 Or 106, 109 , 817 P2d 287 (1991) (“To construe the word ‘shall’ as anything other than mandatory would thwart the intention of the legislature!.]”); Webster’s Third New Int’l Dictionary 2085 (unabridged ed 2002) (defining “shall,” in part, as “used in laws, regulations, or directives to express what is mandatory”); Legislative Administration Committee, Form and Style Manual for Legislative Measures 10 (2014) (“To impose an obligation to act, use ‘shall.’”). 3 Thus, the statutory language demonstrates the legislature’s

2015ORS 742.502(2)(b) (emphases added); see Dika v. Dept. of Ins. & Finance, 312 Or 106, 109 , 817 P2d 287 (1991) (“To construe the word ‘shall’ as anything other than mandatory would thwart the intention of the legislature!.]”); Webster’s Third New Int’l Dictionary 2085 (unabridged ed 2002) (defining “shall,” in part, as “used in laws, regulations, or directives to express what is mandatory”); Legislative Administration Committee, Form and Style Manual for Legislative Measures 10 (2014) (“To impose an obligation to act, use ‘shall.’”). 3 Thus, the statutory language demonstrates the legislature’s

11
Schenck v. . State Line Telephone Co.green
ny · 1924 · cited in 1 Oregon opinions naming this issue, 1970–1970
2 sentences

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (11)

CaseCitedYears
Johnson v. Zerbst green
scotus · 1938
2 sentences

1996Carnley v. Cochran, 369 US 506 , 82 S Ct 884 , 8 L Ed 2d 70 (1962); Johnson v. Zerbst, 304 US 458, 465 , 58 S Ct 1019 , 82 L Ed 1461, 1466 , 146 ALR 357 (1938); State v. Coli-man, 9 Or App 476 , 497 P2d 1233 (1972).

1996Carnley v. Cochran, 369 US 506 , 82 S Ct 884 , 8 L Ed 2d 70 (1962); Johnson v. Zerbst, 304 US 458, 465 , 58 S Ct 1019 , 82 L Ed 1461, 1466 , 146 ALR 357 (1938); State v. Coli-man, 9 Or App 476 , 497 P2d 1233 (1972).

51972–1996
Carnley v. Cochran green
scotus · 1962
2 sentences

1996Carnley v. Cochran, 369 US 506 , 82 S Ct 884 , 8 L Ed 2d 70 (1962); Johnson v. Zerbst, 304 US 458, 465 , 58 S Ct 1019 , 82 L Ed 1461, 1466 , 146 ALR 357 (1938); State v. Coli-man, 9 Or App 476 , 497 P2d 1233 (1972).

1996Carnley v. Cochran, 369 US 506 , 82 S Ct 884 , 8 L Ed 2d 70 (1962); Johnson v. Zerbst, 304 US 458, 465 , 58 S Ct 1019 , 82 L Ed 1461, 1466 , 146 ALR 357 (1938); State v. Coli-man, 9 Or App 476 , 497 P2d 1233 (1972).

51972–1996
State v. Collman green
orctapp · 1972
2 sentences

1996Carnley v. Cochran, 369 US 506 , 82 S Ct 884 , 8 L Ed 2d 70 (1962); Johnson v. Zerbst, 304 US 458, 465 , 58 S Ct 1019 , 82 L Ed 1461, 1466 , 146 ALR 357 (1938); State v. Coli-man, 9 Or App 476 , 497 P2d 1233 (1972).

1996Carnley v. Cochran, 369 US 506 , 82 S Ct 884 , 8 L Ed 2d 70 (1962); Johnson v. Zerbst, 304 US 458, 465 , 58 S Ct 1019 , 82 L Ed 1461, 1466 , 146 ALR 357 (1938); State v. Coli-man, 9 Or App 476 , 497 P2d 1233 (1972).

51972–1996
State v. Verna green
orctapp · 1972
2 sentences

1991I am prepared to continue today.” In State v. Verna, 9 Or App 620, 626 , 498 P2d 793 (1972), we said: “Because the election to defend pro se necessarily involves a waiver of the right to counsel, it is incumbent upon the court to determine, by recorded colloquy, that the election or waiver is intelligent and competent. * * * At minimum, the court should determine whether defendant understands the nature of the charge, the elements of the offense and the punishments which may be exacted.

1991I am prepared to continue today.” In State v. Verna, 9 Or App 620, 626 , 498 P2d 793 (1972), we said: “Because the election to defend pro se necessarily involves a waiver of the right to counsel, it is incumbent upon the court to determine, by recorded colloquy, that the election or waiver is intelligent and competent. * * * At minimum, the court should determine whether defendant understands the nature of the charge, the elements of the offense and the punishments which may be exacted.

51983–1991
Cook v. Corbett green
or · 1968
2 sentences

2017Under former ORS 251.025 (1967), renumbered as ORS 258.016 (1983), the court determined that a “material violation,” in the context of an election violation for making false statements in an advertisement, means “substantial,” as compared to “trivial” or “unimportant.” Cook v. Corbett, 251 Or 263, 271 , 446 P2d 179 (1968).

2017Under former ORS 251.025 (1967), renumbered as ORS 258.016 (1983), the court determined that a “material violation,” in the context of an election violation for making false statements in an advertisement, means “substantial,” as compared to “trivial” or “unimportant.” Cook v. Corbett, 251 Or 263, 271 , 446 P2d 179 (1968).

12017–2017
State v. Cole neutral
orctapp · 1995
2 sentences

1996State v. Cole, 135 Or App 643, 651 , 900 P2d 517 (1995). 3 As the Court of Appeals has stated: *35 “Because the election to defend pro se necessarily involves a waiver of the right to counsel, it is incumbent upon the court to determine, by recorded colloquy, that the election or waiver is intelligent and competent.

1996State v. Cole, 135 Or App 643, 651 , 900 P2d 517 (1995). 3 As the Court of Appeals has stated: *35 “Because the election to defend pro se necessarily involves a waiver of the right to counsel, it is incumbent upon the court to determine, by recorded colloquy, that the election or waiver is intelligent and competent.

11996–1996
State v. Boswell neutral
orctapp · 1988
2 sentences

1991In State v. Boswell, 92 Or App 652 , 760 P2d 276 , we reiterated the language in Verna : “Because the election to defend pro se necessarily involves a waiver of the right to counsel, it is incumbent upon *52 the court to determine, by recorded colloquy, that the election or waiver is intelligent and competent.

1991In State v. Boswell, 92 Or App 652 , 760 P2d 276 , we reiterated the language in Verna : “Because the election to defend pro se necessarily involves a waiver of the right to counsel, it is incumbent upon *52 the court to determine, by recorded colloquy, that the election or waiver is intelligent and competent.

11991–1991
Ladd v. General Insurance Co. green
or · 1963
2 sentences

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

11970–1970
Payne v. Griffin neutral
or · 1964
2 sentences

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

11970–1970
Elliott v. Mosgrove green
or · 1939
2 sentences

1970Elliott v. Mosgrove, 162 Or. 507, 553 , 93 P.2d 1070 (1939).

1970Elliott v. Mosgrove, 162 Or. 507, 553 , 93 P.2d 1070 (1939).

11970–1970
Fuller-Warren Co. v. Harter green
wis · 1901
2 sentences

1947Fuller-Warren Company v. Harter, 110 Wis. 80 , 85 N. W. 698 , 53 L.

1947Fuller-Warren Company v. Harter, 110 Wis. 80 , 85 N. W. 698 , 53 L.

11947–1947

Where else courts name it

TN 164 (1906–2026) TX 134 (1875–2025) CA 49 (1898–2024) IL 31 (1895–2023) AL 29 (1888–2025) NC 26 (1898–2025) WA 23 (1896–2026) MD 20 (1904–2025) NY 17 (1889–2019) AZ 16 (1926–2023) HI 15 (1979–2023) GA 14 (1908–2025) MI 14 (1918–2019) OR 14 (1947–2017) FL 13 (1960–2018) IN 12 (1874–2025) NJ 11 (1935–2026) LA 11 (1925–2020) AR 10 (1875–2000) PA 10 (1875–2024) MO 10 (1925–2019) OK 9 (1920–2023) CO 9 (1983–2025) MA 8 (1913–2005) MS 8 (1962–2021) MN 8 (1912–2012) SC 7 (1941–2024) KS 7 (1911–2014) IA 6 (1915–2020) CT 6 (1899–2019) WI 5 (1910–1963) OH 5 (2002–2022) NE 5 (1900–1992) VT 4 (1937–2018) UT 3 (1912–2021) AK 3 (1998–2008) ME 2 (1917–2012) MT 2 (1928–2024) WY 2 (1954–2013) DE 2 (1941–2020) KY 2 (1891–1952)

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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