comity doctrine (Washington) · Go Syfert
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comity doctrine in Washington

14 Washington opinions name it 2 courts 1981–2020 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 (3)

CaseFollowedCited
Fair Assessment in Real Estate Assn., Inc. v. McNarygreen
scotus · 1981 · cited in 2 Washington opinions naming this issue, 2016–2017
2 sentences

2017Under the comity principle, courts "will stay their hand when remedies at law are plain, adequate, and complete." Fair Assessment, 454 U.S. at 108 .

2017However, as with the comity principle, the ESA restrains interference 18In Fair Assessment, the district court concluded that the remedy was adequate and the plaintiffs did not appeal that finding. 454 U.S. at 116 .

12
Wal-Mart Puerto Rico, Inc. v. Zaragoza-Gomezgreen
ca1 · 2016 · cited in 1 Washington opinions naming this issue, 2017–2017
1 sentence

2017While the Supreme Court has never explicitly held that these inquiries are identical, it has "suggested that adequacy of the state system for comity purposes is the same standard as 'plain, speedy and efficient' under the TIA." Wal-Mart P.R., Inc. v. Zaragoza-Gomez, 834 F.3d 110, 125 (1st Cir. 2016). -17- --- ------WasHington Trucking Ass 'ns, et al. v-:EmjiTSec.7Teji't, et al., 93079-1 - --- - - - ---- - - - Although the Supreme Court once stated that "Congress did not equate [the TIA's] 'plain, speedy and efficient' with equity's 'plain, adequate and complete,"' Rosewell, 450 U.S. at 526 , l

11
Rosewell v. LaSalle National Bankgreen
scotus · 1981 · cited in 1 Washington opinions naming this issue, 2017–2017
2 sentences

2017While the Supreme Court has never explicitly held that these inquiries are identical, it has "suggested that adequacy of the state system for comity purposes is the same standard as 'plain, speedy and efficient' under the TIA." Wal-Mart P.R., Inc. v. Zaragoza-Gomez, 834 F.3d 110, 125 (1st Cir. 2016). -17- --- ------WasHington Trucking Ass 'ns, et al. v-:EmjiTSec.7Teji't, et al., 93079-1 - --- - - - ---- - - - Although the Supreme Court once stated that "Congress did not equate [the TIA's] 'plain, speedy and efficient' with equity's 'plain, adequate and complete,"' Rosewell, 450 U.S. at 526 , l

2017Levin, 560 U.S. at 424 ; see also Rosewell, 450 U.S. at 525 n.33 ("And even where -18- -~--~-- WasfUngton Truc1ang 71.ss 'ns, ef al. v. Emp 't Sec.

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
Haberman v. Washington Public Power Supply System green
wash · 1988
2 sentences

2015In Haberman v. Washington Public Power Supply System, 109 Wn.2d 107, 160 , 744 P.2d 1032 , 750 P.2d 254 (1987), the court explained, “[T]he doctrine of comity is not a rule of law, but one of practice, convenience and expediency.” “ ‘[C]omity is properly exercised when the assumption of jurisdiction would not promote cooperative efforts between states.’ ” Glover v. Alaska, 142 Wn.

2015In Haberman v. Washington Public Power Supply System, 109 Wn.2d 107, 160 , 744 P.2d 1032 , 750 P.2d 254 (1987), the court explained, “[T]he doctrine of comity is not a rule of law, but one of practice, convenience and expediency.” “ ‘[C]omity is properly exercised when the assumption of jurisdiction would not promote cooperative efforts between states.’ ” Glover v. Alaska, 142 Wn.

62007–2020
Carrigan v. California Horse Racing Board green
washctapp · 1990
2 sentences

2016App. 79, 85 , 802 P.2d 813 (1990). “[T]he doctrine of comity is not a rule of law, but one of practice, convenience and expediency.” Haberman v. Wash. Pub.

2015App. 442, 447 , 174 P.3d 1246 (2008) (quoting Carrigan v. Cal. Horse Racing Bd., 60 Wn.

32015–2016
Dille v. Toland green
wash · 2014
2 sentences

2020“The comity doctrine allows a court, acting within its discretion, to give effect to the law and resulting orders of another jurisdiction out of deference and respect, considering the interests of each jurisdiction.” Toland, 180 Wn.2d at 846 (citing Haberman v. Wash. Pub.

2016The doctrine of comity, however, does not apply beyond the “immediate parties and the underlying claim.” In re Estate of Toland, 180 Wn.2d 836, 848 , 329 P.3d 878 (2014).

22016–2020
Glover v. State neutral
washctapp · 2008
2 sentences

2015In Haberman v. Washington Public Power Supply System, 109 Wn.2d 107, 160 , 744 P.2d 1032 , 750 P.2d 254 (1987), the court explained "the doctrine of comity is not a rule of law, but one of practice, convenience and expediency." "[C]omity is properly exercised when the assumption ofjurisdiction would not promote cooperative efforts between states." Glover v. Alaska, 142 Wn.

2015In Haberman v. Washington Public Power Supply System, 109 Wn.2d 107, 160 , 744 P.2d 1032 , 750 P.2d 254 (1987), the court explained, “[T]he doctrine of comity is not a rule of law, but one of practice, convenience and expediency.” “ ‘[C]omity is properly exercised when the assumption of jurisdiction would not promote cooperative efforts between states.’ ” Glover v. Alaska, 142 Wn.

22015–2015
Glover v. STATE OF ALASKA, DEPT. OF TRANSP. neutral
washctapp · 2008
2 sentences

2015App. 442, 447 , 174 P.3d 1246 (2008) (quoting Carrigan v. California Horse Racing Bd., 60 Wn.

2015App. 442, 447 , 174 P.3d 1246 (2008) (quoting Carrigan v. Cal. Horse Racing Bd., 60 Wn.

22015–2015
Korslund v. Dyncorp Tri-Cities Services green
wash · 2005
2 sentences

2007Id. ¶ 8 Under the comity doctrine, a court has discretion to "give effect to the laws [and resulting judicial orders] of another jurisdiction out of deference and respect, considering the interests of each [jurisdiction]." Haberman v. Wash. Pub.

2007Id. ¶8 Under the comity doctrine, a court has discretion to “give effect to laws [and resulting judicial orders] of another jurisdiction out of deference and respect, considering the interests of each [jurisdiction].” Haberman v. Wash. Pub.

22007–2007
First Bank of Lincoln v. Donald C. Tuschoff green
washctapp · 2016
1 sentence

2018First Bank of Lincoln v. Tuschoff, 193 Wn.

12018–2018
Reynolds v. Day green
wash · 1914
2 sentences

2018App. at 240 (internal quotation marks omitted) (quoting Reynolds v. Day, 79 Wash. 499, 506 , 140 P. 681 (1914)). -14- No. 77630-4-1/15 The doctrine of comity does not apply here because the trial court was not recognizing or enforcing the Court of Rome’s order.

2018App. at 240 (internal quotation marks omitted) (quoting Reynolds v. Day, 79 Wash. 499, 506 , 140 P. 681 (1914)). -14- No. 77630-4-1/15 The doctrine of comity does not apply here because the trial court was not recognizing or enforcing the Court of Rome’s order.

12018–2018
Levin v. Commerce Energy, Inc. green
scotus · 2010
1 sentence

2017Levin, 560 U.S. at 424 ; see also Rosewell, 450 U.S. at 525 n.33 ("And even where -18- -~--~-- WasfUngton Truc1ang 71.ss 'ns, ef al. v. Emp 't Sec.

12017–2017
Township of Hillsborough v. Cromwell green
scotus · 1946
2 sentences

2017Next, WTA and the Carriers rely on Carrier Corp. v. Perez, 677 F.2d 162 (1st Cir. 1982), Hillsborough v. Cromwell, 326 U.S. 620 , 66 S. Ct. 445 , 90 L.

2017Next, WTA and the Carriers rely on Carrier Corp. v. Perez, 677 F.2d 162 (1st Cir. 1982), Hillsborough v. Cromwell, 326 U.S. 620 , 66 S. Ct. 445 , 90 L.

12017–2017
Carrier Corporation v. Hon. Julio Cesar Perez, Etc. green
ca1 · 1982
1 sentence

2017Next, WTA and the Carriers rely on Carrier Corp. v. Perez, 677 F.2d 162 (1st Cir. 1982), Hillsborough v. Cromwell, 326 U.S. 620 , 66 S. Ct. 445 , 90 L.

12017–2017
Washington Trucking Ass'n v. Employment Security Department neutral
washctapp · 2016
1 sentence

2017Dep 't, 192 Wn.

12017–2017
California v. Grace Brethren Church green
scotus · 1982
2 sentences

2017California v. Grace Brethren Church, 457 U.S. 393, 408 , 102 S. Ct. 2498 , 73 L.

2017California v. Grace Brethren Church, 457 U.S. 393, 408 , 102 S. Ct. 2498 , 73 L.

12017–2017
New West Fisheries, Inc. v. Department of Revenue neutral
washctapp · 2001
1 sentence

2014App. 370, 379 , 22 P.3d 1274 (2001) (same). ¶22 The comity doctrine allows a court, acting within its discretion, to give effect to the law and resulting orders of another jurisdiction out of deference and respect, considering the interests of each jurisdiction.

12014–2014
MacKenzie v. Barthol green
washctapp · 2007
1 sentence

2012App. 235, 240 , 173 P.3d 980 (2007) (alterations in original) (quoting Haberman v. Wash. Pub.

12012–2012
MacKenzie v. Barthol green
washctapp · 2007
1 sentence

2012But under the doctrine of comity, courts have discretion to “ ‘give effect to the laws [and resulting judicial orders] of another jurisdiction out of deference and respect, considering the interests of each [jurisdiction].’” 9 MacKenzie v. Barthol, 142 Wn.

12012–2012
Mirgon v. Sherk neutral
wash · 1938
2 sentences

1981Yet, as stated in Mirgon v. Sherk, 196 Wash. 690, 693 , 84 P.2d 362 (1938) (overriding foreign law concerning usury): A doctrine of comity, however, does not require that any sister state shall enforce contracts to be performed in another which are so contrary to the laws of the state in which they are sought to be enforced as to work a serious interference with its own policy or laws.

1981Yet, as stated in Mirgon v. Sherk, 196 Wash. 690, 693 , 84 P.2d 362 (1938) (overriding foreign law concerning usury): A doctrine of comity, however, does not require that any sister state shall enforce contracts to be performed in another which are so contrary to the laws of the state in which they are sought to be enforced as to work a serious interference with its own policy or laws.

11981–1981

Statutes the citing opinions construe

WA § Wash. Rev. Code § 10.31.100 (3) WA § Wash. Rev. Code § 10.93.020 (3) WA § Wash. Rev. Code § 10.93.090 (3) WA § Wash. Rev. Code § 26.09.140 (3) WA § Wash. Rev. Code § 4.28.185 (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

NY 67 (1890–2026) TX 40 (1911–2024) CA 28 (1923–2025) IL 22 (1934–2024) MD 14 (1934–2020) WI 14 (1950–2025) WA 14 (1981–2020) NM 11 (1997–2017) MO 10 (1906–2025) NJ 9 (1952–2026) FL 9 (1959–2025) CT 8 (1974–2019) CO 7 (1911–2019) SD 7 (1985–2024) VA 7 (1979–1997) OK 6 (1914–2008) IN 6 (1993–2013) OH 5 (1907–2012) KS 5 (1949–2021) ND 4 (1903–1990) DE 4 (2010–2018) AL 4 (1980–2009) PA 4 (1786–1937) UT 4 (1993–2019) MS 4 (1930–1997) MI 3 (1895–2017) NE 3 (1913–1951) AK 3 (1999–2025) AZ 3 (1939–2006) ME 3 (1982–2018) TN 3 (1932–2019) HI 3 (2007–2016) MN 3 (1903–2019) GA 2 (1902–1990) LA 2 (1989–2008) VT 2 (2005–2025) WY 2 (1925–1982) MA 2 (2009–2010) NV 2 (2014–2020) NH 2 (1998–2006) NC 2 (1982–2001) KY 2 (1913–2013) IA 2 (1942–2016) WV 2 (1928–2001) AR 2 (1932–2023)

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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