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14 Washington opinions name it 2 courts 1951–2026 3 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.
| Case | Followed | Cited |
|---|---|---|
David Glen Meyers v. Contra Costa County Department of Social Services, Defendantsgreen1 sentence1992Meyers , at 1156 (citing Briscoe v. LaHue, 460 U.S. 325 , 75 L. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
J. D. B. v. North Carolina
green
2 sentences2026In J.D.B., the court stated, “Not once have we excluded from the custody analysis a circumstance that we determined was relevant 22 State of Washington v. Ahmed Mohamud Wasuge, No. 103530-6 and objective, simply to make the fault line between custodial and noncustodial ‘brighter.’ Indeed, were the guiding concern clarity and nothing else, the custody test would presumably ask only whether the suspect had been placed under formal arrest.” 564 U.S. at 280 . 2026In J.D.B., the court stated, “Not once have we excluded from the custody analysis a circumstance that we determined was relevant 22 State of Washington v. Ahmed Mohamud Wasuge, No. 103530-6 and objective, simply to make the fault line between custodial and noncustodial ‘brighter.’ Indeed, were the guiding concern clarity and nothing else, the custody test would presumably ask only whether the suspect had been placed under formal arrest.” 564 U.S. at 280 . | 3 | 2016–2026 |
Berkemer v. McCarty
green
2 sentences2004The custody requirement is satisfied “as soon as a suspect’s freedom of action is curtailed to a ‘degree associated with formal arrest.’ ” Berkemer v. McCarty, 468 U.S. 420, 440 , 104 S. Ct. 3138 , 82 L. 2004The custody requirement is satisfied “as soon as a suspect’s freedom of action is curtailed to a ‘degree associated with formal arrest.’ ” Berkemer v. McCarty, 468 U.S. 420, 440 , 104 S. Ct. 3138 , 82 L. | 3 | 2004–2023 |
Thompson v. Keohane
green
2 sentences2015App. at 928 (quoting State v. Lorenz, 152 Wn.2d 22, 36-37 , 93 P.3d 133 (2004)). 18 Howes v. Fields, 132 S. Ct. 1181, 1189 , 182 L Ed. 2d 17(2012) (alteration in original) (quoting Thompson v. Keohane, 516 U.S. 99, 112 , 116 S. Ct. 457 , 133 L. 2015App. at 928 (quoting State v. Lorenz, 152 Wn.2d 22, 36-37 , 93 P.3d 133 (2004)). 18 Howes v. Fields, 132 S. Ct. 1181, 1189 , 182 L Ed. 2d 17(2012) (alteration in original) (quoting Thompson v. Keohane, 516 U.S. 99, 112 , 116 S. Ct. 457 , 133 L. | 3 | 2002–2015 |
Howes v. Fields
green
2 sentences2024The custody inquiry simply asks “whether an individual was put in an environment that ‘present[s] a serious 9 No. 86614-1-I/10 danger of coercion.’ ” Id. at 536 (quoting Howes v. Fields, 565 U.S. 499, 508-09 , 132 S. Ct. 1181 , 182 L. 2024The custody inquiry simply asks “whether an individual was put in an environment that ‘present[s] a serious 9 No. 86614-1-I/10 danger of coercion.’ ” Id. at 536 (quoting Howes v. Fields, 565 U.S. 499, 508-09 , 132 S. Ct. 1181 , 182 L. | 2 | 2015–2024 |
State v. D.R.
green
2 sentences2016State v. D.R., 84 Wn. 2016State v. D.R., 84 Wn. | 2 | 2016–2016 |
Sandin v. Conner
green
1 sentence2015Restraint ofDyer, 143 Wn.2d 384, 393 , 20 P. 3d 907 ( 2001) citing Sandin, 515 U.S. at 484 ). | 1 | 2015–2015 |
State v. Lorenz
green
1 sentence2015App. at 928 (quoting State v. Lorenz, 152 Wn.2d 22, 36-37 , 93 P.3d 133 (2004)). 18 Howes v. Fields, 132 S. Ct. 1181, 1189 , 182 L Ed. 2d 17(2012) (alteration in original) (quoting Thompson v. Keohane, 516 U.S. 99, 112 , 116 S. Ct. 457 , 133 L. | 1 | 2015–2015 |
In re the Personal Restraint of Dyer
green
1 sentence2015Restraint ofDyer, 143 Wn.2d 384, 393 , 20 P. 3d 907 ( 2001) citing Sandin, 515 U.S. at 484 ). | 1 | 2015–2015 |
State v. Lorenz
green
1 sentence2015App. at 928 (quoting State v. Lorenz, 152 Wn.2d 22, 36-37 , 93 P.3d 133 (2004)). 18 Howes v. Fields, 132 S. Ct. 1181, 1189 , 182 L Ed. 2d 17(2012) (alteration in original) (quoting Thompson v. Keohane, 516 U.S. 99, 112 , 116 S. Ct. 457 , 133 L. | 1 | 2015–2015 |
In Re Dyer
green
1 sentence2015Restraint ofDyer, 143 Wn.2d 384, 393 , 20 P. 3d 907 ( 2001) citing Sandin, 515 U.S. at 484 ). | 1 | 2015–2015 |
State v. S.J.W.
green
1 sentence2015No. 72967-5-1/5 associated with formal arrest."'17 We can also ask whether "a 'reasonable person [would] have felt he or she was not at liberty to terminate the interrogation and leave.'"18 Courts must also look at other relevant factors to determine whether an individual is in custody, including the location and duration of the questioning, the statements made during the questioning, "the presence or absence of physical restraints during the questioning," and the individual's release after questioning.19 But "whether the police had probable cause to arrest" is "irrelevant" to the custody anal | 1 | 2015–2015 |
Miranda v. Arizona
green
2 sentences2004In Miranda , the United States Supreme Court defined custodial interrogation as "questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way." Miranda, 384 U.S. at 444 , 86 S.Ct. 1602 . 2004In Miranda , the United States Supreme Court defined custodial interrogation as "questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way." Miranda, 384 U.S. at 444 , 86 S.Ct. 1602 . | 1 | 2004–2004 |
California v. Beheler
green
2 sentences2004Ed. 2d 317 (1984) (quoting California v. Beheler, 463 U.S. 1121, 1125 , 103 S. Ct. 3517 , 77 L. 2004Ed. 2d 317 (1984) (quoting California v. Beheler, 463 U.S. 1121, 1125 , 103 S. Ct. 3517 , 77 L. | 1 | 2004–2004 |
Briscoe v. LaHue
green
2 sentences1992Meyers , at 1156 (citing Briscoe v. LaHue, 460 U.S. 325 , 75 L. 1992Meyers , at 1156 (citing Briscoe v. LaHue, 460 U.S. 325 , 75 L. | 1 | 1992–1992 |
Trusley v. Trusley
neutral
2 sentences1951Trusley v. Trusley, 186 Wash. 23 , 56 P. (2d) 676 . 1951Trusley v. Trusley, 186 Wash. 23 , 56 P. (2d) 676 . | 1 | 1951–1951 |
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.
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.