enumerated factors (Washington) · Go Syfert
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enumerated factors in Washington

14 Washington opinions name it 2 courts 1993–2026 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.

Followed or applied (2)

CaseFollowedCited
In Re the Marriage of Jacobsongreen
washctapp · 1998 · cited in 1 Washington opinions naming this issue, 2016–2016
1 sentence

2016See also Jacobson v. Jacobson, 90 Wn.

11
Clearwater v. Skyline Construction Co.green
washctapp · 1992 · cited in 1 Washington opinions naming this issue, 1994–1994
1 sentence

1994See also Clearwater, 67 Wn.

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 (19)

CaseCitedYears
In re the Disciplinary Proceeding Against Boelter green
wash · 1999
2 sentences

2003In re Disciplinary Proceeding Against Boelter, 139 Wash.2d 81, 96 , 985 P.2d 328 (1999).

2003In re Disciplinary Proceeding Against Boelter, 139 Wn.2d 81, 96 , 985 P.2d 328 (1999).

22003–2003
In Re Boelter green
wash · 1999
2 sentences

2003In re Disciplinary Proceeding Against Boelter, 139 Wash.2d 81, 96 , 985 P.2d 328 (1999).

2003In re Disciplinary Proceeding Against Boelter, 139 Wn.2d 81, 96 , 985 P.2d 328 (1999).

22003–2003
State v. Cruz red
wash · 1999
2 sentences

2000Cruz, 139 Wn.2d at 193 .

2000Cruz, 139 Wash.2d at 193 , 985 P.2d 384 .

22000–2000
Beltran-Serrano v. City of Tacoma green
wash · 2019
1 sentence

2026While “an enumerated exception is not always necessary to find that a duty is owed to an individual and not to the public at large,” Beltran-Serrano v. City of Tacoma, 193 Wn.2d 537 , 549, 442 P.3d 608 (2019), the public duty doctrine essentially asks “whether the government owes a duty to particular individuals.” Ehrhart v. King County, 195 Wn.2d 388 , 400, 460 P.3d 612 (2020).

12026–2026
In re the Marriage of Littlefield red
wash · 1997
1 sentence

2025Id.

12025–2025
State v. Crossguns green
wash · 2022
2 sentences

2024As detailed in the Crossguns opinion, “Washington first held that such evidence may be admissible over 100 years ago, early in our state’s jurisprudence, though we did not then use the term ‘lustful disposition.’ We later adopted the label ‘lustful disposition.’” 199 Wn.2d 282, 290-91 , 505 P.3d 529 (2022) (citation omitted) (quoting State v. Crowder, 119 Wash. 450, 452 , 205 P. 850 (1922)). - 14 - No. 86166-2-I/15 of evidence but argues that admission here was nonetheless proper under ER 404(b) to demonstrate motive, intent, opportunity, absence of mistake, and as res gestae.

2024As detailed in the Crossguns opinion, “Washington first held that such evidence may be admissible over 100 years ago, early in our state’s jurisprudence, though we did not then use the term ‘lustful disposition.’ We later adopted the label ‘lustful disposition.’” 199 Wn.2d 282, 290-91 , 505 P.3d 529 (2022) (citation omitted) (quoting State v. Crowder, 119 Wash. 450, 452 , 205 P. 850 (1922)). - 14 - No. 86166-2-I/15 of evidence but argues that admission here was nonetheless proper under ER 404(b) to demonstrate motive, intent, opportunity, absence of mistake, and as res gestae.

12024–2024
State v. Crowder neutral
wash · 1922
2 sentences

2024As detailed in the Crossguns opinion, “Washington first held that such evidence may be admissible over 100 years ago, early in our state’s jurisprudence, though we did not then use the term ‘lustful disposition.’ We later adopted the label ‘lustful disposition.’” 199 Wn.2d 282, 290-91 , 505 P.3d 529 (2022) (citation omitted) (quoting State v. Crowder, 119 Wash. 450, 452 , 205 P. 850 (1922)). - 14 - No. 86166-2-I/15 of evidence but argues that admission here was nonetheless proper under ER 404(b) to demonstrate motive, intent, opportunity, absence of mistake, and as res gestae.

2024As detailed in the Crossguns opinion, “Washington first held that such evidence may be admissible over 100 years ago, early in our state’s jurisprudence, though we did not then use the term ‘lustful disposition.’ We later adopted the label ‘lustful disposition.’” 199 Wn.2d 282, 290-91 , 505 P.3d 529 (2022) (citation omitted) (quoting State v. Crowder, 119 Wash. 450, 452 , 205 P. 850 (1922)). - 14 - No. 86166-2-I/15 of evidence but argues that admission here was nonetheless proper under ER 404(b) to demonstrate motive, intent, opportunity, absence of mistake, and as res gestae.

12024–2024
Brown v. MacPherson's, Inc. green
wash · 1975
2 sentences

2019The rescue doctrine recognizes that a duty to exercise reasonable care arises when a person undertakes "to render aid to or warn a person in danger." Brown v. MacPherson's, Inc., 86 Wash.2d 293 , 299, 545 P.2d 13 (1975).

2019The rescue doctrine recognizes that a duty to exercise reasonable care arises when a person undertakes "to render aid to or warn a person in danger." Brown v. MacPherson's, Inc., 86 Wash.2d 293 , 299, 545 P.2d 13 (1975).

12019–2019
Munich v. Skagit Emergency Communications Center green
wash · 2012
2 sentences

2019While there are four exceptions to the public duty doctrine that provide for liability even in the face of otherwise public duties, see Munich, 175 Wash.2d at 879 , 288 P.3d 328 , an enumerated exception is not always necessary to find that a duty is owed to an individual and not to the public at large. 7 Instead, the public duty doctrine is simply a "focusing tool" to ensure that the government is not held liable in tort for duties owed solely to the general public.

2019While there are four exceptions to the public duty doctrine that provide for liability even in the face of otherwise public duties, see Munich, 175 Wash.2d at 879 , 288 P.3d 328 , an enumerated exception is not always necessary to find that a duty is owed to an individual and not to the public at large. 7 Instead, the public duty doctrine is simply a "focusing tool" to ensure that the government is not held liable in tort for duties owed solely to the general public.

12019–2019
United States v. Cecil Hsu green
ca9 · 1988
1 sentence

2016Hsu, 852 F.2d at 410 . ¶113 The touchstone of the analysis under Mosley is whether a “review of the circumstances” leading up to the statements made to police show the “ ‘right to cut off *134 questioning’ was fully respected.” Mosley, 423 U.S. at 104 (quoting Miranda, 384 U.S. at 474). ¶114 Here, the undisputed findings support the conclusion that the right to cut off questioning was scrupulously honored.

12016–2016
Michigan v. Mosley green
scotus · 1975
1 sentence

2016Hsu, 852 F.2d at 410 . ¶113 The touchstone of the analysis under Mosley is whether a “review of the circumstances” leading up to the statements made to police show the “ ‘right to cut off *134 questioning’ was fully respected.” Mosley, 423 U.S. at 104 (quoting Miranda, 384 U.S. at 474). ¶114 Here, the undisputed findings support the conclusion that the right to cut off questioning was scrupulously honored.

12016–2016
Dairyland Greyhound Park, Inc. v. McCallum green
wisctapp · 2002
2 sentences

2012Dairyland Greyhound Park, Inc. v. McCallum, 2002 WI App 259 , 258 Wis. 2d 210 , 655 N.W.2d 474 , 486 n.14.

2012Dairyland Greyhound Park, Inc. v. McCallum, 2002 WI App 259 , 258 Wis. 2d 210 , 655 N.W.2d 474 , 486 n.14.

12012–2012
State v. Cooper green
wash · 1996
1 sentence

2009State v. Cooper, 130 Wash.2d 770, 774 , 928 P.2d 406 (1996); State v. Pink, 144 Wash.App. 945, 952 , 185 P.3d 634 (2008).

12009–2009
State v. Cooper green
wash · 1996
1 sentence

2009State v. Cooper, 130 Wash.2d 770, 774 , 928 P.2d 406 (1996); State v. Pink, 144 Wash.App. 945, 952 , 185 P.3d 634 (2008).

12009–2009
State v. Malone green
wash · 1986
2 sentences

2009Authority to arrest was not an enumerated requirement at common law. [18] Cf. State v. Malone, 106 Wash.2d 607 , 610 n. 1, 612, 724 P.2d 364 (1986) (holding an Idaho police officer had authority to pursue a suspect into Washington under common law "fresh pursuit" doctrine — even though the officer had no authority to arrest under Idaho law — because eluding an officer was a felony under Washington law). [19] The State lacks jurisdiction over Indians who breaks laws on reservations, except for eight exceptions under RCW 37.12.010 in which the State has concurrent jurisdiction.

2009Authority to arrest was not an enumerated requirement at common law. [18] Cf. State v. Malone, 106 Wash.2d 607 , 610 n. 1, 612, 724 P.2d 364 (1986) (holding an Idaho police officer had authority to pursue a suspect into Washington under common law "fresh pursuit" doctrine — even though the officer had no authority to arrest under Idaho law — because eluding an officer was a felony under Washington law). [19] The State lacks jurisdiction over Indians who breaks laws on reservations, except for eight exceptions under RCW 37.12.010 in which the State has concurrent jurisdiction.

12009–2009
State v. Pink green
washctapp · 2008
1 sentence

2009State v. Cooper, 130 Wash.2d 770, 774 , 928 P.2d 406 (1996); State v. Pink, 144 Wash.App. 945, 952 , 185 P.3d 634 (2008).

12009–2009
State v. Pink green
washctapp · 2008
1 sentence

2009State v. Cooper, 130 Wash.2d 770, 774 , 928 P.2d 406 (1996); State v. Pink, 144 Wash.App. 945, 952 , 185 P.3d 634 (2008).

12009–2009
State v. Cruz red
wash · 1999
1 sentence

2000Cruz, 139 Wash.2d at 193 , 985 P.2d 384 .

12000–2000
State v. Gatalski green
washctapp · 1985
1 sentence

1993App. 601, 606-07 , 699 P.2d 804 , review denied, 104 Wn.2d 1019 (1985), the court enumerated the factors showing prejudice as (1) the strength of the State's evidence on each count; (2) the clarity *887 of defenses to each count; (3) the propriety of the court's instruction to the jury to consider the evidence of each crime separately; and (4) the admissibility of the evidence of the other crimes, even if they had been tried separately or never charged or joined.

11993–1993

Statutes the citing opinions construe

WA § Wash. Rev. Code § 2.06.040 (3) WA § Wash. Rev. Code § 46.61.024 (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

PA 308 (1980–2026) GA 201 (1966–2026) OH 170 (1991–2026) NY 87 (1965–2026) CA 69 (1980–2026) TN 59 (1994–2026) TX 45 (1978–2025) IL 41 (1985–2026) NJ 31 (1990–2025) MI 30 (1980–2026) NH 29 (1980–2025) IN 27 (1978–2025) IA 25 (1985–2026) VA 20 (1992–2024) LA 19 (1980–2014) FL 19 (1972–2025) CO 18 (1978–2026) MD 17 (1984–2025) NC 16 (1972–2026) AZ 16 (1966–2025) MO 15 (1984–2025) WA 14 (1993–2026) NV 13 (1994–2022) OR 12 (1984–2022) WI 11 (1964–2026) MS 9 (1990–2010) MA 8 (1982–2025) NM 8 (1986–2024) CT 7 (2000–2025) KS 6 (1983–2021) DC 6 (1985–2025) UT 6 (1988–2023) ND 6 (1981–2014) AK 6 (2013–2025) AR 6 (2004–2017) ID 5 (1983–2025) MT 5 (1986–2020) HI 5 (1982–2022) KY 4 (1981–2022) WV 4 (1998–2013) VT 3 (2009–2023) AL 3 (1968–1979) ME 3 (1986–2004) RI 2 (1985–2017) MN 2 (2002–2007) SD 2 (1999–2023)

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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