first element test (Washington) · Go Syfert
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first element test in Washington

14 Washington opinions name it 2 courts 1970–2019 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 (1)

CaseFollowedCited
Horner v. NORTHERN PAC. ETC. HOSP., INC.green
wash · 1963 · cited in 1 Washington opinions naming this issue, 2019–2019
1 sentence

2019In Horner, the Washington Supreme Court identified three situations where negligence could be inferred without affirmative proof, thereby satisfying the first element of the doctrine: (1) When the act causing the injury is so palpably negligent that it may be inferred as a matter of law, i.e., leaving foreign objects, sponges, scissors, etc., in the body, or amputation of a wrong member; (2) when the general experience and observation of mankind teaches that the result would not be expected without negligence; and (3) when proof by experts in an esoteric field creates an inference that neglige

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 (14)

CaseCitedYears
State v. Laplant green
washctapp · 2010
2 sentences

2014State v. LaPlant, 157 Wn.

2014State v. LaPlant, 157 Wn.

22014–2014
Grimsby v. Samson green
wash · 1975
2 sentences

2002Although the three elements are fact questions for the jury, this first element of the test goes to the jury only after the court "determine[s] if reasonable minds could differ on whether the conduct was sufficiently extreme to result in liability." Id.

2002Although the three elements are fact questions for the jury, this first element of the test goes to the jury only after the court “determine [s] if reasonable minds could differ on whether the conduct was sufficiently extreme to result in liability.” Id.

22002–2002
Robel v. Roundup Corp. green
washctapp · 2000
2 sentences

2002Here, the trial court entered factual findings in Robel's favor on the three elements, CP at 1336-37 (Findings of Fact 51, 52, 57, 59, 60), but the Court of Appeals reversed, determining as a matter of law that "reasonable minds could not differ on whether the conduct was so extreme as to result in liability." Robel, 103 Wash.App. at 90 , 10 P.3d 1104 . *620 While the standard for an outrage claim is admittedly very high (by which we mean that the conduct supporting the claim must be appallingly low), we disagree with the Court of Appeals on the threshold legal question and conclude that reaso

2002Here, the trial court entered factual findings in Robel’s favor on the three elements, CP at 1336-37 (findings of fact 51, 52, 57, 59, 60), but the Court of Appeals reversed, determining as a matter of law that “reasonable minds could not differ on whether the conduct was so extreme as to result in liability.” Robel, 103 Wn.

22002–2002
Dicomes v. State green
wash · 1989
2 sentences

2000Dicomes, 113 Wn.2d at 630 .

2000Dicomes, 113 Wash.2d at 630 , 782 P.2d 1002 .

22000–2000
Strickland v. Washington green
scotus · 1984
2 sentences

2017Ed. 2d 674 (1984). 28 Id. at 697 . 27 Id. at 688 . 28 Id. at 689 . 7 No. 76736-4-1/8 no conceivable legitimate tactic explaining counsel's performance."29 But the defendant must show this or any other deficiency based on the record established in the proceedings below.33 Determining whether counsel provided ineffective assistance is a mixed question of law and fact.31 We review de novo whether a defendant received ineffective assistance of counse1.32 In each challenge, Fisher fails to satisfy the first element of this test and thus we need not consider the second, regarding prejudice.

2017Ed. 2d 674 (1984). 28 Id. at 697 . 27 Id. at 688 . 28 Id. at 689 . 7 No. 76736-4-1/8 no conceivable legitimate tactic explaining counsel's performance."29 But the defendant must show this or any other deficiency based on the record established in the proceedings below.33 Determining whether counsel provided ineffective assistance is a mixed question of law and fact.31 We review de novo whether a defendant received ineffective assistance of counse1.32 In each challenge, Fisher fails to satisfy the first element of this test and thus we need not consider the second, regarding prejudice.

12017–2017
State v. Boswell green
washctapp · 2014
1 sentence

2017State v. Boswell, 185 Wn.

12017–2017
Meisel v. M & N Modern Hydraulic Press Co. green
wash · 1982
1 sentence

2016Meisel. 97 Wn.2d at 410 .

12016–2016
State v. Levy green
wash · 2006
1 sentence

2014He bases his argument primarily upon Becker and State v. Levy, 156 Wn.2d 709 , 132 P.3d 1076 (2006).

12014–2014
State v. Levy green
wash · 2006
1 sentence

2014He bases his argument primarily upon Becker and State v. Levy, 156 Wn.2d 709 , 132 P.3d 1076 (2006).

12014–2014
State v. GARY JE neutral
washctapp · 2000
1 sentence

2012App. 258, 262 , 991 P.2d 1220 (2000). ¶31 The first element of the test is not met in this case.

12012–2012
Equipto Division Aurora Equipment Co. v. Yarmouth green
wash · 1998
1 sentence

2011“Once dissolved, the corporation ‘continues its corporate existence but may not carry on any business except that necessary to wind up and liquidate its business and affairs under RCW 23B.14.050 and notify claimants under RCW 23B.14.060.’ ” Equipto, 134 Wn.2d at 362 (quoting former RCW 23B. 14.210(3) (1989)). ¶26 In analyzing RCW 23B.02.040, Equipto found the first element of a claim—that a defendant “ ‘purport [s] to act as or on behalf of a corporation’ ”—to be straightforward. 134 Wn.2d at 364.

12011–2011
Robel v. Roundup Corp. green
washctapp · 2000
1 sentence

2002Here, the trial court entered factual findings in Robel's favor on the three elements, CP at 1336-37 (Findings of Fact 51, 52, 57, 59, 60), but the Court of Appeals reversed, determining as a matter of law that "reasonable minds could not differ on whether the conduct was so extreme as to result in liability." Robel, 103 Wash.App. at 90 , 10 P.3d 1104 . *620 While the standard for an outrage claim is admittedly very high (by which we mean that the conduct supporting the claim must be appallingly low), we disagree with the Court of Appeals on the threshold legal question and conclude that reaso

12002–2002
Holland v. Niemi green
wash · 1959
2 sentences

1970Holland v. Niemi, 55 Wn.2d 85 , 345 P.2d 1106 (1959); Schock v. Ringling Bros. & Barnum & Bailey Combined Shows, 5 Wn.2d 599, 616 , 105 P.2d 838 (1940).

1970Holland v. Niemi, 55 Wn.2d 85 , 345 P.2d 1106 (1959); Schock v. Ringling Bros. & Barnum & Bailey Combined Shows, 5 Wn.2d 599, 616 , 105 P.2d 838 (1940).

11970–1970
Schock v. Ringling Bros. Etc. neutral
wash · 1940
2 sentences

1970Holland v. Niemi, 55 Wn.2d 85 , 345 P.2d 1106 (1959); Schock v. Ringling Bros. & Barnum & Bailey Combined Shows, 5 Wn.2d 599, 616 , 105 P.2d 838 (1940).

1970Holland v. Niemi, 55 Wn.2d 85 , 345 P.2d 1106 (1959); Schock v. Ringling Bros. & Barnum & Bailey Combined Shows, 5 Wn.2d 599, 616 , 105 P.2d 838 (1940).

11970–1970

Statutes the citing opinions construe

WA § Wash. Rev. Code § 49.60.180 (4) WA § Wash. Rev. Code § 51.48.025 (4) WA § Wash. Rev. Code § 2.06.040 (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

TX 56 (1990–2025) CA 23 (1956–2025) IL 19 (1987–2025) OH 18 (2002–2025) TN 16 (1998–2019) MI 15 (2015–2025) MO 14 (1983–2024) WA 14 (1970–2019) WI 13 (1980–2025) NC 13 (1990–2025) PA 12 (1990–2026) UT 11 (1986–2026) NJ 10 (1993–2026) DE 9 (1987–2023) KS 9 (2019–2025) NY 8 (1990–2025) CO 8 (1983–2026) SD 7 (1978–2026) IA 7 (1984–2024) MA 7 (1992–2020) FL 7 (1988–2026) CT 7 (1991–2025) GA 6 (2002–2019) NM 6 (2013–2022) MN 6 (1987–2018) RI 6 (1980–2021) IN 6 (1982–2005) ID 6 (1993–2020) NE 5 (1959–2025) WV 5 (1988–2017) AR 4 (2002–2020) MT 4 (1994–2025) MS 4 (1994–2002) KY 4 (2013–2024) DC 4 (1986–2025) LA 3 (2001–2015) MD 3 (2002–2017) AL 3 (1995–2009) WY 3 (2003–2016) SC 3 (2003–2018) HI 3 (1978–2016) ME 3 (2001–2019) ND 2 (1982–2025) AZ 2 (1976–2006) OK 2 (1985–1993)

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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