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

14 Washington opinions name it 2 courts 1924–2026 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 (5)

CaseFollowedCited
Strickland v. Washingtongreen
scotus · 1984 · cited in 3 Washington opinions naming this issue, 2006–2021
2 sentences

2021When evaluating whether counsel’s representation is deficient, “the performance inquiry must be whether counsel’s assistance was reasonable considering all the circumstances.” Strickland, 466 U.S. at 688 .

2006Even if counsel gave weight to Crawford’s wishes in proceeding to trial, it was unreasonable under the circumstances to neglect to investigate Crawford’s prior convictions. 124 In evaluating a claim for ineffective assistance of counsel, “the performance inquiry must be whether counsel’s assistance was reasonable considering all the circumstances.” Strickland, 466 U.S. at 688 (emphasis added).

13
Jacobson v. Gulbransengreen
sd · 2001 · cited in 1 Washington opinions naming this issue, 2007–2007
2 sentences

2007Whatever the rationale, however, it is clear when a party breaches a contract to convey real property, the presumptive remedy is specific performance. 71 AM.JUR.2D Specific Performance § 133 (2001); see Jacobson v. Gulbransen, 2001 SD 33 , 623 N.W.2d 84, 91 (2001) ("Specific performance is `[t]he presumed remedy for the breach of an agreement to transfer real property.'") (quoting Wiggins v. Shewmake, 374 N.W.2d 111, 115 (S.D.1985)). [8] At oral argument, Pitts' counsel claimed if we allow the Crafts' specific performance claim to stand, then a bankruptcy court could never discharge a real pro

2007Whatever the rationale, however, it is clear when a party breaches a contract to convey real property, the presumptive remedy is specific performance. 71 AM.JUR.2D Specific Performance § 133 (2001); see Jacobson v. Gulbransen, 2001 SD 33 , 623 N.W.2d 84, 91 (2001) ("Specific performance is `[t]he presumed remedy for the breach of an agreement to transfer real property.'") (quoting Wiggins v. Shewmake, 374 N.W.2d 111, 115 (S.D.1985)). [8] At oral argument, Pitts' counsel claimed if we allow the Crafts' specific performance claim to stand, then a bankruptcy court could never discharge a real pro

11
Wiggins v. Shewmakegreen
sd · 1985 · cited in 1 Washington opinions naming this issue, 2007–2007
1 sentence

2007Whatever the rationale, however, it is clear when a party breaches a contract to convey real property, the presumptive remedy is specific performance. 71 AM.JUR.2D Specific Performance § 133 (2001); see Jacobson v. Gulbransen, 2001 SD 33 , 623 N.W.2d 84, 91 (2001) ("Specific performance is `[t]he presumed remedy for the breach of an agreement to transfer real property.'") (quoting Wiggins v. Shewmake, 374 N.W.2d 111, 115 (S.D.1985)). [8] At oral argument, Pitts' counsel claimed if we allow the Crafts' specific performance claim to stand, then a bankruptcy court could never discharge a real pro

11
In re the Personal Restraint of Isadoregreen
wash · 2004 · cited in 1 Washington opinions naming this issue, 2006–2006
2 sentences

2006Restraint of Isadore, 151 Wn.2d 294, 303, 88 P.3d 390 (2004) (concluding that, because the State “ha[d] not objected to the defendant’s chosen remedy and in oral argument could not assert any reasons why specific performance would be unjust,” Isadore was entitled to specific performance of the original sentence). ¶[19 While the State argues that the sole available remedy is the withdrawal of Bisson’s entire plea (complete rescission), Bisson contends that he should be permitted to choose between the two remedies: the withdrawal of the plea to the enhancements only (partial rescission of the ag

2006Restraint of Isadore, 151 Wash.2d 294, 303 , 88 P.3d 390 (2004) (concluding that, because the State "ha[d] not objected to the defendant's chosen remedy and in oral argument could not assert any reasons why specific performance would be unjust," Isadore was entitled to specific performance of the original sentence). ¶ 19 While the State argues that the sole available remedy is the withdrawal of Bisson's entire plea (complete rescission), Bisson contends that he should be permitted to choose between the two remedies, the withdrawal of the plea to the enhancements only (partial rescission of the

11
Cannon v. Huhndorfgreen
wash · 1966 · cited in 1 Washington opinions naming this issue, 1986–1986
2 sentences

1986Restatement (Second) of Contracts §§ 261, 263 (1981); see also Cannon v. Huhndorf, 67 Wn.2d 778 , 409 P.2d 865 (1966).

1986Restatement (Second) of Contracts §§ 261, 263 (1981); see also Cannon v. Huhndorf, 67 Wn.2d 778 , 409 P.2d 865 (1966).

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 (12)

CaseCitedYears
State v. Bertrand green
wash · 2024
1 sentence

2026Id.

12026–2026
City of Seattle v. Heatley green
washctapp · 1993
1 sentence

2023He also testified, “‘I determined that Mr. Heatley was obviously intoxicated and affected by the alcoholic drink that he’d been, he could not drive a motor vehicle in a safe manner.’” Id. at 576 .

12023–2023
State v. Kyllo green
wash · 2009
1 sentence

2018"When counsel's conduct can be characterized as legitimate trial strategy or tactics, performance is not deficient." KvIlo, 166 Wn.2d at 863 .

12018–2018
Berg v. Ting green
wash · 1995
2 sentences

2017Berg v. Ting, 125 Wn.2d 544, 556 , 886 P.2d 564 (1995).

2017Berg v. Ting, 125 Wn.2d 544, 556 , 886 P.2d 564 (1995).

12017–2017
Navlet v. Port of Seattle green
wash · 2008
1 sentence

2014Specifically, petitioners argue that because the faculty class had worked for most of the 2008-2009 academic year in reliance on the university’s promise of a raise in salary for the 2009-2010 academic year, they had substantially performed and thereby accepted the university’s offer. ¶15 Pointing to our decision in Navlet v. Port of Seattle, 164 Wn.2d 818 , 194 P.3d 221 (2008), petitioners urge that this court has adopted the substantial performance doctrine.

12014–2014
Navlet v. Port of Seattle green
wash · 2008
1 sentence

2014Specifically, petitioners argue that because the faculty class had worked for most of the 2008-2009 academic year in reliance on the university’s promise of a raise in salary for the 2009-2010 academic year, they had substantially performed and thereby accepted the university’s offer. ¶15 Pointing to our decision in Navlet v. Port of Seattle, 164 Wn.2d 818 , 194 P.3d 221 (2008), petitioners urge that this court has adopted the substantial performance doctrine.

12014–2014
In Re Isadore green
wash · 2004
2 sentences

2006Restraint of Isadore, 151 Wn.2d 294, 303, 88 P.3d 390 (2004) (concluding that, because the State “ha[d] not objected to the defendant’s chosen remedy and in oral argument could not assert any reasons why specific performance would be unjust,” Isadore was entitled to specific performance of the original sentence). ¶[19 While the State argues that the sole available remedy is the withdrawal of Bisson’s entire plea (complete rescission), Bisson contends that he should be permitted to choose between the two remedies: the withdrawal of the plea to the enhancements only (partial rescission of the ag

2006Restraint of Isadore, 151 Wash.2d 294, 303 , 88 P.3d 390 (2004) (concluding that, because the State "ha[d] not objected to the defendant's chosen remedy and in oral argument could not assert any reasons why specific performance would be unjust," Isadore was entitled to specific performance of the original sentence). ¶ 19 While the State argues that the sole available remedy is the withdrawal of Bisson's entire plea (complete rescission), Bisson contends that he should be permitted to choose between the two remedies, the withdrawal of the plea to the enhancements only (partial rescission of the

12006–2006
Bulmon v. Bailey green
wash · 1945
2 sentences

1977The law is well stated by the court in Bulmon v. Bailey, 22 Wn.2d 372 , 156 P.2d 231 (1945), at 376-77: Time of payment of the installments of purchase price was made of the essence of the contracts, and if the vendors had from the beginning insisted upon strict performance they could have forfeited either contract upon the happening of the first default thereof.

1977The law is well stated by the court in Bulmon v. Bailey, 22 Wn.2d 372 , 156 P.2d 231 (1945), at 376-77: Time of payment of the installments of purchase price was made of the essence of the contracts, and if the vendors had from the beginning insisted upon strict performance they could have forfeited either contract upon the happening of the first default thereof.

11977–1977
Harrild v. Spokane School District neutral
wash · 1920
2 sentences

1925App. 489 , wherein the court relying oh Estep v. Fenton, 66 Ill. 467 , and Keeler v. Kerr, 157 Ill. 57 , 41 N. E. 750 , said: “Whether a contract has been substantially performed is a question of law, and the submission of that question to a jury without informing them what constitutes a substantial performance is error.” This view is in harmony with what was said in Harrild v. Spokane School District, 112 Wash. 266 , 192 Pac. 1 , 19 A. L.

1925App. 489 , wherein the court relying oh Estep v. Fenton, 66 Ill. 467 , and Keeler v. Kerr, 157 Ill. 57 , 41 N. E. 750 , said: “Whether a contract has been substantially performed is a question of law, and the submission of that question to a jury without informing them what constitutes a substantial performance is error.” This view is in harmony with what was said in Harrild v. Spokane School District, 112 Wash. 266 , 192 Pac. 1 , 19 A. L.

11925–1925
Estep v. Fenton neutral
ill · 1873
1 sentence

1925App. 489 , wherein the court relying oh Estep v. Fenton, 66 Ill. 467 , and Keeler v. Kerr, 157 Ill. 57 , 41 N. E. 750 , said: “Whether a contract has been substantially performed is a question of law, and the submission of that question to a jury without informing them what constitutes a substantial performance is error.” This view is in harmony with what was said in Harrild v. Spokane School District, 112 Wash. 266 , 192 Pac. 1 , 19 A. L.

11925–1925
Keeler v. Herr green
ill · 1895
2 sentences

1925App. 489 , wherein the court relying oh Estep v. Fenton, 66 Ill. 467 , and Keeler v. Kerr, 157 Ill. 57 , 41 N. E. 750 , said: “Whether a contract has been substantially performed is a question of law, and the submission of that question to a jury without informing them what constitutes a substantial performance is error.” This view is in harmony with what was said in Harrild v. Spokane School District, 112 Wash. 266 , 192 Pac. 1 , 19 A. L.

1925App. 489 , wherein the court relying oh Estep v. Fenton, 66 Ill. 467 , and Keeler v. Kerr, 157 Ill. 57 , 41 N. E. 750 , said: “Whether a contract has been substantially performed is a question of law, and the submission of that question to a jury without informing them what constitutes a substantial performance is error.” This view is in harmony with what was said in Harrild v. Spokane School District, 112 Wash. 266 , 192 Pac. 1 , 19 A. L.

11925–1925
Wadham v. McVicar green
wash · 1921
2 sentences

1924In support of this contention appellant relies on the doctrine announced in Wadham v. McVicar, 115 Wash. 503 , 197 Pac. 616 , and cases there cited, to the effect that where, under a contract calling for payment at designated times and for strict performance, the vendor receives payments after the times provided therefor or grants other indulgences, he thereby waives the strict performance clause of his contract and cannot claim forfeiture until he has given the vendee notice of intention so to do and a reasonable time within which tO'make the overdue payments.

1924In support of this contention appellant relies on the doctrine announced in Wadham v. McVicar, 115 Wash. 503 , 197 Pac. 616 , and cases there cited, to the effect that where, under a contract calling for payment at designated times and for strict performance, the vendor receives payments after the times provided therefor or grants other indulgences, he thereby waives the strict performance clause of his contract and cannot claim forfeiture until he has given the vendee notice of intention so to do and a reasonable time within which tO'make the overdue payments.

11924–1924

Statutes the citing opinions construe

WA § Wash. Rev. Code § 9A.36.021 (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

OH 352 (1986–2026) TX 203 (1961–2026) KS 84 (1990–2025) IL 62 (1891–2025) CT 58 (1909–2025) CA 58 (1919–2026) NY 53 (1903–2026) MS 48 (1988–2022) AL 36 (1975–2023) FL 35 (1963–2026) PA 32 (1912–2025) MI 32 (1920–2025) UT 30 (1982–2026) MD 24 (1884–2025) RI 23 (1970–2026) IN 21 (1894–2023) GA 20 (1977–2025) OR 16 (1929–2026) MT 15 (1944–2020) TN 14 (1915–2026) MO 14 (1975–2025) WA 14 (1924–2026) NJ 11 (1961–2023) IA 10 (1909–2025) WY 10 (1926–2026) DC 10 (1985–2024) MN 10 (1905–2007) WI 10 (1965–2024) NM 10 (1986–2023) VA 9 (1969–2018) NC 9 (1984–2022) SC 9 (1981–2025) KY 9 (1924–2022) MA 8 (1978–2024) AZ 8 (1966–2023) DE 8 (1999–2026) CO 8 (1940–2025) NE 7 (1894–2022) ND 6 (1974–2016) ME 5 (1947–2011) VT 5 (1972–2024) OK 4 (1937–2007) LA 4 (1895–2026) SD 4 (2005–2023) WV 4 (1995–2015) ID 3 (2009–2026) HI 2 (1967–2024) AR 2 (1989–1996) AK 2 (1970–2021) NV 2 (1950–2015) NH 2 (1988–1997)

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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