departure rule (District of Columbia) · Go Syfert
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departure rule in District of Columbia

13 District of Columbia opinions name it 1 courts 1975–2021 1 in the last five years

The cases below were cited by District of Columbia 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 (12)

CaseFollowedCited
Lenaerts v. District of Columbia Department of Employment Servicesgreen
dc · 1988 · cited in 2 District of Columbia opinions naming this issue, 2017–2017
2 sentences

2017See DeShazo, 638 A.2d at 1156 (noting that “scheduled benefit will be an appropriate, if arbitrary, compensation to offset wage losses that eventually can be anticipated”); Smith, 548 A.2d at 101 (quoting LARSON for proposition that “the schedule was never intended to be a departure from or an exception to the wage- loss principle”); Lenaerts v. District of Columbia Dep’t of Emp’t Servs., 545 A.2d 1234, 1236-39 (D.C. 1988) (distinguishing between different and mutually exclusive formulas for calculating compensation for schedule and non-schedule work injuries).

2017See DeShazo, 638 A.2d at 1156 (noting that “scheduled benefit will be an appropriate, if arbitrary, compensation to offset wage losses that eventually can be anticipated”); Smith, 548 A.2d at 101 (quoting Larson for proposi *903 tion that “the schedule was never intended to be a departure from or an exception to the wage-loss principle”); Lenaerts v. District of Columbia Dep’t of Emp’t Servs., 545 A.2d 1234, 1236-39 (D.C. 1988) (distinguishing between different and mutually exclusive formulas for calculating compensation for schedule and non-schedule work injuries).

22
Smith v. District of Columbia Department of Employment Servicesgreen
dc · 1988 · cited in 3 District of Columbia opinions naming this issue, 2009–2017
2 sentences

2017See DeShazo, 638 A.2d at 1156 (noting that “scheduled benefit will be an appropriate, if arbitrary, compensation to offset wage losses that eventually can be anticipated”); Smith, 548 A.2d at 101 (quoting LARSON for proposition that “the schedule was never intended to be a departure from or an exception to the wage- loss principle”); Lenaerts v. District of Columbia Dep’t of Emp’t Servs., 545 A.2d 1234, 1236-39 (D.C. 1988) (distinguishing between different and mutually exclusive formulas for calculating compensation for schedule and non-schedule work injuries).

2017See DeShazo, 638 A.2d at 1156 (noting that “scheduled benefit will be an appropriate, if arbitrary, compensation to offset wage losses that eventually can be anticipated”); Smith, 548 A.2d at 101 (quoting Larson for proposi *903 tion that “the schedule was never intended to be a departure from or an exception to the wage-loss principle”); Lenaerts v. District of Columbia Dep’t of Emp’t Servs., 545 A.2d 1234, 1236-39 (D.C. 1988) (distinguishing between different and mutually exclusive formulas for calculating compensation for schedule and non-schedule work injuries).

13
Watkins v. Sowdersgreen
scotus · 1981 · cited in 1 District of Columbia opinions naming this issue, 2021–2021
1 sentence

2021See, e.g., Watkins v. Sowders, 449 U.S. 341 , 347–49 (1981) (“the proper evaluation of evidence under the instructions of the trial judge is the very task our system must assume juries can perform”; “[w]here identification evidence is at issue . . . no . . . special considerations justify a departure from the presumption that juries will follow instructions” because “the time-honored process of cross- examination [is] the device best suited to determine the trustworthiness of testimonial evidence”).

11
DeShazo v. District of Columbia Department of Employment Servicesgreen
dc · 1994 · cited in 1 District of Columbia opinions naming this issue, 2017–2017
1 sentence

2017See DeShazo, 638 A.2d at 1156 (noting that “scheduled benefit will be an appropriate, if arbitrary, compensation to offset wage losses that eventually can be anticipated”); Smith, 548 A.2d at 101 (quoting Larson for proposi *903 tion that “the schedule was never intended to be a departure from or an exception to the wage-loss principle”); Lenaerts v. District of Columbia Dep’t of Emp’t Servs., 545 A.2d 1234, 1236-39 (D.C. 1988) (distinguishing between different and mutually exclusive formulas for calculating compensation for schedule and non-schedule work injuries).

11
In Re Bachgreen
dc · 2009 · cited in 1 District of Columbia opinions naming this issue, 2010–2010
1 sentence

2010While the Addams rule operates "presumptively,” the presumption may be overcome only by a showing of "extraordinary circumstances warranting a departure from the rule.” In re Bach, 966 A.2d 350, 365 (D.C.2009) (Board’s opinion, adopted by the court).

11
Ladner v. United Statesgreen
scotus · 1958 · cited in 1 District of Columbia opinions naming this issue, 1997–1997
2 sentences

1997See, e.g., Ladner v. United States, 358 U.S. 169, 178 , 79 S.Ct. 209, 214 , 3 L.Ed.2d 199 (1958).

1997See, e.g., Ladner v. United States, 358 U.S. 169, 178 , 79 S.Ct. 209, 214 , 3 L.Ed.2d 199 (1958).

11
Luck v. District of Columbiagreen
dc · 1992 · cited in 1 District of Columbia opinions naming this issue, 1997–1997
2 sentences

1997In what I view as a departure from the rule of M.A.P. v. Ryan, 285 A.2d 310 (D.C.1971), my colleagues have declined to follow a key part of our decision in Luck v. District of Columbia, 617 A.2d 509, 515 (D.C. 1992) ( Luck I ), a case in which we held unambiguously that the interpretation by the District of Columbia Department of Corrections (DOC) of the identical statutory provisions here at issue, and of the interplay between them, is entitled to "great weight." Finally, the majority has impermissibly construed a penal statute broadly beyond its text, to the prejudice of the liberty of the c

1997In what I view as a departure from the rule of M.A.P. v. Ryan, 285 A.2d 310 (D.C.1971), my colleagues have declined to follow a key part of our decision in Luck v. District of Columbia, 617 A.2d 509, 515 (D.C. 1992) (Luck I), a case in which we held unambiguously that the interpretation by the District of Columbia Department of Corrections (DOC) of the identical statutory provisions here at issue, and of the interplay between them, is entitled to “great weight.” Finally, the majority has impermissibly construed a penal statute broadly beyond its text, to the prejudice of the liberty of the cit

11
Wallace v. Warehouse Employees Union No. 730green
dc · 1984 · cited in 1 District of Columbia opinions naming this issue, 1994–1994
1 sentence

1994See Wallace v. Warehouse Employees Union No. 730, 482 A.2d 801 , 803 n. 5 (D.C.1984) (citation omitted); see also Clement v. District of Columbia Dep't of Human Servs., 629 A.2d 1215, 1219 (D.C.1993) (relief pursuant to Rule 60(b) is granted only in "exceptional circumstances” as a departure from the rule of "finality of judgments”) (citations omitted); Forgotson v. Shea, 491 A.2d 523, 528 (D.C.1985) ("where reconsideration is sought on the basis of 'newly discovered evidence,’ the movant must demonstrate it could not reasonably have been discovered in advance of trial and would likely produce

11
Forgotson v. Sheagreen
dc · 1985 · cited in 1 District of Columbia opinions naming this issue, 1994–1994
1 sentence

1994See Wallace v. Warehouse Employees Union No. 730, 482 A.2d 801 , 803 n. 5 (D.C.1984) (citation omitted); see also Clement v. District of Columbia Dep't of Human Servs., 629 A.2d 1215, 1219 (D.C.1993) (relief pursuant to Rule 60(b) is granted only in "exceptional circumstances” as a departure from the rule of "finality of judgments”) (citations omitted); Forgotson v. Shea, 491 A.2d 523, 528 (D.C.1985) ("where reconsideration is sought on the basis of 'newly discovered evidence,’ the movant must demonstrate it could not reasonably have been discovered in advance of trial and would likely produce

11
Clement v. District of Columbia Department of Human Servicesgreen
dc · 1993 · cited in 1 District of Columbia opinions naming this issue, 1994–1994
1 sentence

1994See Wallace v. Warehouse Employees Union No. 730, 482 A.2d 801 , 803 n. 5 (D.C.1984) (citation omitted); see also Clement v. District of Columbia Dep't of Human Servs., 629 A.2d 1215, 1219 (D.C.1993) (relief pursuant to Rule 60(b) is granted only in "exceptional circumstances” as a departure from the rule of "finality of judgments”) (citations omitted); Forgotson v. Shea, 491 A.2d 523, 528 (D.C.1985) ("where reconsideration is sought on the basis of 'newly discovered evidence,’ the movant must demonstrate it could not reasonably have been discovered in advance of trial and would likely produce

11
Duncan v. Cessna Aircraft Co.red
tex · 1984 · cited in 1 District of Columbia opinions naming this issue, 1985–1985
2 sentences

1985Under this concept recovery is barred because of the plaintiff's departure from the standard of reasonable conduct and notwithstanding the misconduct of the defendant"), cert. denied, 382 U.S. 987 , 86 S.Ct. 549 , 15 L.Ed.2d 475 (1966); Duncan v. Cessna Aircraft Co., 665 S.W.2d 414, 423 (Tex.1984) ("Assumed risk . . . [is] nothing more than [an] extreme variant[] of contributory negligence.

1985Under this concept recovery is barred because of the plaintiff’s departure from the standard of reasonable conduct and notwithstanding the misconduct of the defendant”), cert. denied, 382 U.S. 987 , 86 S.Ct. 549 , 15 L.Ed.2d 475 (1966); Duncan v. Cessna Aircraft Co., 665 S.W.2d 414, 423 (Tex.1984) (“Assumed risk ... [is] nothing more than [an] extreme variant[] of contributory negligence.

11
National Marine Service Incorporated v. Petroleum Service Corporation v. Kaiser Aluminum and Chemical Corporationgreen
ca5 · 1984 · cited in 1 District of Columbia opinions naming this issue, 1985–1985
2 sentences

1985To varying degrees, [both] . . . focus on the reasonableness of a plaintiff's conduct."); National Marine Services, Inc. v. Petroleum Services Corp., 736 F.2d 272, 276-77 (5th Cir. 1984) (in a comparative negligence jurisdiction, court holds that since "[e]xperience has demonstrated . . . the niceties of these theoretical distinctions [between assumption of risk and contributory negligence] are often lost in the practical application of these defenses," the court is "persuaded that no distinction should be made between [them], but that the plaintiff's conduct (whether theoretically mere contri

1985To varying degrees, [both] ... focus on the reasonableness of a plaintiff’s conduct.”); National Marine Services, Inc. v. Petroleum Services Corp., 736 F.2d 272, 276-77 (5th Cir.1984) (in a comparative negligence jurisdiction, court holds that since “[experience has demonstrated ... the niceties of these theoretical distinctions [between assumption of risk and contributory negligence] are often lost in the practical application of these defenses,” the court is “persuaded that no distinction should be made between [them], but that the plaintiff’s conduct (whether theoretically mere contributory

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in District of Columbia. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
Matter of Addams green
dc · 1990
1 sentence

2011In Addams , we noted that mitigating factors “of the usual sort” “will suffice to overcome the presumption of disbarment only if they are especially strong *287 and, where there are aggravating factors, they substantially outweigh any aggravating factors as well.” Id. at 191 .

12011–2011
Sioux City Bridge Co. v. Dakota County green
scotus · 1923
2 sentences

2007The conclusion is based on the principle that where it is impossible to secure both the standard of the true value, and the uniformity and equality required by law, the latter requirement is to be preferred as the just and ultimate purpose of the law.” Sioux City Bridge Co. v. Dakota County, 260 U.S. 441, 446 , 43 S.Ct. 190 , 67 L.Ed. 340 (1923).

2007The conclusion is based on the principle that where it is impossible to secure both the standard of the true value, and the uniformity and equality required by law, the latter requirement is to be preferred as the just and ultimate purpose of the law.” Sioux City Bridge Co. v. Dakota County, 260 U.S. 441, 446 , 43 S.Ct. 190 , 67 L.Ed. 340 (1923).

12007–2007
M. A. P. v. Ryan green
dc · 1971
2 sentences

1997In what I view as a departure from the rule of M.A.P. v. Ryan, 285 A.2d 310 (D.C.1971), my colleagues have declined to follow a key part of our decision in Luck v. District of Columbia, 617 A.2d 509, 515 (D.C. 1992) ( Luck I ), a case in which we held unambiguously that the interpretation by the District of Columbia Department of Corrections (DOC) of the identical statutory provisions here at issue, and of the interplay between them, is entitled to "great weight." Finally, the majority has impermissibly construed a penal statute broadly beyond its text, to the prejudice of the liberty of the c

1997In what I view as a departure from the rule of M.A.P. v. Ryan, 285 A.2d 310 (D.C.1971), my colleagues have declined to follow a key part of our decision in Luck v. District of Columbia, 617 A.2d 509, 515 (D.C. 1992) (Luck I), a case in which we held unambiguously that the interpretation by the District of Columbia Department of Corrections (DOC) of the identical statutory provisions here at issue, and of the interplay between them, is entitled to “great weight.” Finally, the majority has impermissibly construed a penal statute broadly beyond its text, to the prejudice of the liberty of the cit

11997–1997
In Re Garner green
dc · 1990
1 sentence

1994Id.

11994–1994
Liggett & Myers Tobacco Co. v. Pritchard green
scotus · 1966
2 sentences

1985Under this concept recovery is barred because of the plaintiff's departure from the standard of reasonable conduct and notwithstanding the misconduct of the defendant"), cert. denied, 382 U.S. 987 , 86 S.Ct. 549 , 15 L.Ed.2d 475 (1966); Duncan v. Cessna Aircraft Co., 665 S.W.2d 414, 423 (Tex.1984) ("Assumed risk . . . [is] nothing more than [an] extreme variant[] of contributory negligence.

1985Under this concept recovery is barred because of the plaintiff’s departure from the standard of reasonable conduct and notwithstanding the misconduct of the defendant”), cert. denied, 382 U.S. 987 , 86 S.Ct. 549 , 15 L.Ed.2d 475 (1966); Duncan v. Cessna Aircraft Co., 665 S.W.2d 414, 423 (Tex.1984) (“Assumed risk ... [is] nothing more than [an] extreme variant[] of contributory negligence.

11985–1985
Thompson v. Kisen green
scotus · 1966
2 sentences

1985Under this concept recovery is barred because of the plaintiff's departure from the standard of reasonable conduct and notwithstanding the misconduct of the defendant"), cert. denied, 382 U.S. 987 , 86 S.Ct. 549 , 15 L.Ed.2d 475 (1966); Duncan v. Cessna Aircraft Co., 665 S.W.2d 414, 423 (Tex.1984) ("Assumed risk . . . [is] nothing more than [an] extreme variant[] of contributory negligence.

1985Under this concept recovery is barred because of the plaintiff’s departure from the standard of reasonable conduct and notwithstanding the misconduct of the defendant”), cert. denied, 382 U.S. 987 , 86 S.Ct. 549 , 15 L.Ed.2d 475 (1966); Duncan v. Cessna Aircraft Co., 665 S.W.2d 414, 423 (Tex.1984) (“Assumed risk ... [is] nothing more than [an] extreme variant[] of contributory negligence.

11985–1985
Griffith v. Board of Commissioners of the Alabama State Bar green
scotus · 1966
2 sentences

1985Under this concept recovery is barred because of the plaintiff's departure from the standard of reasonable conduct and notwithstanding the misconduct of the defendant"), cert. denied, 382 U.S. 987 , 86 S.Ct. 549 , 15 L.Ed.2d 475 (1966); Duncan v. Cessna Aircraft Co., 665 S.W.2d 414, 423 (Tex.1984) ("Assumed risk . . . [is] nothing more than [an] extreme variant[] of contributory negligence.

1985Under this concept recovery is barred because of the plaintiff’s departure from the standard of reasonable conduct and notwithstanding the misconduct of the defendant”), cert. denied, 382 U.S. 987 , 86 S.Ct. 549 , 15 L.Ed.2d 475 (1966); Duncan v. Cessna Aircraft Co., 665 S.W.2d 414, 423 (Tex.1984) (“Assumed risk ... [is] nothing more than [an] extreme variant[] of contributory negligence.

11985–1985
Nunan v. Timberlake green
cadc · 1936
1 sentence

1980These cases, which admit for the establishment of a prima facie case evidence of the nature of medical treatment and the amount of the bill incurred, see Nunan, supra at 153 , 85 F.2d at 410 , represent a departure from the rule common in many jurisdictions requiring separate proof of the reasonableness of charges sought to be admitted as evidence of damages in personal injury and wrongful death actions.

11980–1980
United States v. Hark green
scotus · 1944
2 sentences

1975That court relied on United States v. Hark, 320 U.S. 531 , 64 S.Ct. 359 , 88 L.Ed. 290 (1944), for the presumption that the formal order was intended to be the final one.

1975That court relied on United States v. Hark, 320 U.S. 531 , 64 S.Ct. 359 , 88 L.Ed. 290 (1944), for the presumption that the formal order was intended to be the final one.

11975–1975
United States v. Carl T. Lee and Darlene C. Humphries green
cadc · 1974
1 sentence

1975The government also urges that we follow a recent holding of the federal Circuit Court here that where . . . the District Judge sees fit to enter a formal order and does so before the time to file notice of appeal expires, we will presume, in the absence of any contrary showing, that she intended the formal order to be the final judgment from which the appeal may be taken. . . . [United States v. Lee, 501 F.2d 890 , 891 n. 1 (D.C.Cir. 1974).] While that holding does reflect a departure from the rule of strict application on notice of appeal timing, we are not persuaded by that court’s reasonin

11975–1975

Statutes the citing opinions construe

DC § D.C. Code § 32-1508 (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 129 (1848–2026) WA 99 (1896–2026) OR 53 (1887–2022) TX 52 (1856–2024) CA 47 (1910–2025) PA 45 (1895–2026) MN 40 (1888–2026) OH 35 (1924–2026) IL 32 (1899–2024) FL 31 (1929–2025) MI 25 (1894–2022) NJ 22 (1891–2026) MD 22 (1930–2025) TN 21 (1882–2012) AL 20 (1879–2000) KS 19 (1900–2022) VA 18 (1842–2013) NE 17 (1902–2022) MA 16 (1862–2012) MO 16 (1878–2018) MS 16 (1962–2008) CO 14 (1899–2013) IN 14 (1891–2024) SD 14 (1966–2024) WI 13 (1880–2006) LA 13 (1848–1991) DC 13 (1975–2021) ND 13 (1905–2022) MT 12 (1887–2024) AZ 12 (1938–2024) WV 11 (1907–2024) RI 11 (1966–2020) IA 10 (1895–2016) NC 8 (1898–2026) NM 8 (1914–2022) AR 6 (1898–2004) GA 6 (1859–2022) NV 6 (1926–2018) UT 6 (1891–2007) HI 6 (1978–2018) SC 5 (1932–2010) KY 5 (1913–1998) CT 5 (1974–2019) OK 4 (1927–2018) ME 4 (1854–2009) NH 4 (1840–2014) ID 4 (1928–2005) WY 4 (1963–2004) VT 4 (1926–2015) DE 3 (1961–1991) AK 3 (1886–2013)

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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