day hearing in Washington

2025F.L. nevertheless avers the court did not apply the correct standard because there was no evidence of a “recent overt act,” as required under In re Detention of Harris, 98 Wn.2d 276, 284 , 654 P.2d 109 (1982), and the court based its findings on his “elderly stepmother’s subjective fear,” instead of applying an objective standard as required by law.

2025F.L. nevertheless avers the court did not apply the correct standard because there was no evidence of a “recent overt act,” as required under In re Detention of Harris, 98 Wn.2d 276, 284 , 654 P.2d 109 (1982), and the court based its findings on his “elderly stepmother’s subjective fear,” instead of applying an objective standard as required by law.

2024App. 657, 669 , 50 P.3d 298 (2002); RAP 10.3(a)(6). 5 As Nguyen notes, McCullough could have addressed the Zoom issues with the trial court by filing a motion under RCW 7.105.205(5)(g), which provides a remedy for problems with remote hearings for protection orders: “If a party was unable to provide the notification regarding issues with remote access or other technological difficulties on the day of the hearing prior to the court’s ruling, that party may seek relief via a motion for reconsideration.” The first version of the statute, which contained this provision, went into effect on July 25

2021Zigler & Sidwell, 154 Wn.

2016Paul Fire and Marine Insurance Co. v. Onvia, Inc., our Supreme Court extended Coventry to a third-party coverage setting where an insurer did not defend under a reservation of rights and bad faith consisted solely of "procedural missteps."23 Reading Onvia broadly, MOE argues that its failure to promptly investigate Day's claim for reformation and promptly communicate with her about that investigation "[did] not trigger the policy concerns that have led courts to apply" coverage by estoppe1.24 But Onvia rejected a presumption of harm and coverage by estoppel because, as in Coventry, neither a f

2016Paul Fire and Marine Insurance Co. v. Onvia, Inc., our Supreme Court extended Coventry to a third-party coverage setting where an insurer did not defend under a reservation of rights and bad faith consisted solely of "procedural missteps."23 Reading Onvia broadly, MOE argues that its failure to promptly investigate Day's claim for reformation and promptly communicate with her about that investigation "[did] not trigger the policy concerns that have led courts to apply" coverage by estoppe1.24 But Onvia rejected a presumption of harm and coverage by estoppel because, as in Coventry, neither a f

2015She argues that "[t]he court denied the stay pending appeal because [Cina] could not pay the [homeowner association] dues and the back rent in one lump sum at the day of the hearing."14 But the record expressly establishes that Cina voluntarily struck her motion to stay the writ of restitution.15 13 See Phillips v. Hardwick. 29 Wn.

2015App. 382, 386 , 628 P.2d 506 (1981) (an unlawful detainer action is limited to the right of possession, plus incidental issues such as restitution, rent, or damages). 14 Appellant's Br. at 10. 15 The order on civil motion states, "The above-entitled Court, having heard a motion to stay the writ of restitution pending appeal, and the defendant having stricken the motion at 8:30 a.m. for a 9:00 a.m. hearing, and the court and plaintiff's counsel having learned of the strike at 9:00 a.m. when the hearing was called.

1990It cites Zamora v. Mobil Oil Corp., 104 Wn.2d 211, 222, 704 P.2d 591 (1985) and Pickett v. Stephens-Nelsen, Inc., 43 Wn.

1989State v. Edwards, 104 Wn.2d 63 , 701 P.2d 508 (1985) (the common law year and a day rule of ensuing death adopted as a constituent element of the crime of murder in the absence of the statutory provision to the contrary). *456 Indecent exposure at common law consists of exposure in public of the entire person or of parts that should not be exhibited.

1989State v. Edwards, 104 Wn.2d 63 , 701 P.2d 508 (1985) (the common law year and a day rule of ensuing death adopted as a constituent element of the crime of murder in the absence of the statutory provision to the contrary). *456 Indecent exposure at common law consists of exposure in public of the entire person or of parts that should not be exhibited.

1987Co., 352 F.2d 460, 462 (5th Cir. 1965) (permission to file opposing affidavits on the day of hearing should be declined where the opponent fails to show that the failure to make a timely filing was the result of excusable neglect), cert. denied, 384 U.S. 1004 (1966).

1987Contra, Cofer v. County of Pierce, 8 Wn.

1985III Inasmuch as the common law year and a day rule was in effect at the time of the shooting and was a constituent element of the crime of homicide, amendment of the homicide statute to permit charges to be brought if death occurs within 3 years and a day raises the issue of ex post facto legislation. " [I]t is the law on the date of a defendant's criminal act . . . that is significant to an ex post facto determination." Johnson v. Morris, 87 Wn.2d 922, 927 , 557 P.2d 1299 (1976).

1985III Inasmuch as the common law year and a day rule was in effect at the time of the shooting and was a constituent element of the crime of homicide, amendment of the homicide statute to permit charges to be brought if death occurs within 3 years and a day raises the issue of ex post facto legislation. " [I]t is the law on the date of a defendant's criminal act . . . that is significant to an ex post facto determination." Johnson v. Morris, 87 Wn.2d 922, 927 , 557 P.2d 1299 (1976).

1936Co., 182 Wash. 267 , 46 P. (2d) 1059 .) Upon the going down of the remittitur in that appeal, on the day of the hearing, appellant moved in open court for leave to amend and for a continuance.

1936Co., 182 Wash. 267 , 46 P. (2d) 1059 .) Upon the going down of the remittitur in that appeal, on the day of the hearing, appellant moved in open court for leave to amend and for a continuance.

1911Carnegie Steel Co. v. Cambria Iron Co., 185 U. S. 403 .