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13 Washington opinions name it 2 courts 1978–2013 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.
| Case | Followed | Cited |
|---|---|---|
In Re the Marriage of Olivergreen2 sentences1993See In re Marriage of Oliver, 43 Wn. 1993App. 48 , 651 P.2d 262 (1982)] and Edwards." Oliver, 43 Wn. | 2 | 2 |
In Re the Marriage of Mahalingamgreen2 sentences2005App. 228, 234-35 , 584 P.2d 971 (1978) (enforcing an escalation clause in a provision on child support contained in a separation agreement). ¶54 Therefore, we find no merit in Robert’s assertion that the trial court is bound to comply with the restrictions in RCW 26.19.080(2) when determining which party should bear the cost of extraordinary medical and dental expenses. ¶55 Here, we have held that the parties’ economic situation was changed in a way that compelled the trial court to reject the economic provisions of the 2000 Agreement. 2005See e.g., In re Marriage of Mahalingam, 21 Wash.App. 228, 234-35 , 584 P.2d 971 (1978) (enforcing an escalation clause in a provision on child support contained in a separation agreement.). ¶ 54 Therefore, we find no merit in Robert's assertion that the trial court is bound to comply with the restrictions in RCW 26.19.080(2) when determining which party should bear the cost of extraordinary medical and dental expenses. ¶ 55 Here, we have held that the parties' economic situation was changed in a way that compelled the trial court to reject the economic provisions of the 2000 Agreement. | 1 | 4 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Matter of Marriage of Stoltzfus
green
2 sentences2013In re Marriage of Stoltzfus, 69 Wn. 2013In re Marriage of Stoltzfus, 69 Wn. | 3 | 2013–2013 |
In Re the Marriage of Edwards
green
2 sentences1990The court also concluded that only a payor may invoke the doctrine of In re Marriage of Edwards, 99 Wn.2d 913 , 665 P.2d 883 (1983), to avoid the escalation clause and, even if the payee could avoid the clause, Edwards does not apply to escalation clauses filed prior to the Edwards decision. 1990The court also concluded that only a payor may invoke the doctrine of In re Marriage of Edwards, 99 Wn.2d 913 , 665 P.2d 883 (1983), to avoid the escalation clause and, even if the payee could avoid the clause, Edwards does not apply to escalation clauses filed prior to the Edwards decision. | 3 | 1987–1991 |
In the Matter of Marriage of Peters
neutral
2 sentences1993Noting that the escalation clause did not meet the Edwards criteria, we concluded as follows: "Thus, while the judge refused enforcement in this case for different reasons his actions must be sustained on appeal as a result of [In re Marriage of] Peters[, 33 Wn. 1993App. 48 , 651 P.2d 262 (1982)] and Edwards." Oliver, 43 Wn. | 1 | 1993–1993 |
Vollenhover v. Vollenhover
green
1 sentence1978Second, and more important, it focuses exclusively on the "circumstances" of the paying parent while ignoring the complex of factors relating to the "benefit of the children" and their changing or unchanging needs. [5] Elbinger v. Elbinger, 33 Mich. App. 166 , 189 N.W.2d 823 (1971); Vollenhover v. Vollenhover, 4 Ill. | 1 | 1978–1978 |
Stanaway v. Stanaway
green
2 sentences1978In Stanaway v. Stanaway, 70 Mich. App. 294 , 245 N.W.2d 723 (1976), the court struck down an escalation clause stating: [I]t abrogates the requirement for [a petition to modify] by allowing the continual (here, yearly) alteration of the judgment as to amount of support. 1978In Stanaway v. Stanaway, 70 Mich. App. 294 , 245 N.W.2d 723 (1976), the court struck down an escalation clause stating: [I]t abrogates the requirement for [a petition to modify] by allowing the continual (here, yearly) alteration of the judgment as to amount of support. | 1 | 1978–1978 |
Elbinger v. Elbinger
green
2 sentences1978Second, and more important, it focuses exclusively on the "circumstances" of the paying parent while ignoring the complex of factors relating to the "benefit of the children" and their changing or unchanging needs. [5] Elbinger v. Elbinger, 33 Mich. App. 166 , 189 N.W.2d 823 (1971); Vollenhover v. Vollenhover, 4 Ill. 1978Second, and more important, it focuses exclusively on the "circumstances" of the paying parent while ignoring the complex of factors relating to the "benefit of the children" and their changing or unchanging needs. [5] Elbinger v. Elbinger, 33 Mich. App. 166 , 189 N.W.2d 823 (1971); Vollenhover v. Vollenhover, 4 Ill. | 1 | 1978–1978 |
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.
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.