four-pronged analysis (Washington) · Go Syfert
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four-pronged analysis in Washington

13 Washington opinions name it 2 courts 2004–2026 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 (0)

CaseFollowedCited
No positive-treatment citations attached to this issue in Washington.

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 (13)

CaseCitedYears
State v. Christensen green
wash · 2004
2 sentences

2016State v. Christensen, 153 Wn.2d 186, 192 , 102 P.3d 789 (2004).

2014App. 59, 64 , 279 P.3d 461 (citing State v. Christensen, 153 Wn.2d 186, 192 , 102 P.3d 789 (2004)), review granted, 175 Wn.2d 1022 (2012).

42012–2016
State v. Christensen green
wash · 2005
2 sentences

2016State v. Christensen, 153 Wn.2d 186, 192 , 102 P.3d 789 (2004).

2014App. 59, 64 , 279 P.3d 461 (citing State v. Christensen, 153 Wn.2d 186, 192 , 102 P.3d 789 (2004)), review granted, 175 Wn.2d 1022 (2012).

42012–2016
City v. NORTHSHORE UNITED CHURCH green
wash · 2009
2 sentences

2021Generally, “we have applied the same four-pronged analysis in an article I, section 11 challenge: where a party has (1) a sincere religious belief and (2) the exercise of that belief is substantially burdened by the challenged law, the law is enforceable against that party only if it (3) serves a compelling government interest and (4) is the least restrictive means of achieving that interest.” Id. (citing City of Woodinville v. Northshore United Church of Christ, 166 Wn.2d 633, 642 , 211 P.3d 406 (2009)).

2019City of Woodinville v. Northshore United Church of Christ , 166 Wash.2d 633 , 642, 211 P.3d 406 (2009) ; Backlund , 106 Wash.2d at 641 , 724 P.2d 981 .

32017–2021
City of Woodinville v. Northshore United Church of Christ green
wash · 2009
2 sentences

2021Generally, “we have applied the same four-pronged analysis in an article I, section 11 challenge: where a party has (1) a sincere religious belief and (2) the exercise of that belief is substantially burdened by the challenged law, the law is enforceable against that party only if it (3) serves a compelling government interest and (4) is the least restrictive means of achieving that interest.” Id. (citing City of Woodinville v. Northshore United Church of Christ, 166 Wn.2d 633, 642 , 211 P.3d 406 (2009)).

2019City of Woodinville v. Northshore United Church of Christ , 166 Wash.2d 633 , 642, 211 P.3d 406 (2009) ; Backlund , 106 Wash.2d at 641 , 724 P.2d 981 .

32017–2021
Backlund v. BOARD OF COMMISSIONERS OF KING CTY. HOSP. DIST. NO. 2 green
wash · 1986
2 sentences

2019City of Woodinville v. Northshore United Church of Christ , 166 Wash.2d 633 , 642, 211 P.3d 406 (2009) ; Backlund , 106 Wash.2d at 641 , 724 P.2d 981 .

2019City of Woodinville v. Northshore United Church of Christ , 166 Wash.2d 633 , 642, 211 P.3d 406 (2009) ; Backlund , 106 Wash.2d at 641 , 724 P.2d 981 .

22017–2019
State v. Valencia green
wash · 2010
2 sentences

2015No. 72338-3-1 / 5 possessing "paraphernalia" was ripe under a four pronged test. 169 Wn.2d 782, 786-91 , 239 P.3d 1059 (2010).

2015State v. Sanchez Valencia, 169 Wn.2d 782, 790 , 239 P.3d 1059 (2010). ¶10 In Sanchez Valencia, the court held that a preenforcement challenge to a community custody condition prohibiting the defendant from possessing “paraphernalia” was ripe under a four pronged test. 169 Wn.2d at 786-91 .

22015–2015
State v. Valencia green
wash · 2010
2 sentences

2015No. 72338-3-1 / 5 possessing "paraphernalia" was ripe under a four pronged test. 169 Wn.2d 782, 786-91 , 239 P.3d 1059 (2010).

2015State v. Sanchez Valencia, 169 Wn.2d 782, 790 , 239 P.3d 1059 (2010). ¶10 In Sanchez Valencia, the court held that a preenforcement challenge to a community custody condition prohibiting the defendant from possessing “paraphernalia” was ripe under a four pronged test. 169 Wn.2d at 786-91 .

22015–2015
State v. Roden green
washctapp · 2012
2 sentences

2014“We engage in a four-pronged analysis to determine whether an individual has violated the Act.” State v. Roden, 169 Wn.

2014"We engage in a four-pronged analysis to determine whether an individual has violated the Act." State v. Roden. 169 Wn.

22014–2014
Clark v. Baines green
wash · 2004
2 sentences

2004Clark, 150 Wn.2d at 913 .

2004Clark, 150 Wash.2d at 913 , 84 P.3d 245 .

22004–2004
State v. Fisher green
wash · 2009
1 sentence

2026Id.

12026–2026
Little v. King green
wash · 2007
1 sentence

2024Little, 160 Wn.2d at 703-04 .

12024–2024
First Covenant Church of Seattle v. City of Seattle green
wash · 1992
1 sentence

2021Generally, “we have applied the same four-pronged analysis in an article I, section 11 challenge: where a party has (1) a sincere religious belief and (2) the exercise of that belief is substantially burdened by the challenged law, the law is enforceable against that party only if it (3) serves a compelling government interest and (4) is the least restrictive means of achieving that interest.” Id. (citing City of Woodinville v. Northshore United Church of Christ, 166 Wn.2d 633, 642 , 211 P.3d 406 (2009)).

12021–2021
Clark v. Baines green
wash · 2004
1 sentence

2004Clark, 150 Wash.2d at 913 , 84 P.3d 245 .

12004–2004

Statutes the citing opinions construe

WA § Wash. Rev. Code § 9.73.030 (4) WA § Wash. Rev. Code § 9.73.050 (4) WA § Wash. Rev. Code § 2.06.040 (3) WA § Wash. Rev. Code § 49.60.030 (3) WA § Wash. Rev. Code § 49.60.040 (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

PA 72 (1974–2026) NJ 31 (1987–2026) CT 29 (1983–2026) MI 28 (1981–2021) TX 17 (1981–2025) GA 17 (1981–2026) WA 13 (2004–2026) IL 13 (1974–2006) NY 11 (1974–2024) FL 10 (1980–2024) OH 10 (1987–2026) AL 8 (1991–2015) ID 8 (1995–2022) RI 8 (1979–2016) VA 7 (1987–2012) NC 6 (1976–2018) CA 6 (1995–2014) MO 6 (1976–2001) WV 5 (1996–2023) UT 4 (1984–2001) TN 4 (1979–2010) LA 4 (2008–2023) MN 4 (1981–2015) DC 3 (1978–1996) KY 3 (2015–2024) WI 2 (1986–2003) VT 2 (1984–1989) MS 2 (2012–2014) IN 2 (1998–2006) ND 2 (2022–2022) KS 2 (1985–1990) MA 2 (2014–2022) WY 2 (1989–2003) NM 2 (2014–2014)

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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