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12 Washington opinions name it 2 courts 1994–2017 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 |
|---|---|---|
Waite v. Waitegreen1 sentence1994See Freehe v. Freehe, 81 Wn.2d 183, 192 , 500 P.2d 771 (1972); Waite v. Waite, 618 So. 2d 1360, 1361 (Fla. 1993) ("[W]e now find that there no longer is a sufficient reason warranting a continued adherence to the doctrine of interspousal immunity. . . . [B]oth public necessity and fundamental rights require judicial abrogation of the doctrine.”). 2 Thus, it is unnecessary for us to engage in a conflict of laws analysis of the laws and policies of the two states and we will simply apply Washington law in determining the issues presented by this appeal. | 1 | 1 |
Freehe v. Freehegreen2 sentences1994See Freehe v. Freehe, 81 Wn.2d 183, 192 , 500 P.2d 771 (1972); Waite v. Waite, 618 So. 2d 1360, 1361 (Fla. 1993) ("[W]e now find that there no longer is a sufficient reason warranting a continued adherence to the doctrine of interspousal immunity. . . . [B]oth public necessity and fundamental rights require judicial abrogation of the doctrine.”). 2 Thus, it is unnecessary for us to engage in a conflict of laws analysis of the laws and policies of the two states and we will simply apply Washington law in determining the issues presented by this appeal. 1994See Freehe v. Freehe, 81 Wn.2d 183, 192 , 500 P.2d 771 (1972); Waite v. Waite, 618 So. 2d 1360, 1361 (Fla. 1993) ("[W]e now find that there no longer is a sufficient reason warranting a continued adherence to the doctrine of interspousal immunity. . . . [B]oth public necessity and fundamental rights require judicial abrogation of the doctrine.”). 2 Thus, it is unnecessary for us to engage in a conflict of laws analysis of the laws and policies of the two states and we will simply apply Washington law in determining the issues presented by this appeal. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Burnside v. Simpson Paper Co.
green
2 sentences2014A. Actual conflict ¶20 As a preliminary matter, when choice of law is disputed, “there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.” Seizer v. Sessions, 132 Wn.2d 642, 648 , 940 P.2d 261 (1997) (citing Burnside v. Simpson Paper Co., 123 Wn.2d 93, 100-01 , 864 P.2d 937 (1994)). 2014A. Actual conflict ¶20 As a preliminary matter, when choice of law is disputed, “there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.” Seizer v. Sessions, 132 Wn.2d 642, 648 , 940 P.2d 261 (1997) (citing Burnside v. Simpson Paper Co., 123 Wn.2d 93, 100-01 , 864 P.2d 937 (1994)). | 6 | 1997–2016 |
Seizer v. Sessions
green
2 sentences2017In Erwin, we explained that in resolving disputes concerning choice of law the court need decide(1) whether there is an actual conflict oflaws and, if so,(2) whether the parties' agreement's choice of law provision is effective. 161 Wn.2d at 692 . "'When parties dispute choice of law, there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.'" Id.(quoting Seizer, 132 Wn.2d at 648 ). 2014A. Actual conflict ¶20 As a preliminary matter, when choice of law is disputed, “there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.” Seizer v. Sessions, 132 Wn.2d 642, 648 , 940 P.2d 261 (1997) (citing Burnside v. Simpson Paper Co., 123 Wn.2d 93, 100-01 , 864 P.2d 937 (1994)). | 5 | 2007–2017 |
Erwin v. Cotter Health Centers, Inc.
green
2 sentences2017In Erwin, we explained that in resolving disputes concerning choice of law the court need decide(1) whether there is an actual conflict oflaws and, if so,(2) whether the parties' agreement's choice of law provision is effective. 161 Wn.2d at 692 . "'When parties dispute choice of law, there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.'" Id.(quoting Seizer, 132 Wn.2d at 648 ). 2014Given that the parties dispute which state's law applies, we must determine whether an actual conflict between the laws of the two states exists before engaging in a conflict of laws analysis. "'When parties dispute choice of law, there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.'" rErwin v. Cotter Health Ctrs., Inc., 161 Wn.2d 676, 692 , 167 P.3d 1112 (2007) (quoting Seizer v. Sessions, 132 Wn.2d 642, 648 , 940 P.2d 261 (1997)).] "If the result for a parti | 5 | 2008–2017 |
Erwin v. Cotter Health Centers
green
2 sentences2017Here, although the parties chose Washington law and the forum is Washington, Cotter argues that the law of California— neither the parties' chosen law nor the law of the forum—should apply. 7 No. 75373-8-1/8 Health Centers, 161 Wn.2d 676, 691 , 167 P.3d 1112 (2007). 2014Given that the parties dispute which state's law applies, we must determine whether an actual conflict between the laws of the two states exists before engaging in a conflict of laws analysis. "'When parties dispute choice of law, there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.'" rErwin v. Cotter Health Ctrs., Inc., 161 Wn.2d 676, 692 , 167 P.3d 1112 (2007) (quoting Seizer v. Sessions, 132 Wn.2d 642, 648 , 940 P.2d 261 (1997)).] "If the result for a parti | 4 | 2008–2017 |
Seizer v. Sessions
green
2 sentences2014Given that the parties dispute which state's law applies, we must determine whether an actual conflict between the laws of the two states exists before engaging in a conflict of laws analysis. "'When parties dispute choice of law, there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.'" rErwin v. Cotter Health Ctrs., Inc., 161 Wn.2d 676, 692 , 167 P.3d 1112 (2007) (quoting Seizer v. Sessions, 132 Wn.2d 642, 648 , 940 P.2d 261 (1997)).] "If the result for a parti 2014A. Actual conflict ¶20 As a preliminary matter, when choice of law is disputed, “there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.” Seizer v. Sessions, 132 Wn.2d 642, 648 , 940 P.2d 261 (1997) (citing Burnside v. Simpson Paper Co., 123 Wn.2d 93, 100-01 , 864 P.2d 937 (1994)). | 3 | 2007–2014 |
Ito International Corp. v. Prescott, Inc.
green
2 sentences2007Seizer v. Sessions, 132 Wash.2d 642, 650 , 940 P.2d 261 (1997) (reviewing de novo the Court of Appeals choice-of-law determination); Ito Int'l Corp. v. Prescott, Inc., 83 Wash.App. 282, 288 , 921 P.2d 566 (1996) (whether a "contract's choice-of-law provision is invalid . . . is a question of law that we review de novo."). ¶ 27 This case does not present a classic conflict of laws problem in which the forum state undertakes a conflict of laws analysis to determine whether the contractually chosen law or forum law will govern. 2007App. 282, 288 , 921 P.2d 566 (1996) (whether a “contract’s choice-of-law provision is invalid ... is a question of law that we review de novo”). ¶27 This case does not present a classic conflict of laws problem in which the forum state undertakes a conflict of laws analysis to determine whether the contractually chosen law or forum law will govern. | 2 | 2007–2007 |
Freestone Capital v. Mka Real Estate
green
1 sentence2014App. 643, 664 , 230 P.3d 625 (2010). | 1 | 2014–2014 |
Freestone Capital Partners, LP v. MKA Real Estate Opportunity Fund I, LLC
green
1 sentence2014Given that the parties dispute which state's law applies, we must determine whether an actual conflict between the laws of the two states exists before engaging in a conflict of laws analysis. "'When parties dispute choice of law, there must be an actual conflict between the laws or interests of Washington and the laws or interests of another state before Washington courts will engage in a conflict of laws analysis.'" rErwin v. Cotter Health Ctrs., Inc., 161 Wn.2d 676, 692 , 167 P.3d 1112 (2007) (quoting Seizer v. Sessions, 132 Wn.2d 642, 648 , 940 P.2d 261 (1997)).] "If the result for a parti | 1 | 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.