Hangman Ridge test in Washington

12 Washington opinions name it 2 courts 1990–2013 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.

Followed or applied (3)

Case	Followed	Cited
Nordstrom, Inc. v. Tampourlosgreen wash · 1987 · cited in 5 Washington opinions naming this issue, 1990–2009 2 sentences 2009See generally Nordstrom, 107 Wn.2d at 740 (“The fourth prong of the Hangman Ridge test is that Nordstrom must be injured in its business or property. 2009See generally Nordstrom, 107 Wn.2d at 740 (“The fourth prong of the Hangman Ridge test is that Nordstrom must be injured in its business or property.	2	5
Ambach v. Frenchgreen wash · 2009 · cited in 2 Washington opinions naming this issue, 2013–2013 2 sentences 2013As the Supreme Court stated, “Ambach’s failure to state a cognizable CPA claim is not just that she attempts to disguise her personal injuries as sounding in business or property, but also that she fails to allege the truly public nature of Dr. French’s actions.” Ambach, 167 Wn.2d at 177-78 . ¶30 The Supreme Court also said that the individual Hangman Ridge factors “should not be read in isolation so as to render absurd conclusions.” Ambach, 167 Wn.2d at 178 . 2013As the Supreme Court stated, “Ambach’s failure to state a cognizable CPA claim is not just that she attempts to disguise her personal injuries as sounding in business or property, but also that she fails to allege the truly public nature of Dr. French’s actions.” Ambach, 167 Wn.2d at 177-78 . ¶30 The Supreme Court also said that the individual Hangman Ridge factors “should not be read in isolation so as to render absurd conclusions.” Ambach, 167 Wn.2d at 178 .	2	2
Hangman Ridge Training Stables, Inc. v. Safeco Title Insurancegreen · 1986 · cited in 3 Washington opinions naming this issue, 2009–2012 2 sentences 2009Co., 105 Wn.2d 778, 784 , 719 P.2d 531 (1986). 3 ¶14 CCS contends that the respondents lack standing to bring suit under the CPA, that the respondents have failed to establish that the collection notices are unfair or deceptive, and that respondent Panag has not shown sufficient injury for purposes of a CPA claim. ¶15 Turning first to CCS’s contention that respondents lack standing, CCS contends the Hangman Ridge test states the elements of proof necessary to prevail in a CPA action, but does not address the threshold issue of standing. 2009Co., 105 Wn.2d 778, 784 , 719 P.2d 531 (1986). 3 ¶14 CCS contends that the respondents lack standing to bring suit under the CPA, that the respondents have failed to establish that the collection notices are unfair or deceptive, and that respondent Panag has not shown sufficient injury for purposes of a CPA claim. ¶15 Turning first to CCS’s contention that respondents lack standing, CCS contends the Hangman Ridge test states the elements of proof necessary to prevail in a CPA action, but does not address the threshold issue of standing.	1	3

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (6)

Case	Cited	Years
Keyes v. Bollinger green washctapp · 1982 2 sentences 1996App. 553, 560 , 825 P.2d 714 , review denied, 120 Wn.2d 1002 (1992); Keyes v. Bollinger, 31 Wn. 1996App. 553, 560 , 825 P.2d 714 , review denied, 120 Wn.2d 1002 (1992); Keyes v. Bollinger, 31 Wn.	1	1996–1996
Aubrey's R. v. Center, Inc. v. Tandy Corp. green washctapp · 1987 2 sentences 1996App. 595, 609 , 731 P.2d 1124 (1987) (retroactively applying the Hangman Ridge test). 7 Sign-O-Lite Signs, Inc. v. DeLaurenti Florists, Inc., 64 Wn. 1996App. 595, 609 , 731 P.2d 1124 (1987) (retroactively applying the Hangman Ridge test). 7 Sign-O-Lite Signs, Inc. v. DeLaurenti Florists, Inc., 64 Wn.	1	1996–1996
Sign-O-Lite Signs, Inc. v. DeLaurenti Florists, Inc. green washctapp · 1992 2 sentences 1996App. 595, 609 , 731 P.2d 1124 (1987) (retroactively applying the Hangman Ridge test). 7 Sign-O-Lite Signs, Inc. v. DeLaurenti Florists, Inc., 64 Wn. 1996App. 595, 609 , 731 P.2d 1124 (1987) (retroactively applying the Hangman Ridge test). 7 Sign-O-Lite Signs, Inc. v. DeLaurenti Florists, Inc., 64 Wn.	1	1996–1996
State v. Pike green wash · 1992 2 sentences 1994Set Clark v. Luepke, 118 Wn.2d 577 , 826 P.2d 147 (1992); State v. Pike, 118 Wn.2d 585 , 826 P.2d 152 (1992); Bill McCurley Chevrolet, Inc. v. Rutz, 61 Wn. 1994Set Clark v. Luepke, 118 Wn.2d 577 , 826 P.2d 147 (1992); State v. Pike, 118 Wn.2d 585 , 826 P.2d 152 (1992); Bill McCurley Chevrolet, Inc. v. Rutz, 61 Wn.	1	1994–1994
Clark v. Luepke green wash · 1992 2 sentences 1994Set Clark v. Luepke, 118 Wn.2d 577 , 826 P.2d 147 (1992); State v. Pike, 118 Wn.2d 585 , 826 P.2d 152 (1992); Bill McCurley Chevrolet, Inc. v. Rutz, 61 Wn. 1994Set Clark v. Luepke, 118 Wn.2d 577 , 826 P.2d 147 (1992); State v. Pike, 118 Wn.2d 585 , 826 P.2d 152 (1992); Bill McCurley Chevrolet, Inc. v. Rutz, 61 Wn.	1	1994–1994
Bill McCurley Chevrolet, Inc. v. Rutz green washctapp · 1991 2 sentences 1994Set Clark v. Luepke, 118 Wn.2d 577 , 826 P.2d 147 (1992); State v. Pike, 118 Wn.2d 585 , 826 P.2d 152 (1992); Bill McCurley Chevrolet, Inc. v. Rutz, 61 Wn. 1994Set Clark v. Luepke, 118 Wn.2d 577 , 826 P.2d 147 (1992); State v. Pike, 118 Wn.2d 585 , 826 P.2d 152 (1992); Bill McCurley Chevrolet, Inc. v. Rutz, 61 Wn.	1	1994–1994

Statutes the citing opinions construe

WA § Wash. Rev. Code § 19.86.090 (11) WA § Wash. Rev. Code § 19.86.920 (7) WA § Wash. Rev. Code § 19.86.020 (5) WA § Wash. Rev. Code § 19.86.170 (5) USC § 15u.s.c.1692 (4) USC § 15u.s.c.1692a(5) (4) WA § Wash. Rev. Code § 19.16.100 (4) WA § Wash. Rev. Code § 19.86.010 (4) WA § Wash. Rev. Code § 48.01.030 (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.

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