policies underlying rule in Washington

1997The United States Supreme Court has stated in McKart v. United States, 395 U.S. 185 , 89 S.Ct. 1657 , 23 L.Ed.2d 194 (1969) the policies underlying this principle: (1) insure against premature interruption of the administrative process; (2) allow the agency to develop the necessary factual background on which to base a decision; (3) allow exercise of agency expertise in its area; (4) provide for a more efficient process; and (5) protect the administrative agency's autonomy by allowing it to correct its own errors and insuring that individuals were not encouraged to ignore its procedures by res

1997The United States Supreme Court has stated in McKart v. United States, 395 U.S. 185 , 89 S.Ct. 1657 , 23 L.Ed.2d 194 (1969) the policies underlying this principle: (1) insure against premature interruption of the administrative process; (2) allow the agency to develop the necessary factual background on which to base a decision; (3) allow exercise of agency expertise in its area; (4) provide for a more efficient process; and (5) protect the administrative agency's autonomy by allowing it to correct its own errors and insuring that individuals were not encouraged to ignore its procedures by res

2025App. 2d at 679 (citing King County v. Boundary Review Bd., 122 Wn.2d 648, 669 , 860 P.2d 1024 (1993)).

2018Circuit for the policies underlying the waiver doctrine, noting that the rule furthers the purposes of: “(1) discouraging the frequent and deliberate flouting of administrative processes; (2) protecting agency autonomy by allowing an agency the first opportunity to apply its expertise, exercise its discretion, and correct its errors; (3) aiding judicial review by promoting the development of facts during the administrative proceeding; and (4) promoting judicial economy by reducing duplication, and perhaps even obviating judicial involvement.” King County, 122 Wn.2d at 669 (quoting Fertilizer I

1997McKart, 395 U.S. at 193-94 , 89 S.Ct. at 1662-63 ; South Hollywood Hills Citizens, 101 Wash.2d at 73-74 , 677 P.2d 114 .

1997McKart, 395 U.S. at 193-94 ; South Hollywood Hills Citizens, 101 Wn.2d at 73-74 .

2023And the White court explained “‘preservation of tribal cultural autonomy [and] preservation of tribal self-determination,’ are some of the central policies underlying the doctrine of tribal sovereign immunity.” 765 F.3d at 1025 (quoting Breakthrough, 629 F.3d at 1188 ). -7- No. 84628-1-I/8 incorporation under state law does not mean its method of creation weighs against its claim to sovereignty.”).

2023And the White court explained “‘preservation of tribal cultural autonomy [and] preservation of tribal self-determination,’ are some of the central policies underlying the doctrine of tribal sovereign immunity.” 765 F.3d at 1025 (quoting Breakthrough, 629 F.3d at 1188 ). -7- No. 84628-1-I/8 incorporation under state law does not mean its method of creation weighs against its claim to sovereignty.”).

2016Because attorneys and clients must be able to predict with at least some certainty where their discussions will be protected, “[a]n uncertain privilege ... is little better than no privilege at all.” Upjohn, 449 U.S. at 393 .

2006See In re Segall, 117 Ill.2d 1, 5-6 , 509 N.E.2d 988 , 109 Ill.Dec. 149 (1987); Comm. on Legal Ethics v. Simmons, 184 W.Va. 183, 185 , 399 S.E.2d 894 (1990); Sandstrom v. Sandstrom, 880 P.2d 103, 108-09 (Wyo.1994); Runsvold v. Idaho State Bar, 129 Idaho 419, 420-21 , 925 P.2d 1118 (1996); Vickery v. Comm'n for Lawyer Discipline, 5 S.W.3d 241, 259 (Tex.App.1999); In re Discipline of Schaefer, 117 Nev. 496, 507-08 , 25 P.3d 191 (2001). ¶ 19 Haley asks this court to take the contrary view and hold that the plain meaning of the word "client" in RPC 4.2(a) precludes application of the rule to a law

2006See In re Segall, 117 Ill.2d 1, 5-6 , 509 N.E.2d 988 , 109 Ill.Dec. 149 (1987); Comm. on Legal Ethics v. Simmons, 184 W.Va. 183, 185 , 399 S.E.2d 894 (1990); Sandstrom v. Sandstrom, 880 P.2d 103, 108-09 (Wyo.1994); Runsvold v. Idaho State Bar, 129 Idaho 419, 420-21 , 925 P.2d 1118 (1996); Vickery v. Comm'n for Lawyer Discipline, 5 S.W.3d 241, 259 (Tex.App.1999); In re Discipline of Schaefer, 117 Nev. 496, 507-08 , 25 P.3d 191 (2001). ¶ 19 Haley asks this court to take the contrary view and hold that the plain meaning of the word "client" in RPC 4.2(a) precludes application of the rule to a law

2006See In re Segall, 117 Ill.2d 1, 5-6 , 509 N.E.2d 988 , 109 Ill.Dec. 149 (1987); Comm. on Legal Ethics v. Simmons, 184 W.Va. 183, 185 , 399 S.E.2d 894 (1990); Sandstrom v. Sandstrom, 880 P.2d 103, 108-09 (Wyo.1994); Runsvold v. Idaho State Bar, 129 Idaho 419, 420-21 , 925 P.2d 1118 (1996); Vickery v. Comm'n for Lawyer Discipline, 5 S.W.3d 241, 259 (Tex.App.1999); In re Discipline of Schaefer, 117 Nev. 496, 507-08 , 25 P.3d 191 (2001). ¶ 19 Haley asks this court to take the contrary view and hold that the plain meaning of the word "client" in RPC 4.2(a) precludes application of the rule to a law

2006See In re Segall, 117 Ill.2d 1, 5-6 , 509 N.E.2d 988 , 109 Ill.Dec. 149 (1987); Comm. on Legal Ethics v. Simmons, 184 W.Va. 183, 185 , 399 S.E.2d 894 (1990); Sandstrom v. Sandstrom, 880 P.2d 103, 108-09 (Wyo.1994); Runsvold v. Idaho State Bar, 129 Idaho 419, 420-21 , 925 P.2d 1118 (1996); Vickery v. Comm'n for Lawyer Discipline, 5 S.W.3d 241, 259 (Tex.App.1999); In re Discipline of Schaefer, 117 Nev. 496, 507-08 , 25 P.3d 191 (2001). ¶ 19 Haley asks this court to take the contrary view and hold that the plain meaning of the word "client" in RPC 4.2(a) precludes application of the rule to a law

2006See In re Segall, 117 Ill.2d 1, 5-6 , 509 N.E.2d 988 , 109 Ill.Dec. 149 (1987); Comm. on Legal Ethics v. Simmons, 184 W.Va. 183, 185 , 399 S.E.2d 894 (1990); Sandstrom v. Sandstrom, 880 P.2d 103, 108-09 (Wyo.1994); Runsvold v. Idaho State Bar, 129 Idaho 419, 420-21 , 925 P.2d 1118 (1996); Vickery v. Comm'n for Lawyer Discipline, 5 S.W.3d 241, 259 (Tex.App.1999); In re Discipline of Schaefer, 117 Nev. 496, 507-08 , 25 P.3d 191 (2001). ¶ 19 Haley asks this court to take the contrary view and hold that the plain meaning of the word "client" in RPC 4.2(a) precludes application of the rule to a law

2006See In re Segall, 117 Ill.2d 1, 5-6 , 509 N.E.2d 988 , 109 Ill.Dec. 149 (1987); Comm. on Legal Ethics v. Simmons, 184 W.Va. 183, 185 , 399 S.E.2d 894 (1990); Sandstrom v. Sandstrom, 880 P.2d 103, 108-09 (Wyo.1994); Runsvold v. Idaho State Bar, 129 Idaho 419, 420-21 , 925 P.2d 1118 (1996); Vickery v. Comm'n for Lawyer Discipline, 5 S.W.3d 241, 259 (Tex.App.1999); In re Discipline of Schaefer, 117 Nev. 496, 507-08 , 25 P.3d 191 (2001). ¶ 19 Haley asks this court to take the contrary view and hold that the plain meaning of the word "client" in RPC 4.2(a) precludes application of the rule to a law

1987Orion Corp. v. State, 103 Wn.2d 441 , 693 P.2d 1369 (1985). 1 See also Schreiber v. Riemcke, 11 Wn.

1987Orion Corp. v. State, 103 Wn.2d 441 , 693 P.2d 1369 (1985). 1 See also Schreiber v. Riemcke, 11 Wn.

1987Orion Corp. v. State, 103 Wn.2d 441 , 693 P.2d 1369 (1985). 1 See also Schreiber v. Riemcke, 11 Wn.

1984The County, however, relying on Creelman v. Svenning, 67 Wn.2d 882, 885 , 410 P.2d 606 (1966), argues that a governmental entity can invoke an employee's immunity if the policies underlying the immunity favor its extension to the governmental employer.

1984The County, however, relying on Creelman v. Svenning, 67 Wn.2d 882, 885 , 410 P.2d 606 (1966), argues that a governmental entity can invoke an employee's immunity if the policies underlying the immunity favor its extension to the governmental employer.

1982App. at 330 ), and that many of the policies underlying the rule did not apply to Ms. Krug. 29 Wn.