overbreadth doctrine (Washington) · Go Syfert
← Washington issues

overbreadth doctrine in Washington

83 Washington opinions name it 2 courts 1971–2021 4 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 (24)

CaseFollowedCited
City of Seattle v. Huffgreen
wash · 1989 · cited in 8 Washington opinions naming this issue, 1990–2021
2 sentences

2021In City of Seattle v. Huff, 111 Wn.2d 923, 928 (1989), our high court denied the overbreadth challenge to a City of Seattle telephonic harassment ordinance, which ordinance used identical language to the Washington’s telephonic harassment statute.

1994In Seattle v. Huff, 111 Wn.2d at 925-26 , the Washington Supreme Court set out the overbreadth analysis in the context of determining the constitutionality of a subsection of a municipal telephone harassment ordinance identical to RCW 9.61.230(3).

28
State v. Talleygreen
wash · 2005 · cited in 3 Washington opinions naming this issue, 1994–2021
2 sentences

2021Id. (citing Talley, 122 Wn.2d at 198, 210 ).

1994See Talley, 122 Wn.2d at 210 (upholding a subsection of the malicious harassment statute against an overbreadth challenge because it primarily regulated conduct and its "incidental impact” on speech was minimal).

23
Ward v. State of Utahgreen
ca10 · 2005 · cited in 2 Washington opinions naming this issue, 2006–2006
22
State v. Gunwallgreen
wash · 1986 · cited in 2 Washington opinions naming this issue, 2002–2002
22
Broadrick v. Oklahomagreen
scotus · 1973 · cited in 17 Washington opinions naming this issue, 1983–2017
2 sentences

2017Overbreadth doctrine creates a limited exception to the usual rule that a party "will not be heard to challenge [a] statute on the ground that it may conceivably be applied unconstitutionally to others, in other situations not before the Court." Broadrick v. Oklahoma, 413 U.S. 601, 610 , 93 S. Ct. 2908 , 37 L.

2017Overbreadth doctrine creates a limited exception to the usual rule that a party "will not be heard to challenge [a] statute on the ground that it may conceivably be applied unconstitutionally to others, in other situations not before the Court." Broadrick v. Oklahoma, 413 U.S. 601, 610 , 93 S. Ct. 2908 , 37 L.

117
State v. Halstiengreen
· 1993 · cited in 12 Washington opinions naming this issue, 1996–2021
2 sentences

2021“Application of the overbreadth doctrine is strong medicine, . . . and should be employed by a court sparingly and only as a last resort.” State v. Halstien, 17 No. 37693-1-III State v. Warnock 122 Wn.2d 109, 122 , 857 P.2d 270 (1993).

2021“Application of the overbreadth doctrine is strong medicine, . . . and should be employed by a court sparingly and only as a last resort.” State v. Halstien, 17 No. 37693-1-III State v. Warnock 122 Wn.2d 109, 122 , 857 P.2d 270 (1993).

112
Members of the City Council of Los Angeles v. Taxpayers for Vincentgreen
scotus · 1984 · cited in 9 Washington opinions naming this issue, 2004–2013
2 sentences

2013However, “the mere fact that one can conceive of some impermissible applications of a statute is not sufficient to render it susceptible to an overbreadth challenge.” Members of City Council v. Taxpayers for Vincent, 466 U.S. 789, 800 , 104 S. Ct. 2118 , 80 L.

2013However, “the mere fact that one can conceive of some impermissible applications of a statute is not sufficient to render it susceptible to an overbreadth challenge.” Members of City Council v. Taxpayers for Vincent, 466 U.S. 789, 800 , 104 S. Ct. 2118 , 80 L.

19
Hoffman Estates v. Flipside, Hoffman Estates, Inc.green
scotus · 1982 · cited in 7 Washington opinions naming this issue, 2006–2019
2 sentences

2017"A law that does not reach constitutionally protected conduct and therefore satisfies the overbreadth test may nevertheless be challenged on its face as unduly vague." Viii. of Hoffman Estates v. Flipside, Hoffman Estates, Inc., 455 U.S. 489,497 , 102 S. Ct. 1186 , 71 L.

2017"A law that does not reach constitutionally protected conduct and therefore satisfies the overbreadth test may nevertheless be challenged on its face as unduly vague." Viii. of Hoffman Estates v. Flipside, Hoffman Estates, Inc., 455 U.S. 489,497 , 102 S. Ct. 1186 , 71 L.

17
New York v. Ferbergreen
scotus · 1982 · cited in 7 Washington opinions naming this issue, 1988–2009
2 sentences

2009O'Day v. King County, 109 Wash.2d 796, 804 , 749 P.2d 142 (1988) (quoting New York v. Ferber, 458 U.S. 747, 769 , 102 S.Ct. 3348 , 73 L.Ed.2d 1113 (1982)). ¶ 15 In conducting an overbreadth analysis, a court's first task is to determine whether the statute reaches a substantial amount of constitutionally protected speech or conduct.

2009O'Day v. King County, 109 Wash.2d 796, 804 , 749 P.2d 142 (1988) (quoting New York v. Ferber, 458 U.S. 747, 769 , 102 S.Ct. 3348 , 73 L.Ed.2d 1113 (1982)). ¶ 15 In conducting an overbreadth analysis, a court's first task is to determine whether the statute reaches a substantial amount of constitutionally protected speech or conduct.

17
City of Seattle v. Webstergreen
wash · 1990 · cited in 4 Washington opinions naming this issue, 1991–2011
2 sentences

2011A violation of SCC 10.010.040 is an infraction unless two violations of the ordinance are committed within a 24-hour period, in which case the second violation is criminalized as a misdemeanor. ¶3 Although the facts of this case are not critical in an overbreadth challenge, see City of Seattle v. Webster, 115 Wn.2d 635, 640 , 802 P.2d 1333 (1990), we offer them by way of background.

2011A violation of SCC 10.010.040 is an infraction unless two violations of the ordinance are committed within a 24-hour period, in which case the second violation is criminalized as a misdemeanor. ¶3 Although the facts of this case are not critical in an overbreadth challenge, see City of Seattle v. Webster, 115 Wn.2d 635, 640 , 802 P.2d 1333 (1990), we offer them by way of background.

14
City of Bellevue v. Loranggreen
wash · 2000 · cited in 4 Washington opinions naming this issue, 2006–2011
2 sentences

2011Lorang, 140 Wn.2d at 27 . ¶28 The threshold inquiry in the overbreadth analysis is whether the statute prohibits a substantial amount of constitutionally protected speech.

2011City of Bellevue v. Lorang, 140 Wn.2d 19, 26 , 992 P.2d 496 (2000) (“An overbreadth challenge is facial, and will prevail even if the statute could constitutionally be applied to a litigant.”). ¶70 With these principles in mind, I turn to the county’s horn ordinance, which contains several relevant provisions.

14
State v. Rilesred
wash · 1998 · cited in 3 Washington opinions naming this issue, 2007–2020
2 sentences

2020See State v. Riles, 135 Wn.2d 326, 346 , 957 P.2d 655 (1998), abrogated on other grounds by State v. Sanchez Valencia, 169 Wn.2d 782 , 239 P.3d 1059 (2010); see also State v. Aljutily, 149 Wn.

2008As the court said there, imposing such orders “seems in context to require some relationship to the crime.” Id.

13
State v. Rilesred
wash · 1998 · cited in 3 Washington opinions naming this issue, 2007–2020
2 sentences

2020See State v. Riles, 135 Wn.2d 326, 346 , 957 P.2d 655 (1998), abrogated on other grounds by State v. Sanchez Valencia, 169 Wn.2d 782 , 239 P.3d 1059 (2010); see also State v. Aljutily, 149 Wn.

2008As the court said there, imposing such orders "seems in context to require some relationship to the crime." Id. [25] The judgment and sentence indicates a maximum term of life and imposes community custody per RCW 9.94A.712 for "any period of time the defendant is released from total confinement before the expiration of the maximum sentence as set forth above." RCW 9.94A.712(5) provides: When a court sentences a person to the custody of the department under this section, the court shall, in addition to the other terms of the sentence, sentence the offender to community custody under the superv

13
United States v. Williamsgreen
scotus · 2008 · cited in 3 Washington opinions naming this issue, 2009–2011
2 sentences

2011Ed. 2d 772 (1984). “[T]here must be a realistic danger that the statute itself will significantly compromise recognized First Amendment protections of parties not before the Court.” Id. at 801 . ¶17 The purpose of the overbreadth doctrine is to “strike a balance between competing social costs.” United States v. Williams, 553 U.S. 285, 292, 128 S. Ct. 1830 , 170 L.

2011Ed. 2d 772 (1984). “[T]here must be a realistic danger that the statute itself will significantly compromise recognized First Amendment protections of parties not before the Court.” Id. at 801 . ¶17 The purpose of the overbreadth doctrine is to “strike a balance between competing social costs.” United States v. Williams, 553 U.S. 285, 292, 128 S. Ct. 1830 , 170 L.

13
City of Bellevue v. Loranggreen
wash · 2000 · cited in 3 Washington opinions naming this issue, 2006–2011
2 sentences

2011City of Bellevue v. Lorang, 140 Wn.2d 19, 26 , 992 P.2d 496 (2000) (“An overbreadth challenge is facial, and will prevail even if the statute could constitutionally be applied to a litigant.”). ¶70 With these principles in mind, I turn to the county’s horn ordinance, which contains several relevant provisions.

2006“An overbreadth challenge is facial.. ..” City of Bellevue v. Lorang, 140 Wn.2d 19, 26 , 992 P.2d 496 (2000); see Ward v. Utah, 398 F.3d 1239, 1246 (10th Cir. 2005) (an overbreadth challenge is a facial challenge).

13
Grayned v. City of Rockfordgreen
scotus · 1972 · cited in 3 Washington opinions naming this issue, 1978–1986
2 sentences

1986Ed. 2d 222 , 92 S. Ct. 2294 (1972) discloses that the third aspect of the vagueness inquiry is really little more than a truncated approach to the traditional overbreadth analysis.

1978As we said in Grayned v. City of Rockford, 408 U.S. 104, 114 (1972): "Because overbroad laws, like vague ones, deter privileged activity, our cases firmly establish appellant's standing to raise an overbreadth challenge.11 Although the majority opinion appears somewhat critical of this rule, it is nonetheless binding on this court under the supremacy clause.

13
State v. Paulinggreen
wash · 2003 · cited in 2 Washington opinions naming this issue, 2006–2019
2 sentences

2019That statute provided, “A person is guilty of extortion in the second degree if he commits extortion by means of a threat as defined in then RCW 9A.04.1 10(25)(d) through 0).” The court concluded the statute prohibited “a real and substantial amount of protected speech that the government may not infringe upon.”44 But our Supreme Court determined it was “unnecessary to strike [the extortion statute] because we may impose a limiting construction in the form of a requirement that there be a ‘lack of nexus’ that limits its application to only unprotected speech.”45 According to Pauling, in the co

2006See State v. Pauling, 149 Wash.2d 381, 386 , 69 P.3d 331 (2003); Lorang, 140 Wash.2d at 26-27 , 992 P.2d 496 .

12
State v. Paulinggreen
wash · 2003 · cited in 2 Washington opinions naming this issue, 2006–2019
2 sentences

2019That statute provided, “A person is guilty of extortion in the second degree if he commits extortion by means of a threat as defined in then RCW 9A.04.1 10(25)(d) through 0).” The court concluded the statute prohibited “a real and substantial amount of protected speech that the government may not infringe upon.”44 But our Supreme Court determined it was “unnecessary to strike [the extortion statute] because we may impose a limiting construction in the form of a requirement that there be a ‘lack of nexus’ that limits its application to only unprotected speech.”45 According to Pauling, in the co

2006See State v. Pauling, 149 Wash.2d 381, 386 , 69 P.3d 331 (2003); Lorang, 140 Wash.2d at 26-27 , 992 P.2d 496 .

12
State v. Valenciagreen
wash · 2010 · cited in 1 Washington opinions naming this issue, 2020–2020
11
State v. Valenciagreen
wash · 2010 · cited in 1 Washington opinions naming this issue, 2020–2020
11
State v. Aljutilygreen
washctapp · 2009 · cited in 1 Washington opinions naming this issue, 2020–2020
11
State Of Washington, V Russell David Homangreen
washctapp · 2015 · cited in 1 Washington opinions naming this issue, 2018–2018
11
Meaney v. Devergreen
ca1 · 2003 · cited in 1 Washington opinions naming this issue, 2011–2011
11
Weil v. McCloughgreen
nysd · 1985 · cited in 1 Washington opinions naming this issue, 2011–2011
11

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 (56)

CaseCitedYears
City of Tacoma v. Luvene green
· 1992
2 sentences

2021Id. at 7 (quoting State v. Halstien, 122 Wn.2d 109, 122 , 857 P.2d 270 (1995)).

2019That statute provided, “A person is guilty of extortion in the second degree if he commits extortion by means of a threat as defined in then RCW 9A.04.1 10(25)(d) through 0).” The court concluded the statute prohibited “a real and substantial amount of protected speech that the government may not infringe upon.”44 But our Supreme Court determined it was “unnecessary to strike [the extortion statute] because we may impose a limiting construction in the form of a requirement that there be a ‘lack of nexus’ that limits its application to only unprotected speech.”45 According to Pauling, in the co

101993–2021
O'DAY v. King County green
wash · 1988
2 sentences

2009O'Day v. King County, 109 Wash.2d 796, 804 , 749 P.2d 142 (1988) (quoting New York v. Ferber, 458 U.S. 747, 769 , 102 S.Ct. 3348 , 73 L.Ed.2d 1113 (1982)). ¶ 15 In conducting an overbreadth analysis, a court's first task is to determine whether the statute reaches a substantial amount of constitutionally protected speech or conduct.

2009O'Day v. King County, 109 Wash.2d 796, 804 , 749 P.2d 142 (1988) (quoting New York v. Ferber, 458 U.S. 747, 769 , 102 S.Ct. 3348 , 73 L.Ed.2d 1113 (1982)). ¶ 15 In conducting an overbreadth analysis, a court's first task is to determine whether the statute reaches a substantial amount of constitutionally protected speech or conduct.

101996–2009
State v. Motherwell green
wash · 1990
2 sentences

2019Constitutionality of RCW 9A.76.180 Whether a statute is unconstitutionally overbroad under the First Amendment presents a question of law that we review de novo.13 Because of the important rights protected by the First Amendment, the overbreadth doctrine allows a litigant to challenge a statute on its face, rather than as applied to his own facts, and have a statute invalidated for overbreadth where it would be unconstitutional as applied to others even if not as applied to him.t14~ ~ ki.at 11:34-12:37. 12 Ex. 28. 13 State v. Immelt, 173 Wn.2d 1, 6 , 267 P.3d 305 (2011). 14 State v. Motherwell

2019Constitutionality of RCW 9A.76.180 Whether a statute is unconstitutionally overbroad under the First Amendment presents a question of law that we review de novo.13 Because of the important rights protected by the First Amendment, the overbreadth doctrine allows a litigant to challenge a statute on its face, rather than as applied to his own facts, and have a statute invalidated for overbreadth where it would be unconstitutional as applied to others even if not as applied to him.t14~ ~ ki.at 11:34-12:37. 12 Ex. 28. 13 State v. Immelt, 173 Wn.2d 1, 6 , 267 P.3d 305 (2011). 14 State v. Motherwell

42000–2019
Dice v. Akron, Canton & Youngstown Railroad green
scotus · 1952
2 sentences

2006The overbreadth doctrine will invalidate a statute only if the “ ‘enactment reaches a substantial amount of constitutionally protected conduct,’ ” City of Houston v. Hill, 482 U.S. 451, 458 , 107 S. Ct. 2502 , 96 L.

2006The overbreadth doctrine will invalidate a statute only if the "`enactment reaches a substantial amount of constitutionally protected conduct,'" City of Houston v. Hill, 482 U.S. 451, 458 , 107 S.Ct. 2502 , 96 L.Ed.2d 398 (1987) (quoting Hoffman Estates v. Flipside, Hoffman Estates, Inc., 455 U.S. 489, 494 , 102 S.Ct. 1186 , 71 L.Ed.2d 362 (1982)), "judged in relation to the statute's plainly legitimate sweep," Broadrick v. Oklahoma, 413 U.S. 601, 615 , 93 S.Ct. 2908 , 37 L.Ed.2d 830 (1973).

41990–2006
City of Houston v. Hill green
scotus · 1987
2 sentences

2006The overbreadth doctrine will invalidate a statute only if the “ ‘enactment reaches a substantial amount of constitutionally protected conduct,’ ” City of Houston v. Hill, 482 U.S. 451, 458 , 107 S. Ct. 2502 , 96 L.

2006The overbreadth doctrine will invalidate a statute only if the “ ‘enactment reaches a substantial amount of constitutionally protected conduct,’ ” City of Houston v. Hill, 482 U.S. 451, 458 , 107 S. Ct. 2502 , 96 L.

41990–2006
Blondheim v. State green
wash · 1975
2 sentences

2003Blondheim v. State, 84 Wash.2d 874, 878 , 529 P.2d 1096 (1975).

1986The State responds that an overbreadth challenge may only be made when a claim is made that the statute is "so broad that it may not only prohibit unprotected behavior but may also prohibit constitutionally protected activity as well." Blondheim v. State, 84 Wn.2d at 878 .

41980–2003
City of Seattle v. Ivan green
washctapp · 1993
2 sentences

2020“Overbreadth analysis is intended to ensure that the legislative enactments do not prohibit constitutionally protected conduct, such as free speech.” City of Seattle v. hian, 71 Wn.

2020“Overbreadth analysis is intended to ensure that legislative enactments do not prohibit constitutionally protected conduct, such as free speech.” City of Seattle v. Ivan, 71 Wn.

31998–2020
Virginia v. Hicks green
scotus · 2003
2 sentences

2014The showing that a law punishes a “substantial” amount of protected free speech, “judged in relation to the statute’s plainly legitimate sweep,” suffices to invalidate all enforcement of that law, “until and unless a limiting construction or partial invalidation so narrows it as to remove the seeming threat or deterrence to constitutionally protected expression.” Virginia v. Hicks, 539 U.S. 113, 118-19 , 123 S. Ct. 2191 , 156 L.

2011Instead, it noted that “[t]he First Amendment doctrine of overbreadth is an exception to our normal rule regarding the standards for facial challenges.” Id.

32011–2014
Eastland v. Texas green
scotus · 1991
2 sentences

2005The First Amendment overbreadth doctrine may invalidate a law on its face only if the law is ‘substantially overbroad.’ In determining overbreadth, ‘a court’s first task is to determine whether the enactment reaches a substantial amount of constitutionally protected conduct.’ Criminal statutes require particular scrutiny and may be facially invalid if they ‘make unlawful a substantial amount of constitutionally protected conduct. .. even if they also have legitimate application.’ ” Glas, 147 Wn.2d at 419 (quoting City of Seattle v. Webster, 115 Wn.2d 635, 641 , 802 P.2d 1333 (1990), cert. deni

1991We disagree. [5, 6] Our Supreme Court recently outlined the overbreadth doctrine in Seattle v. Webster, 115 Wn.2d 635 , 802 P.2d 1333 (1990), cert. denied, 111 S.Ct. 1690 (1991): A law is overbroad if it sweeps within its prohibitions constitutionally protected free speech activities.

31991–2005
State v. Immelt green
wash · 2011
2 sentences

2019Constitutionality of RCW 9A.76.180 Whether a statute is unconstitutionally overbroad under the First Amendment presents a question of law that we review de novo.13 Because of the important rights protected by the First Amendment, the overbreadth doctrine allows a litigant to challenge a statute on its face, rather than as applied to his own facts, and have a statute invalidated for overbreadth where it would be unconstitutional as applied to others even if not as applied to him.t14~ ~ ki.at 11:34-12:37. 12 Ex. 28. 13 State v. Immelt, 173 Wn.2d 1, 6 , 267 P.3d 305 (2011). 14 State v. Motherwell

2019Constitutionality of RCW 9A.76.180 Whether a statute is unconstitutionally overbroad under the First Amendment presents a question of law that we review de novo.13 Because of the important rights protected by the First Amendment, the overbreadth doctrine allows a litigant to challenge a statute on its face, rather than as applied to his own facts, and have a statute invalidated for overbreadth where it would be unconstitutional as applied to others even if not as applied to him.t14~ ~ ki.at 11:34-12:37. 12 Ex. 28. 13 State v. Immelt, 173 Wn.2d 1, 6 , 267 P.3d 305 (2011). 14 State v. Motherwell

22019–2021
State v. Dyson green
washctapp · 1994
2 sentences

2021Id. (citing Talley, 122 Wn.2d at 198, 210 ).

1996Finally, even if the statute reaches a substantial amount of protected speech, it will not be overturned if: (1) the court can place a sufficient limiting construction on the statute; or (2) the statute’s regulation of protected speech is permissible under the First Amendment. 11 Use of the overbreadth doctrine to invalidate a statute is considered "strong medicine” to be applied "only as a last resort.” Dyson, 74 Wn.

21996–2021
State v. Moultrie green
washctapp · 2008
2 sentences

2014Moultrie, 143 Wn.

2014Moultrie,. 143 Wn.

22014–2014
United States v. American Library Assn., Inc. green
scotus · 2003
2 sentences

2010But a public library has no obligation to make available any and all constitutionally protected material, and the goal of libraries has never, as the plurality in A.L.A. noted, been to provide "`universal coverage.'" A.L.A., 539 U.S. at 204 , 123 S.Ct. 2297 (quoting Am.

2010But a public library has no obligation to make available any and all constitutionally protected material, and the goal of libraries has never, as the plurality in A.L.A. noted, been to provide “ ‘universal coverage.’ ’’A.L.A., 539 U.S. at 204 (quoting Am.

22010–2010
State v. Hearn green
washctapp · 2006
2 sentences

2007“An offender’s usual constitutional rights during community placement are subject to [Sentencing Reform Act]-authorized infringements.” State v. Hearn, 131 Wn.

2007"An offender's usual constitutional rights during community placement are subject to SRA-authorized infringements." State v. Hearn, 131 Wash. App. 601, 607 , 128 P.3d 139 (2006)(citing State v. Riles, 135 Wash.2d 326, 347 , 957 P.2d 655 (1998)).

22007–2007
City of Bellevue v. Miller green
wash · 1975
22005–2005
State v. Glas green
wash · 2002
22005–2005
State v. Knowles green
washctapp · 1998
22005–2005
City of Seattle v. Eze green
wash · 1988
22005–2005
City of Seattle v. Montana green
wash · 1996
21997–2001
City of Seattle v. Montana green
wash · 1996
21997–2001
Schall v. Martin green
scotus · 1984
21996–1996
State v. Padilla green
wash · 2018
12021–2021
State v. Alexander green
washctapp · 1995
12019–2019
Forsyth County v. Nationalist Movement green
scotus · 1992
12019–2019
City of Lakewood v. Willis green
wash · 2016
12019–2019
Board of Airport Comm'rs of Los Angeles v. Jews for Jesus, Inc. green
scotus · 1987
12019–2019
Brockett v. Spokane Arcades, Inc. green
scotus · 1985
12019–2019
State v. Bradford green
washctapp · 2013
12019–2019
State v. Dana green
washctapp · 1996
12018–2018
Kitsap County v. Mattress Outlet green
wash · 2005
12015–2015
City of Seattle v. Abercrombie green
washctapp · 1997
12013–2013
Cox v. Louisiana green
scotus · 1965
12012–2012
cluster 2144 green
·
12011–2011
Holder v. Humanitarian Law Project green
scotus · 2010
12011–2011
State v. Compas green
mont · 1998
12011–2011
Dombrowski v. Pfister green
scotus · 1965
12011–2011
Colten v. Kentucky green
scotus · 1972
12011–2011
State v. Hearn neutral
washctapp · 2006
12007–2007
Wisconsin v. Mitchell green
scotus · 1993
12006–2006
Texas v. Johnson green
scotus · 1989
12006–2006

Statutes the citing opinions construe

WA § Wash. Rev. Code § 2.06.040 (12) WA § Wash. Rev. Code § 9A.04.110 (11) WA § Wash. Rev. Code § 9A.46.020 (8) WA § Wash. Rev. Code § 9.61.230 (6) WA § Wash. Rev. Code § 9A.72.160 (6) WA § Wash. Rev. Code § 9.68A.011 (5) WA § Wash. Rev. Code § 9A.46.110 (5) USC § 42u.s.c.1983 (4) WA § Wash. Rev. Code § 35.22.280 (4) WA § Wash. Rev. Code § 9.94A.030 (4) WA § Wash. Rev. Code § 9A.76.180 (4) WA § Wash. Rev. Code § 9.68A.090 (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

CA 249 (1971–2026) TX 204 (1984–2026) IL 89 (1980–2025) WA 83 (1971–2021) OH 81 (1972–2026) FL 70 (1973–2023) CO 52 (1979–2026) WI 47 (1978–2021) MN 46 (1976–2019) PA 43 (1979–2026) NJ 42 (1979–2026) MI 29 (1979–2024) OR 29 (1980–2025) MA 28 (1975–2022) KS 27 (1979–2026) ID 26 (1985–2026) AL 24 (1983–2015) NY 23 (1978–2025) CT 23 (1977–2026) IA 22 (1973–2024) MO 22 (1976–2025) NV 21 (1981–2024) IN 21 (1976–2024) HI 20 (1977–2020) AZ 19 (1982–2026) VA 19 (1988–2024) LA 16 (1984–2025) UT 16 (1983–2021) OK 14 (1974–2025) NE 14 (1983–2024) TN 14 (1993–2026) ND 13 (1982–2025) DC 13 (1981–2016) AK 12 (1974–2006) MD 11 (1988–2025) NC 11 (1978–2015) NM 11 (1993–2021) KY 10 (1985–2021) RI 10 (1977–2012) NH 9 (1973–2025) GA 9 (1983–2024) MS 8 (1989–2024) MT 7 (1994–2016) AR 7 (1998–2026) DE 7 (1988–2024) SC 6 (1997–2012) SD 5 (2003–2014) WY 4 (2004–2019) WV 3 (1982–2016) VT 2 (2013–2021) ME 2 (1985–2022)

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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