corollary principle (District of Columbia) · Go Syfert
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corollary principle in District of Columbia

11 District of Columbia opinions name it 1 courts 1976–2025 1 in the last five years

The cases below were cited by District of Columbia 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 (10)

CaseFollowedCited
Garces v. Bradleygreen
dc · 1973 · cited in 2 District of Columbia opinions naming this issue, 1984–2015
2 sentences

2015See Garces v. Bradley, 299 A.2d 142, 144 (D.C.1973) (noting "the well settled rule that the law abhors a default, and the corollary of the rule that dispositions on the merits are favored"). 12 .

1984See Garces v. Bradley, supra, 299 A.2d at 144 (recognizing well-settled rule that the “law abhors a default, and the corollary of the rule [is] that dispositions on the merits are favored”).

22
United States v. Lee R. Smithgreen
cadc · 1974 · cited in 2 District of Columbia opinions naming this issue, 1981–2014
2 sentences

2014As early as Rease, supra, 403 A.2d at 327-28 , we noted that prior consistent statements could be admitted “for rehabilitation purposes” where they “can be of very clear help to the factfinder in determining whether the witness is truthful” and where the proposed evidence “is directed only at the particular impeachment that occurred.” 4 Subsequently, in Johnson v. United States, 434 A.2d 415 (D.C.1981), we articulated much the same evidentiary standard in sustaining a trial court admittance of a prior consistent statement where the witness had been impeached specifically by a prior inconsisten

2014As early as Rease, supra, 403 A.2d at 327-28 , we noted that prior consistent statements could be admitted “for rehabilitation purposes” where they “can be of very clear help to the factfinder in determining whether the witness is truthful” and where the proposed evidence “is directed only at the particular impeachment that occurred.” 4 Subsequently, in Johnson v. United States, 434 A.2d 415 (D.C.1981), we articulated much the same evidentiary standard in sustaining a trial court admittance of a prior consistent statement where the witness had been impeached specifically by a prior inconsisten

22
United States v. McDougaldgreen
dc · 1976 · cited in 2 District of Columbia opinions naming this issue, 2000–2000
2 sentences

2000This court has repeatedly held that “the law does not require ... access where witnesses for private reasons and absent government interference refuse to discuss the case with defense counsel.” In re B.L.B., 432 A.2d 722, 725 (D.C.1981); Khaalis v. United States, 408 A.2d 313, 336-39 (D.C.1979) (upholding trial court ruling that witness could not be cross-examined about his personal decision not to speak with defense counsel); United States v. McDougald, 350 A.2d 375, 378 (1976) (due process not violated where “witnesses for private reasons and absent government interference refuse to discuss

2000This court has repeatedly held that "the law does not require . . . access where witnesses for private reasons and absent government interference refuse to discuss the case with defense counsel." In re B.L.B., 432 A.2d 722, 725 (D.C.1981); Khaalis v. United States, 408 A.2d 313, 336-39 (D.C.1979) (upholding trial court ruling that witness could not be cross-examined about his personal decision not to speak with defense counsel); United States v. McDougald, 350 A.2d 375, 378 (1976) (due process not violated where "witnesses for private reasons and absent government interference refuse to discus

22
Khaalis v. United Statesgreen
dc · 1979 · cited in 2 District of Columbia opinions naming this issue, 2000–2000
2 sentences

2000This court has repeatedly held that “the law does not require ... access where witnesses for private reasons and absent government interference refuse to discuss the case with defense counsel.” In re B.L.B., 432 A.2d 722, 725 (D.C.1981); Khaalis v. United States, 408 A.2d 313, 336-39 (D.C.1979) (upholding trial court ruling that witness could not be cross-examined about his personal decision not to speak with defense counsel); United States v. McDougald, 350 A.2d 375, 378 (1976) (due process not violated where “witnesses for private reasons and absent government interference refuse to discuss

2000This court has repeatedly held that "the law does not require . . . access where witnesses for private reasons and absent government interference refuse to discuss the case with defense counsel." In re B.L.B., 432 A.2d 722, 725 (D.C.1981); Khaalis v. United States, 408 A.2d 313, 336-39 (D.C.1979) (upholding trial court ruling that witness could not be cross-examined about his personal decision not to speak with defense counsel); United States v. McDougald, 350 A.2d 375, 378 (1976) (due process not violated where "witnesses for private reasons and absent government interference refuse to discus

22
Matter of BLBgreen
dc · 1981 · cited in 2 District of Columbia opinions naming this issue, 2000–2000
2 sentences

2000This court has repeatedly held that “the law does not require ... access where witnesses for private reasons and absent government interference refuse to discuss the case with defense counsel.” In re B.L.B., 432 A.2d 722, 725 (D.C.1981); Khaalis v. United States, 408 A.2d 313, 336-39 (D.C.1979) (upholding trial court ruling that witness could not be cross-examined about his personal decision not to speak with defense counsel); United States v. McDougald, 350 A.2d 375, 378 (1976) (due process not violated where “witnesses for private reasons and absent government interference refuse to discuss

2000This court has repeatedly held that "the law does not require . . . access where witnesses for private reasons and absent government interference refuse to discuss the case with defense counsel." In re B.L.B., 432 A.2d 722, 725 (D.C.1981); Khaalis v. United States, 408 A.2d 313, 336-39 (D.C.1979) (upholding trial court ruling that witness could not be cross-examined about his personal decision not to speak with defense counsel); United States v. McDougald, 350 A.2d 375, 378 (1976) (due process not violated where "witnesses for private reasons and absent government interference refuse to discus

22
Intercounty Construction Corp. v. District of Columbiagreen
dc · 1982 · cited in 1 District of Columbia opinions naming this issue, 2003–2003
2 sentences

2003Corp. v. District of Columbia, 443 A.2d 29, 32 (D.C. 1982).

2003Corp. v. District of Columbia, 443 A.2d 29, 32 (D.C. 1982).

11
1010 Potomac Associates v. Grocery Manufacturers of America, Inc.green
dc · 1984 · cited in 1 District of Columbia opinions naming this issue, 2003–2003
2 sentences

2003To support its investigation of the history of the pollution exclusion, the majority relies on the corollary principle that “extrinsic evidence may be considered to determine the circumstances surrounding the making of the contract so that it may be ascertained what a reasonable person in the position of the parties would have thought the words meant.” 1010 Potomac Assocs., 485 A.2d at 205-06 (citations omitted); accord, Christacos, 583 A.2d at 194 ; see also Intercounty Constr.

2003To support its investigation of the history of the pollution exclusion, the majority relies on the corollary principle that "extrinsic evidence may be considered to determine the circumstances surrounding the making of the contract so that it may be ascertained what a reasonable person in the position of the parties would have thought the words meant." 1010 Potomac Assocs., 485 A.2d at 205-06 (citations omitted); accord, Christacos, 583 A.2d at 194 ; see also Intercounty Constr.

11
Christacos v. Blackie's House of Beef, Inc.green
dc · 1990 · cited in 1 District of Columbia opinions naming this issue, 2003–2003
2 sentences

2003To support its investigation of the history of the pollution exclusion, the majority relies on the corollary principle that “extrinsic evidence may be considered to determine the circumstances surrounding the making of the contract so that it may be ascertained what a reasonable person in the position of the parties would have thought the words meant.” 1010 Potomac Assocs., 485 A.2d at 205-06 (citations omitted); accord, Christacos, 583 A.2d at 194 ; see also Intercounty Constr.

2003To support its investigation of the history of the pollution exclusion, the majority relies on the corollary principle that "extrinsic evidence may be considered to determine the circumstances surrounding the making of the contract so that it may be ascertained what a reasonable person in the position of the parties would have thought the words meant." 1010 Potomac Assocs., 485 A.2d at 205-06 (citations omitted); accord, Christacos, 583 A.2d at 194 ; see also Intercounty Constr.

11
Presley v. Commercial Credit Corporationgreen
dc · 1962 · cited in 1 District of Columbia opinions naming this issue, 1995–1995
1 sentence

1995See Presley v. Commercial Credit Corp., 177 A.2d 916, 918 (D.C.1962); Park Transfer Co. v. Lumbermen’s Mutual Casualty Co., 79 U.S.App.D.C. 48 , 142 F.2d 100 (1944).

11
Akinyode v. Hawkinsgreen
dc · 1972 · cited in 1 District of Columbia opinions naming this issue, 1984–1984
1 sentence

1984Although a motion to dismiss for failure to prosecute is committed to the sound discretion of the trial court, see, e.g., Garces v. Bradley, supra, 299 A.2d at 144 ; Akinyode v. Hawkins, 292 A.2d 795, 796 (D.C. 1972); Sitwell v. Government Employees Ins.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in District of Columbia. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Rease v. United States green
dc · 1979
2 sentences

2014As early as Rease, supra, 403 A.2d at 327-28 , we noted that prior consistent statements could be admitted “for rehabilitation purposes” where they “can be of very clear help to the factfinder in determining whether the witness is truthful” and where the proposed evidence “is directed only at the particular impeachment that occurred.” 4 Subsequently, in Johnson v. United States, 434 A.2d 415 (D.C.1981), we articulated much the same evidentiary standard in sustaining a trial court admittance of a prior consistent statement where the witness had been impeached specifically by a prior inconsisten

2014As early as Rease, supra, 403 A.2d at 327-28 , we noted that prior consistent statements could be admitted “for rehabilitation purposes” where they “can be of very clear help to the factfinder in determining whether the witness is truthful” and where the proposed evidence “is directed only at the particular impeachment that occurred.” 4 Subsequently, in Johnson v. United States, 434 A.2d 415 (D.C.1981), we articulated much the same evidentiary standard in sustaining a trial court admittance of a prior consistent statement where the witness had been impeached specifically by a prior inconsisten

21981–2014
Clifton Gregory v. United States green
cadc · 1966
2 sentences

2000This was the holding in Gregory v. United States, 125 U.S.App.D.C. 140 , 369 F.2d 185 (1966). 16 In that case, a prosecutor instructed two eyewitnesses not to speak to the defense attorney unless he were present.

2000This was the holding in Gregory v. United States, 125 U.S.App.D.C. 140 , 369 F.2d 185 (1966). 16 In that case, a prosecutor instructed two eyewitnesses not to speak to the defense attorney unless he were present.

22000–2000
Firfer Et Ux. v. United States green
cadc · 1953
1 sentence

2025The general rule Generally, “[t]respassers may only recover for ‘intentional, wanton or willful injury or maintenance of a hidden engine of destruction.’” Holland, 431 A.2d at 599 (quoting Firfer, 208 F.2d at 528 ); see also Restatement (Second) of Torts § 333 (The general rule is that “a possessor of land is not liable to trespassers for physical harm 25 caused by his failure to exercise reasonable care (a) to put the land in a condition reasonably safe for their reception, or (b) to carry on his activities so as not to endanger them.”).

12025–2025
Holland v. Baltimore & Ohio Railroad green
dc · 1981
1 sentence

2025The general rule Generally, “[t]respassers may only recover for ‘intentional, wanton or willful injury or maintenance of a hidden engine of destruction.’” Holland, 431 A.2d at 599 (quoting Firfer, 208 F.2d at 528 ); see also Restatement (Second) of Torts § 333 (The general rule is that “a possessor of land is not liable to trespassers for physical harm 25 caused by his failure to exercise reasonable care (a) to put the land in a condition reasonably safe for their reception, or (b) to carry on his activities so as not to endanger them.”).

12025–2025
Johnson v. United States green
dc · 1981
1 sentence

2014As early as Rease, supra, 403 A.2d at 327-28 , we noted that prior consistent statements could be admitted “for rehabilitation purposes” where they “can be of very clear help to the factfinder in determining whether the witness is truthful” and where the proposed evidence “is directed only at the particular impeachment that occurred.” 4 Subsequently, in Johnson v. United States, 434 A.2d 415 (D.C.1981), we articulated much the same evidentiary standard in sustaining a trial court admittance of a prior consistent statement where the witness had been impeached specifically by a prior inconsisten

12014–2014
Speyer, Inc. v. Goodyear Tire & Rubber Co. green
pa · 1972
2 sentences

1997The ease of Speyer, Inc. v. Goodyear Tire and Rubber Co., 222 Pa.Super. 261 , 295 A.2d 143 (1972), relied upon by the dissent for its conclusion, simply illustrates a corollary to the rule of collateral estoppel; “if a judgment of a court of first instance is based on determinations of two issues, either of which standing independently would be sufficient to support the result, the judgment is not conclusive with respect to either issue standing alone.” Restatement (Second) of Judgments § 27, cmt. i. The determinations, not being “essential to the judgment,” have no issue preclusive effect in

1997The ease of Speyer, Inc. v. Goodyear Tire and Rubber Co., 222 Pa.Super. 261 , 295 A.2d 143 (1972), relied upon by the dissent for its conclusion, simply illustrates a corollary to the rule of collateral estoppel; “if a judgment of a court of first instance is based on determinations of two issues, either of which standing independently would be sufficient to support the result, the judgment is not conclusive with respect to either issue standing alone.” Restatement (Second) of Judgments § 27, cmt. i. The determinations, not being “essential to the judgment,” have no issue preclusive effect in

11997–1997
Park Transfer Co. v. Lumbermens Mut. Casualty Co. green
cadc · 1944
2 sentences

1995See Presley v. Commercial Credit Corp., 177 A.2d 916, 918 (D.C.1962); Park Transfer Co. v. Lumbermen’s Mutual Casualty Co., 79 U.S.App.D.C. 48 , 142 F.2d 100 (1944).

1995See Presley v. Commercial Credit Corp., 177 A.2d 916, 918 (D.C.1962); Park Transfer Co. v. Lumbermen’s Mutual Casualty Co., 79 U.S.App.D.C. 48 , 142 F.2d 100 (1944).

11995–1995
Hughes v. United States green
dc · 1973
1 sentence

1976Cf. Hughes v. United States, D.C.App., 308 A. 2d 238 , 242 n. 12 (1973).

11976–1976

Where else courts name it

TX 409 (1913–2026) CA 280 (1900–2026) IL 103 (1873–2023) NY 87 (1911–2025) PA 86 (1915–2024) NJ 77 (1896–2026) MD 69 (1928–2023) WA 66 (1922–2026) MO 65 (1905–2025) GA 57 (1912–2023) FL 49 (1938–2023) AL 44 (1909–2015) OH 39 (1932–2026) MI 37 (1940–2023) CT 37 (1937–2025) LA 35 (1919–2024) IN 34 (1918–2019) IA 32 (1917–2023) MS 32 (1876–2022) WI 32 (1965–2024) KS 27 (1875–2026) OR 26 (1897–2026) TN 26 (1904–2025) KY 25 (1922–2024) WV 24 (1901–2023) VA 23 (1963–2024) WY 23 (1968–2022) SC 20 (1907–2020) CO 19 (1912–2021) DE 19 (1945–2026) VT 17 (1913–2025) MT 16 (1898–2012) NC 15 (1921–2018) AZ 15 (1956–2018) MA 14 (1951–2024) NM 14 (1914–2014) RI 14 (1968–2018) OK 13 (1925–2014) ME 12 (1922–2020) NE 12 (1959–2023) MN 12 (1954–2025) ID 11 (1977–2021) DC 11 (1976–2025) UT 11 (1979–2026) AR 11 (1927–2017) ND 7 (1895–2015) NV 6 (1983–2015) NH 3 (1997–2021) SD 3 (1998–2003) HI 2 (1944–2015) AK 2 (1993–2023)

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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