situation defense (District of Columbia) · Go Syfert
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situation defense in District of Columbia

11 District of Columbia opinions name it 1 courts 1956–2013 0 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 (8)

CaseFollowedCited
Zellerbach Paper Co. v. Helveringgreen
scotus · 1934 · cited in 1 District of Columbia opinions naming this issue, 2013–2013
2 sentences

2013See Zellerbach, 293 U.S. at 182 , 55 S.Ct. 127 (“An examiner needs more time for an audit when errors are latent, to be discovered only by digging into books and vouchers, than when errors are apparent upon a bare inspection of the record.”); see also Colony, Inc. v. Commissioner, 357 U.S. 28, 36 , 78 S.Ct. 1033 , 2 L.Ed.2d 1119 (1958) (discussing the extension for 25 percent under-reporting of income — created because Congress recognized in such cases that the government was “at a special disadvantage in detecting errors”).

2013See Zellerbach, 293 U.S. at 182 , 55 S.Ct. 127 (“An examiner needs more time for an audit when errors are latent, to be discovered only by digging into books and vouchers, than when errors are apparent upon a bare inspection of the record.”); see also Colony, Inc. v. Commissioner, 357 U.S. 28, 36 , 78 S.Ct. 1033 , 2 L.Ed.2d 1119 (1958) (discussing the extension for 25 percent under-reporting of income — created because Congress recognized in such cases that the government was “at a special disadvantage in detecting errors”).

11
Colony, Inc. v. Commissionergreen
scotus · 1958 · cited in 1 District of Columbia opinions naming this issue, 2013–2013
2 sentences

2013See Zellerbach, 293 U.S. at 182 , 55 S.Ct. 127 (“An examiner needs more time for an audit when errors are latent, to be discovered only by digging into books and vouchers, than when errors are apparent upon a bare inspection of the record.”); see also Colony, Inc. v. Commissioner, 357 U.S. 28, 36 , 78 S.Ct. 1033 , 2 L.Ed.2d 1119 (1958) (discussing the extension for 25 percent under-reporting of income — created because Congress recognized in such cases that the government was “at a special disadvantage in detecting errors”).

2013See Zellerbach, 293 U.S. at 182 , 55 S.Ct. 127 (“An examiner needs more time for an audit when errors are latent, to be discovered only by digging into books and vouchers, than when errors are apparent upon a bare inspection of the record.”); see also Colony, Inc. v. Commissioner, 357 U.S. 28, 36 , 78 S.Ct. 1033 , 2 L.Ed.2d 1119 (1958) (discussing the extension for 25 percent under-reporting of income — created because Congress recognized in such cases that the government was “at a special disadvantage in detecting errors”).

11
United States v. Agursgreen
scotus · 1976 · cited in 1 District of Columbia opinions naming this issue, 2001–2001
2 sentences

2001In Bagley, the Court expanded on the “upon request” language, noting that “where the defense makes a specific request and the prosecutor fails to disclose responsive evidence .... the standard might be more lenient than in the situation in which the defense makes no request or only a general request.” 473 U.S. at 681 , 105 S.Ct. 3375 (citing United States v. Agurs, 427 U.S. 97, 106 , 96 S.Ct. 2392 , 49 L.Ed.2d 342 (1976) (“When the prosecutor receives a specific and relevant request, the failure to make any response is seldom, if ever, excusable.”)).

2001In Bagley, the Court expanded on the “upon request” language, noting that “where the defense makes a specific request and the prosecutor fails to disclose responsive evidence .... the standard might be more lenient than in the situation in which the defense makes no request or only a general request.” 473 U.S. at 681 , 105 S.Ct. 3375 (citing United States v. Agurs, 427 U.S. 97, 106 , 96 S.Ct. 2392 , 49 L.Ed.2d 342 (1976) (“When the prosecutor receives a specific and relevant request, the failure to make any response is seldom, if ever, excusable.”)).

11
Lee v. District of Columbia Zoning Commissiongreen
dc · 1980 · cited in 1 District of Columbia opinions naming this issue, 1988–1988
1 sentence

1988Ordinarily, “ ‘[i]f the agency fails to make a finding on a material, contested issue of fact, this court cannot fill the gap by making its own determination from the record, but must remand the case for findings on that issue.’ ” Nursing Servs., Inc. v. District of Columbia Dep’t of Employment Servs., 512 A.2d 301, 303 (D.C.1986) (quoting Colton v. District of Columbia Dep’t of Employment Servs., 484 A.2d 550, 552 (D.C.1984)); Lee v. District of Columbia Zoning Comm’n, 411 A.2d 635, 639 (D.C.1980).

11
Colton v. District of Columbia Department of Employment Servicesgreen
dc · 1984 · cited in 1 District of Columbia opinions naming this issue, 1988–1988
1 sentence

1988Ordinarily, “ ‘[i]f the agency fails to make a finding on a material, contested issue of fact, this court cannot fill the gap by making its own determination from the record, but must remand the case for findings on that issue.’ ” Nursing Servs., Inc. v. District of Columbia Dep’t of Employment Servs., 512 A.2d 301, 303 (D.C.1986) (quoting Colton v. District of Columbia Dep’t of Employment Servs., 484 A.2d 550, 552 (D.C.1984)); Lee v. District of Columbia Zoning Comm’n, 411 A.2d 635, 639 (D.C.1980).

11
Nursing Services, Inc. v. District of Columbia Department of Employment Servicesgreen
dc · 1986 · cited in 1 District of Columbia opinions naming this issue, 1988–1988
1 sentence

1988Ordinarily, “ ‘[i]f the agency fails to make a finding on a material, contested issue of fact, this court cannot fill the gap by making its own determination from the record, but must remand the case for findings on that issue.’ ” Nursing Servs., Inc. v. District of Columbia Dep’t of Employment Servs., 512 A.2d 301, 303 (D.C.1986) (quoting Colton v. District of Columbia Dep’t of Employment Servs., 484 A.2d 550, 552 (D.C.1984)); Lee v. District of Columbia Zoning Comm’n, 411 A.2d 635, 639 (D.C.1980).

11
Goodwin v. District of Columbia Board of Educationgreen
dc · 1975 · cited in 1 District of Columbia opinions naming this issue, 1985–1985
2 sentences

1985Therefore, where the later general statute does not present an irreconciliable conflict, the prior special statute will be construed as remaining in effect as a qualification of or exception to the general law. 1A SUTHERLAND, STATUTES AND STATUTORY CONSTRUCTION § 23.15 (4th ed.1972) (footnotes omitted); see, e.g., Goodwin v. District of Columbia Board of Education, 343 A.2d 63, 65-66 (D.C.1975).

1985Therefore, where the later general statute does not present an irreconciliable conflict, the prior special statute will be construed as remaining in effect as a qualification of or exception to the general law. 1A SUTHERLAND; STATUTES AND STATUTORY CONSTRUCTION § 23.15 (4th ed.1972) (footnotes omitted); see, e.g., Goodwin v. District of Columbia Board of Education, 343 A.2d 63, 65-66 (D.C.1975).

11
United States v. George Gray, Jr.green
cadc · 1973 · cited in 1 District of Columbia opinions naming this issue, 1980–1980
2 sentences

1980It has been stated that a flexible rule is “responsive to the underlying rationale of the corroboration requirement — the avoidance of baseless accusations — and it is far more consonant with the realities of the trial situation than a rule which would compel the Government to prove virtually its entire case twice: once by the victim’s testimony and again by independent evidence.” United States v. Gray, supra 155 U.S.App.D.C. at 277, 477 F.2d at 445 .

1980It has been stated that a flexible rule is “responsive to the underlying rationale of the corroboration requirement — the avoidance of baseless accusations — and it is far more consonant with the realities of the trial situation than a rule which would compel the Government to prove virtually its entire case twice: once by the victim’s testimony and again by independent evidence.” United States v. Gray, supra 155 U.S.App.D.C. at 277, 477 F.2d at 445 .

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 (7)

CaseCitedYears
United States v. Bagley green
scotus · 1985
2 sentences

2001In Bagley, the Court expanded on the “upon request” language, noting that “where the defense makes a specific request and the prosecutor fails to disclose responsive evidence .... the standard might be more lenient than in the situation in which the defense makes no request or only a general request.” 473 U.S. at 681 , 105 S.Ct. 3375 (citing United States v. Agurs, 427 U.S. 97, 106 , 96 S.Ct. 2392 , 49 L.Ed.2d 342 (1976) (“When the prosecutor receives a specific and relevant request, the failure to make any response is seldom, if ever, excusable.”)).

2001In Bagley , the Court expanded on the "upon request" language, noting that "where the defense makes a specific request and the prosecutor fails to disclose responsive evidence.... the standard might be more lenient than in the situation in which the defense makes no request or only a general request." 473 U.S. at 681 , 105 S.Ct. 3375 (citing United States v. Agurs, 427 U.S. 97, 106 , 96 S.Ct. 2392 , 49 L.Ed.2d 342 (1976) ("When the prosecutor receives a specific and relevant request, the failure to make any response is seldom, if ever, excusable.")).

21988–2001
Dyson v. United States green
dc · 1982
2 sentences

1984Instead, we are guided by the well-settled standard recently enunciated in Dyson v. United States, 450 A.2d 432 (D.C.1982) where, significantly, it appears that, as in the case before us, appellant made but one motion for judgment of acquittal at the close of the government’s case.

1984Instead, we are guided by the well-settled standard recently enunciated in Dyson v. United States, 450 A.2d 432 (D.C.1982) where, significantly, it appears that, as in the case before us, appellant made but one motion for judgment of acquittal at the close of the government's case.

21984–1984
Kyles v. Whitley green
scotus · 1995
2 sentences

2001In Kyles , the Court reiterated what it had said in Bagley, that “regardless of request, favorable evidence is material, and constitutional error results from its suppression by the government, ‘if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.’” Kyles, 514 U.S. at 433 , 115 S.Ct. 1555 (quoting Bagley, 473 U.S. at 682 , 105 S.Ct. 3375 ).

2001In Kyles , the Court reiterated what it had said in Bagley, that “regardless of request, favorable evidence is material, and constitutional error results from its suppression by the government, ‘if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.’” Kyles, 514 U.S. at 433 , 115 S.Ct. 1555 (quoting Bagley, 473 U.S. at 682 , 105 S.Ct. 3375 ).

12001–2001
Williams v. United States green
dc · 1978
2 sentences

1992A principal purpose of the plain error rule “is to permit trial courts fully to consider issues and thereby avoid potential error.” Williams v. United States, 382 A.2d 1 , 7 n. 12 (D.C.1978).

1992A principal purpose of the plain error rule "is to permit trial courts fully to consider issues and thereby avoid potential error." Williams v. United States, 382 A.2d 1 , 7 n. 12 (D.C.1978).

11992–1992
Hercules & Co. v. Shama Restaurant Corp. green
dc · 1989
2 sentences

1990Recently, in Hercules & Co. v. Shama Restaurant Corp., 566 A.2d 31 (D.C.1989), we declined to extend another outmoded doctrine, which was inconsistent with Supreme Court precedent in analogous federal cases, but to which this court was committed under M.A.P. v. Ryan, 285 A.2d 310 (D.C.1971), even though it was arguably difficult to articulate a persuasive distinction between the situation to which the doctrine applied and the circumstances to which we were asked to extend it.

1990Recently, in Hercules & Co. v. Shama Restaurant Corp., 566 A.2d 31 (D.C.1989), we declined to extend another outmoded doctrine, which was inconsistent with Supreme Court precedent in analogous federal cases, but to which this court was committed under M.A.P. v. Ryan, 285 A.2d 310 (D.C.1971), even though it was arguably difficult to articulate a persuasive distinction between the situation to which the doctrine applied and the circumstances to which we were asked to extend it.

11990–1990
M. A. P. v. Ryan green
dc · 1971
2 sentences

1990Recently, in Hercules & Co. v. Shama Restaurant Corp., 566 A.2d 31 (D.C.1989), we declined to extend another outmoded doctrine, which was inconsistent with Supreme Court precedent in analogous federal cases, but to which this court was committed under M.A.P. v. Ryan, 285 A.2d 310 (D.C.1971), even though it was arguably difficult to articulate a persuasive distinction between the situation to which the doctrine applied and the circumstances to which we were asked to extend it.

1990Recently, in Hercules & Co. v. Shama Restaurant Corp., 566 A.2d 31 (D.C.1989), we declined to extend another outmoded doctrine, which was inconsistent with Supreme Court precedent in analogous federal cases, but to which this court was committed under M.A.P. v. Ryan, 285 A.2d 310 (D.C.1971), even though it was arguably difficult to articulate a persuasive distinction between the situation to which the doctrine applied and the circumstances to which we were asked to extend it.

11990–1990
Nolan v. Werth green
cadc · 1944
2 sentences

1956In such a situation the principle laid down in Nolan v. Werth, 79 U.S.App.D.C. 33 , 142 F.2d 9 , is controlling.

1956In such a situation the principle laid down in Nolan v. Werth, 79 U.S.App.D.C. 33 , 142 F.2d 9 , is controlling.

11956–1956

Where else courts name it

NY 192 (1873–2024) CA 98 (1928–2026) IL 89 (1908–2026) TX 73 (1927–2024) PA 50 (1923–2024) FL 36 (1922–2015) MI 36 (1914–2025) MD 34 (1930–2025) AL 33 (1922–2017) LA 33 (1912–2018) GA 33 (1931–2012) IN 32 (1882–2018) MO 26 (1924–2012) OH 26 (1932–2019) IA 23 (1910–2026) OK 22 (1922–2022) WA 21 (1916–2020) WI 20 (1901–2021) KS 20 (1907–2014) NJ 18 (1929–2005) CT 17 (1902–2002) NE 17 (1930–2014) UT 14 (1894–2024) OR 14 (1919–2026) CO 14 (1938–2025) MA 13 (1885–2025) AZ 12 (1919–2017) TN 11 (1936–2005) NM 11 (1958–2024) DC 11 (1956–2013) KY 11 (1966–2018) MS 10 (1976–2017) WY 9 (1959–2003) WV 8 (1931–2014) MN 8 (1924–2017) NC 8 (1940–2021) DE 7 (1963–1995) ID 7 (1908–2014) AR 7 (1963–2001) VA 7 (1988–2023) RI 6 (1976–2024) MT 6 (1935–2005) ME 6 (1941–2024) SD 5 (1919–1999) SC 5 (1927–2014) VT 5 (1942–2006) AK 4 (1976–2022) HI 3 (2009–2014) ND 3 (1981–1999) NV 2 (1972–1994)

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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