Dean factors in Washington

11 Washington opinions name it 2 courts 2011–2026 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 (3)

Case	Followed	Cited
Dean v. Jordangreen wash · 1938 · cited in 5 Washington opinions naming this issue, 2011–2026 2 sentences 2026Dean v. Jordan, 194 Wash. 661, 672 , 79 P.2d 331 (1938); see also Mueller v. Wells, 185 Wn.2d 1, 10-11 , 367 P.3d 580 (2016) (holding that trial court’s findings “established an unrebutted presumption of undue influence based on the Dean factors, supported by “further positive evidence,” which together were sufficient to establish undue influence by clear, cogent, and convincing evidence). 2026Dean v. Jordan, 194 Wash. 661, 672 , 79 P.2d 331 (1938); see also Mueller v. Wells, 185 Wn.2d 1, 10-11 , 367 P.3d 580 (2016) (holding that trial court’s findings “established an unrebutted presumption of undue influence based on the Dean factors, supported by “further positive evidence,” which together were sufficient to establish undue influence by clear, cogent, and convincing evidence).	3	5
Baucom v. Sisco Stevedoring, LLCgreen alsd · 2007 · cited in 2 Washington opinions naming this issue, 2013–2013 2 sentences 2013We agree with Dean and conclude that the trial court erred in applying a summary judgment standard to Dean’s motion to reinstate maintenance and cure. ¶16 We begin our analysis by noting that a shipowner’s duty to pay maintenance and cure is “virtually automatic.” Baucom v. Sisco Stevedoring, LLC, 506 F. Supp. 2d 1064, 1073 (S.D. 2013We begin our analysis by noting that a shipowner's duty to pay maintenance and cure is "virtually automatic." Baucom v. Sisco Stevedoring, LLC, 506 F. Supp. 2d 1064, 1073 (S.D.	2	2
Mueller v. Wellsgreen wash · 2016 · cited in 5 Washington opinions naming this issue, 2019–2026 2 sentences 2026Dean v. Jordan, 194 Wash. 661, 672 , 79 P.2d 331 (1938); see also Mueller v. Wells, 185 Wn.2d 1, 10-11 , 367 P.3d 580 (2016) (holding that trial court’s findings “established an unrebutted presumption of undue influence based on the Dean factors, supported by “further positive evidence,” which together were sufficient to establish undue influence by clear, cogent, and convincing evidence). 2026Dean v. Jordan, 194 Wash. 661, 672 , 79 P.2d 331 (1938); see also Mueller v. Wells, 185 Wn.2d 1, 10-11 , 367 P.3d 580 (2016) (holding that trial court’s findings “established an unrebutted presumption of undue influence based on the Dean factors, supported by “further positive evidence,” which together were sufficient to establish undue influence by clear, cogent, and convincing evidence).	1	5

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 (10)

Case	Cited	Years
Kitsap Bank v. Denley green washctapp · 2013 2 sentences 2022Kitsap Bank, 177 Wn. 2019App. at 295-97 . 25 In re Estate of Barnes, 185 Wn.2d 1, 10 , 367 P.3d 580 (2016)(internal quotation marks omitted)(quoting In re Estate of Lint, 135 Wn.2d 518, 535 , 957 P.2d 755 (1998)). 26 Kitsap Bank v. Denlev, 177 Wn.	2	2019–2022
Rhinehart v. Seattle Times, Inc. green washctapp · 1990 2 sentences 2026“A contention not supported by authority or argument need not be considered on appeal.” Rhinehart v. Seattle Times, 59 Wn. 2026“A contention not supported by authority or argument need not be considered on appeal.” Rhinehart v. Seattle Times, 59 Wn.	1	2026–2026
In Re Estate of Ehlers green washctapp · 1996 2 sentences 2026Overall, no reasonable fact finder could determine that the age and health of the testators and the opportunity for exerting undue influence outweigh the other Dean factors as outlined above. 16 No. 87652-0-I/17 Ehlers, 80 Wn. 2026Overall, no reasonable fact finder could determine that the age and health of the testators and the opportunity for exerting undue influence outweigh the other Dean factors as outlined above. 16 No. 87652-0-I/17 Ehlers, 80 Wn.	1	2026–2026
Melter v. Melter green washctapp · 2012 1 sentence 2019A testamentary gift is invalid if a party shows by clear, cogent, and convincing evidence that the beneficiary exercised undue influence to obtain it.24 "Undue influence' that is sufficient to void a will must be 'something more than mere influence but, rather, influence which, at the time of the testamentary act, controlled the volition of the testator, interfered with his free will, and prevented an exercise of his judgment and choice.'"25 "[It] involves unfair persuasion that seriously impairs the free and competent exercise of judgment.'"26 In Dean v. Jordan,27 our Supreme Court held that	1	2019–2019
Murphy v. Lint green wash · 1998 1 sentence 2019App. at 295-97 . 25 In re Estate of Barnes, 185 Wn.2d 1, 10 , 367 P.3d 580 (2016)(internal quotation marks omitted)(quoting In re Estate of Lint, 135 Wn.2d 518, 535 , 957 P.2d 755 (1998)). 26 Kitsap Bank v. Denlev, 177 Wn.	1	2019–2019
Matter of Estate of Lint green wash · 1998 1 sentence 2019App. at 295-97 . 25 In re Estate of Barnes, 185 Wn.2d 1, 10 , 367 P.3d 580 (2016)(internal quotation marks omitted)(quoting In re Estate of Lint, 135 Wn.2d 518, 535 , 957 P.2d 755 (1998)). 26 Kitsap Bank v. Denlev, 177 Wn.	1	2019–2019
Vella v. Ford Motor Co. green scotus · 1975 2 sentences 2013Background Under general maritime law, a shipowner has a duty to provide maintenance and cure to a seaman who "becomes ill or is injured while in the service of the ship." Vella v. Ford Motor Co., 421 U.S. 1, 3 , 95 S. Ct. 1381 , 43 L. 2013Background Under general maritime law, a shipowner has a duty to provide maintenance and cure to a seaman who "becomes ill or is injured while in the service of the ship." Vella v. Ford Motor Co., 421 U.S. 1, 3 , 95 S. Ct. 1381 , 43 L.	1	2013–2013
Sunnyside Valley Irr. Dist. v. Dickie green wash · 2003 2 sentences 2011Dwyer, C.J., and Becker, J., concur. 1 To avoid confusion, Mary Haviland will be referred to by her first name. 2 194 Wash. 661 , 79 P.2d 331 (1938). 3 They also established a number of charitable trusts that paid income during their lifetimes. 4 See Sunnyside Valley Irrigation Dist. v. Dickie, 149 Wn.2d 873, 880 , 73 P.3d 369 (2003) (questions of law and conclusions of law reviewed de novo). 5 In re Estate of Eubank, 50 Wn. 2011Dwyer, C.J., and Becker, J., concur. 1 To avoid confusion, Mary Haviland will be referred to by her first name. 2 194 Wash. 661 , 79 P.2d 331 (1938). 3 They also established a number of charitable trusts that paid income during their lifetimes. 4 See Sunnyside Valley Irrigation Dist. v. Dickie, 149 Wn.2d 873, 880 , 73 P.3d 369 (2003) (questions of law and conclusions of law reviewed de novo). 5 In re Estate of Eubank, 50 Wn.	1	2011–2011
Sunnyside Valley Irrigation District v. Dickie green wash · 2003 2 sentences 2011Dwyer, C.J., and Becker, J., concur. 1 To avoid confusion, Mary Haviland will be referred to by her first name. 2 194 Wash. 661 , 79 P.2d 331 (1938). 3 They also established a number of charitable trusts that paid income during their lifetimes. 4 See Sunnyside Valley Irrigation Dist. v. Dickie, 149 Wn.2d 873, 880 , 73 P.3d 369 (2003) (questions of law and conclusions of law reviewed de novo). 5 In re Estate of Eubank, 50 Wn. 2011Dwyer, C.J., and Becker, J., concur. 1 To avoid confusion, Mary Haviland will be referred to by her first name. 2 194 Wash. 661 , 79 P.2d 331 (1938). 3 They also established a number of charitable trusts that paid income during their lifetimes. 4 See Sunnyside Valley Irrigation Dist. v. Dickie, 149 Wn.2d 873, 880 , 73 P.3d 369 (2003) (questions of law and conclusions of law reviewed de novo). 5 In re Estate of Eubank, 50 Wn.	1	2011–2011
Lighter v. Marvin green washctapp · 1988 2 sentences 2011Dwyer, C.J., and Becker, J., concur. 1 To avoid confusion, Mary Haviland will be referred to by her first name. 2 194 Wash. 661 , 79 P.2d 331 (1938). 3 They also established a number of charitable trusts that paid income during their lifetimes. 4 See Sunnyside Valley Irrigation Dist. v. Dickie, 149 Wn.2d 873, 880 , 73 P.3d 369 (2003) (questions of law and conclusions of law reviewed de novo). 5 In re Estate of Eubank, 50 Wn. 2011Dwyer, C.J., and Becker, J., concur. 1 To avoid confusion, Mary Haviland will be referred to by her first name. 2 194 Wash. 661 , 79 P.2d 331 (1938). 3 They also established a number of charitable trusts that paid income during their lifetimes. 4 See Sunnyside Valley Irrigation Dist. v. Dickie, 149 Wn.2d 873, 880 , 73 P.3d 369 (2003) (questions of law and conclusions of law reviewed de novo). 5 In re Estate of Eubank, 50 Wn.	1	2011–2011

Statutes the citing opinions construe

WA § Wash. Rev. Code § 11.96A.150 (8) WA § Wash. Rev. Code § 11.24.030 (4) WA § Wash. Rev. Code § 11.24.050 (4)

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

MI 15 (2017–2026) WA 11 (2011–2026) TX 5 (2009–2022) UT 5 (1991–2017) WY 4 (1998–2004) CA 4 (2000–2024) CO 3 (2016–2016) IA 3 (2014–2023) GA 3 (1989–2012) OH 3 (2013–2018) SC 3 (2015–2020) TN 2 (2018–2018) MS 2 (1997–2000) MO 2 (1972–1998) NY 2 (1977–2007) MD 2 (1980–2015) IN 2 (2015–2017)

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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