exhaustion of administrative remedies doctrine (Washington) · Go Syfert
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exhaustion of administrative remedies doctrine in Washington

11 Washington opinions name it 2 courts 1969–2016 0 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)

CaseFollowedCited
Retail Store Employees Union, Local 1001 v. Washington Surveying & Rating Bureaugreen
wash · 1976 · cited in 1 Washington opinions naming this issue, 1987–1987
2 sentences

1987Multiple Listing Serv., 95 Wn.2d 280, 284 , 622 P.2d 1190 (1980) (quoting from Retail Store Employees, Local 1001 v. Washington Surveying & Rating Bur., 87 Wn.2d 887, 906-07, 909 , 558 P.2d 215 (1976)); accord, South Hollywood Hills Citizens Ass'n v. King Cy., supra. The doctrine of exhaustion of administrative remedies is "founded upon the belief that the judiciary should give proper deference to that body possessing expertise in areas outside the conventional experience of judges." South Hollywood Hills Citizens Ass'n v. King Cy., supra at 73.

1987Multiple Listing Serv., 95 Wn.2d 280, 284 , 622 P.2d 1190 (1980) (quoting from Retail Store Employees, Local 1001 v. Washington Surveying & Rating Bur., 87 Wn.2d 887, 906-07, 909 , 558 P.2d 215 (1976)); accord, South Hollywood Hills Citizens Ass'n v. King Cy., supra. The doctrine of exhaustion of administrative remedies is "founded upon the belief that the judiciary should give proper deference to that body possessing expertise in areas outside the conventional experience of judges." South Hollywood Hills Citizens Ass'n v. King Cy., supra at 73.

11
Fallon v. City of Leavenworthgreen
washctapp · 1985 · cited in 1 Washington opinions naming this issue, 1986–1986
1 sentence

1986South Hollywood Hills Citizens Ass'n v. King Cy., 101 Wn.2d 68, 73 , 677 P.2d 114 (1984); Fallon v. Leavenworth, 42 Wn.

11
Koepke v. Fontecchiogreen
ca9 · 1949 · cited in 1 Washington opinions naming this issue, 1969–1969
2 sentences

1969See Koepke v. Fontecchio, 177 F.2d 125 (9th Cir. 1949).

1969See Koepke v. Fontecchio, 177 F.2d 125 (9th Cir.1949).

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 (12)

CaseCitedYears
South Hollywood Hills Citizens Ass'n v. King County green
wash · 1984
2 sentences

1999Workers Health & Welfare Trust Fund v. Merit Co., 123 Wn.2d 565, 572-73 , 870 P.2d 960 (1994). 19 See South Hollywood Hills Citizens Ass’n for Preservation of Neighborhood Safety & Env’t v. King County, 101 Wn.2d 68, 74 , 677 P.2d 114 (1984) (recognizing exceptions to the exhaustion of administrative remedies requirement where resort to the administrative process would be futile). 20 Southeastern Wash. Bldg. & Constr., 91 Wn.2d at 47 . 21 RCW 39.12.060. 22 RCW 39.12.065(1).

1999Workers Health & Welfare Trust Fund v. Merit Co., 123 Wn.2d 565, 572-73 , 870 P.2d 960 (1994). 19 See South Hollywood Hills Citizens Ass’n for Preservation of Neighborhood Safety & Env’t v. King County, 101 Wn.2d 68, 74 , 677 P.2d 114 (1984) (recognizing exceptions to the exhaustion of administrative remedies requirement where resort to the administrative process would be futile). 20 Southeastern Wash. Bldg. & Constr., 91 Wn.2d at 47 . 21 RCW 39.12.060. 22 RCW 39.12.065(1).

31986–1999
Smith v. Bates Technical College green
wash · 2000
2 sentences

2003The doctrine of exhaustion of administrative remedies applies when: “(1) a claim is cognizable in the first instance by an agency alone; (2) the agency has clearly established mechanisms for the resolution of complaints by aggrieved parties; and (3) the administrative remedies can provide the relief sought.” Smith, 139 Wn.2d at 808 .

2003The doctrine of exhaustion of administrative remedies applies when: "(1) a claim is cognizable in the first instance by an agency alone; (2) the agency has clearly established mechanisms for the resolution of complaints by aggrieved parties; and (3) the administrative remedies can provide the relief *701 sought." Smith, 139 Wash.2d at 808 , 991 P.2d 1135 .

22003–2003
Chaney v. Fetterly green
washctapp · 2000
2 sentences

2001App. 140, 147 , 995 P.2d 1284 (quoting Spokane County Fire Prot.

2001The doctrine of exhaustion of administrative remedies provides that "`[i]n general an agency action cannot be challenged on review until all rights of administrative appeal have been exhausted.'" Chaney v. Fetterly, 100 Wash.App. 140, 147 , 995 P.2d 1284 (quoting Spokane County Fire Protec.

22001–2001
Chaney v. Fetterly green
washctapp · 2000
2 sentences

2001The doctrine of exhaustion of administrative remedies provides that “ ‘[i]n general an agency action cannot be challenged on review until all rights of administrative appeal have been exhausted.’ ” Chaney v. Fetterly, 100 Wn.

2001The doctrine of exhaustion of administrative remedies provides that "`[i]n general an agency action cannot be challenged on review until all rights of administrative appeal have been exhausted.'" Chaney v. Fetterly, 100 Wash.App. 140, 147 , 995 P.2d 1284 (quoting Spokane County Fire Protec.

22001–2001
Jones v. State green
wash · 2010
1 sentence

2016Jones v. State, 170 Wn.2d 338, 356 , 242 P.3d 825 (2010).

12016–2016
Jones v. State, Dept. of Health green
wash · 2010
1 sentence

2016Jones v. State, 170 Wn.2d 338, 356 , 242 P.3d 825 (2010).

12016–2016
Smith v. Bates Technical College green
wash · 2000
1 sentence

2003The doctrine of exhaustion of administrative remedies applies when: "(1) a claim is cognizable in the first instance by an agency alone; (2) the agency has clearly established mechanisms for the resolution of complaints by aggrieved parties; and (3) the administrative remedies can provide the relief *701 sought." Smith, 139 Wash.2d at 808 , 991 P.2d 1135 .

12003–2003
Puget Sound Electrical Workers Health & Welfare Trust Fund v. Merit Co. green
wash · 1994
2 sentences

1999Workers Health & Welfare Trust Fund v. Merit Co., 123 Wn.2d 565, 572-73 , 870 P.2d 960 (1994). 19 See South Hollywood Hills Citizens Ass’n for Preservation of Neighborhood Safety & Env’t v. King County, 101 Wn.2d 68, 74 , 677 P.2d 114 (1984) (recognizing exceptions to the exhaustion of administrative remedies requirement where resort to the administrative process would be futile). 20 Southeastern Wash. Bldg. & Constr., 91 Wn.2d at 47 . 21 RCW 39.12.060. 22 RCW 39.12.065(1).

1999Workers Health & Welfare Trust Fund v. Merit Co., 123 Wn.2d 565, 572-73 , 870 P.2d 960 (1994). 19 See South Hollywood Hills Citizens Ass’n for Preservation of Neighborhood Safety & Env’t v. King County, 101 Wn.2d 68, 74 , 677 P.2d 114 (1984) (recognizing exceptions to the exhaustion of administrative remedies requirement where resort to the administrative process would be futile). 20 Southeastern Wash. Bldg. & Constr., 91 Wn.2d at 47 . 21 RCW 39.12.060. 22 RCW 39.12.065(1).

11999–1999
Southeastern Washington Building & Construction Trades Council v. Department of Labor & Industries green
wash · 1978
1 sentence

1999Workers Health & Welfare Trust Fund v. Merit Co., 123 Wn.2d 565, 572-73 , 870 P.2d 960 (1994). 19 See South Hollywood Hills Citizens Ass’n for Preservation of Neighborhood Safety & Env’t v. King County, 101 Wn.2d 68, 74 , 677 P.2d 114 (1984) (recognizing exceptions to the exhaustion of administrative remedies requirement where resort to the administrative process would be futile). 20 Southeastern Wash. Bldg. & Constr., 91 Wn.2d at 47 . 21 RCW 39.12.060. 22 RCW 39.12.065(1).

11999–1999
Orion Corporation v. State green
wash · 1985
2 sentences

1989In Orion Corp. v. State, 103 Wn.2d 441 , 693 P.2d 1369 (1985) (Orion I), the court recognized that the futility exception to the doctrine of exhaustion of administrative remedies may apply not only in cases where administrative remedies are legally inadequate, but also where those remedies are factually inadequate.

1989In Orion Corp. v. State, 103 Wn.2d 441 , 693 P.2d 1369 (1985) (Orion I), the court recognized that the futility exception to the doctrine of exhaustion of administrative remedies may apply not only in cases where administrative remedies are legally inadequate, but also where those remedies are factually inadequate.

11989–1989
State v. Tacoma-Pierce County Multiple Listing Service green
wash · 1980
2 sentences

1987Multiple Listing Serv., 95 Wn.2d 280, 284 , 622 P.2d 1190 (1980) (quoting from Retail Store Employees, Local 1001 v. Washington Surveying & Rating Bur., 87 Wn.2d 887, 906-07, 909 , 558 P.2d 215 (1976)); accord, South Hollywood Hills Citizens Ass'n v. King Cy., supra. The doctrine of exhaustion of administrative remedies is "founded upon the belief that the judiciary should give proper deference to that body possessing expertise in areas outside the conventional experience of judges." South Hollywood Hills Citizens Ass'n v. King Cy., supra at 73.

1987Multiple Listing Serv., 95 Wn.2d 280, 284 , 622 P.2d 1190 (1980) (quoting from Retail Store Employees, Local 1001 v. Washington Surveying & Rating Bur., 87 Wn.2d 887, 906-07, 909 , 558 P.2d 215 (1976)); accord, South Hollywood Hills Citizens Ass'n v. King Cy., supra. The doctrine of exhaustion of administrative remedies is "founded upon the belief that the judiciary should give proper deference to that body possessing expertise in areas outside the conventional experience of judges." South Hollywood Hills Citizens Ass'n v. King Cy., supra at 73.

11987–1987
McKart v. United States green
scotus · 1969
1 sentence

1986South Hollywood Hills Citizens Ass'n v. King Cy., supra at 73-74 (citing McKart v. United States, 395 U.S. 185 , 23 L.

11986–1986

Statutes the citing opinions construe

USC § 42u.s.c.1983 (3) WA § Wash. Rev. Code § 34.05.562 (3) WA § Wash. Rev. Code § 34.05.570 (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 235 (1941–2026) TX 89 (1973–2025) NY 79 (1958–2026) PA 78 (1969–2026) IL 71 (1963–2025) CT 48 (1983–2026) NJ 39 (1952–2025) OH 36 (1990–2025) AZ 29 (1957–2025) MD 26 (1982–2020) MI 26 (1972–2026) AL 25 (1976–2025) IN 25 (1977–2019) ME 24 (1974–2024) AR 22 (1988–2025) MO 18 (1969–2025) WI 15 (1972–2026) AK 14 (1985–2023) NM 13 (1998–2026) UT 13 (1993–2020) CO 12 (1982–2012) FL 12 (1958–2022) DC 11 (1972–2010) WA 11 (1969–2016) TN 10 (1946–2020) MS 10 (1966–2021) MA 10 (1979–2014) DE 10 (1992–2025) SC 10 (1977–2023) MN 10 (1957–2007) KS 9 (1986–2021) NC 8 (2008–2020) RI 7 (1966–2017) WV 7 (1966–2026) IA 7 (1971–2016) NH 6 (1998–2018) HI 6 (2012–2025) GA 5 (1986–2017) WY 4 (1982–2020) OK 4 (1980–2005) VT 3 (1952–2001) ID 3 (1990–2023) SD 3 (1975–1987) LA 3 (1976–2024) NV 3 (1979–2021) NE 2 (1998–2017) OR 2 (1997–2019) ND 2 (2014–2024) VA 2 (2000–2010) MT 2 (2022–2024)

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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