five Bone-Club factors (Washington) · Go Syfert
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five Bone-Club factors in Washington

11 Washington opinions name it 2 courts 2008–2020 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 (1)

CaseFollowedCited
State v. Smithgreen
wash · 2014 · cited in 1 Washington opinions naming this issue, 2015–2015
2 sentences

2015Smith, 181 Wn.2d at 520 (stating that “[a] closure unaccompanied by a Bone-Club analysis on the record will almost never be considered justified”). ¶36 Our Supreme Court has recognized that in extremely rare circumstances, a closure could be justified without a Bone-Club analysis if an examination of the record shows that the trial court “effectively weighed the defendant’s public trial right against other compelling interests.” Smith, 181 Wn.2d at 520 .

2015Smith, 181 Wn.2d at 520 (stating that “[a] closure unaccompanied by a Bone-Club analysis on the record will almost never be considered justified”). ¶36 Our Supreme Court has recognized that in extremely rare circumstances, a closure could be justified without a Bone-Club analysis if an examination of the record shows that the trial court “effectively weighed the defendant’s public trial right against other compelling interests.” Smith, 181 Wn.2d at 520 .

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 (5)

CaseCitedYears
State v. Bone-Club green
wash · 1995
2 sentences

2020Discussion Chihuly first argues that the trial court’s reference to the Bone-Club5 factors shows that it focused on the use of Chihuly’s confidential information at 5 State v. Bone-Club, 128 Wn.2d 254, 258-59 , 906 P.2d 325 (1995) (courts apply and weigh the five Bone-Club factors, which are identical to the Ishikawa factors, when determining whether to close a courtroom). 4 No. 79235-1-I/5 trial, rather than on the relevance of such information to the summary judgment motion.

2020Discussion Chihuly first argues that the trial court’s reference to the Bone-Club5 factors shows that it focused on the use of Chihuly’s confidential information at 5 State v. Bone-Club, 128 Wn.2d 254, 258-59 , 906 P.2d 325 (1995) (courts apply and weigh the five Bone-Club factors, which are identical to the Ishikawa factors, when determining whether to close a courtroom). 4 No. 79235-1-I/5 trial, rather than on the relevance of such information to the summary judgment motion.

32008–2020
State v. Wise green
wash · 2012
2 sentences

2016Wise, 176 Wn.2d at 10 .

2016Wise, 176 Wn.2d at 10 .

22016–2016
State v. Sublett green
wash · 2012
2 sentences

2014Sublett, 176 Wn.2d at 73 . "5.

2014Sublett, 176 Wn.2d at 73 .

22014–2014
State v. Brightman green
wash · 2005
2 sentences

2011State v. Brightman, 155 Wn.2d 506, 514-15 , 122 P.3d 150 (2005); Bone-Club, 128 Wn.2d at 258-60.

2011State v. Brightman, 155 Wn.2d 506, 514-15 , 122 P.3d 150 (2005); Bone-Club, 128 Wn.2d at 258-60.

22011–2011
United States v. Perry, Antoine green
cadc · 2007
2 sentences

2010Our analysis assumes a closure occurred, but we find that the trial court’s actions here did not implicate Lormor’s public trial right. ¶11 Instructive is United States v. Perry, 375 U.S. App. D.C. 238 , 479 F.3d 885 (2007).

2010Our analysis assumes a closure occurred, but we find that the trial court’s actions here did not implicate Lormor’s public trial right. ¶11 Instructive is United States v. Perry, 375 U.S. App. D.C. 238 , 479 F.3d 885 (2007).

22010–2010

Statutes the citing opinions construe

WA § Wash. Rev. Code § 2.06.040 (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.

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