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12 Washington opinions name it 1 courts 2016–2026 11 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.
| Case | Followed | Cited |
|---|---|---|
Erlinger v. United Statesgreen2 sentences2026The Court issued a narrow holding, stating, “While recognizing [the defendant] was entitled to have a jury resolve ACCA’s occasions inquiry unanimously and beyond a reasonable doubt, we decide no more than that.” Id. 2026State v. Frieday, 33 Wn. App. 2d 719 , 747, 565 P.3d 139 , review denied, 5 Wn.3d 1006 (2025), cert. denied, --- U.S. ---, 146 S. Ct. 1609 (2026) (“Erlinger should be limited to the ACCA and . . . did ‘no more’ than impose a requirement that a jury resolve the ACCA’s occasions inquiry.”) (quoting Erlinger, 602 U.S. at 835 ). | 3 | 9 |
State v. Lynngreen2 sentences2016App. 339, 345 , 835 P.2d 251 (1992) ("Essential to this determination is a plausible showing by the defendant that the asserted error had practical and identifiable consequences in the trial of the case."). 2016On the few occasions when defense counsel asked a witness or the court to speak more directly into the microphone, the absence of further complaints from Warner indicates that the problem was 2 State v. McFarland. 127 Wn.2d 322, 333 , 899 P.2d 1251 (1995) ("The defendant must identify a constitutional error and show how, in the context of the trial, the alleged error actually affected the defendant's rights; it is this showing of actual prejudice that makes the error 'manifest', allowing appellate review."); State v. Lynn. 67 Wn. | 1 | 1 |
State v. McFarlandgreen2 sentences2016On the few occasions when defense counsel asked a witness or the court to speak more directly into the microphone, the absence of further complaints from Warner indicates that the problem was 2 State v. McFarland. 127 Wn.2d 322, 333 , 899 P.2d 1251 (1995) ("The defendant must identify a constitutional error and show how, in the context of the trial, the alleged error actually affected the defendant's rights; it is this showing of actual prejudice that makes the error 'manifest', allowing appellate review."); State v. Lynn. 67 Wn. 2016On the few occasions when defense counsel asked a witness or the court to speak more directly into the microphone, the absence of further complaints from Warner indicates that the problem was 2 State v. McFarland. 127 Wn.2d 322, 333 , 899 P.2d 1251 (1995) ("The defendant must identify a constitutional error and show how, in the context of the trial, the alleged error actually affected the defendant's rights; it is this showing of actual prejudice that makes the error 'manifest', allowing appellate review."); State v. Lynn. 67 Wn. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Almendarez-Torres v. United States
red
2 sentences2025Indeed, the Court expressed its desire to limit the breadth of the fact of conviction exception, even isolating its opinion in Almendarez-Torres v. United States, 523 U.S. 224 , 118 S. Ct. 1219 , 140 L. 2025Indeed, the Court expressed its desire to limit the breadth of the fact of conviction exception, even isolating its opinion in Almendarez-Torres v. United States, 523 U.S. 224 , 118 S. Ct. 1219 , 140 L. | 4 | 2024–2025 |
State Of Washington, V. Nicholas Windsor Anderson
green
2 sentences2025State v. Anderson, 31 Wn. App. 2d 668 , 681, 552 P.3d 803 (explaining that Erlinger’s holding did not overrule our Supreme Court’s precedent that the fact of a prior conviction can be determined by a judge even when used to increase a criminal sentence), review denied, 3 Wn.3d 1034 (2024). 2025In addition, Erlinger limited its holding: “[w]hile recognizing Mr. Erlinger was entitled to have a jury resolve ACCA’s occasions inquiry unanimously and beyond a reasonable doubt, we decide no more than that.” Id. at 835. 14 In addition, our Supreme Court has clarified the reach of Erlinger in Washington, noting Erlinger’s holding “is limited to resolving ACCA’s occasions inquiry and does not overrule our state’s well-established precedent in Wheeler.” State v. Anderson, 31 Wn. App. 2d 668 , 681, 552 P.3d 803 (2024). | 3 | 2025–2025 |
State Of Washington, V. Jeremy Ian Frieday
green
2 sentences2026State v. Frieday, 33 Wn. App. 2d 719 , 747, 565 P.3d 139 , review denied, 5 Wn.3d 1006 (2025), cert. denied, --- U.S. ---, 146 S. Ct. 1609 (2026) (“Erlinger should be limited to the ACCA and . . . did ‘no more’ than impose a requirement that a jury resolve the ACCA’s occasions inquiry.”) (quoting Erlinger, 602 U.S. at 835 ). 2025This caveat is the reason we held in State v. Anderson, 31 Wn. App. 2d 668 , 681, 552 P.3d 803 (2024), that “Erlinger’s holding is limited to resolving ACCA’s occasions inquiry and does not overrule our state’s well-established precedent in [State v.] Wheeler, 145 Wn.2d 116 , 34 P.3d 799 [(2001)].” We reaffirmed this holding in State v. Frieday, 33 Wn. App. 2d 719 , 747, 565 P.3d 139 (2025). | 2 | 2025–2026 |
State v. Wheeler
green
2 sentences2025This caveat is the reason we held in State v. Anderson, 31 Wn. App. 2d 668 , 681, 552 P.3d 803 (2024), that “Erlinger’s holding is limited to resolving ACCA’s occasions inquiry and does not overrule our state’s well-established precedent in [State v.] Wheeler, 145 Wn.2d 116 , 34 P.3d 799 [(2001)].” We reaffirmed this holding in State v. Frieday, 33 Wn. App. 2d 719 , 747, 565 P.3d 139 (2025). 2025This caveat is the reason we held in State v. Anderson, 31 Wn. App. 2d 668 , 681, 552 P.3d 803 (2024), that “Erlinger’s holding is limited to resolving ACCA’s occasions inquiry and does not overrule our state’s well-established precedent in [State v.] Wheeler, 145 Wn.2d 116 , 34 P.3d 799 [(2001)].” We reaffirmed this holding in State v. Frieday, 33 Wn. App. 2d 719 , 747, 565 P.3d 139 (2025). | 1 | 2025–2025 |
Mathis v. United States
green
2 sentences2025The Court clarified that while it was not revisiting its holding in Almendarez-Torres v. United States, 523 U.S. 224 , 118 S. Ct. 1219 , 140 L. Ed. 2d 350 (1998) (permitting a judge to find the fact of a prior conviction), “a judge may ‘do no more, consistent with the Sixth Amendment, than determine what crime, with what elements, the defendant was convicted of.’ ” Erlinger, 602 U.S. at 838 (quoting Mathis v. United States, 579 U.S. 500, 511-12 , 136 S. Ct. 2243 , 195 L. Ed. 2d 604 (2016)). 2025The Court clarified that while it was not revisiting its holding in Almendarez-Torres v. United States, 523 U.S. 224 , 118 S. Ct. 1219 , 140 L. Ed. 2d 350 (1998) (permitting a judge to find the fact of a prior conviction), “a judge may ‘do no more, consistent with the Sixth Amendment, than determine what crime, with what elements, the defendant was convicted of.’ ” Erlinger, 602 U.S. at 838 (quoting Mathis v. United States, 579 U.S. 500, 511-12 , 136 S. Ct. 2243 , 195 L. Ed. 2d 604 (2016)). | 1 | 2025–2025 |
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.
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.