reporting requirement (Washington) · Go Syfert
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reporting requirement in Washington

11 Washington opinions name it 2 courts 1983–2022 1 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 (2)

CaseFollowedCited
Ratzlaf v. United Statesgreen
scotus · 1994 · cited in 2 Washington opinions naming this issue, 2009–2009
2 sentences

2009In that case, the United States Supreme Court held that "willful" in the context of § 5322 means acting with the knowledge that one's conduct is unlawful, and it approvingly cited appellate court cases defining "willfully" has having both "knowledge of the reporting requirement" and a "specific intent to commit the crime." Ratzlaf, 510 U.S. at 137, 141 , 114 S.Ct. 655 .

2009In that case, the United States Supreme Court held that “willful” in the context of § 5322 means acting with the knowledge that one’s conduct is unlawful, and it approvingly cited appellate court cases defining “willfully” as having both “ ‘knowledge of the reporting requirement’ ” and a “ ‘specific intent to commit the crime.’ ” Ratzlaf, 510 U.S. at 137, 141 .

22
United States v. Bajakajiangreen
scotus · 1998 · cited in 1 Washington opinions naming this issue, 2022–2022
1 sentence

2022The Court ruled that the “amount of the forfeiture must bear some relationship to the gravity of the offense that it is designed to punish.” Bajakajian, 524 U.S. at 334 (emphasis added).

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 (10)

CaseCitedYears
In re the Disciplinary Proceeding Against Perez-Pena green
wash · 2007
2 sentences

2009Based on our analysis above, the Board properly struck this mitigating factor because it conflicted with the hearing officer's finding that Vanderveen acted "intentionally" based on Ratzlaf . [22] FF 30. ¶ 37 Third, Vanderveen now seeks the mitigator of "other penalties and sanctions." He argues that the three months he served in prison, his time on house arrest, as well as his other sanctions [23] and the adverse publicity he suffered as a result of some unproven conspiracy charges against him constitute the mitigating factor of "other penalties and sanctions." Resp't's Br. at 23. ¶ 38 In pre

2009Based on our analysis above, the Board properly struck this mitigating factor because it conflicted with the hearing officer’s finding that Vanderveen acted “intentionally” based on Ratzlaf . 22 FF 30. ¶37 Third, Vanderveen now seeks the mitigator of “other penalties and sanctions.” He argues that the three months he served in prison, his time on house arrest, as well as his other sanctions 23 and the adverse publicity he suffered as a result of some unproven conspiracy charges against him constitute the mitigating factor of “other penalties and sanctions.” Resp’t’s Br. at 23. ¶38 In previous

22009–2009
Matter of Disciplinary Proceeding Against Curran green
wash · 1990
2 sentences

2009Based on our analysis above, the Board properly struck this mitigating factor because it conflicted with the hearing officer’s finding that Vanderveen acted “intentionally” based on Ratzlaf . 22 FF 30. ¶37 Third, Vanderveen now seeks the mitigator of “other penalties and sanctions.” He argues that the three months he served in prison, his time on house arrest, as well as his other sanctions 23 and the adverse publicity he suffered as a result of some unproven conspiracy charges against him constitute the mitigating factor of “other penalties and sanctions.” Resp’t’s Br. at 23. ¶38 In previous

2009Based on our analysis above, the Board properly struck this mitigating factor because it conflicted with the hearing officer’s finding that Vanderveen acted “intentionally” based on Ratzlaf . 22 FF 30. ¶37 Third, Vanderveen now seeks the mitigator of “other penalties and sanctions.” He argues that the three months he served in prison, his time on house arrest, as well as his other sanctions 23 and the adverse publicity he suffered as a result of some unproven conspiracy charges against him constitute the mitigating factor of “other penalties and sanctions.” Resp’t’s Br. at 23. ¶38 In previous

22009–2009
State v. Warner green
wash · 1995
2 sentences

2000Warner, 125 Wash.2d at 891 , 889 P.2d 479 .

2000Warner, 125 Wn.2d at 891 .

22000–2000
State v. Motherwell green
wash · 1990
2 sentences

1999Nevertheless, the reporting requirement continues to apply to those church officials who are engaged in "encouraging or promoting the health, welfare, support or education of children, or providing social services to adults or families, whether in an individual capacity, or as an employee or agent of any public or private organization or institution." State v. Motherwell, 114 Wash.2d 353, 357 , 788 P.2d 1066 (1990) (citing former RCW 26.44.020(8)).

1999Nevertheless, the reporting requirement continues to apply to those church officials who are engaged in "encouraging or promoting the health, welfare, support or education of children, or providing social services to adults or families, whether in an individual capacity, or as an employee or agent of any public or private organization or institution." State v. Motherwell, 114 Wash.2d 353, 357 , 788 P.2d 1066 (1990) (citing former RCW 26.44.020(8)).

21999–1999
State v. Durrett green
washctapp · 2009
1 sentence

2018In Durrett, the defendant failed multiple times to report weekly in violation of RCW 9A.44.130(6)(b). 150 Wn.

12018–2018
State ex rel. Public Disclosure Commission v. Permanent Offense green
washctapp · 2006
1 sentence

2017Permanent Offense, 136 Wn.

12017–2017
State v. Radan green
wash · 2001
1 sentence

2011This makes no sense; if a trial judge lacks authority to restore gun rights to a sex offender, surely a trial court’s decision to terminate a reporting requirement cannot become an “equivalent” procedure that would permit the trial court to do what the legislature has specifically prohibited in the same statute. ¶16 The majority says, though, that its decision is supported by our decision in State v. Radan, 143 Wn.2d 323 , 21 P.3d 255 (2001).

12011–2011
State v. Radan green
wash · 2001
1 sentence

2011This makes no sense; if a trial judge lacks authority to restore gun rights to a sex offender, surely a trial court’s decision to terminate a reporting requirement cannot become an “equivalent” procedure that would permit the trial court to do what the legislature has specifically prohibited in the same statute. ¶16 The majority says, though, that its decision is supported by our decision in State v. Radan, 143 Wn.2d 323 , 21 P.3d 255 (2001).

12011–2011
Matter of Disciplinary Proceeding Against Perez-Pena green
wash · 2007
1 sentence

2009Based on our analysis above, the Board properly struck this mitigating factor because it conflicted with the hearing officer's finding that Vanderveen acted "intentionally" based on Ratzlaf . [22] FF 30. ¶ 37 Third, Vanderveen now seeks the mitigator of "other penalties and sanctions." He argues that the three months he served in prison, his time on house arrest, as well as his other sanctions [23] and the adverse publicity he suffered as a result of some unproven conspiracy charges against him constitute the mitigating factor of "other penalties and sanctions." Resp't's Br. at 23. ¶ 38 In pre

12009–2009
Scannell v. City of Seattle green
wash · 1983
2 sentences

1983Scannell v. Seattle, 97 Wn.2d 701 , 648 P.2d 435 (1982).

1983Scannell v. Seattle, 97 Wn.2d 701 , 648 P.2d 435 (1982).

11983–1983

Statutes the citing opinions construe

WA § Wash. Rev. Code § 26.44.030 (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

CA 48 (1974–2026) PA 45 (1962–2026) NJ 30 (1961–2025) TX 26 (1977–2016) OH 25 (1997–2026) FL 20 (1990–2024) KS 19 (1989–2024) NY 16 (1978–2026) OR 16 (2007–2026) MI 13 (1990–2023) IL 13 (1978–2026) WA 11 (1983–2022) MO 11 (1976–2024) IN 11 (1996–2023) MA 10 (1981–2023) NM 8 (2013–2016) MD 8 (1993–2013) GA 6 (1982–2007) LA 6 (2006–2020) IA 6 (1993–2020) AZ 5 (1983–2017) KY 5 (2009–2017) VA 5 (2007–2025) DE 5 (2014–2025) TN 4 (2010–2015) NC 4 (2001–2020) NH 4 (1984–2013) WI 4 (1987–2015) AK 4 (1979–1998) CO 3 (2001–2016) ME 3 (2006–2011) SD 3 (1969–1993) MN 3 (1995–2010) CT 3 (2004–2022) NE 2 (1994–1996) AL 2 (1985–2000) ND 2 (2001–2006) MS 2 (2006–2013) DC 2 (1995–2005) WY 2 (2015–2018) RI 2 (1994–2002) NV 2 (2012–2021)

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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