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

11 Washington opinions name it 2 courts 1973–2025 3 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 (7)

CaseFollowedCited
In Re the Detention Swansongreen
wash · 1990 · cited in 2 Washington opinions naming this issue, 1999–1999
2 sentences

1999See In re Detention of Swanson, 115 Wash.2d 21, 27 , 804 P.2d 1 (1990) (had Legislature intended initial detention period to be measured in days rather than hours, it would have said so).

1999See In re Detention of Swanson, 115 Wn.2d 21, 27 , 804 P.2d 1 (1990) (had Legislature intended initial detention period to be measured in days rather than hours, it would have said so).

22
Vitek v. Jonesgreen
scotus · 1980 · cited in 2 Washington opinions naming this issue, 1999–1999
2 sentences

1999See CPC Fairfax Hospital, 129 Wash.2d at 453 , 918 P.2d 497 (once the State has granted a liberty interest by statute, "`due process protections are necessary "to insure that the state-created right is not arbitrarily abrogated."'") (quoting Vitek, 445 U.S. at 489 , 100 S.Ct. 1254 ).

1999See CPC Fairfax Hosp., 129 Wn.2d at 453 (once the State has granted a liberty interest by statute, “ ‘due process protections are necessary “to insure that the state-created right is not arbitrarily abrogated.” ’ ”) (quoting Vitek, 445 U.S. at 489 ).

22
State Ex Rel. TB v. CPC Fairfax Hosp.green
wash · 1996 · cited in 2 Washington opinions naming this issue, 1999–1999
2 sentences

1999See CPC Fairfax Hospital, 129 Wash.2d at 453 , 918 P.2d 497 (once the State has granted a liberty interest by statute, "`due process protections are necessary "to insure that the state-created right is not arbitrarily abrogated."'") (quoting Vitek, 445 U.S. at 489 , 100 S.Ct. 1254 ).

1999See CPC Fairfax Hosp., 129 Wn.2d at 453 (once the State has granted a liberty interest by statute, “ ‘due process protections are necessary “to insure that the state-created right is not arbitrarily abrogated.” ’ ”) (quoting Vitek, 445 U.S. at 489 ).

22
Amalgamated Transit Union Local 587 v. Stategreen
wash · 2000 · cited in 2 Washington opinions naming this issue, 2007–2007
2 sentences

2007Id.; cf. Amalgamated Transit, 142 Wash.2d at 244 , 11 P.3d 762 (overturning I-695 in part because it attempted to sidestep the signature requirement for referendums). [4] I-747's challengers also argue that proponents could have drafted I-747 such that it provided an alternative text if I-722 were declared unconstitutional.

2007Id.; cf. Amalgamated Transit, 142 Wn.2d at 244 (overturning 1-695 in part because it attempted to sidestep the signature requirement for referendums).

12
State v. Kullgreen
wash · 2005 · cited in 1 Washington opinions naming this issue, 2025–2025
2 sentences

2025See State v. Kull, 155 Wn.2d 80, 88 , 118 P.3d 307 (2005). 29 Furthermore, even if the trial court applied CrR 3.3(f)(1), a Supreme Court order in effect at the time due to COVID waived a defendant’s signature requirement.

2025See State v. Kull, 155 Wn.2d 80, 88 , 118 P.3d 307 (2005). 29 Furthermore, even if the trial court applied CrR 3.3(f)(1), a Supreme Court order in effect at the time due to COVID waived a defendant’s signature requirement.

11
Kathleen Hanson, V. Jose Luna-ramirezgreen
washctapp · 2021 · cited in 1 Washington opinions naming this issue, 2023–2023
1 sentence

2023See Russell v. Maas, 166 Wn. App. 885, 887-88, 891 , 272 P.3d 273 (2012) (signature requirement satisfied when an attorney signs a trial de novo request on behalf of a client); see also Hanson v. Luna-Ramirez, 19 Wn. App. 2d 459 , 462, 496 P.3d 314 (2021) (noting that cases permitting “only an attorney, rather than the aggrieved party, to sign a request for trial de novo . . . have been superseded by statute”).

11
Russell v. Maasgreen
washctapp · 2012 · cited in 1 Washington opinions naming this issue, 2023–2023
2 sentences

2023See Russell v. Maas, 166 Wn. App. 885, 887-88, 891 , 272 P.3d 273 (2012) (signature requirement satisfied when an attorney signs a trial de novo request on behalf of a client); see also Hanson v. Luna-Ramirez, 19 Wn. App. 2d 459 , 462, 496 P.3d 314 (2021) (noting that cases permitting “only an attorney, rather than the aggrieved party, to sign a request for trial de novo . . . have been superseded by statute”).

2023See Russell v. Maas, 166 Wn. App. 885, 887-88, 891 , 272 P.3d 273 (2012) (signature requirement satisfied when an attorney signs a trial de novo request on behalf of a client); see also Hanson v. Luna-Ramirez, 19 Wn. App. 2d 459 , 462, 496 P.3d 314 (2021) (noting that cases permitting “only an attorney, rather than the aggrieved party, to sign a request for trial de novo . . . have been superseded by statute”).

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 (7)

CaseCitedYears
State v. Foxhoven green
wash · 2007
2 sentences

2012Foxhoven, 161 Wn.2d at 174 . a.

2011Id. at 175 .

22011–2012
Crossroads Mgmt., LLC v. Ridgway green
wash · 2023
1 sentence

2025“This signature requirement essentially abrogates an attorney’s authority as an agent to sign the [trial de novo] request on behalf of the aggrieved party.” Crossroads, 2 Wn.3d at 539 .

12025–2025
Detention of Marshall v. State green
wash · 2005
2 sentences

2012See ER 703; In re Det. of Marshall, 156 Wn.2d 150 , 161-62, 125 P.3d 111 (2005). 14 In Marshall, this court held that Dr. Phenix properly relied on records, which were inadmissible hearsay, to form her opinion that the accused was an SVP. 156 Wn.2d at 162-63 .

2012See ER 703; In re Det. of Marshall, 156 Wn.2d 150 , 161-62, 125 P.3d 111 (2005). 14 In Marshall, this court held that Dr. Phenix properly relied on records, which were inadmissible hearsay, to form her opinion that the accused was an SVP. 156 Wn.2d at 162-63 .

12012–2012
Washington State Grange v. Locke green
wash · 2005
2 sentences

2007Resp'ts' Br. at 27-28 (citing Wash. State Grange v. Locke, 153 Wash.2d 475, 483 , 105 P.3d 9 (2005)).

2007Resp'ts' Br. at 27-28 (citing Wash. State Grange v. Locke, 153 Wash.2d 475, 483 , 105 P.3d 9 (2005)).

12007–2007
Kadoranian v. Bellingham Police Department green
wash · 1992
2 sentences

1999Kadoranian v. Bellingham Police Dep't, 119 Wash.2d 178, 191 , 829 P.2d 1061 (1992) (issue not briefed deemed waived). [1] RCW 71.05.020(15) defines "mental disorder" as "any organic, mental, or emotional impairment which has substantial adverse effects on an individual's cognitive or volitional functions...." [2] Of course, the majority fails to define the parameters of this judicially created exception or to explain why substantial compliance is applicable only if "unique circumstances" are present. [3] Had the Legislature intended to create an exception to the signature requirement, it would

1999Kadoranian v. Bellingham Police Dep't, 119 Wash.2d 178, 191 , 829 P.2d 1061 (1992) (issue not briefed deemed waived). [1] RCW 71.05.020(15) defines "mental disorder" as "any organic, mental, or emotional impairment which has substantial adverse effects on an individual's cognitive or volitional functions...." [2] Of course, the majority fails to define the parameters of this judicially created exception or to explain why substantial compliance is applicable only if "unique circumstances" are present. [3] Had the Legislature intended to create an exception to the signature requirement, it would

11999–1999
Fisher Bros. Corp. v. Des Moines Sewer Dist. green
wash · 1982
2 sentences

1988Corp. v. Des Moines Sewer Dist., 97 Wn.2d 227, 230-31 , 643 P.2d 436 (1982). [2] The purpose of the signature requirement of RCW 35.13.130 is to insure that a significant number of the persons most affected by a decision to annex support that decision.

1988Corp. v. Des Moines Sewer Dist., 97 Wn.2d 227, 230-31 , 643 P.2d 436 (1982). [2] The purpose of the signature requirement of RCW 35.13.130 is to insure that a significant number of the persons most affected by a decision to annex support that decision.

11988–1988
Whitemarsh Township Authority v. Finelli Bros. neutral
pa · 1962
1 sentence

1973Thus, an express signature requirement was treated as a matter of substance in Whitemarsh Township Auth. v. Finelli Bros., Inc., 408 Pa. 373 , 184 A.2d 512 (1962), and in certain other instances was treated merely as a matter of form.

11973–1973

Where else courts name it

IL 40 (1915–2025) PA 36 (1982–2026) CA 28 (1969–2025) TX 27 (1948–2026) MO 22 (1982–2023) CT 13 (1983–2022) TN 13 (2000–2026) NY 13 (1928–2025) WA 11 (1973–2025) MD 11 (1914–2022) NC 11 (1940–2025) IN 10 (1913–2015) OH 10 (1991–2025) AL 9 (1985–2003) AZ 9 (1991–2022) GA 9 (1907–2023) MI 8 (1970–2023) AR 8 (1983–2016) KY 7 (1961–2026) IA 7 (1909–2025) CO 7 (2002–2025) ID 7 (1978–2023) MN 7 (1981–2016) WI 6 (1980–2020) MA 4 (1982–2024) VA 4 (2001–2023) OR 4 (1984–2023) UT 4 (2011–2024) LA 3 (1989–2024) AK 3 (1982–2021) SD 3 (2011–2026) NM 3 (1995–2012) FL 3 (1994–2009) WV 3 (1992–2019) NE 3 (1995–2026) OK 3 (1917–2000) KS 2 (2003–2024) MT 2 (1984–2002) NJ 2 (2003–2020) MS 2 (2017–2018)

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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