approach analysis (Washington) · Go Syfert
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approach analysis in Washington

9 Washington opinions name it 2 courts 1980–2021 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 (8)

CaseFollowedCited
State v. Broadawaygreen
wash · 1997 · cited in 2 Washington opinions naming this issue, 2008–2008
2 sentences

2008See State v. Broadaway, 133 Wash.2d 118, 132 , 942 P.2d 363 (1997) (establishing the "totality of the circumstances" and stating, "[t]he court must determine whether there is a causal relationship between the promise and the confession").

2008See State v. Broadaway, 133 Wn.2d 118, 132 , 942 P.2d 263 (1997) (establishing the “totality of the circumstances” and stating, “[t]he court must determine whether there is a causal relationship between the promise and the confession”).

22
Bond v. Independent Order of Forestersgreen
wash · 1966 · cited in 1 Washington opinions naming this issue, 2020–2020
1 sentence

2020See Bond, 69 Wn.2d at 880 (holding that the mere filing of a lawsuit for personal injuries does not waive the physician-patient privilege).

11
Deborah L. Schoffstall v. William Henderson, Agent U.S. Postal Servicegreen
ca8 · 2000 · cited in 1 Washington opinions naming this issue, 2020–2020
1 sentence

2020For example, in Schoffstall, a case often cited as an example of the broad approach, the court reasoned “that, similar to attorney-client privilege that can be waived when the client places the attorney’s representation at issue, a plaintiff waives the psychotherapist-patient privilege by placing his or her medical condition at issue.” 223 F.3d at 823 (relying on several federal district court opinions).

11
Progressive Animal Welfare Society v. University of Washingtongreen
wash · 1994 · cited in 1 Washington opinions naming this issue, 2013–2013
1 sentence

2013See PAWS, 125 Wn.2d at 251 .

11
Prall v. Great Northern Railway Co.green
wash · 1919 · cited in 1 Washington opinions naming this issue, 2013–2013
2 sentences

2013See 5 Tegland, §301.14, for a collection of these cases. 5 Tegland, § 301.15, at 244. 5 Tegland, § 301.14, at 238. 121 Wash. 24 , 207 P. 1062 (1922). 5 Tegland, § 301.17, at 249. 5 Tegland, § 301.17, at 250 (citing Prall v. Great N. Ry., 105 Wash. 24 , 177 P. 637 (1919)).

2013See 5 Tegland, §301.14, for a collection of these cases. 5 Tegland, § 301.15, at 244. 5 Tegland, § 301.14, at 238. 121 Wash. 24 , 207 P. 1062 (1922). 5 Tegland, § 301.17, at 249. 5 Tegland, § 301.17, at 250 (citing Prall v. Great N. Ry., 105 Wash. 24 , 177 P. 637 (1919)).

11
Parker v. Parkergreen
wash · 1922 · cited in 1 Washington opinions naming this issue, 2013–2013
2 sentences

2013See 5 Tegland, §301.14, for a collection of these cases. 5 Tegland, § 301.15, at 244. 5 Tegland, § 301.14, at 238. 121 Wash. 24 , 207 P. 1062 (1922). 5 Tegland, § 301.17, at 249. 5 Tegland, § 301.17, at 250 (citing Prall v. Great N. Ry., 105 Wash. 24 , 177 P. 637 (1919)).

2013See 5 Tegland, §301.14, for a collection of these cases. 5 Tegland, § 301.15, at 244. 5 Tegland, § 301.14, at 238. 121 Wash. 24 , 207 P. 1062 (1922). 5 Tegland, § 301.17, at 249. 5 Tegland, § 301.17, at 250 (citing Prall v. Great N. Ry., 105 Wash. 24 , 177 P. 637 (1919)).

11
State v. Broadawaygreen
wash · 1997 · cited in 1 Washington opinions naming this issue, 2008–2008
1 sentence

2008See State v. Broadaway, 133 Wash.2d 118, 132 , 942 P.2d 363 (1997) (establishing the "totality of the circumstances" and stating, "[t]he court must determine whether there is a causal relationship between the promise and the confession").

11
In Re the Marriage of Johnsongreen
wash · 1981 · cited in 1 Washington opinions naming this issue, 1984–1984
2 sentences

1984See In re Marriage of Johnson, 96 Wn.2d 255, 264 , 634 P.2d 877 (1981).

1984See In re Marriage of Johnson, 96 Wn.2d 255, 264 , 634 P.2d 877 (1981).

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
People v. Andersen green
calctapp · 1980
2 sentences

2008People v. Andersen, 101 Cal. App. 3d 563, 575 , 161 Cal. Rptr. 707 (1980). ¶51 Nor is this a new approach to analysis of a suspect’s confession.

2008People v. Andersen, 101 Cal. App. 3d 563, 575 , 161 Cal. Rptr. 707 (1980). ¶51 Nor is this a new approach to analysis of a suspect’s confession.

22008–2008
Grimsby v. Samson green
wash · 1975
2 sentences

2021In its effort to “modernize” the court’s approach to this claim, the majority looks to Grimsby v. Samson, 85 Wn.2d 52 , 530 P.2d 291 (1975), to hold the tort of outrage is analogous to tortious interference.

2021In its effort to “modernize” the court’s approach to this claim, the majority looks to Grimsby v. Samson, 85 Wn.2d 52 , 530 P.2d 291 (1975), to hold the tort of outrage is analogous to tortious interference.

12021–2021
Vanderbilt v. Town of Chilmark green
mad · 1997
1 sentence

2020“By analogy, a patient would waive the psychotherapist-patient privilege when he sues the therapist for malpractice, or relies upon the therapist’s diagnoses or treatment in making or defending a case.” Id. (citing Vanderbilt, 174 F.R.D. at 229 ).6 To be sure, courts that adopt the broad approach also claim that they are attempting to treat waiver of the psychotherapist-patient privilege the same way they treat waiver of the attorney-client privilege—but that claim falls flat.

12020–2020
First-Citizens Bank & Trust Co. v. Cornerstone Homes & Development, LLC green
washctapp · 2013
1 sentence

2014The Grantor under 96 Clerk's Papers at 774-75. 97 id, 98 First-Citizens Bank. 314 P.3d at 423 n.8. 99 See, e.g..

12014–2014
Lindsay v. City of Seattle green
wash · 1976
2 sentences

1980In Lindsay v. Seattle, 86 Wn.2d 698 , 548 P.2d 320 , cert. denied, 429 U.S. 886 , 50 L.

1980In Lindsay v. Seattle, 86 Wn.2d 698 , 548 P.2d 320 , cert. denied, 429 U.S. 886 , 50 L.

11980–1980
Beneficial Finance Co. of Gary, Inc. v. Allen green
scotus · 1976
1 sentence

1980In Lindsay v. Seattle, 86 Wn.2d 698 , 548 P.2d 320 , cert. denied, 429 U.S. 886 , 50 L.Ed.2d 167 , 97 S.Ct. 237 (1976), the plaintiff contended that Seattle's civil service commission lacked the authority to delegate to its secretary the discretionary power vested in it by prior charter article 16, section 9 to certify eligible candidates to a department head for possible employment by the City.

11980–1980
Reinhart v. Pennsylvania green
scotus · 1976
2 sentences

1980In Lindsay v. Seattle, 86 Wn.2d 698 , 548 P.2d 320 , cert. denied, 429 U.S. 886 , 50 L.

1980In Lindsay v. Seattle, 86 Wn.2d 698 , 548 P.2d 320 , cert. denied, 429 U.S. 886 , 50 L.Ed.2d 167 , 97 S.Ct. 237 (1976), the plaintiff contended that Seattle's civil service commission lacked the authority to delegate to its secretary the discretionary power vested in it by prior charter article 16, section 9 to certify eligible candidates to a department head for possible employment by the City.

11980–1980

Where else courts name it

MI 37 (1988–2025) CA 24 (1985–2025) NY 19 (1959–2020) PA 15 (1946–2019) TX 11 (1992–2026) WA 9 (1980–2021) NJ 8 (1962–2021) IL 7 (1965–2006) MD 7 (1947–2021) IA 7 (2016–2022) CT 6 (2000–2017) AZ 6 (2008–2018) OH 5 (1989–2023) NM 4 (2007–2024) FL 4 (1970–2016) MO 3 (1964–1972) WI 3 (1982–2004) OR 3 (1989–2020) MA 3 (1975–2009) DC 3 (1981–2001) LA 3 (1974–2006) MS 3 (1991–2025) AL 3 (1964–1987) WY 2 (1982–1982) GA 2 (1981–1991) CO 2 (1991–2004) TN 2 (2002–2025) UT 2 (2004–2017) NH 2 (1989–2020) WV 2 (1980–1992)

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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