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9 Washington opinions name it 2 courts 1994–2023 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.
| Case | Followed | Cited |
|---|---|---|
Donaldson v. Jonesgreen2 sentences1994The rule has been phrased as follows: [W]here the work of an independent contractor is completed, turned over to, and accepted by, the owner, the contractor is not liable to third persons for damages or injuries subsequently suffered by reason of the condition of the work, even though he was negligent in carrying out the contract!.] andrews v. Del Guzzi, 56 Wn.2d 381, 388 , 353 P.2d 422 (1960) (recognizing doctrine but finding contractors liable under exception for inherently or imminently dangerous conditions) (quoting 65 C.J.S. 613); Donaldson v. Jones, 188 Wash. 46, 50 , 61 P.2d 1007 (1936) 1994The rule has been phrased as follows: [W]here the work of an independent contractor is completed, turned over to, and accepted by, the owner, the contractor is not liable to third persons for damages or injuries subsequently suffered by reason of the condition of the work, even though he was negligent in carrying out the contract!.] andrews v. Del Guzzi, 56 Wn.2d 381, 388 , 353 P.2d 422 (1960) (recognizing doctrine but finding contractors liable under exception for inherently or imminently dangerous conditions) (quoting 65 C.J.S. 613); Donaldson v. Jones, 188 Wash. 46, 50 , 61 P.2d 1007 (1936) | 2 | 3 |
Pierce v. ALSC Architects, P.S.green2 sentences2007See Pierce v. ALSO Architects, PS, 270 Mont. 97 , 890 P.2d 1254, 1262 (1995). 2007See Pierce v. ALSO Architects, PS, 270 Mont. 97 , 890 P.2d 1254, 1262 (1995). | 2 | 2 |
Andrews v. Del Guzzigreen2 sentences2007Andrews v. Del Guzzi, 56 Wn.2d 381, 388 , 353 P.2d 422 (1960). ¶20 Washington has recognized the completion and acceptance rule for nearly a century. 2007Andrews v. Del Guzzi, 56 Wn.2d 381, 388 , 353 P.2d 422 (1960). ¶20 Washington has recognized the completion and acceptance rule for nearly a century. | 1 | 5 |
First Church of Christ Scientist v. City of Seattlegreen2 sentences2007See, e.g., Garza v. McCain Foods, Inc., 124 Wash. App. 908, 913 , 103 P.3d 848 (2004); First Church of Christ Scientist v. City of Seattle, 92 Wash.App. 229, 234 , 964 P.2d 374 (1998). ¶ 21 Washington recognizes three exceptions to the completion and acceptance rule. 2007App. 229, 234 , 964 P.2d 374 (1998). ¶21 Washington recognizes three exceptions to the completion and acceptance rule. | 1 | 4 |
Garza v. McCain Foods, Inc.green1 sentence2007See, e.g., Garza v. McCain Foods, Inc., 124 Wash. App. 908, 913 , 103 P.3d 848 (2004); First Church of Christ Scientist v. City of Seattle, 92 Wash.App. 229, 234 , 964 P.2d 374 (1998). ¶ 21 Washington recognizes three exceptions to the completion and acceptance rule. | 1 | 1 |
Garza v. McCain Foods, Inc.green1 sentence2007See, e.g., Garza v. McCain Foods, Inc., 124 Wash. App. 908, 913 , 103 P.3d 848 (2004); First Church of Christ Scientist v. City of Seattle, 92 Wash.App. 229, 234 , 964 P.2d 374 (1998). ¶ 21 Washington recognizes three exceptions to the completion and acceptance rule. | 1 | 1 |
Tennyson v. Plum Creek Timber Co.green1 sentence1998App. at 559 n.9 (fully concurring with majority opinion that contractors immune by virtue of doctrine of completion and acceptance, “to which this court is currently bound by virtue of the rulings of our Supreme Court.”) (Kennedy, J., dissenting in part). 9 Tennyson, 73 Wn. | 1 | 1 |
King v. Masongreen1 sentence1998App. at 559 (Kennedy, J., dissenting in part). 10 CR 56(c). 11 Cf. Wilton v. City of Spokane, 73 Wash. 619, 623 , 132 P. 404 (1913) (doctrine had no application to act of leaving unexploded charge of dynamite under surface of street “not a matter connected with the contract work”); see also King v. Mason, 95 So. 2d 705, 709, 712 (La. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Davis v. Baugh Industrial Contractors, Inc.
green
2 sentences2023Contractors, Inc., 159 Wn.2d 413, 419 , 150 P.3d 545 (2007) (deciding whether to abandon the common law doctrine of completion and acceptance); Parkridge Assocs., Ltd. v. Ledcor Indus., Inc., 113 Wn. 2016HDR/Tumer's "work" on [the] North Close Project under Davis included . . . (b) providing information to the WSP about the building in the OMM[18] which specifically included an affirmative duty that HDR/Turner provide copies of warranties for [the] metal security ceiling, and (c) "lists of circumstances and conditions that would affect the validity" of those ceiling warranties.[19] In analyzing why it was appropriate to abandon the completion and acceptance doctrine, the Davis court discussed how the doctrine had previously been justified based on the property owner's assumed responsibility fo | 3 | 2010–2023 |
Staats v. Brown
green
2 sentences2007Staats v. Brown, 139 Wash.2d 757, 766 , 991 P.2d 615 (2000); Irwin v. Rogers, 91 Wash. 284, 287 , 157 P. 690 (1916). ¶ 38 The statute of repose neither expressly nor impliedly supersedes the completion and acceptance rule. 2007Staats v. Brown, 139 Wn.2d 757, 766 , 991 P.2d 615 (2000); Irwin v. Rogers, 91 Wash. 284, 287 , 157 P. 690 (1916). ¶38 The statute of repose neither expressly nor impliedly supersedes the completion and acceptance rule. | 2 | 2007–2007 |
Staats v. Brown
green
2 sentences2007Staats v. Brown, 139 Wash.2d 757, 766 , 991 P.2d 615 (2000); Irwin v. Rogers, 91 Wash. 284, 287 , 157 P. 690 (1916). ¶ 38 The statute of repose neither expressly nor impliedly supersedes the completion and acceptance rule. 2007Staats v. Brown, 139 Wn.2d 757, 766 , 991 P.2d 615 (2000); Irwin v. Rogers, 91 Wash. 284, 287 , 157 P. 690 (1916). ¶38 The statute of repose neither expressly nor impliedly supersedes the completion and acceptance rule. | 2 | 2007–2007 |
Maltman v. Sauer
green
2 sentences2007Id. ¶ 9 The completion and acceptance doctrine is also grounded in the assumption that if owners of land inspect and accept the work, the owner should be responsible for any defects in that accepted work. 2007Id. ¶9 The completion and acceptance doctrine is also grounded in the assumption that if owners of land inspect and accept the work, the owner should be responsible for any defects in that accepted work. | 2 | 2007–2007 |
Thornton v. Dow
red
2 sentences2007See, e.g., Donaldson v. Jones, 188 Wash. 46 , 61 P.2d 1007 (1936); Thornton v. Dow, 60 Wash. 622 , 111 P. 899 (1910). 2007See, e.g., Donaldson v. Jones, 188 Wash. 46 , 61 P.2d 1007 (1936); Thornton v. Dow, 60 Wash. 622 , 111 P. 899 (1910). | 2 | 2007–2007 |
Irwin v. Rogers
neutral
2 sentences2007Staats v. Brown, 139 Wn.2d 757, 766 , 991 P.2d 615 (2000); Irwin v. Rogers, 91 Wash. 284, 287 , 157 P. 690 (1916). ¶38 The statute of repose neither expressly nor impliedly supersedes the completion and acceptance rule. 2007Staats v. Brown, 139 Wn.2d 757, 766 , 991 P.2d 615 (2000); Irwin v. Rogers, 91 Wash. 284, 287 , 157 P. 690 (1916). ¶38 The statute of repose neither expressly nor impliedly supersedes the completion and acceptance rule. | 2 | 2007–2007 |
MacPherson v. . Buick Motor Co.
green
2 sentences2004A thing is inherently dangerous if the nature and quality of it is reasonably certain “to place life and limb in peril.” MacPherson v. Buick Motor Co., 217 N.Y. 382, 389 , 111 N.E. 1050 (1916). 2 Whether the result of the work is imminently or inherently dangerous is then a question of fact generally calling for expert testimony. 2004A thing is inherently dangerous if the nature and quality of it is reasonably certain “to place life and limb in peril.” MacPherson v. Buick Motor Co., 217 N.Y. 382, 389 , 111 N.E. 1050 (1916). 2 Whether the result of the work is imminently or inherently dangerous is then a question of fact generally calling for expert testimony. | 2 | 2004–2004 |
Davis v. Baugh Indus. Contractors, Inc.
green
1 sentence2023Contractors, Inc., 159 Wn.2d 413, 419 , 150 P.3d 545 (2007) (deciding whether to abandon the common law doctrine of completion and acceptance); Parkridge Assocs., Ltd. v. Ledcor Indus., Inc., 113 Wn. | 1 | 2023–2023 |
Parkridge Associates, Ltd. v. Ledcor Industries, Inc.
green
1 sentence2023Contractors, Inc., 159 Wn.2d 413, 419 , 150 P.3d 545 (2007) (deciding whether to abandon the common law doctrine of completion and acceptance); Parkridge Assocs., Ltd. v. Ledcor Indus., Inc., 113 Wn. | 1 | 2023–2023 |
Parkridge Associates, Ltd v. Ledcor Industries, Inc.
green
1 sentence2023App. 592, 602 , 54 P.3d 225 (2002) (construing the phrase “all claims or causes of action[ ] of any kind . . . arising from . . . construction” to determine whether that phrase was broad enough to include equitable indemnity claims); 1519-1525 Lakeview Blvd. | 1 | 2023–2023 |
Wilton v. City of Spokane
neutral
2 sentences1998App. at 559 (Kennedy, J., dissenting in part). 10 CR 56(c). 11 Cf. Wilton v. City of Spokane, 73 Wash. 619, 623 , 132 P. 404 (1913) (doctrine had no application to act of leaving unexploded charge of dynamite under surface of street “not a matter connected with the contract work”); see also King v. Mason, 95 So. 2d 705, 709, 712 (La. 1998App. at 559 (Kennedy, J., dissenting in part). 10 CR 56(c). 11 Cf. Wilton v. City of Spokane, 73 Wash. 619, 623 , 132 P. 404 (1913) (doctrine had no application to act of leaving unexploded charge of dynamite under surface of street “not a matter connected with the contract work”); see also King v. Mason, 95 So. 2d 705, 709, 712 (La. | 1 | 1998–1998 |
Axland v. Pacific Heating Co.
neutral
2 sentences1994The rule has been phrased as follows: [W]here the work of an independent contractor is completed, turned over to, and accepted by, the owner, the contractor is not liable to third persons for damages or injuries subsequently suffered by reason of the condition of the work, even though he was negligent in carrying out the contract!.] andrews v. Del Guzzi, 56 Wn.2d 381, 388 , 353 P.2d 422 (1960) (recognizing doctrine but finding contractors liable under exception for inherently or imminently dangerous conditions) (quoting 65 C.J.S. 613); Donaldson v. Jones, 188 Wash. 46, 50 , 61 P.2d 1007 (1936) 1994The rule has been phrased as follows: [W]here the work of an independent contractor is completed, turned over to, and accepted by, the owner, the contractor is not liable to third persons for damages or injuries subsequently suffered by reason of the condition of the work, even though he was negligent in carrying out the contract!.] andrews v. Del Guzzi, 56 Wn.2d 381, 388 , 353 P.2d 422 (1960) (recognizing doctrine but finding contractors liable under exception for inherently or imminently dangerous conditions) (quoting 65 C.J.S. 613); Donaldson v. Jones, 188 Wash. 46, 50 , 61 P.2d 1007 (1936) | 1 | 1994–1994 |
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.