Dunn rule (Washington) · Go Syfert
← Washington issues

Dunn rule in Washington

9 Washington opinions name it 2 courts 1988–2021 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 (4)

CaseFollowedCited
Gray v. Stategreen
oklacrimapp · 1982 · cited in 2 Washington opinions naming this issue, 2002–2002
2 sentences

2002See Gray v. State, 650 P.2d 880, 884 (Okla.

2002See Gray v. State, 650 P.2d 880, 884 (Okla.

22
State v. Nggreen
wash · 1988 · cited in 6 Washington opinions naming this issue, 2002–2021
2 sentences

2005Our Supreme Court noted in Ng that the Dunn rule establishes “ ‘the unreviewable power of a jury to return a verdict of not guilty for impermissible reasons.’ ” Ng, 110 Wn.2d at 48 (quoting United States v. Powell, 469 U.S. 57, 63 , 105 S. Ct. 471 , 83 L.

2005Our Supreme Court noted in Ng that the Dunn rule establishes “ ‘the unreviewable power of a jury to return a verdict of not guilty for impermissible reasons.’ ” Ng, 110 Wn.2d at 48 (quoting United States v. Powell, 469 U.S. 57, 63 , 105 S. Ct. 471 , 83 L.

16
State v. McNealgreen
wash · 2002 · cited in 1 Washington opinions naming this issue, 2002–2002
1 sentence

2002There the jury by general verdict implied that the defendant was operating a vehicle under the influence of drugs for purposes of a vehicular assault conviction, but at the same time by special verdict found the defendant was not under the influence of drugs for purposes of a vehicular homicide conviction arising out of the same facts. 5 McNeal, 145 Wn.2d at 356, 358-61 .

11
McCloud v. Stategreen
fla · 1976 · cited in 1 Washington opinions naming this issue, 1988–1988
2 sentences

1988See, e.g., McCloud v. State, 335 So. 2d 257 (Fla. 1976) (robbery conviction proper although inconsistent with conviction of manslaughter as lesser included offense of felony murder; defendant in no position to complain of lesser sentence); People v. Parks, 49 Ill.

1988See, e.g., McCloud v. State, 335 So. 2d 257 (Fla. 1976) (robbery conviction proper although inconsistent with conviction of manslaughter as lesser included offense of felony murder; defendant in no position to complain of lesser sentence); People v. Parks, 49 Ill.

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State v. O'Neilred
wash · 1946 · cited in 3 Washington opinions naming this issue, 1988–2002
2 sentences

1988In State v. O'Neil, 24 Wn.2d 802, 808-09 , 167 P.2d 471 (1946), this court noted the Dunn rule, but adopted the then prevalent state court rule that where two offenses growing out of the same transaction are charged in separate counts of an indictment and one offense includes elements necessary to the commission of the other, a verdict of acquittal of the one is inconsistent with a verdict of guilty on the other and must be reversed.

1988In State v. O'Neil, 24 Wn.2d 802, 808-09 , 167 P.2d 471 (1946), this court noted the Dunn rule, but adopted the then prevalent state court rule that where two offenses growing out of the same transaction are charged in separate counts of an indictment and one offense includes elements necessary to the commission of the other, a verdict of acquittal of the one is inconsistent with a verdict of guilty on the other and must be reversed.

13

Also cited on this issue (6)

CaseCitedYears
United States v. Powell green
scotus · 1984
2 sentences

2013As the Supreme Court noted, the Dunn rule establishes `the to unreviewable power of a jury to return a verdict of not guilty for impermissible reasons. "' Ng, 110 Wn. d at 48 (internal quotation marks omitted) quoting United States v. Powell, 469 U. . 2 ( S 57, 63, 105 S. Ct. 471 , 83 L.Ed. 2d 461 (1984)). 17 No. 42352 9 II - - SAG JUDICIAL COMMENT ON THE EVIDENCE Brady argues that the trial court impermissibly commented on the evidence.

2013As the Supreme Court noted, the Dunn rule establishes `the to unreviewable power of a jury to return a verdict of not guilty for impermissible reasons. "' Ng, 110 Wn. d at 48 (internal quotation marks omitted) quoting United States v. Powell, 469 U. . 2 ( S 57, 63, 105 S. Ct. 471 , 83 L.Ed. 2d 461 (1984)). 17 No. 42352 9 II - - SAG JUDICIAL COMMENT ON THE EVIDENCE Brady argues that the trial court impermissibly commented on the evidence.

61988–2013
United States v. Daigle green
dcd · 1957
2 sentences

2002Cir. 1957), which recognizes that rational consistency is not necessary in the conviction-acquittal context under the Dunn rule, but “[o]n the other hand, where a guilty verdict on one count negatives some fact essential to a finding of guilty on a second count, two guilty verdicts may not stand.” Daigle, 149 F. Supp. at 414 .

2002Cir. 1957), which recognizes that rational consistency is not necessary in the conviction-acquittal context under the Dunn rule, but “[o]n the other hand, where a guilty verdict on one count negatives some fact essential to a finding of guilty on a second count, two guilty verdicts may not stand.” Daigle, 149 F. Supp. at 414 .

22002–2002
Emile J. Daigle v. United States green
cadc · 1958
2 sentences

2002In this regard, Powell further cites United States v. Daigle, 149 F.Supp. 409 (D.D.C.), aff'd, 248 F.2d 608 (D.C.Cir.1957), which recognizes that rational consistency is not necessary in the conviction-acquittal context under the Dunn rule, but "[o]n the other hand, where a guilty verdict on one count negatives some fact essential to a finding of guilty on a second count, two guilty verdicts may not stand." Daigle, 149 F.Supp. at 414 .

2002In this regard, Powell further cites United States v. Daigle, 149 F.Supp. 409 (D.D.C.), aff'd, 248 F.2d 608 (D.C.Cir.1957), which recognizes that rational consistency is not necessary in the conviction-acquittal context under the Dunn rule, but "[o]n the other hand, where a guilty verdict on one count negatives some fact essential to a finding of guilty on a second count, two guilty verdicts may not stand." Daigle, 149 F.Supp. at 414 .

12002–2002
State v. Hall green
wva · 1985
2 sentences

2002See Gray v. State, 650 P.2d 880, 884 (Okla.Crim.1982) (court did not err in accepting inconsistent verdicts of guilty of shooting with intent to kill for unintended transferred intent victim, but acquittal for intended victim); State v. Hall, 174 W.Va. 599, 602 , 328 S.E.2d 206 (1985) (verdicts not necessarily inconsistent under facts, but even if under transferred intent theory a verdict for second degree murder requiring malice was inconsistent with unlawful wounding verdict, Dunn rationale precluded claim of reversible error). [6] At sentencing, Mr. Wilson did not concede he was the Arron W

2002See Gray v. State, 650 P.2d 880, 884 (Okla.Crim.1982) (court did not err in accepting inconsistent verdicts of guilty of shooting with intent to kill for unintended transferred intent victim, but acquittal for intended victim); State v. Hall, 174 W.Va. 599, 602 , 328 S.E.2d 206 (1985) (verdicts not necessarily inconsistent under facts, but even if under transferred intent theory a verdict for second degree murder requiring malice was inconsistent with unlawful wounding verdict, Dunn rationale precluded claim of reversible error). [6] At sentencing, Mr. Wilson did not concede he was the Arron W

12002–2002
People v. Parks green
illappct · 1977
2 sentences

1988See, e.g., McCloud v. State, 335 So. 2d 257 (Fla. 1976) (robbery conviction proper although inconsistent with conviction of manslaughter as lesser included offense of felony murder; defendant in no position to complain of lesser sentence); People v. Parks, 49 Ill.

1988See, e.g., McCloud v. State, 335 So. 2d 257 (Fla. 1976) (robbery conviction proper although inconsistent with conviction of manslaughter as lesser included offense of felony murder; defendant in no position to complain of lesser sentence); People v. Parks, 49 Ill.

11988–1988
Harris v. Rivera green
scotus · 1981
2 sentences

1988As the Supreme Court noted, the Dunn rule establishes " 'the unreviewable power of a jury to return a verdict of not guilty for impermissible reasons.'" Powell , at 63 (quoting Harris v. Rivera, 454 U.S. 339, 346 , 70 L.

1988As the Supreme Court noted, the Dunn rule establishes " 'the unreviewable power of a jury to return a verdict of not guilty for impermissible reasons.'" Powell , at 63 (quoting Harris v. Rivera, 454 U.S. 339, 346 , 70 L.

11988–1988

Statutes the citing opinions construe

WA § Wash. Rev. Code § 2.06.040 (5) WA § Wash. Rev. Code § 9A.36.021 (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

TX 28 (1996–2024) CA 18 (1980–2025) PA 14 (1975–2025) OH 13 (1985–2022) WI 12 (1990–2024) IL 10 (1981–2020) GA 9 (1986–2016) WA 9 (1988–2021) TN 8 (2005–2025) KS 8 (1988–2017) FL 7 (1994–2018) WV 7 (2011–2025) MI 7 (1972–2017) MA 6 (2009–2020) AL 6 (1963–2009) IN 6 (1979–2020) VA 6 (1990–2021) DC 5 (1992–2009) MN 5 (2016–2024) NJ 5 (1970–2025) UT 4 (1993–2020) CT 4 (1985–2017) SC 4 (2015–2017) NY 4 (2012–2014) DE 3 (2004–2015) ND 3 (2010–2015) ID 3 (2001–2026) NC 3 (2011–2016) VT 2 (1998–2019) KY 2 (2016–2022) MD 2 (1965–2014) IA 2 (2010–2019) ME 2 (1992–1997)

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.

← Caselaw search · G Cite Topics · Brief Check