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9 Washington opinions name it 2 courts 2005–2024 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 |
|---|---|---|
Dreiling v. Jaingreen2 sentences2014“To balance the constitutional requirement of the open administration of justice against potentially conflicting rights, we directed courts to apply the five Ishikawa factors.” 7 Id. at 544 (citing Dreiling, 151 Wn.2d at 908, 913 ). ¶49 Here, the lower court properly applied the Ishikawa factors. 2014“To balance the constitutional requirement of the open administration of justice against potentially conflicting rights, we directed courts to apply the five Ishikawa factors.” 7 Id. at 544 (citing Dreiling, 151 Wn.2d at 908, 913 ). ¶49 Here, the lower court properly applied the Ishikawa factors. | 4 | 4 |
Seattle Times Co. v. Ishikawagreen2 sentences2024GR 15(c)(3). 6 The five Ishikawa factors the court must consider are (1) the “need for closure or sealing,” (2) that “ ‘[a]nyone present when the closure [and/or sealing] motion is made must be given an opportunity to object to the [suggested restriction],’ ” (3) whether “the requested method for curtailing open access would be both the least restrictive means available and effective in protecting the interests threatened,” (4) “ ‘the competing interests of the defendant and the public,’ ” and (5) that “ ‘[t]he order must be no broader in its application or duration than necessary to serve its 2015The order must be no broader in its application or duration than necessary to serve its purpose." Eikenberry, 121 Wn.2d at 210 -11 (citing Ishikawa, 97 Wn.2d at 36-39 ). 12 12 The five Ishikawa factors are essentially identical to the five factors of the test adopted in State v. Bone-Club, 128 Wn.2d 254, 261 , 906 P.2d 325 (1995) to assess the propriety of sealing and closures in criminal cases. 21 In re the Dependency of M.H.P., No. 90468-5 Here, the superior court's memorandum opinion did not analyze the sealing requests using the Ishikawa factors; in fact, the opinion does not even mention | 1 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Federated Publications, Inc. v. Kurtz
green
2 sentences2024GR 15(c)(3). 6 The five Ishikawa factors the court must consider are (1) the “need for closure or sealing,” (2) that “ ‘[a]nyone present when the closure [and/or sealing] motion is made must be given an opportunity to object to the [suggested restriction],’ ” (3) whether “the requested method for curtailing open access would be both the least restrictive means available and effective in protecting the interests threatened,” (4) “ ‘the competing interests of the defendant and the public,’ ” and (5) that “ ‘[t]he order must be no broader in its application or duration than necessary to serve its 2024GR 15(c)(3). 6 The five Ishikawa factors the court must consider are (1) the “need for closure or sealing,” (2) that “ ‘[a]nyone present when the closure [and/or sealing] motion is made must be given an opportunity to object to the [suggested restriction],’ ” (3) whether “the requested method for curtailing open access would be both the least restrictive means available and effective in protecting the interests threatened,” (4) “ ‘the competing interests of the defendant and the public,’ ” and (5) that “ ‘[t]he order must be no broader in its application or duration than necessary to serve its | 2 | 2005–2024 |
Allied Daily Newspapers v. Eikenberry
green
2 sentences2015The order must be no broader in its application or duration than necessary to serve its purpose." Eikenberry, 121 Wn.2d at 210 -11 (citing Ishikawa, 97 Wn.2d at 36-39 ). 12 12 The five Ishikawa factors are essentially identical to the five factors of the test adopted in State v. Bone-Club, 128 Wn.2d 254, 261 , 906 P.2d 325 (1995) to assess the propriety of sealing and closures in criminal cases. 21 In re the Dependency of M.H.P., No. 90468-5 Here, the superior court's memorandum opinion did not analyze the sealing requests using the Ishikawa factors; in fact, the opinion does not even mention 2005Id. [7] In Dreiling, we quoted the five Ishikawa factors as follows: 1. | 2 | 2005–2015 |
State v. Bone-Club
green
2 sentences2015The five Ishikawa factors are essentially identical to the five factors of the test adopted in State v. Bone-Club, 128 Wn.2d 254, 261 , 906 P.2d 325 (1995) to assess the propriety of sealing and closures in criminal cases. 2015The five Ishikawa factors are essentially identical to the five factors of the test adopted in State v. Bone-Club, 128 Wn.2d 254, 261 , 906 P.2d 325 (1995) to assess the propriety of sealing and closures in criminal cases. | 2 | 2015–2015 |
Rufer v. Abbott Laboratories
green
2 sentences2010Neither of the respondents challenges the original decision to seal the records. [13] The Washington Supreme Court has not had occasion to review a trial court's application of the five Ishikawa factors to a decision to unseal records, although it did affirm the disclosure order in Rufer because the trial court had used the compelling interest standard in its analysis. 154 Wash.2d at 551 , 114 P.3d 1182 . 2010The Washington Supreme Court has not had occasion to review a trial court’s application of the five Ishikawa factors to a decision to unseal records, although it did affirm the disclosure order in Rufer because the trial court had used the compelling interest standard in its analysis. 154 Wn.2d at 551 . | 2 | 2010–2010 |
Department of Social & Health Services v. Parvin
green
1 sentence2024GR 15(c)(3). 6 The five Ishikawa factors the court must consider are (1) the “need for closure or sealing,” (2) that “ ‘[a]nyone present when the closure [and/or sealing] motion is made must be given an opportunity to object to the [suggested restriction],’ ” (3) whether “the requested method for curtailing open access would be both the least restrictive means available and effective in protecting the interests threatened,” (4) “ ‘the competing interests of the defendant and the public,’ ” and (5) that “ ‘[t]he order must be no broader in its application or duration than necessary to serve its | 1 | 2024–2024 |