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

9 Washington opinions name it 2 courts 2004–2020 0 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
Antonius v. King Countygreen
wash · 2004 · cited in 2 Washington opinions naming this issue, 2009–2015
2 sentences

2009See Antonius, 153 Wn.2d at 261-69 . ¶43 Adopting the Morgan analysis, the Antonius court concludedthatwhereadiscreteactofdiscriminationisalleged, the limitations period runs from the act.

2009See Antonius, 153 Wn.2d at 261-69 . ¶43 Adopting the Morgan analysis, the Antonius court concludedthatwhereadiscreteactofdiscriminationisalleged, the limitations period runs from the act.

12
Lively v. Flexible Packaging Ass'ngreen
dc · 2003 · cited in 2 Washington opinions naming this issue, 2004–2005
2 sentences

2005In contrast, in Lively v. Flexible Packaging Ass'n, 830 A.2d 874, 892 (D.C.Ct.App.2003), the court reasoned that under Morgan's analysis "even if there are significant gaps in the occurrence of the acts constituting the unitary hostile work environment claim, the filing of that claim still may be timely." The court reasoned that this is true because the acts constituting a hostile work environment are treated as an indivisible whole.

2005Lively, 830 A.2d at 892 .

12
National Railroad Passenger Corporation v. Morgangreen
scotus · 2002 · cited in 1 Washington opinions naming this issue, 2004–2004
1 sentence

2004Morgan, 536 U.S. at 121 (O’Connor, J., concurring at 123, 127). ¶15 In applying Morgan’s analysis to this case, the Court of Appeals concluded that Antonius presented sufficient evidence of one or more acts of harassment within three years of her suit filed in December of 2000, and therefore the trial court could consider the discriminatory conduct occurring throughout the time the acts constituting a hostile work environment occurred, i.e., acts occurring before December 1997.

11
Martini v. Boeing Co.green
wash · 1999 · cited in 1 Washington opinions naming this issue, 2004–2004
1 sentence

2004E.g., Martini, 137 Wn.2d at 372-75 (declining to follow federal cases on question whether back pay is recoverable in a successful discrimination action without a showing of constructive discharge). ¶20 The County argues, though, that state and federal law are too dissimilar to apply Morgan’s analysis under chapter 49.60 RCW.

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 (10)

CaseCitedYears
Moore v. Superior Court green
cal · 2010
2 sentences

2011Moore, 50 Cal.4th at 825-26 , 114 Cal.Rptr.3d 199 , 237 P.3d 530 . ¶ 29 The Moore court's reasoning highlights the tension between Morgan's claim to competency and the SVP civil commitment requirements.

2011Moore, 50 Cal.4th at 825-26 , 114 Cal.Rptr.3d 199 , 237 P.3d 530 . ¶ 29 The Moore court's reasoning highlights the tension between Morgan's claim to competency and the SVP civil commitment requirements.

22011–2011
Allison v. Housing Authority of City of Seattle green
wash · 1991
2 sentences

2005A person has the right to hold employment without discrimination, RCW 49.60.030(a), and the discrimination statutes embody "public policy of `the highest priority' " Xieng, 120 Wash.2d at 521 , 844 P.2d 389 (quoting Allison v. Housing Authority of City of Seattle, 118 Wash.2d 79, 86 , 821 P.2d 34 (1991)).

2005A person has the right to hold employment without discrimination, RCW 49.60.030(a), and the discrimination statutes embody "public policy of `the highest priority' " Xieng, 120 Wash.2d at 521 , 844 P.2d 389 (quoting Allison v. Housing Authority of City of Seattle, 118 Wash.2d 79, 86 , 821 P.2d 34 (1991)).

22004–2005
Xieng v. Peoples National Bank green
wash · 1993
2 sentences

2005A person has the right to hold employment without discrimination, RCW 49.60.030(a), and the discrimination statutes embody "public policy of `the highest priority' " Xieng, 120 Wash.2d at 521 , 844 P.2d 389 (quoting Allison v. Housing Authority of City of Seattle, 118 Wash.2d 79, 86 , 821 P.2d 34 (1991)).

2005A person has the right to hold employment without discrimination, RCW 49.60.030(a), and the discrimination statutes embody "public policy of `the highest priority' " Xieng, 120 Wash.2d at 521 , 844 P.2d 389 (quoting Allison v. Housing Authority of City of Seattle, 118 Wash.2d 79, 86 , 821 P.2d 34 (1991)).

22004–2005
William L. Lucas v. Chicago Transit Authority green
ca7 · 2004
2 sentences

2005Lucas, 367 F.3d at 727 .

2004Lucas, 367 F.3d at 727 .

22004–2005
State v. Hills neutral
washctapp · 2003
2 sentences

2005Antonius, No. 50492-4-I, 118 Wash.App. 1011 , 2003 WL 21958392 , slip op. at 5-6.

2004Antonius , noted at 118 Wn.

22004–2005
Michael v. Mosquera-Lacy green
· 2009
1 sentence

2020Michael v. Mosquera-Lacy, 165 Wn.2d 595, 601 , 200 P.3d 695 (2009).

12020–2020
Michael v. Mosquera-Lacy green
wash · 2009
1 sentence

2020Michael v. Mosquera-Lacy, 165 Wn.2d 595, 601 , 200 P.3d 695 (2009).

12020–2020
State v. Morgan green
washctapp · 1997
1 sentence

2018Morgan, 86 Wn.

12018–2018
State v. Alvarado green
wash · 2008
1 sentence

2015See RAP 10.10(c) (an appellate court will not consider an argument made in a statement of additional grounds for review if it does not inform the court of the nature and occurrence of the alleged errors); State v. Alvarado, 164 Wn.2d 556, 559 , 192 P.3d 345 (2008).

12015–2015
State v. Alvarado green
wash · 2008
1 sentence

2015See RAP 10.10(c) (an appellate court will not consider an argument made in a statement of additional grounds for review if it does not inform the court of the nature and occurrence of the alleged errors); State v. Alvarado, 164 Wn.2d 556, 559 , 192 P.3d 345 (2008).

12015–2015

Statutes the citing opinions construe

WA § Wash. Rev. Code § 4.16.080 (4) WA § Wash. Rev. Code § 2.06.040 (3) WA § Wash. Rev. Code § 49.60.010 (3) WA § Wash. Rev. Code § 49.60.030 (3) WA § Wash. Rev. Code § 49.60.180 (3)

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

IL 19 (1974–2017) TX 16 (1979–2026) CA 15 (1962–2026) OH 14 (2000–2026) WA 9 (2004–2020) MD 9 (1983–2025) TN 8 (1978–2010) FL 8 (1981–2022) PA 7 (1983–2022) AZ 6 (2005–2026) NY 6 (1992–2025) NV 6 (2013–2023) NJ 5 (1986–2019) ID 5 (1994–2017) GA 5 (1997–2007) KY 5 (1917–2025) SC 5 (2002–2025) MT 5 (2002–2025) IN 4 (1986–2018) DE 4 (2019–2023) MS 4 (2013–2023) WI 3 (1995–2002) AL 3 (1993–2008) NC 3 (1997–2004) ME 3 (1984–2025) MI 3 (1975–2022) AR 3 (2006–2019) WY 3 (1993–2022) HI 3 (1999–2011) MO 3 (1987–2008) AK 3 (1976–2021) CT 2 (2007–2010) KS 2 (2021–2026) VT 2 (2016–2016) LA 2 (2009–2015) OK 2 (1987–2019) IA 2 (2014–2016)

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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