state action requirement (Washington) · Go Syfert
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state action requirement in Washington

9 Washington opinions name it 2 courts 1980–2023 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.

Followed or applied (4)

CaseFollowedCited
White Egret Condominium, Inc. v. Franklingreen
fla · 1979 · cited in 2 Washington opinions naming this issue, 1998–1998
2 sentences

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So.2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass'n v. Bolotin, 429 So.2d 438 (Fla. 4th Dist.Ct.App.1983) (procedural due process); cf. Thanasoulis v. Winston Tower 200 Ass'n, 214 N.J.Super. 408 , 519 A.2d 911 (1986) (finding constitutional principles inapplicable for lack of state action), rev'd on other grounds, 110 N.J. 650 , 542 A.2d 900 , 76 A.L.R.4th 273 (N.J.1988); Covered Bridge Condominium Ass'n, Inc. v. Chambliss, 705 S.W.2d 211, 213 (Tex.App.1985) (reviewing for constitutionality while recognizing that t

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So. 2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass’n v. Bolotin, 429 So. 2d 438 (Fla. Dist.

22
Covered Bridge Condominium Ass'n v. Chamblissgreen
texapp · 1985 · cited in 1 Washington opinions naming this issue, 1998–1998
1 sentence

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So.2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass'n v. Bolotin, 429 So.2d 438 (Fla. 4th Dist.Ct.App.1983) (procedural due process); cf. Thanasoulis v. Winston Tower 200 Ass'n, 214 N.J.Super. 408 , 519 A.2d 911 (1986) (finding constitutional principles inapplicable for lack of state action), rev'd on other grounds, 110 N.J. 650 , 542 A.2d 900 , 76 A.L.R.4th 273 (N.J.1988); Covered Bridge Condominium Ass'n, Inc. v. Chambliss, 705 S.W.2d 211, 213 (Tex.App.1985) (reviewing for constitutionality while recognizing that t

11
SHAD Alliance v. Smith Haven Mallgreen
ny · 1985 · cited in 1 Washington opinions naming this issue, 1989–1989
2 sentences

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis. 2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and his

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis. 2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and his

11
Woodland v. Michigan Citizens Lobbygreen
mich · 1985 · cited in 1 Washington opinions naming this issue, 1989–1989
2 sentences

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis. 2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and his

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis. 2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and his

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 (15)

CaseCitedYears
Alderwood Associates v. Washington Environmental Council green
wash · 1981
2 sentences

1999"Rather than emasculate the state action requirement from the Declaration of Rights, however, I would hold that the activity engaged in here by the defendants is authorized by Const. art. 2, § 1(a) (amendment 7), RCW 29.79, and the cases decided by this court." Alderwood Assocs., 96 Wash.2d at 251 , 635 P.2d 108 (citing State ex rel.

1999"Rather than emasculate the state action requirement from the Declaration of Rights, however, I would hold that the activity engaged in here by the defendants is authorized by Const. art. 2, § 1(a) (amendment 7), RCW 29.79, and the cases decided by this court." Alderwood Assocs., 96 Wash.2d at 251 , 635 P.2d 108 (citing State ex rel.

21999–1999
State Ex Rel. Evich v. Superior Court neutral
wash · 1936
2 sentences

1999Evich v. Superior Court, 188 Wash. 19 , 61 P.2d 143 (1936); State ex rel.

1999Evich v. Superior Court, 188 Wash. 19 , 61 P.2d 143 (1936); State ex rel.

21999–1999
Majestic View Condominium Ass'n v. Bolotin green
fladistctapp · 1983
2 sentences

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So.2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass'n v. Bolotin, 429 So.2d 438 (Fla. 4th Dist.Ct.App.1983) (procedural due process); cf. Thanasoulis v. Winston Tower 200 Ass'n, 214 N.J.Super. 408 , 519 A.2d 911 (1986) (finding constitutional principles inapplicable for lack of state action), rev'd on other grounds, 110 N.J. 650 , 542 A.2d 900 , 76 A.L.R.4th 273 (N.J.1988); Covered Bridge Condominium Ass'n, Inc. v. Chambliss, 705 S.W.2d 211, 213 (Tex.App.1985) (reviewing for constitutionality while recognizing that t

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So. 2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass’n v. Bolotin, 429 So. 2d 438 (Fla. Dist.

21998–1998
State v. Carter green
wash · 2004
1 sentence

2023As we discussed above, the court’s reasoning for denying A.A.T.’s motion to suppress the gun was based on the state action doctrine. “[N]either state nor federal constitutional protections against unreasonable searches and seizures are implicated, without state action.” Carter, 151 Wn.2d at 124 .

12023–2023
Reitman v. Mulkey green
scotus · 1967
2 sentences

2007Reitman v. Mulkey, 387 U.S. 369, 378 , 87 S.Ct. 1627 , 18 L.Ed.2d 830 (1967) (stating there is no "infallible test" for determining the existence of state action).

2007Reitman v. Mulkey, 387 U.S. 369, 378 , 87 S.Ct. 1627 , 18 L.Ed.2d 830 (1967) (stating there is no "infallible test" for determining the existence of state action).

12007–2007
In Re Dependency of Grove green
wash · 1995
2 sentences

2007We note that Luscier and Myricks were favorably cited more recently in our case, In re Dependency of Grove, 127 Wash.2d 221 , 897 P.2d 1252 (1995). [4] The parenting plan provides for the "resolution of future disputes between the parents, allocation of decision-making authority, and residential provisions for the child." RCW 26.09.184(2). [5] For the sake of this opinion, we assume without deciding that the state action requirement is satisfied.

2007We note that Luscier and Myricks were favorably cited more recently in our case, In re Dependency of Grove, 127 Wash.2d 221 , 897 P.2d 1252 (1995). [4] The parenting plan provides for the "resolution of future disputes between the parents, allocation of decision-making authority, and residential provisions for the child." RCW 26.09.184(2). [5] For the sake of this opinion, we assume without deciding that the state action requirement is satisfied.

12007–2007
Thanasoulis v. Winston Tower 200 Ass'n, Inc. green
njsuperctappdiv · 1986
2 sentences

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So.2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass'n v. Bolotin, 429 So.2d 438 (Fla. 4th Dist.Ct.App.1983) (procedural due process); cf. Thanasoulis v. Winston Tower 200 Ass'n, 214 N.J.Super. 408 , 519 A.2d 911 (1986) (finding constitutional principles inapplicable for lack of state action), rev'd on other grounds, 110 N.J. 650 , 542 A.2d 900 , 76 A.L.R.4th 273 (N.J.1988); Covered Bridge Condominium Ass'n, Inc. v. Chambliss, 705 S.W.2d 211, 213 (Tex.App.1985) (reviewing for constitutionality while recognizing that t

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So.2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass'n v. Bolotin, 429 So.2d 438 (Fla. 4th Dist.Ct.App.1983) (procedural due process); cf. Thanasoulis v. Winston Tower 200 Ass'n, 214 N.J.Super. 408 , 519 A.2d 911 (1986) (finding constitutional principles inapplicable for lack of state action), rev'd on other grounds, 110 N.J. 650 , 542 A.2d 900 , 76 A.L.R.4th 273 (N.J.1988); Covered Bridge Condominium Ass'n, Inc. v. Chambliss, 705 S.W.2d 211, 213 (Tex.App.1985) (reviewing for constitutionality while recognizing that t

11998–1998
Thanasoulis v. Winston Towers 200 Ass'n. green
nj · 1988
2 sentences

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So.2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass'n v. Bolotin, 429 So.2d 438 (Fla. 4th Dist.Ct.App.1983) (procedural due process); cf. Thanasoulis v. Winston Tower 200 Ass'n, 214 N.J.Super. 408 , 519 A.2d 911 (1986) (finding constitutional principles inapplicable for lack of state action), rev'd on other grounds, 110 N.J. 650 , 542 A.2d 900 , 76 A.L.R.4th 273 (N.J.1988); Covered Bridge Condominium Ass'n, Inc. v. Chambliss, 705 S.W.2d 211, 213 (Tex.App.1985) (reviewing for constitutionality while recognizing that t

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So.2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass'n v. Bolotin, 429 So.2d 438 (Fla. 4th Dist.Ct.App.1983) (procedural due process); cf. Thanasoulis v. Winston Tower 200 Ass'n, 214 N.J.Super. 408 , 519 A.2d 911 (1986) (finding constitutional principles inapplicable for lack of state action), rev'd on other grounds, 110 N.J. 650 , 542 A.2d 900 , 76 A.L.R.4th 273 (N.J.1988); Covered Bridge Condominium Ass'n, Inc. v. Chambliss, 705 S.W.2d 211, 213 (Tex.App.1985) (reviewing for constitutionality while recognizing that t

11998–1998
Franklin v. Spadafora green
mass · 1983
2 sentences

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So.2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass'n v. Bolotin, 429 So.2d 438 (Fla. 4th Dist.Ct.App.1983) (procedural due process); cf. Thanasoulis v. Winston Tower 200 Ass'n, 214 N.J.Super. 408 , 519 A.2d 911 (1986) (finding constitutional principles inapplicable for lack of state action), rev'd on other grounds, 110 N.J. 650 , 542 A.2d 900 , 76 A.L.R.4th 273 (N.J.1988); Covered Bridge Condominium Ass'n, Inc. v. Chambliss, 705 S.W.2d 211, 213 (Tex.App.1985) (reviewing for constitutionality while recognizing that t

1998See, e.g., White Egret Condominium, Inc. v. Franklin, 379 So.2d 346 (Fla. 1979) (equal protection); Majestic View Condominium Ass'n v. Bolotin, 429 So.2d 438 (Fla. 4th Dist.Ct.App.1983) (procedural due process); cf. Thanasoulis v. Winston Tower 200 Ass'n, 214 N.J.Super. 408 , 519 A.2d 911 (1986) (finding constitutional principles inapplicable for lack of state action), rev'd on other grounds, 110 N.J. 650 , 542 A.2d 900 , 76 A.L.R.4th 273 (N.J.1988); Covered Bridge Condominium Ass'n, Inc. v. Chambliss, 705 S.W.2d 211, 213 (Tex.App.1985) (reviewing for constitutionality while recognizing that t

11998–1998
Cologne v. Westfarms Associates green
conn · 1984
2 sentences

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis. 2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and his

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis. 2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and his

11989–1989
Jacobs v. Major green
wis · 1987
2 sentences

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis. 2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and his

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis. 2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and his

11989–1989
Sharrock v. Dell Buick-Cadillac, Inc. green
ny · 1978
2 sentences

1989In Sharrock v. Dell Buick-Cadillac, Inc., 45 N.Y.2d 152 , 379 N.E.2d 1169 , 408 N.Y.S.2d 39 (1978), the New York Court of Appeals developed a flexible "state involvement" test when applying the state constitution's due process clause to a dispute over a nonjudicial foreclosure sale.

1989In Sharrock v. Dell Buick-Cadillac, Inc., 45 N.Y.2d 152 , 379 N.E.2d 1169 , 408 N.Y.S.2d 39 (1978), the New York Court of Appeals developed a flexible "state involvement" test when applying the state constitution's due process clause to a dispute over a nonjudicial foreclosure sale.

11989–1989
Woodland v. Michigan Citizens Lobby neutral
mich · 1986
2 sentences

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis. 2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and his

1989See SHAD Alliance v. Smith Haven Mall, 66 N.Y.2d 496 , 488 N.E.2d 1211 , 498 N.Y.S.2d 99 (1985) (court looked at debates at the state constitutional convention and concluded that framers intended a state action requirement; reiterated that Bill of Rights is meant to protect individuals from State, not other private individuals); Cologne v. Westfarms Assocs., 192 Conn. 48 , 469 A.2d 1201 (1984) (court found "no historical basis" for a lack of a state action requirement); Jacobs v. Major, 139 Wis.2d 492 , 407 N.W.2d 832 (1987) (construed state action requirement through "plain language" and hist

11989–1989
PruneYard Shopping Center v. Robins green
scotus · 1980
2 sentences

1981Ed. 2d 741 , 100 S. Ct. 2035 (1980), a "State in the exercise of its police power may adopt reasonable restrictions on private property so long as the restrictions do not amount to a taking without just compensation or contravene any other federal constitutional provision." Rather than emasculate the state action requirement from the Declaration of Rights, however, I would hold that the activity engaged in here by the defendants is authorized by Const, art. 2, § 1(a) (amendment 7), RCW 29.79, and the cases decided by this court.

1981As noted in Pruneyard Shopping Center v. Robins, 447 U.S. 74, 81 , 64 L.Ed.2d 741 , 100 S.Ct. 2035 (1980), a "State in the exercise of its police power may adopt reasonable restrictions on private property so long as the restrictions do not amount to a taking without just compensation or contravene any other federal constitutional provision." Rather than emasculate the state action requirement from the Declaration of Rights, however, I would hold that the activity engaged in here by the defendants is authorized by Const. art. 2, § 1(a) (amendment 7), RCW 29.79, and the cases decided by this co

11981–1981
Flagg Bros., Inc. v. Brooks green
scotus · 1978
2 sentences

1980Flagg Bros. v. Brooks, 436 U.S. 149 , 56 L.

1980Flagg Bros. v. Brooks, 436 U.S. 149 , 56 L.

11980–1980

Where else courts name it

CA 25 (1978–2026) MA 17 (1977–2020) NY 14 (1971–2025) TX 13 (1979–2026) MD 13 (1981–2015) CT 10 (1984–2020) IL 9 (1983–2006) WI 9 (1986–2026) WA 9 (1980–2023) OH 8 (1986–2020) NJ 6 (1983–2025) PA 6 (1980–2025) IA 6 (1936–2016) MO 5 (1978–2012) MI 5 (1977–2008) FL 5 (1978–2004) AZ 5 (1999–2007) NC 4 (1998–2020) NM 4 (1993–2019) TN 4 (1995–2026) IN 4 (1989–2014) AK 4 (1983–2023) NV 4 (1987–2001) UT 3 (1990–2006) DC 3 (1977–1989) ME 3 (2000–2009) DE 2 (1976–2013) ID 2 (1998–2026) NH 2 (1990–2003) MT 2 (1988–1990) AL 2 (2011–2014) GA 2 (1984–1997) AR 2 (2006–2008) RI 2 (2001–2001) CO 2 (1991–1997) MN 2 (1979–2005) SC 2 (2002–2003) LA 2 (1999–2008)

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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