defendant must prove defense (Washington) · Go Syfert
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defendant must prove defense in Washington

8 Washington opinions name it 2 courts 1984–2022 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
State v. Torresgreen
utah · 1980 · cited in 1 Washington opinions naming this issue, 1984–1984
2 sentences

1984See also Berrier v. Egeler, 583 F.2d 515, 517 (6th Cir.), cert. denied, 439 U.S. 955 , 58 L.Ed.2d 347 , 99 S.Ct. 354 (1978) (failure to allocate burden to the State "implies that the defendant must prove his claim of self-defense"); State v. Torres, 619 P.2d 694, 695 (Utah 1980) (failure to instruct "that the defendant need not prove his defense" is reversible error).

1984Ed. 2d 347 , 99 S. Ct. 354 (1978) (failure to allocate burden to the State "implies that the defendant must prove his claim of self-defense"); State v. Torres, 619 P.2d 694, 695 (Utah 1980) (failure to instruct "that the defendant need not prove his defense" is reversible error).

11
Harrison Berrier v. Charles E. Egeler, Warden, State Prison of Southern Michigan at Jacksongreen
ca6 · 1978 · cited in 1 Washington opinions naming this issue, 1984–1984
1 sentence

1984See also Berrier v. Egeler, 583 F.2d 515, 517 (6th Cir.), cert. denied, 439 U.S. 955 , 58 L.Ed.2d 347 , 99 S.Ct. 354 (1978) (failure to allocate burden to the State "implies that the defendant must prove his claim of self-defense"); State v. Torres, 619 P.2d 694, 695 (Utah 1980) (failure to instruct "that the defendant need not prove his defense" is reversible error).

11
Statewide Contractors, Inc. v. Fowler, White, Gillen, Boggs, Villareal & Bankergreen
scotus · 1978 · cited in 1 Washington opinions naming this issue, 1984–1984
2 sentences

1984See also Berrier v. Egeler, 583 F.2d 515, 517 (6th Cir.), cert. denied, 439 U.S. 955 , 58 L.Ed.2d 347 , 99 S.Ct. 354 (1978) (failure to allocate burden to the State "implies that the defendant must prove his claim of self-defense"); State v. Torres, 619 P.2d 694, 695 (Utah 1980) (failure to instruct "that the defendant need not prove his defense" is reversible error).

1984Ed. 2d 347 , 99 S. Ct. 354 (1978) (failure to allocate burden to the State "implies that the defendant must prove his claim of self-defense"); State v. Torres, 619 P.2d 694, 695 (Utah 1980) (failure to instruct "that the defendant need not prove his defense" is reversible error).

11
Sac & Fox Tribe of the Mississippi in Iowa v. Licklidergreen
scotus · 1978 · cited in 1 Washington opinions naming this issue, 1984–1984
1 sentence

1984See also Berrier v. Egeler, 583 F.2d 515, 517 (6th Cir.), cert. denied, 439 U.S. 955 , 58 L.Ed.2d 347 , 99 S.Ct. 354 (1978) (failure to allocate burden to the State "implies that the defendant must prove his claim of self-defense"); State v. Torres, 619 P.2d 694, 695 (Utah 1980) (failure to instruct "that the defendant need not prove his defense" is reversible error).

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 (6)

CaseCitedYears
State v. White green
washctapp · 2007
2 sentences

2018White, 137 Wn.

2014State v. White, 137 Wn.

22014–2018
State v. Jeffrey green
washctapp · 1995
2 sentences

2007Jeffrey, 77 Wash.App. at 225 , 889 P.2d 956 ; WPIC 18.02. ¶ 8 Comparing the two defenses, the statutory defense is a specific iteration of the principles underlying the necessity defense.

2007Jeffrey, 77 Wn.

22007–2007
State v. Sutherby green
wash · 2009
1 sentence

2022App. 2d 245 , 257, 477 P.3d 61 (2020) (citing State v. Sutherby, 165 Wn.2d 870, 883 , 204 P.3d 916 (2009)). 7 No. 83418-5-I/8 A defendant bears the burden of proving defense counsel was ineffective. 18 The defendant must prove defense counsel’s performance was deficient and prejudiced the outcome of trial.19 Failure to prove either deficiency or prejudice ends the analysis.20 After the State presented its case-in-chief, defense counsel asked for a hearing without the State present in order to discuss an issue involving RPC 3.3(a)(4), which prohibits a lawyer from “knowingly . . . offer[ing] ev

12022–2022
State v. Sutherby green
wash · 2009
1 sentence

2022App. 2d 245 , 257, 477 P.3d 61 (2020) (citing State v. Sutherby, 165 Wn.2d 870, 883 , 204 P.3d 916 (2009)). 7 No. 83418-5-I/8 A defendant bears the burden of proving defense counsel was ineffective. 18 The defendant must prove defense counsel’s performance was deficient and prejudiced the outcome of trial.19 Failure to prove either deficiency or prejudice ends the analysis.20 After the State presented its case-in-chief, defense counsel asked for a hearing without the State present in order to discuss an issue involving RPC 3.3(a)(4), which prohibits a lawyer from “knowingly . . . offer[ing] ev

12022–2022
State v. Deer green
wash · 2012
2 sentences

2014State v. Deer, 175 Wn.2d 725, 736 , 287 P.3d 539 (2012). ¶43 The court instructed the jury that involuntary intoxication is a defense to assault if the defendant proves by a preponderance of the evidence that Stacy was given drugs by force or fraud and the drugs prevented him from forming the intent to assault.

2014State v. Deer, 175 Wn.2d 725, 736 , 287 P.3d 539 (2012). ¶43 The court instructed the jury that involuntary intoxication is a defense to assault if the defendant proves by a preponderance of the evidence that Stacy was given drugs by force or fraud and the drugs prevented him from forming the intent to assault.

12014–2014
State v. Carter green
washctapp · 1982
1 sentence

1984App. 572 , 643 P.2d 916 (1982), in which this court held that, because the intoxication defense negates the element of intent required for third degree assault, it was a violation of due process to instruct the jury that the defendant must prove the defense by a preponderance of the evidence.

11984–1984

Statutes the citing opinions construe

WA § Wash. Rev. Code § 9A.76.010 (3) WA § Wash. Rev. Code § 9A.76.170 (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 70 (1987–2026) MI 10 (2014–2023) WA 8 (1984–2022) MO 7 (2004–2021) TX 6 (1993–2004) LA 4 (1986–2018) MN 3 (2001–2009) CA 2 (2024–2025) AZ 2 (2012–2015) NY 2 (2018–2018)

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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