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

8 Washington opinions name it 2 courts 1997–2025 3 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 (1)

CaseFollowedCited
Jayedeane Thompson v. American Home Assurance Company, Cross-Appelleegreen
ca6 · 1996 · cited in 1 Washington opinions naming this issue, 2003–2003
1 sentence

2003The Sixth Circuit discussed the tension between Johnson and Hansen in Thompson v. American Home Assurance Co., 95 F.3d 429, 435-36 (6th Cir. 1996).

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 (11)

CaseCitedYears
State v. Parker green
wash · 1997
1 sentence

2025Parker, 132 Wn.2d at 189 .

12025–2025
State v. Allen green
wash · 2018
1 sentence

2025This court has previously recognized “the difference in analysis between multiple prosecutions and multiple punishments.” Arndt, 194 Wn.2d at 817 (citing State v. Allen, 192 Wn.2d 526 , 541, 431 P.3d 117 (2018)).

12025–2025
State v. Arndt green
wash · 2019
1 sentence

2025This court has previously recognized “the difference in analysis between multiple prosecutions and multiple punishments.” Arndt, 194 Wn.2d at 817 (citing State v. Allen, 192 Wn.2d 526 , 541, 431 P.3d 117 (2018)).

12025–2025
State v. Quismundo green
wash · 2008
1 sentence

2023App. 2d 433, 450 n.7, 523 P.3d 822 (2023) (“[O]ur Supreme Court has made clear that a court’s ‘obligation to follow the law remains the same regardless of the arguments raised by the parties before it.’ ” (quoting State v. Quismundo, 164 Wn.2d 499, 505-06 , 192 P.3d 342 (2008))). 16 No. 83745-1-I/17 have made a difference in the analysis. 7 Indeed, the statute applies to claims arising from a person “having constructed, altered, or repaired any improvement upon real property.” RCW 4.16.300 (emphasis added).

12023–2023
State v. Quismundo green
wash · 2008
1 sentence

2023App. 2d 433, 450 n.7, 523 P.3d 822 (2023) (“[O]ur Supreme Court has made clear that a court’s ‘obligation to follow the law remains the same regardless of the arguments raised by the parties before it.’ ” (quoting State v. Quismundo, 164 Wn.2d 499, 505-06 , 192 P.3d 342 (2008))). 16 No. 83745-1-I/17 have made a difference in the analysis. 7 Indeed, the statute applies to claims arising from a person “having constructed, altered, or repaired any improvement upon real property.” RCW 4.16.300 (emphasis added).

12023–2023
State v. Kelley green
wash · 2010
1 sentence

2019Significantly, we distinguished Kelley, 168 Wn.2d 72 , a case that considered "whether imposition-of a firearm enhancement where use of a firearm was an element of the underlying offense violated the double jeopardy prohibition on multiple punishments for the same offense." Allen, 192 Wn.2d at 542.

12019–2019
Baroid Division of Nl Industries, Inc. v. Occupational Safety and Health Review Commission and Ray Marshall, Secretary of Labor green
ca10 · 1981
1 sentence

2017Apr. 20, 1993). 40 SeaWorld of Florida, 748 F.3d at 1215 (quoting Baroid, 660 F.2d at 447 ). 41 Br. of App. at 25. 12 No. 75615-0-1-13 Rain for Rent contends having the manual with the machine would not have made a difference because the warning is for maintenance or chip removal only "in the context of cleaning shavings 'out of pipe ends.'"42 But the manual refers to removing "shavings out of pipe ends and from between thejaws."43 Landdeck was removing plastic shavings from "between the jaws" at the time of the incident.

12017–2017
Sea World of Florida, LLC v. Thomas Perez green
cadc · 2014
1 sentence

2017Apr. 20, 1993). 40 SeaWorld of Florida, 748 F.3d at 1215 (quoting Baroid, 660 F.2d at 447 ). 41 Br. of App. at 25. 12 No. 75615-0-1-13 Rain for Rent contends having the manual with the machine would not have made a difference because the warning is for maintenance or chip removal only "in the context of cleaning shavings 'out of pipe ends.'"42 But the manual refers to removing "shavings out of pipe ends and from between thejaws."43 Landdeck was removing plastic shavings from "between the jaws" at the time of the incident.

12017–2017
State v. Wade green
wash · 1999
1 sentence

2005RAP 9.10; State v. Wade, 138 Wn.2d 460 , 979 P.2d 850 (1999).

12005–2005
State v. Wade green
wash · 1999
1 sentence

2005RAP 9.10; State v. Wade, 138 Wn.2d 460 , 979 P.2d 850 (1999).

12005–2005
Parratt v. Taylor red
scotus · 1981
2 sentences

1997Parratt v. Taylor, 451 U.S. 527, 542 , 101 S.Ct. 1908, 1916 , 68 L.Ed.2d 420 (1981).

1997Parratt v. Taylor, 451 U.S. 527, 542 , 101 S.Ct. 1908, 1916 , 68 L.Ed.2d 420 (1981).

11997–1997

Where else courts name it

NY 22 (1838–2024) CA 20 (1868–2018) TX 15 (1880–2019) PA 11 (1908–2020) NJ 10 (1913–2020) IL 9 (1926–2025) MD 8 (1998–2014) MO 8 (1851–2016) LA 8 (1923–2019) WA 8 (1997–2025) MI 6 (1900–2017) OH 6 (1887–2015) IA 6 (1914–2018) IN 6 (1893–1980) NC 6 (1918–2004) WI 6 (1914–2000) KS 6 (1925–2008) FL 5 (1878–2005) GA 5 (1916–2018) CT 5 (1997–2019) TN 5 (1925–2014) CO 4 (2002–2024) OR 4 (1984–2026) HI 4 (1994–2012) DC 4 (1981–2025) MN 3 (1893–1969) DE 3 (1932–2019) KY 3 (1917–1973) WV 2 (1919–1920) ND 2 (2020–2020) AL 2 (1925–1926) NM 2 (1977–2025) ID 2 (2009–2014)

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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