fugitive disentitlement doctrine (Washington) · Go Syfert
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fugitive disentitlement doctrine in Washington

8 Washington opinions name it 2 courts 2006–2019 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
Redden v. Stategreen
del · 1980 · cited in 2 Washington opinions naming this issue, 2017–2017
2 sentences

2017Redden v. State, 418 A.2d 996,997 (Del. 1980)), dismiss a defendant's appeal pursuant to the fugitive disentitlement doctrine if (1)the defendant absconds without justification and (2)the delay causes prejudice to the justice system or to the State.

2017Redden v. State, 418 A.2d 996,997 (Del. 1980)), dismiss a defendant's appeal pursuant to the fugitive disentitlement doctrine if (1)the defendant absconds without justification and (2)the delay causes prejudice to the justice system or to the State.

22
City of Seattle v. Kleingreen
wash · 2007 · cited in 2 Washington opinions naming this issue, 2009–2019
2 sentences

2019See City of Seattle v. Klein, 161 Wn.2d 554, 559 , 166 P.3d 1149 (2007) (doctrine applying presumption that defendant in criminal appeal who files an appeal and flees the jurisdiction forfeits right to pursue appeal) 3 No. 78246-1 -114 corpus for an abuse of discretion.

2009Id. at 559, 166 P.3d 1149 .

12
City of Seattle v. Kleingreen
wash · 2007 · cited in 1 Washington opinions naming this issue, 2019–2019
1 sentence

2019See City of Seattle v. Klein, 161 Wn.2d 554, 559 , 166 P.3d 1149 (2007) (doctrine applying presumption that defendant in criminal appeal who files an appeal and flees the jurisdiction forfeits right to pursue appeal) 3 No. 78246-1 -114 corpus for an abuse of discretion.

11
State v. Frenchgreen
wash · 2006 · cited in 1 Washington opinions naming this issue, 2007–2007
2 sentences

2007Id. at 602 n.2. 9 The court then held that “the fugitive disentitlement doctrine generally does not apply to a defendant who absconds after conviction but before sentencing.” Id. at 602. ¶20 The City argues that the trial court’s reliance on French is misplaced because nothing in its language purports to overrule any of the cases applying the FDD to a defendant who has already been sentenced and has filed a notice of appeal before fleeing the court’s jurisdiction.

2007Id. at 602 n.2. 9 The court then held that “the fugitive disentitlement doctrine generally does not apply to a defendant who absconds after conviction but before sentencing.” Id. at 602. ¶20 The City argues that the trial court’s reliance on French is misplaced because nothing in its language purports to overrule any of the cases applying the FDD to a defendant who has already been sentenced and has filed a notice of appeal before fleeing the court’s jurisdiction.

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 (3)

CaseCitedYears
State v. Handy green
wash · 1902
2 sentences

2006Washington courts first recognized the doctrine in State v. Handy, 27 Wash. 469 , 67 P. 1094 (1902).

2006Washington courts first recognized the doctrine in State v. Handy, 27 Wash. 469 , 67 P. 1094 (1902).

22006–2006
State v. Sweet green
wash · 1978
2 sentences

2007No findings of "extremely dilatory" conduct were entered by the court in the instant case. [8] Citing Sweet, 90 Wash.2d at 286 , 581 P.2d 579 . [9] "French appears to be arguing the fugitive disentitlement doctrine itself is unconstitutional, regardless of whether it is applied to a defendant who flees the jurisdiction before or after instigating an appeal.

2007No findings of "extremely dilatory" conduct were entered by the court in the instant case. [8] Citing Sweet, 90 Wash.2d at 286 , 581 P.2d 579 . [9] "French appears to be arguing the fugitive disentitlement doctrine itself is unconstitutional, regardless of whether it is applied to a defendant who flees the jurisdiction before or after instigating an appeal.

12007–2007
State v. French green
wash · 2006
2 sentences

2007Id. at 602 n. 2, 141 P.3d 54 . [9] The court then held that "the fugitive disentitlement doctrine generally does not apply to a defendant who absconds after conviction but before sentencing." Id. at 602, 141 P.3d 54 . ¶ 20 The City argues that the trial court's reliance on French is misplaced because nothing in its language purports to overrule any of the cases applying the FDD to a defendant who has already been sentenced and has filed a notice of appeal before fleeing the court's jurisdiction.

2007Id. at 602 n. 2, 141 P.3d 54 . [9] The court then held that "the fugitive disentitlement doctrine generally does not apply to a defendant who absconds after conviction but before sentencing." Id. at 602, 141 P.3d 54 . ¶ 20 The City argues that the trial court's reliance on French is misplaced because nothing in its language purports to overrule any of the cases applying the FDD to a defendant who has already been sentenced and has filed a notice of appeal before fleeing the court's jurisdiction.

12007–2007

Statutes the citing opinions construe

WA § Wash. Rev. Code § 9.94A.589 (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

NY 28 (2002–2025) VA 10 (2007–2024) CA 8 (2009–2026) WA 8 (2006–2019) TN 6 (2006–2022) NJ 5 (2002–2022) KS 3 (2009–2021) CT 3 (2011–2023) MS 2 (2008–2008) PA 2 (2018–2023) SC 2 (2000–2010) IL 2 (2021–2021) GA 2 (2017–2023) ND 2 (2000–2022)

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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