estoppel doctrine (Washington) · Go Syfert
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estoppel doctrine in Washington

55 Washington opinions name it 2 courts 1895–2020 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 (16)

CaseFollowedCited
Cooper v. Baergreen
wash · 1962 · cited in 2 Washington opinions naming this issue, 2020–2020
2 sentences

2020See Cooper v. Baer, 59 Wn.2d 763, 763 , 370 P.2d 871 (1962) (illegal contracts may not be enforced by estoppel) (citing State v. Nw.

2020See Cooper v. Baer, 59 Wn.2d 763, 763 , 370 P.2d 871 (1962) (illegal contracts may not be enforced by estoppel) (citing State v. Nw.

22
SEATTLE PROFESSIONAL ENGINEERING EMP'S ASS'N v. Boeing Co.green
wash · 2000 · cited in 2 Washington opinions naming this issue, 2007–2007
2 sentences

2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law).

2007See Cannon v. Miller, 22 Wash.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds, Seattle Prof'l Eng'g Employees Ass'n v. Boeing Co., 139 Wash.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal Labor Standards Act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law).

22
Seattle Professional Engineering Employees Ass'n v. Boeing Co.green
wash · 2000 · cited in 2 Washington opinions naming this issue, 2007–2007
2 sentences

2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law).

2007See Cannon v. Miller, 22 Wash.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds, Seattle Prof'l Eng'g Employees Ass'n v. Boeing Co., 139 Wash.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal Labor Standards Act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law).

22
SPEEA v. Boeing Co.green
wash · 2000 · cited in 2 Washington opinions naming this issue, 2007–2007
2 sentences

2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law).

2007See Cannon v. Miller, 22 Wash.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds, Seattle Prof'l Eng'g Employees Ass'n v. Boeing Co., 139 Wash.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal Labor Standards Act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law).

22
Cannon v. Millergreen
wash · 1945 · cited in 2 Washington opinions naming this issue, 2007–2007
2 sentences

2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law).

2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law).

22
Gowdy v. Richtergreen
illappct · 1974 · cited in 2 Washington opinions naming this issue, 2006–2006
2 sentences

2006The sellers wished to defend by showing that the purchasers had sought rescission only after learning that the oil wells were not productive, but the court refused to allow the estoppel defense, reasoning that it "would tend to nullify and defeat the very purpose of the statute, which is clearly penal in nature." Id. at 585 ; see also Gowdy v. Richter, 20 Ill.App.3d 514, 525 , 314 N.E.2d 549 (1974) (concluding that the Illinois Blue Sky Law "is clear in allowing only statutory, not equitable, defenses" and observing that the Law's "penal character" forecloses the " in pari delicto or estoppel

2006The sellers wished to defend by showing that the purchasers had sought rescission only after learning that the oil wells were not productive, but the court refused to allow the estoppel defense, reasoning that it “would tend to nullify and defeat the very purpose of the statute, which is clearly penal in nature.” Id. at 585 ; see also Gowdy v. Richter, 20 Ill.

22
Ranker v. Skyline Corp.green
pa · 1985 · cited in 2 Washington opinions naming this issue, 2000–2000
2 sentences

2000We agree with Isuzu that the repair doctrine, which “is merely a particularized form of estoppel,” Ranker v. Skyline Corp., 342 Pa. Super. 510 , 493 A.2d 706, 709 (1985), is inconsistent with the estoppel principle in Del Guzzi Constr.

2000We agree with Isuzu that the repair doctrine, which “is merely a particularized form of estoppel,” Ranker v. Skyline Corp., 342 Pa. Super. 510 , 493 A.2d 706, 709 (1985), is inconsistent with the estoppel principle in Del Guzzi Constr.

22
Thomas v. Harlangreen
wash · 1947 · cited in 2 Washington opinions naming this issue, 1976–2012
2 sentences

2012Thus, Southview fails to establish the first element of the estoppel test: “an admission, statement, or act inconsistent with the claim afterwards asserted.” Thomas, 27 Wn.2d at 518 . *56 2.

1976See Thomas v. Harlan, 27 Wn.2d 512 , 178 P.2d 965 , 170 A.L.R. 1138 (1947).

12
Department of Ecology v. Theodoratusgreen
wash · 1998 · cited in 1 Washington opinions naming this issue, 2008–2008
1 sentence

2008See Dep’t of Ecology v. Theodoratus, 135 Wn.2d 582, 599 , 957 P.2d 1241 (1998) (citing Berschauer/ Phillips Constr.

11
State, Dept. of Ecology v. Theodoratusgreen
wash · 1998 · cited in 1 Washington opinions naming this issue, 2008–2008
1 sentence

2008See Dep’t of Ecology v. Theodoratus, 135 Wn.2d 582, 599 , 957 P.2d 1241 (1998) (citing Berschauer/ Phillips Constr.

11
Fred Tonniesgreen
· 1995 · cited in 1 Washington opinions naming this issue, 2001–2001
11
New Hampshire v. Mainegreen
scotus · 2001 · cited in 1 Washington opinions naming this issue, 2001–2001
11
Buechel v. Department of Ecologygreen
wash · 1994 · cited in 1 Washington opinions naming this issue, 1999–1999
11
John T. Kennedy v. United States of America, Third Party v. Harold C. Gatewood, Third Partygreen
ca3 · 1992 · cited in 1 Washington opinions naming this issue, 1993–1993
11
Shufeldt v. Department of Labor & Industriesgreen
wash · 1961 · cited in 1 Washington opinions naming this issue, 1982–1982
11
Summers v. Superior Courtgreen
cal · 1959 · cited in 1 Washington opinions naming this issue, 1974–1974
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Conway Import Company v. United Statesgreen
nyed · 1969 · cited in 1 Washington opinions naming this issue, 1983–1983
11

Also cited on this issue (60)

CaseCitedYears
Finch v. Matthews green
wash · 1968
2 sentences

2005If a state agent lacks legal authority, "`no void act of theirs can be cured by aid of the doctrine of estoppel.'" Barendregt, 26 Wash.App. at 250 , 611 P.2d 1385 (quoting Finch, 74 Wash.2d at 172 , 443 P.2d 833 ).

2005If a state agent lacks legal authority, "`no void act of theirs can be cured by aid of the doctrine of estoppel.'" Barendregt, 26 Wash.App. at 250 , 611 P.2d 1385 (quoting Finch, 74 Wash.2d at 172 , 443 P.2d 833 ).

41981–2008
Barendregt v. Walla Walla School District No. 140 neutral
washctapp · 1980
2 sentences

2008If a state agent lacks legal authority, "no void act of theirs can be cured by aid of the doctrine of estoppel." Barendregt, 26 Wash.App. at 250 , 611 P.2d 1385 . ¶ 24 DSHS has statutory authority to negotiate settlements.

2008If a state agent lacks legal authority, “ ‘no void act of theirs can be cured by aid of the doctrine of estoppel.’ ” Barendregt, 26 Wn.

42005–2008
Midwest Management Corp. v. Stephens green
iowa · 1980
2 sentences

2006The Iowa Supreme Court reversed the summary dismissal of Midwest's suit and held that the estoppel defense was available to stock seller Midwest, despite its violation of the registration requirements. 291 N.W.2d at 908 .

2006The Iowa Supreme Court reversed the summary dismissal of Midwest’s suit and held that the estoppel defense was available to stock seller Midwest, despite its violation of the registration requirements. 291 N.W.2d at 908 .

22006–2006
Covert v. Cross green
mo · 1960
2 sentences

2006The sellers wished to defend by showing that the purchasers had sought rescission only after learning that the oil wells were not productive, but the court refused to allow the estoppel defense, reasoning that it "would tend to nullify and defeat the very purpose of the statute, which is clearly penal in nature." Id. at 585 ; see also Gowdy v. Richter, 20 Ill.App.3d 514, 525 , 314 N.E.2d 549 (1974) (concluding that the Illinois Blue Sky Law "is clear in allowing only statutory, not equitable, defenses" and observing that the Law's "penal character" forecloses the " in pari delicto or estoppel

2006The sellers wished to defend by showing that the purchasers had sought rescission only after learning that the oil wells were not productive, but the court refused to allow the estoppel defense, reasoning that it “would tend to nullify and defeat the very purpose of the statute, which is clearly penal in nature.” Id. at 585 ; see also Gowdy v. Richter, 20 Ill.

22006–2006
Logan v. Panuska green
minn · 1980
2 sentences

2006The Minnesota Supreme Court held that the restaurant seller could assert an estoppel defense since the purchasers "were not induced to buy the stock through any misrepresentation of the defendant as to the financial condition of the restaurant ... [and had] actively participated in the management and control of the corporation during the course of their investment." 293 N.W.2d at 363-64 . ¶ 13 In sum, Midwest and Logan would be analogous to the present case only if Go2Net's basis for rescinding its purchase of FreeYellow had been the Act's registration requirement, RCW 21.20.140, rather than i

2006The Minnesota Supreme Court held that the restaurant seller could assert an estoppel defense since the purchasers “were not induced to buy the stock through any misrepresentation of the defendant as to the financial condition of the restaurant [and had] actively participated in the management and control of the corporation during the course of their investment.” 293 N.W.2d at 363-64 . ¶13 In sum, Midwest and Logan would be analogous to the present case only if Go2Net’s basis for rescinding its purchase of FreeYellow had been the Act’s registration requirement, RCW 21.20.140, rather than its an

22006–2006
Standefer v. United States green
scotus · 1980
2 sentences

2003The Court held that these “ ‘competing policy considerations’ ” outweighed the “economy concerns that undergird the estoppel doctrine.” Standefer, 447 U.S. at 25 . 3 We agree with the Supreme Court’s reasoning in Standefer .

2003The Court held that these "`competing policy considerations'" outweighed the "economy concerns that undergird the estoppel doctrine." Standefer, 447 U.S. at 25 , 100 S.Ct. 1999 . [3] We agree with the Supreme Court's reasoning in Standefer .

22003–2003
State v. Ager green
wash · 1995
2 sentences

2002Ager, 128 Wn.2d at 96 .

2002Ager, 128 Wash.2d at 96 , 904 P.2d 715 .

22002–2002
United States v. James Gordon Lansing green
ca9 · 1970
2 sentences

2002Barker, 546 F.2d at 940 ; Lansing, 424 F.2d 225 .

2002Barker, 546 F.2d at 940 ; Lansing, 424 F.2d at 225 .

22002–2002
United States v. Bernard L. Barker, United States of America v. Eugenio R. Martinez green
cadc · 1976
2 sentences

2002Barker, 546 F.2d at 940 ; Lansing, 424 F.2d 225 .

2002Barker, 546 F.2d at 940 ; Lansing, 424 F.2d at 225 .

22002–2002
Raymond v. Ingram green
washctapp · 1987
2 sentences

2001Thus, the following have been enumerated as essentials to the establishment of an estoppel under the rule that a position taken in an earlier action estops the one taking such position from assuming an inconsistent position in a later action: (1) The inconsistent position first asserted must have been successfully maintained; (2) a judgment must have been rendered; (3) the positions must be clearly inconsistent; (4) the parties and questions must be the same; (5) the party claiming estoppel must have been misled and have changed his position; (6) it must appear unjust to one party to permit th

2001Thus, the following have been enumerated as essentials to the establishment of an estoppel under the rule that a position taken in an earlier action estops the one taking such position from assuming an inconsistent position in a later action: (1) The inconsistent position first asserted must have been successfully maintained; (2) a judgment must have been rendered; (3) the positions must be clearly inconsistent; (4) the parties and questions must be the same; (5) the party claiming estoppel must have been misled and have changed his position; (6) it must appear unjust to one party to permit th

22001–2001
Markley v. Markley green
wash · 1948
2 sentences

2001Thus, the following have been enumerated as essentials to the establishment of an estoppel under the rule that a position taken in an earlier action estops the one taking such position from assuming an inconsistent position in a later action: (1) The inconsistent position first asserted must have been successfully maintained; (2) a judgment must have been rendered; (3) the positions must be clearly inconsistent; (4) the parties and questions must be the same; (5) the party claiming estoppel must have been misled and have changed his position; (6) it must appear unjust to one party to permit th

2001Thus, the following have been enumerated as essentials to the establishment of an estoppel under the rule that a position taken in an earlier action estops the one taking such position from assuming an inconsistent position in a later action: (1) The inconsistent position first asserted must have been successfully maintained; (2) a judgment must have been rendered; (3) the positions must be clearly inconsistent; (4) the parties and questions must be the same; (5) the party claiming estoppel must have been misled and have changed his position; (6) it must appear unjust to one party to permit th

22001–2001
State v. City of Pullman neutral
wash · 1900
2 sentences

1980If there is no authority vested by law in officers or agents, "no void act of theirs can be cured by aid of the doctrine of estoppel." Finch v. Matthews, supra at 172, quoting from State v. Pullman, 23 Wash. 583, 592 , 63 P. 265 (1900).

1980If there is no authority vested by law in officers or agents, "no void act of theirs can be cured by aid of the doctrine of estoppel." Finch v. Matthews, supra at 172, quoting from State v. Pullman, 23 Wash. 583, 592 , 63 P. 265 (1900).

21968–1980
Vinneau v. Goede green
wash · 1957
2 sentences

1975In Vinneau v. Goede, 50 Wn.2d 39 , 309 P.2d 376 (1957), we held that the question whether there was an intent to waive is one of fact.

1975In Vinneau v. Goede, 50 Wn.2d 39 , 309 P.2d 376 (1957), we held that the question whether there was an intent to waive is one of fact.

21969–1975
Kessinger v. Anderson green
wash · 1948
2 sentences

1975While reliance is not a requirement, as it is in the doctrine of estoppel (see Kessinger v. Anderson, 31 Wn.2d 157 , 196 P.2d 289 (1948) ), it is still necessary to show that the party who it is claimed has waived a right, did so intentionally and with full knowledge of his rights.

1975While reliance is not a requirement, as it is in the doctrine of estoppel (see Kessinger v. Anderson, 31 Wn.2d 157 , 196 P.2d 289 (1948) ), it is still necessary to show that the party who it is claimed has waived a right, did so intentionally and with full knowledge of his rights.

21969–1975
Hamilton v. Home Fire Insurance neutral
neb · 1894
2 sentences

1944Co., 42 Neb. 883 , 61 N. W. 93 , that knowledge of the existence of a right and the intention to relinquish it must concur to create an estoppel by waiver.

1944Co., 42 Neb. 883 , 61 N. W. 93 , that knowledge of the existence of a right and the intention to relinquish it must concur to create an estoppel by waiver.

21906–1944
Lybbert v. Grant County, State of Wash. green
wash · 2000
1 sentence

2015Lybbert v. Grant County, 141 Wn.2d 29, 35 , 1 P. 3d 1124 ( 2000).

12015–2015
Lybbert v. Grant County green
wash · 2000
2 sentences

2015Lybbert v. Grant County, 141 Wn.2d 29, 35 , 1 P. 3d 1124 ( 2000).

2015Lybbert, 141 Wn.2d at 35 .

12015–2015
Ash v. Department of Labor & Industries neutral
washctapp · 2013
1 sentence

2015App. 559, 566-67 , 294 P.3d 834 (2013). -18- NO. 71114-8-1/19 But a party seeking damages based on an estoppel claim must assert a promissory estoppel claim, not a claim for equitable estoppel.40 While at least one Washington case recasts a claim for equitable estoppel as one for promissory estoppel,41 we decline to do so here.

12015–2015
Niemann v. Vaughn Community Church green
wash · 2005
1 sentence

2014Niemann v. Vaughn Cmty. Church, 154 Wn.2d 365, 374 , 113 P.3d 463 (2005). ¶105 The Club’s estoppel defense is not viable because the County’s enforcement of its Code and nuisance law is not inconsistent with its earlier position.

12014–2014
Niemann v. Vaughn Community Church green
wash · 2005
1 sentence

2014Niemann v. Vaughn Cmty. Church, 154 Wn.2d 365, 374 , 113 P.3d 463 (2005). ¶105 The Club’s estoppel defense is not viable because the County’s enforcement of its Code and nuisance law is not inconsistent with its earlier position.

12014–2014
State v. O'CONNELL green
wash · 1974
12005–2005
State v. Ager green
wash · 1995
12002–2002
Del Guzzi Constr. Co. v. Global Northwest Ltd., Inc. green
wash · 1986
12000–2000
Hillis Homes, Inc. v. Snohomish County green
wash · 2002
11992–1992
Shafer v. State green
wash · 1974
11991–1991
Saunders v. Lloyd's of London green
wash · 1989
11991–1991
McDaniels v. Carlson green
wash · 1987
11991–1991
Group Health Cooperative of Puget Sound, Inc. v. Department of Revenue green
wash · 1986
11987–1987
Harbor Air Service, Inc. v. Board of Tax Appeals green
wash · 1977
11987–1987
Wilson Simmons v. United States green
ca5 · 1962
11983–1983
Wahler v. Department of Social & Health Services green
washctapp · 1978
11982–1982
State v. Charlton green
wash · 1967
11981–1981
Lloyd Hammerstad, Inc. v. Saunders green
washctapp · 1972
11974–1974
Clients' Service, Inc. v. Pupo green
wash · 1967
11974–1974
In Re the Puget Sound Pilots Ass'n green
wash · 1963
11974–1974
Miles v. Chinto Mining Co. green
wash · 1944
11974–1974
Whiting v. Johnson green
wash · 1964
11974–1974
State v. Northwest Magnesite Co. green
wash · 1947
11957–1957
Carpenter v. Okanogan County neutral
wash · 1931
11953–1953
Mottin v. Board of County Commissioners green
kan · 1913
11947–1947

Statutes the citing opinions construe

WA § Wash. Rev. Code § 49.48.030 (3) WA § Wash. Rev. Code § 49.60.010 (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

CA 370 (1890–2026) IL 282 (1877–2025) TX 227 (1881–2025) NY 226 (1828–2025) PA 136 (1849–2025) FL 84 (1904–2024) MI 73 (1871–2026) NJ 71 (1881–2026) MO 67 (1877–2025) AL 63 (1846–2023) TN 60 (1895–2024) CT 58 (1896–2024) WI 58 (1869–2023) WA 55 (1895–2020) IN 54 (1861–2023) OR 54 (1897–2026) OH 53 (1897–2026) SC 49 (1846–2022) MA 47 (1889–2025) GA 46 (1914–2021) MD 45 (1907–2024) VA 44 (1877–2026) OK 40 (1901–2024) NC 39 (1887–2017) MN 38 (1894–2016) AZ 36 (1924–2024) KY 35 (1876–2024) IA 35 (1864–2024) LA 33 (1910–2016) CO 33 (1891–2025) MS 30 (1893–2024) NE 28 (1884–2025) WV 27 (1888–2020) DC 26 (1953–2015) AR 26 (1896–2012) RI 25 (1877–2011) NM 24 (1912–2022) UT 23 (1921–2025) ND 23 (1912–2023) MT 20 (1924–2019) ID 19 (1895–2022) SD 19 (1894–2021) KS 18 (1900–2012) HI 17 (1952–2015) ME 17 (1889–2021) VT 14 (1902–2024) WY 12 (1923–2008) DE 11 (1947–2024) NH 10 (1932–2019) AK 9 (1983–2015) NV 9 (1947–2017) PR 2 (1916–2003)

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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