long-held rule in Washington

7 Washington opinions name it 2 courts 1968–2004 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 (3)

Case	Followed	Cited
State v. Dentgreen wash · 1994 · cited in 2 Washington opinions naming this issue, 1998–1998 2 sentences 1998See Dent, 123 Wash.2d at 479 , 869 P.2d 392 (noting venue need not be proved beyond a reasonable doubt, direct evidence of venue is not required, and circumstantial evidence may establish proper venue) (citing State v. Hardamon, 29 Wash.2d 182, 188 , 186 P.2d 634 (1947); State v. Johnson, 45 Wash.App. 794 , 905 796, 727 P.2d 693 (1986), review denied, 107 Wash.2d 1035 (1987); and clarifying State v. Marino, 100 Wash.2d 719, 727 , 674 P.2d 171 (1984)). 1998See Dent, 123 Wash.2d at 479 , 869 P.2d 392 (noting venue need not be proved beyond a reasonable doubt, direct evidence of venue is not required, and circumstantial evidence may establish proper venue) (citing State v. Hardamon, 29 Wash.2d 182, 188 , 186 P.2d 634 (1947); State v. Johnson, 45 Wash.App. 794 , 905 796, 727 P.2d 693 (1986), review denied, 107 Wash.2d 1035 (1987); and clarifying State v. Marino, 100 Wash.2d 719, 727 , 674 P.2d 171 (1984)).	2	2
State v. Hardamongreen wash · 1947 · cited in 2 Washington opinions naming this issue, 1998–1998 2 sentences 1998See Dent, 123 Wash.2d at 479 , 869 P.2d 392 (noting venue need not be proved beyond a reasonable doubt, direct evidence of venue is not required, and circumstantial evidence may establish proper venue) (citing State v. Hardamon, 29 Wash.2d 182, 188 , 186 P.2d 634 (1947); State v. Johnson, 45 Wash.App. 794 , 905 796, 727 P.2d 693 (1986), review denied, 107 Wash.2d 1035 (1987); and clarifying State v. Marino, 100 Wash.2d 719, 727 , 674 P.2d 171 (1984)). 1998See Dent, 123 Wash.2d at 479 , 869 P.2d 392 (noting venue need not be proved beyond a reasonable doubt, direct evidence of venue is not required, and circumstantial evidence may establish proper venue) (citing State v. Hardamon, 29 Wash.2d 182, 188 , 186 P.2d 634 (1947); State v. Johnson, 45 Wash.App. 794 , 905 796, 727 P.2d 693 (1986), review denied, 107 Wash.2d 1035 (1987); and clarifying State v. Marino, 100 Wash.2d 719, 727 , 674 P.2d 171 (1984)).	2	2
Kirk v. Moegreen wash · 1990 · cited in 2 Washington opinions naming this issue, 1994–1994 2 sentences 1994See Kirk v. Moe, 114 Wn.2d 550, 557 , 789 P.2d 84 (1990); Mutual of Enumclaw Ins. 1994See Kirk v. Moe, 114 Wn.2d 550, 557 , 789 P.2d 84 (1990); Mutual of Enumclaw Ins.	2	2

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (7)

Case	Cited	Years
State v. Johnson green washctapp · 1986 2 sentences 1998See Dent, 123 Wash.2d at 479 , 869 P.2d 392 (noting venue need not be proved beyond a reasonable doubt, direct evidence of venue is not required, and circumstantial evidence may establish proper venue) (citing State v. Hardamon, 29 Wash.2d 182, 188 , 186 P.2d 634 (1947); State v. Johnson, 45 Wash.App. 794 , 905 796, 727 P.2d 693 (1986), review denied, 107 Wash.2d 1035 (1987); and clarifying State v. Marino, 100 Wash.2d 719, 727 , 674 P.2d 171 (1984)). 1998See Dent, 123 Wash.2d at 479 , 869 P.2d 392 (noting venue need not be proved beyond a reasonable doubt, direct evidence of venue is not required, and circumstantial evidence may establish proper venue) (citing State v. Hardamon, 29 Wash.2d 182, 188 , 186 P.2d 634 (1947); State v. Johnson, 45 Wash.App. 794 , 905 796, 727 P.2d 693 (1986), review denied, 107 Wash.2d 1035 (1987); and clarifying State v. Marino, 100 Wash.2d 719, 727 , 674 P.2d 171 (1984)).	2	1998–1998
Asia Investment Co. v. Levin neutral wash · 1922 2 sentences 2004Asia Investment Co. v. Levin, 118 Wash. 620, 624-27 , 204 P. 808 (1922); McCutchen v. Brink, 129 Wash. 103, 104-07 , 224 P. 605 (1924). 2004Asia Investment Co. v. Levin, 118 Wash. 620, 624-27 , 204 P. 808 (1922); McCutchen v. Brink, 129 Wash. 103, 104-07 , 224 P. 605 (1924).	1	2004–2004
McCutchen v. Brink green wash · 1924 2 sentences 2004Asia Investment Co. v. Levin, 118 Wash. 620, 624-27 , 204 P. 808 (1922); McCutchen v. Brink, 129 Wash. 103, 104-07 , 224 P. 605 (1924). 2004Asia Investment Co. v. Levin, 118 Wash. 620, 624-27 , 204 P. 808 (1922); McCutchen v. Brink, 129 Wash. 103, 104-07 , 224 P. 605 (1924).	1	2004–2004
State v. Marino green wash · 1984 2 sentences 1998See Dent, 123 Wash.2d at 479 , 869 P.2d 392 (noting venue need not be proved beyond a reasonable doubt, direct evidence of venue is not required, and circumstantial evidence may establish proper venue) (citing State v. Hardamon, 29 Wash.2d 182, 188 , 186 P.2d 634 (1947); State v. Johnson, 45 Wash.App. 794 , 905 796, 727 P.2d 693 (1986), review denied, 107 Wash.2d 1035 (1987); and clarifying State v. Marino, 100 Wash.2d 719, 727 , 674 P.2d 171 (1984)). 1998See Dent, 123 Wash.2d at 479 , 869 P.2d 392 (noting venue need not be proved beyond a reasonable doubt, direct evidence of venue is not required, and circumstantial evidence may establish proper venue) (citing State v. Hardamon, 29 Wash.2d 182, 188 , 186 P.2d 634 (1947); State v. Johnson, 45 Wash.App. 794 , 905 796, 727 P.2d 693 (1986), review denied, 107 Wash.2d 1035 (1987); and clarifying State v. Marino, 100 Wash.2d 719, 727 , 674 P.2d 171 (1984)).	1	1998–1998
Warner v. McCaughan green wash · 1969 2 sentences 1972Warner v. McCaughan, 77 Wn.2d 178 , 460 P.2d 272 (1969), cited by the majority, does no more than restate a long-held principle which I think has little application here. 1972Warner v. McCaughan, 77 Wn.2d 178 , 460 P.2d 272 (1969), cited by the majority, does no more than restate a long-held principle which I think has little application here.	1	1972–1972
Siragusa v. Swedish Hospital green wash · 1962 2 sentences 1968Examples of marked changes in the law as declared by this court come readily to mind: In Siragusa v. Swedish Hosp., 60 Wn.2d 310 , 373 P.2d 767 (1962), we departed from a long-held rule and modified the assumption of risk doctrine in ruling that that doctrine had no application to an employee or servant when the master or employer was negligent in creating a dangerous condition. 1968Examples of marked changes in the law as declared by this court come readily to mind: In Siragusa v. Swedish Hosp., 60 Wn.2d 310 , 373 P.2d 767 (1962), we departed from a long-held rule and modified the assumption of risk doctrine in ruling that that doctrine had no application to an employee or servant when the master or employer was negligent in creating a dangerous condition.	1	1968–1968
Pederson v. Dumouchel green wash · 1967 2 sentences 1968Or, in Pederson v. Dumouchel, 72 Wn.2d 73 , 431 P.2d 973 (1967), would this court have been free to adopt new standards of due care in the practice of medicine and change the long-held rule from medical standards of the community to standards of practice in essence for the state at large? 1968Or, in Pederson v. Dumouchel, 72 Wn.2d 73 , 431 P.2d 973 (1967), would this court have been free to adopt new standards of due care in the practice of medicine and change the long-held rule from medical standards of the community to standards of practice in essence for the state at large?	1	1968–1968

Where else courts name it

MI 17 (1981–2022) TX 12 (2000–2015) IL 11 (1993–2025) CA 11 (1981–2020) PA 10 (1984–2021) MD 10 (2000–2025) OH 7 (2002–2023) WA 7 (1968–2004) NC 6 (1988–2023) TN 6 (2010–2025) NY 5 (1988–2025) VA 4 (1994–1998) WI 4 (1988–2016) MS 4 (2008–2017) GA 4 (2006–2020) MO 4 (1983–2020) MN 4 (1985–2014) AL 3 (1987–2011) MT 3 (1988–2026) KS 3 (1974–2013) AR 3 (2003–2020) DC 3 (2011–2012) KY 3 (2021–2026) RI 3 (2006–2011) IN 2 (1993–2009) NJ 2 (1987–2025) UT 2 (2012–2022) FL 2 (2015–2020)

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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