mutuality requirement (Washington) · Go Syfert
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mutuality requirement in Washington

7 Washington opinions name it 2 courts 1970–2019 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 (1)

CaseFollowedCited
Henderson v. Bardahl International Corp.green
wash · 1967 · cited in 2 Washington opinions naming this issue, 1998–1998
2 sentences

1998Henderson v. Bardahl Int'l Corp., 72 Wash.2d 109, 116 , 431 P.2d 961 *321 (1967).

1998Henderson v. Bardahl Int'l Corp., 72 Wash.2d 109, 116 , 431 P.2d 961 *321 (1967).

12

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 (5)

CaseCitedYears
Bernhard v. Bank of America National Trust & Saving Association green
cal · 1942
2 sentences

1970Ass’n, 19 Cal. 2d 807 , 122 P.2d 892 (1942), but the mutuality requirement had been criticized for more than a century. 1 Even if, in a proper case, the requirement of mutuality need not be imposed, collateral estoppel may not be applied to prevent litigation of an issue unless it is certain that the same issue has already been litigated and decided.

1970Ass’n, 19 Cal. 2d 807 , 122 P.2d 892 (1942), but the mutuality requirement had been criticized for more than a century. 1 Even if, in a proper case, the requirement of mutuality need not be imposed, collateral estoppel may not be applied to prevent litigation of an issue unless it is certain that the same issue has already been litigated and decided.

21970–1970
Peoples National Bank of Washington v. National Bank of Commerce of Seattle green
wash · 1966
2 sentences

2019"The party alleging an accord and satisfaction must prove 6 Offset cases cited by Thomas in support of his claim are inapposite because they involve claims that meet the mutuality requirement in re Smith’s Estate, 179 Wash. 417 , 38 P.2d 244 (1934); Peoples Nat’l Bank of Wash. v. Nat‘l Bank of Commerce, 69 Wn.2d 682 , 420 P.2d 208 (1966).

2019"The party alleging an accord and satisfaction must prove 6 Offset cases cited by Thomas in support of his claim are inapposite because they involve claims that meet the mutuality requirement in re Smith’s Estate, 179 Wash. 417 , 38 P.2d 244 (1934); Peoples Nat’l Bank of Wash. v. Nat‘l Bank of Commerce, 69 Wn.2d 682 , 420 P.2d 208 (1966).

12019–2019
In Re Smith's Estate green
wash · 1934
2 sentences

2019"The party alleging an accord and satisfaction must prove 6 Offset cases cited by Thomas in support of his claim are inapposite because they involve claims that meet the mutuality requirement in re Smith’s Estate, 179 Wash. 417 , 38 P.2d 244 (1934); Peoples Nat’l Bank of Wash. v. Nat‘l Bank of Commerce, 69 Wn.2d 682 , 420 P.2d 208 (1966).

2019"The party alleging an accord and satisfaction must prove 6 Offset cases cited by Thomas in support of his claim are inapposite because they involve claims that meet the mutuality requirement in re Smith’s Estate, 179 Wash. 417 , 38 P.2d 244 (1934); Peoples Nat’l Bank of Wash. v. Nat‘l Bank of Commerce, 69 Wn.2d 682 , 420 P.2d 208 (1966).

12019–2019
Lucas v. Velikanje green
washctapp · 1970
1 sentence

1986Lucas v. Velikanje, 2 Wn.

11986–1986
Kyreacos v. Smith green
wash · 1977
2 sentences

1978Lucas v. Velikanje, supra; Kyreacos v. Smith, 89 Wn.2d 425 , 572 P.2d 723 (1977); Blonder-Tongue Laboratories, Inc. v. University of Ill.

1978Lucas v. Velikanje, supra; Kyreacos v. Smith, 89 Wn.2d 425 , 572 P.2d 723 (1977); Blonder-Tongue Laboratories, Inc. v. University of Ill.

11978–1978

Where else courts name it

MI 44 (1943–2026) IL 32 (1956–2024) OH 21 (1983–2025) VA 18 (1974–2023) CT 16 (1988–2020) FL 13 (1976–2022) CA 10 (1978–2022) NC 10 (1983–2025) SC 8 (2008–2023) MD 7 (1969–2018) AR 7 (1974–2009) NJ 7 (1967–1993) WA 7 (1970–2019) NY 6 (1926–1989) MN 6 (1902–2012) NM 6 (1974–2002) AL 6 (1994–2024) CO 5 (1987–2017) VT 5 (1932–2018) AZ 5 (1981–2019) IN 5 (1984–2023) TX 5 (1970–1993) TN 5 (2006–2026) AK 4 (1970–1992) WI 4 (1986–1996) MO 4 (1920–2018) IA 3 (1975–2021) PA 3 (1977–1986) KS 3 (1986–2004) ND 3 (1992–2019) WY 2 (1984–2020) DE 2 (1991–2020) GA 2 (1974–1975) OR 2 (1952–2007) MA 2 (1954–1995) HI 2 (1975–2004) DC 2 (1980–1984) KY 2 (1964–2018)

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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