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7 Washington opinions name it 2 courts 1985–2026 2 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.
| Case | Followed | Cited |
|---|---|---|
New York v. Quarlesgreen2 sentences1999To determine whether the public safety exception applies, the court asks whether there was "an objectively reasonable need to protect the police or the public from any immediate danger...." Quarles, 467 U.S. at 659 n. 8, 104 S.Ct. 2626 . 1999To determine whether the public safety exception applies, the Court asks whether there was “an objectively reasonable need to protect the police or the public from any immediate danger . . . .” Quarles, 467 U.S. at 659 n.8. | 1 | 3 |
State v. Spotted Elkgreen2 sentences2018See State v. Spotted Elk, 109 Wn. 2017The State must also demonstrate that circumstances were "sufficiently urgent to warrant an immediate question." Spotted Elk, 109 Wn. | 1 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Finch
green
2 sentences2026In State v. Finch, 137 Wn.2d 792, 828-30 , 975 P.2d 967 (1999), our Supreme Court held that police negotiations with barricaded suspects fall within the public safety exception to the Miranda requirement. 2017To determine whether the public-safety exception applies, we ask whether there was an "objectively reasonable need to protect the police or the public from any immediate danger." State v. Finch, 137 Wn.2d 792, 829 , 975 P.2d 967 (1999). -7- No. 74217-5-1/8 At the outset, there is no dispute that the challenged statements were made after Rife was in custody. | 2 | 2017–2026 |
State v. Finch
green
2 sentences2026In State v. Finch, 137 Wn.2d 792, 828-30 , 975 P.2d 967 (1999), our Supreme Court held that police negotiations with barricaded suspects fall within the public safety exception to the Miranda requirement. 2017To determine whether the public-safety exception applies, we ask whether there was an "objectively reasonable need to protect the police or the public from any immediate danger." State v. Finch, 137 Wn.2d 792, 829 , 975 P.2d 967 (1999). -7- No. 74217-5-1/8 At the outset, there is no dispute that the challenged statements were made after Rife was in custody. | 2 | 2017–2026 |
People v. Manzella
green
2 sentences1999For example, in People v. Manzella, 150 Misc. 2d 956 , 571 N.Y.S.2d 875 (1991), the defendant sought to suppress statements made to a police negotiator while armed and barricaded in his home. 1999For example, in People v. Manzella, 150 Misc. 2d 956 , 571 N.Y.S.2d 875 (1991), the defendant sought to suppress statements made to a police negotiator while armed and barricaded in his home. | 2 | 1999–1999 |
Kennedy v. Mendoza-Martinez
green
2 sentences1999The Supreme Court has noted that the public safety exception created by the Court in Quarles reflects the reality that the Constitution “is not a suicide pact.” Kennedy v. Mendoza-Martinez, 372 U.S. 144, 160 , 83 S. Ct. 554 , 9 L. 1999The Supreme Court has noted that the public safety exception created by the Court in Quarles reflects the reality that the Constitution “is not a suicide pact.” Kennedy v. Mendoza-Martinez, 372 U.S. 144, 160 , 83 S. Ct. 554 , 9 L. | 2 | 1999–1999 |
Washington State Farm Bureau v. Reed
green
1 sentence2025Wash. State Farm Bureau Fed’n v. Reed, 154 Wn.2d 668, 673 , 115 P.3d 301 (2005). | 1 | 2025–2025 |
Washington State Farm Bureau Federation v. Reed
green
1 sentence2025Wash. State Farm Bureau Fed’n v. Reed, 154 Wn.2d 668, 673 , 115 P.3d 301 (2005). | 1 | 2025–2025 |
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.