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7 Washington opinions name it 2 courts 1999–2015 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.
| Case | Followed | Cited |
|---|---|---|
Paty v. Town of Palm Beachgreen2 sentences2009Prior to abandoning the common enemy doctrine in favor of the reasonable use standard, the Florida Supreme Court stated, “The waters of the sea are usually considered a common enemy.” Paty v. Town of Palm Beach, 158 Fla. 575 , 29 So. 2d 363, 363 (1947). 2009Prior to abandoning the common enemy doctrine in favor of the reasonable use standard, the Florida Supreme Court stated, “The waters of the sea are usually considered a common enemy.” Paty v. Town of Palm Beach, 158 Fla. 575 , 29 So. 2d 363, 363 (1947). | 2 | 2 |
Locklin v. City of Lafayettegreen2 sentences2009Prior to its full adoption of the reasonable use standard in 1994, Locklin v. City of Lafayette, 7 Cal. 4th 327, 357, 359 , 867 P.2d 724 , 27 Cal. Rptr. 2d 613 (1994), California appears to have applied the common enemy doctrine (1) in urban areas, see Keys v. Romley, 64 Cal. 2d 396, 406-07 , 412 P.2d 529 , 50 Cal. Rptr. 273 (1966); (2) “to the state and its agencies,” Beckley v. Reclamation Bd., 205 Cal. App. 2d 734, 745 , 23 Cal. Rptr. 428 (1962); and (3) in cases of flooding, Weaver, 206 Cal. App. 3d at 1353-54 . 2009Prior to its full adoption of the reasonable use standard in 1994, Locklin v. City of Lafayette, 7 Cal. 4th 327, 357, 359 , 867 P.2d 724 , 27 Cal. Rptr. 2d 613 (1994), California appears to have applied the common enemy doctrine (1) in urban areas, see Keys v. Romley, 64 Cal. 2d 396, 406-07 , 412 P.2d 529 , 50 Cal. Rptr. 273 (1966); (2) “to the state and its agencies,” Beckley v. Reclamation Bd., 205 Cal. App. 2d 734, 745 , 23 Cal. Rptr. 428 (1962); and (3) in cases of flooding, Weaver, 206 Cal. App. 3d at 1353-54 . | 2 | 2 |
Heins Implement Co. v. Missouri Highway & Transportation Commissiongreen2 sentences1999Comm’n, 859 S.W.2d 681, 690 (Mo. 1993) (listing 19 states that follow the reasonable use rule, 9 that follow the civil law rule, and 9 that follow the common enemy doctrine). 1999Comm'n, 859 S.W.2d 681, 690 (Mo.1993) (listing 19 states that follow the reasonable use rule, 9 that follow the civil law rule, and 9 that follow the common enemy doctrine). | 2 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Keys v. Romley
green
2 sentences2009Prior to its full adoption of the reasonable use standard in 1994, Locklin v. City of Lafayette, 7 Cal. 4th 327, 357, 359 , 867 P.2d 724 , 27 Cal. Rptr. 2d 613 (1994), California appears to have applied the common enemy doctrine (1) in urban areas, see Keys v. Romley, 64 Cal. 2d 396, 406-07 , 412 P.2d 529 , 50 Cal. Rptr. 273 (1966); (2) “to the state and its agencies,” Beckley v. Reclamation Bd., 205 Cal. App. 2d 734, 745 , 23 Cal. Rptr. 428 (1962); and (3) in cases of flooding, Weaver, 206 Cal. App. 3d at 1353-54 . 2009Prior to its full adoption of the reasonable use standard in 1994, Locklin v. City of Lafayette, 7 Cal. 4th 327, 357, 359 , 867 P.2d 724 , 27 Cal. Rptr. 2d 613 (1994), California appears to have applied the common enemy doctrine (1) in urban areas, see Keys v. Romley, 64 Cal. 2d 396, 406-07 , 412 P.2d 529 , 50 Cal. Rptr. 273 (1966); (2) “to the state and its agencies,” Beckley v. Reclamation Bd., 205 Cal. App. 2d 734, 745 , 23 Cal. Rptr. 428 (1962); and (3) in cases of flooding, Weaver, 206 Cal. App. 3d at 1353-54 . | 4 | 1999–2009 |
Currens v. Sleek
green
2 sentences2003Currens v. Sleek, 138 Wn.2d 858, 867-68 , 983 P.2d 626 , 993 P.2d 900 (1999) (refusing to abandon the common enemy doctrine altogether in favor of the reasonable use rule); Borden, 113 Wn. 2003Currens v. Sleek, 138 Wash.2d 858, 866 , 983 P.2d 626 , 993 P.2d 900 (1999) (refusing to abandon the common enemy doctrine altogether in favor of the reasonable use rule); Borden, 113 Wash.App. at 367-68 , 53 P.3d 1020 . | 3 | 2003–2015 |
Beckley v. Reclamation Board
green
2 sentences2009Prior to its full adoption of the reasonable use standard in 1994, Locklin v. City of Lafayette, 7 Cal. 4th 327, 357, 359 , 867 P.2d 724 , 27 Cal. Rptr. 2d 613 (1994), California appears to have applied the common enemy doctrine (1) in urban areas, see Keys v. Romley, 64 Cal. 2d 396, 406-07 , 412 P.2d 529 , 50 Cal. Rptr. 273 (1966); (2) “to the state and its agencies,” Beckley v. Reclamation Bd., 205 Cal. App. 2d 734, 745 , 23 Cal. Rptr. 428 (1962); and (3) in cases of flooding, Weaver, 206 Cal. App. 3d at 1353-54 . 2009Prior to its full adoption of the reasonable use standard in 1994, Locklin v. City of Lafayette, 7 Cal. 4th 327, 357, 359 , 867 P.2d 724 , 27 Cal. Rptr. 2d 613 (1994), California appears to have applied the common enemy doctrine (1) in urban areas, see Keys v. Romley, 64 Cal. 2d 396, 406-07 , 412 P.2d 529 , 50 Cal. Rptr. 273 (1966); (2) “to the state and its agencies,” Beckley v. Reclamation Bd., 205 Cal. App. 2d 734, 745 , 23 Cal. Rptr. 428 (1962); and (3) in cases of flooding, Weaver, 206 Cal. App. 3d at 1353-54 . | 2 | 2009–2009 |
Weaver v. Bishop
green
2 sentences2009Prior to its full adoption of the reasonable use standard in 1994, Locklin v. City of Lafayette, 7 Cal.4th 327, 357, 359 , 867 P.2d 724 , 27 Cal.Rptr.2d 613 (1994), California appears to have applied the common enemy doctrine (1) in urban areas, see Keys v. Romley, 64 Cal.2d 396, 406-07 , 412 P.2d 529 , 50 Cal.Rptr. 273 (1966); (2) "to the state and its agencies," Beckley v. Reclamation Board., 205 Cal.App.2d 734, 745 , 23 Cal.Rptr. 428 (1962); and (3) in cases of flooding, Weaver , 206 Cal. App.3d. at 1353-54, 254 Cal.Rptr. 425 . 2009Prior to its full adoption of the reasonable use standard in 1994, Locklin v. City of Lafayette, 7 Cal. 4th 327, 357, 359 , 867 P.2d 724 , 27 Cal. Rptr. 2d 613 (1994), California appears to have applied the common enemy doctrine (1) in urban areas, see Keys v. Romley, 64 Cal. 2d 396, 406-07 , 412 P.2d 529 , 50 Cal. Rptr. 273 (1966); (2) “to the state and its agencies,” Beckley v. Reclamation Bd., 205 Cal. App. 2d 734, 745 , 23 Cal. Rptr. 428 (1962); and (3) in cases of flooding, Weaver, 206 Cal. App. 3d at 1353-54 . | 2 | 2009–2009 |
Currens v. Sleek
green
2 sentences2003Currens v. Sleek, 138 Wn.2d 858, 867-68 , 983 P.2d 626 , 993 P.2d 900 (1999) (refusing to abandon the common enemy doctrine altogether in favor of the reasonable use rule); Borden, 113 Wn. 2003Currens v. Sleek, 138 Wash.2d 858, 866 , 983 P.2d 626 , 993 P.2d 900 (1999) (refusing to abandon the common enemy doctrine altogether in favor of the reasonable use rule); Borden, 113 Wash.App. at 367-68 , 53 P.3d 1020 . | 2 | 2003–2003 |
Borden v. City of Olympia
green
2 sentences2003Currens v. Sleek, 138 Wn.2d 858, 867-68 , 983 P.2d 626 , 993 P.2d 900 (1999) (refusing to abandon the common enemy doctrine altogether in favor of the reasonable use rule); Borden, 113 Wn. 2003Currens v. Sleek, 138 Wash.2d 858, 866 , 983 P.2d 626 , 993 P.2d 900 (1999) (refusing to abandon the common enemy doctrine altogether in favor of the reasonable use rule); Borden, 113 Wash.App. at 367-68 , 53 P.3d 1020 . | 2 | 2003–2003 |
Borden v. City of Olympia
green
1 sentence2003Currens v. Sleek, 138 Wash.2d 858, 866 , 983 P.2d 626 , 993 P.2d 900 (1999) (refusing to abandon the common enemy doctrine altogether in favor of the reasonable use rule); Borden, 113 Wash.App. at 367-68 , 53 P.3d 1020 . | 1 | 2003–2003 |
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.