two-dismissal rule (Washington) · Go Syfert
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two-dismissal rule in Washington

7 Washington opinions name it 2 courts 1983–2021 1 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 (8)

CaseFollowedCited
Spokane County v. Specialty Auto & Truck Painting, Inc.green
wash · 2004 · cited in 4 Washington opinions naming this issue, 2007–2021
2 sentences

2021The purpose of the two dismissal rule is “to prevent the abuse and harassment of a defendant . . . and . . . the unfair use of dismissal.” Specialty Auto, 153 Wn.2d at 245 .

2016The two dismissal rule’s purpose is “to prevent the abuse and harassment of a defendant . . . and . . . the unfair use of dismissal.” Specialty Auto, 153 Wn.2d at 245 .

24
Island Stevedoring, Inc. v. Barge CCBIgreen
prd · 1990 · cited in 2 Washington opinions naming this issue, 2007–2007
2 sentences

2007Conn. 1998) (first dismissals by court order); Island Stevedoring, Inc. v. Barge CCBI, 129 F.R.D. 430, 432 (D.P.R. 1990) (second dismissal by court order). ¶10 Our holding in Specialty Auto is in line with our own circuit’s interpretation of the two-dismissal rule.

2007Corp. v. Newton, 183 F.3d 1265 , 1267 (11th Cir.1999) (first dismissal by court order); Poloron Prods., Inc. v. Lybrand Ross Bros. & Montgomery, 534 F.2d 1012, 1017 (2d Cir.1976) (first dismissal by stipulation); Loubier v. Modern Acoustics, Inc., 178 F.R.D. 17, 20 (D.Conn.1998) (first dismissals by court order); Island Stevedoring, Inc. v. Barge, CCBI, 129 F.R.D. 430, 432 (D.P.R.1990) (second dismissal by court order). ¶ 10 Our holding in Specialty Auto is in line with our own circuit's interpretation of the two-dismissal rule.

22
Feature Realty, Inc. v. Kirkpatrick & Lockhart Preston Gates Ellis, LLPgreen
wash · 2007 · cited in 1 Washington opinions naming this issue, 2016–2016
1 sentence

2016App. 278, 285 , 110 P.3d 1184 (2005); see also Feature Realty, Inc., 161 Wn.2d at 223 (“We do not inquire into the plaintiff’s intent in obtaining the dismissal.”).

11
cluster 335136green
ca2 · 1976 · cited in 1 Washington opinions naming this issue, 2007–2007
1 sentence

2007Corp. v. Newton, 183 F.3d 1265 , 1267 (11th Cir.1999) (first dismissal by court order); Poloron Prods., Inc. v. Lybrand Ross Bros. & Montgomery, 534 F.2d 1012, 1017 (2d Cir.1976) (first dismissal by stipulation); Loubier v. Modern Acoustics, Inc., 178 F.R.D. 17, 20 (D.Conn.1998) (first dismissals by court order); Island Stevedoring, Inc. v. Barge, CCBI, 129 F.R.D. 430, 432 (D.P.R.1990) (second dismissal by court order). ¶ 10 Our holding in Specialty Auto is in line with our own circuit's interpretation of the two-dismissal rule.

11
Spokane County v. Specialty Auto and Truck Painting, Inc.green
wash · 2004 · cited in 1 Washington opinions naming this issue, 2007–2007
2 sentences

2007However, we expressly held that "the plain language of the `two dismissal' rule of CR 41(a)(4) does not allow for court discretion" and that the rule "operates as a nondiscretionary adjudication upon the merits when the dismissals at issue are unilaterally obtained by the plaintiff." Id. at 246, 103 P.3d 792 (emphasis added).

2007See 153 Wash.2d at 247 , 103 P.3d 792 . ¶ 8 Feature cites numerous cases from other jurisdictions, arguing that they establish that the two-dismissal rule does not apply when "the plaintiff merely acquiesces in the defendants' demands." Appellant's Opening Br. at 21.

11
Loubier v. Modern Acoustics, Inc.green
ctd · 1998 · cited in 1 Washington opinions naming this issue, 2007–2007
1 sentence

2007Corp. v. Newton, 183 F.3d 1265 , 1267 (11th Cir.1999) (first dismissal by court order); Poloron Prods., Inc. v. Lybrand Ross Bros. & Montgomery, 534 F.2d 1012, 1017 (2d Cir.1976) (first dismissal by stipulation); Loubier v. Modern Acoustics, Inc., 178 F.R.D. 17, 20 (D.Conn.1998) (first dismissals by court order); Island Stevedoring, Inc. v. Barge, CCBI, 129 F.R.D. 430, 432 (D.P.R.1990) (second dismissal by court order). ¶ 10 Our holding in Specialty Auto is in line with our own circuit's interpretation of the two-dismissal rule.

11
Poloron Products, Inc. v. Lybrand, Ross Bros. & Montgomerygreen
nysd · 1975 · cited in 1 Washington opinions naming this issue, 1983–1983
1 sentence

1983Poloron Prods., Inc. v. Lybrand, Ross Bros. & Montgomery, 66 F.R.D. 610, 614 (S.D.N.Y. 1975).

11
Orr v. Stuartgreen
arwd · 1963 · cited in 1 Washington opinions naming this issue, 1983–1983
1 sentence

1983Orr v. Stuart, 32 F.R.D. 435, 441 (W.D.

11

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 (7)

CaseCitedYears
Burnet v. Spokane Ambulance green
wash · 1997
2 sentences

2007We found that the purpose of the two-dismissal rule is to “prevent the abuse and harassment of a defendant and the unfair use of dismissal.” Id.

2007We found that the purpose of the two-dismissal rule is to "prevent the abuse and harassment of a defendant and the unfair use of dismissal." Id.

22007–2007
Lake At Las Vegas Investors Group, Inc. v. Pacific Malibu Development Corp. green
ca9 · 1991
2 sentences

2007In Lake at Las Vegas Investors Group, Inc. v. Pacific Malibu Development Corp., 933 F.2d 724 (9th Cir. 1991), the Ninth Circuit considered whether the two-dismissal rule applied where the complaint was subject to dismissal under Nevada law but the plaintiff voluntarily dismissed the action.

2007In Lake at Las Vegas Investors Group, Inc. v. Pacific Malibu Development Corp., 933 F.2d 724 (9th Cir. 1991), the Ninth Circuit considered whether the two-dismissal rule applied where the complaint was subject to dismissal under Nevada law, but the plaintiff voluntarily dismissed the action.

22007–2007
Spokane County v. Specialty Auto & Truck Painting, Inc. neutral
washctapp · 2003
2 sentences

2004Spokane County v. Specialty Auto & Truck Painting, Inc., 119 Wn.

2004Specialty Auto, 119 Wash.App. at 397 , 79 P.3d 448 .

22004–2004
Guillen v. Pierce County green
washctapp · 2005
2 sentences

2016However, Noel cannot avoid the application of the two dismissal rule by explaining why he sought the second dismissal. 4 RCW 4.96.020 requires that all claims for damages based on the tortious conduct of local governmental entities and their agents be presented to the entity and/or agent on a standard tort claim form at least 60 days before commencing the action. 4 No. 48098-1-II “The two dismissal rule of CR 41(a) applies automatically to unilateral dismissals by the plaintiff and ‘does not provide for court discretion to look into the reasons for the dismissal.’” Guillen v. Pierce County, 12

2016However, Noel cannot avoid the application of the two dismissal rule by explaining why he sought the second dismissal. 4 RCW 4.96.020 requires that all claims for damages based on the tortious conduct of local governmental entities and their agents be presented to the entity and/or agent on a standard tort claim form at least 60 days before commencing the action. 4 No. 48098-1-II “The two dismissal rule of CR 41(a) applies automatically to unilateral dismissals by the plaintiff and ‘does not provide for court discretion to look into the reasons for the dismissal.’” Guillen v. Pierce County, 12

12016–2016
ASX Investment Corp. v. Newton green
ca11 · 1999
1 sentence

2007Corp. v. Newton, 183 F.3d 1265 , 1267 (11th Cir.1999) (first dismissal by court order); Poloron Prods., Inc. v. Lybrand Ross Bros. & Montgomery, 534 F.2d 1012, 1017 (2d Cir.1976) (first dismissal by stipulation); Loubier v. Modern Acoustics, Inc., 178 F.R.D. 17, 20 (D.Conn.1998) (first dismissals by court order); Island Stevedoring, Inc. v. Barge, CCBI, 129 F.R.D. 430, 432 (D.P.R.1990) (second dismissal by court order). ¶ 10 Our holding in Specialty Auto is in line with our own circuit's interpretation of the two-dismissal rule.

12007–2007
Spokane County v. Specialty Auto and Truck Painting, Inc. neutral
washctapp · 2003
1 sentence

2004Specialty Auto, 119 Wash.App. at 397 , 79 P.3d 448 .

12004–2004
Burley v. Johnson green
washctapp · 1983
2 sentences

2004Division Three's construction of the two dismissal rule appears to contradict Division One's earlier construction of CR 41(a)(4) in In re Burley, 33 Wash.App. 629 , 658 P.2d 8 (1983).

2004Division Three's construction of the two dismissal rule appears to contradict Division One's earlier construction of CR 41(a)(4) in In re Burley, 33 Wash.App. 629 , 658 P.2d 8 (1983).

12004–2004

Statutes the citing opinions construe

WA § Wash. Rev. Code § 42.30.060 (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 33 (1993–2025) FL 12 (1957–2024) OH 12 (1990–2019) NC 9 (1989–2019) AR 8 (2000–2015) WA 7 (1983–2021) GA 5 (2022–2023) UT 3 (2002–2016) IL 2 (2020–2024) KS 2 (1995–2021)

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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