assigned error in Washington

2020Cowiche Canyon Conservancy v. Bosley, 118 Wn.2d 801, 809 , 828 P.2d 549 (1992).

2018Cowiche Canyon Conservancy v. Bosley, 118 Wn.2d 801, 809 , 828 P.2d 3 549(1992). 2 No. 75597-8-1/3 before it all relevant evidence.4 An insufficient record on appeal precludes review of the assigned error.5 Although we recognize both parties are self-represented on appeal, we hold such litigants to the same standard as an attorney.6 These deficiencies present substantial obstacles to our consideration of Khanof's appeal.

2014State v. Thomas, 150 Wn.2d 821, 844 , 83 P.3d 970 (2004). ¶11 Because of the language in her statement on plea of guilty, we conclude that Heather Mercado did not invite or create the assigned error.

2010See RAP 10.3(a)(6); State v. Thomas, 150 Wn.2d 821, 874 , 83 P.3d 970 (2004), abrogated on other grounds by Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 , 158 L.

2014State v. Thomas, 150 Wn.2d 821, 844 , 83 P.3d 970 (2004). ¶11 Because of the language in her statement on plea of guilty, we conclude that Heather Mercado did not invite or create the assigned error.

2010See RAP 10.3(a)(6); State v. Thomas, 150 Wn.2d 821, 874 , 83 P.3d 970 (2004), abrogated on other grounds by Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 , 158 L.

2026State v. O’Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009).

2026O’Hara, 167 Wn.2d at 98 .

2015Misled by DLI, the majority dismisses this appeal and incorrectly reasons the assigned error is thus moot. disagree with the majority approach for three reasons. 2 No. 32177-1~11I Burnett v. DOL- Dissent First, I would hold: (1) Walla Walla Community College employed Ms. Burnett as a "worker" under the Industrial Insurance Act, Novenson v. Spokane Culvert & Fabricating Co., 91 Wn.2d 550, 553 , 588 P.2d 1174 (1979); (2) The "dual capacity doctrine" does not operate to preclude DLI's suit, see 16 DAVID K.

2015Misled by DLI, the majority dismisses this appeal and incorrectly reasons the assigned error is thus moot. disagree with the majority approach for three reasons. 2 No. 32177-1~11I Burnett v. DOL- Dissent First, I would hold: (1) Walla Walla Community College employed Ms. Burnett as a "worker" under the Industrial Insurance Act, Novenson v. Spokane Culvert & Fabricating Co., 91 Wn.2d 550, 553 , 588 P.2d 1174 (1979); (2) The "dual capacity doctrine" does not operate to preclude DLI's suit, see 16 DAVID K.

2010See RAP 10.3(a)(6); State v. Thomas, 150 Wn.2d 821, 874 , 83 P.3d 970 (2004), abrogated on other grounds by Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 , 158 L.

2010See RAP 10.3(a)(6); State v. Thomas, 150 Wn.2d 821, 874 , 83 P.3d 970 (2004), abrogated on other grounds by Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 , 158 L.

2002Ochoa v. Dep’t of Labor & Indus., 143 Wn.2d 422, 425-26 , 20 P.3d 939 (2001).

2002Ochoa v. Dep't of Labor & Indus., 143 Wash.2d 422, 425-26 , 20 P.3d 939 (2001).

2002Ochoa v. Dep’t of Labor & Indus., 143 Wn.2d 422, 425-26 , 20 P.3d 939 (2001).

2002Ochoa v. Dep't of Labor & Indus., 143 Wash.2d 422, 425-26 , 20 P.3d 939 (2001).

2026State v. O’Hara, 167 Wn.2d 91, 98 , 217 P.3d 756 (2009).

2025Challenges to the Findings and Conclusions Morton assigns error to the trial court “factually finding and legally concluding that the original paper Note . . . was transferred to Chase by way of an assignment dated February 2, 2001, from a Bank One employee.” He also challenges several specific findings and conclusions relating to the assigned error. 1 “We review the trial court’s decision following a bench trial to determine whether the findings of fact are supported by substantial evidence and whether those findings support the conclusions of law.” 224 Westlake, LLC v. Engstrom Props., LLC,

2025App. 700, 720 , 281 P.3d 693 (2012).

2021App. 2d ___, 496 P.3d 742 , 746 (2021) (citing Blomster v. Nordstrom, Inc., 103 Wn.

2020State v. McFarland, 127 Wn.2d 322, 335 , 899 P.2d 1251 (1995). 7 No. 35851-8-III State v. Scyphers CONCLUSION We affirm Douglas Scyphers’s convictions and sentences, except that we remand for vacation of the $200 criminal filing fee obligation.

2020State v. McFarland, 127 Wn.2d 322, 335 , 899 P.2d 1251 (1995). 7 No. 35851-8-III State v. Scyphers CONCLUSION We affirm Douglas Scyphers’s convictions and sentences, except that we remand for vacation of the $200 criminal filing fee obligation.

2020State v. Thorgerson, 172 Wn.2d 438, 442 , 258 P.3d 43 (2011).

2020State v. Thorgerson, 172 Wn.2d 438, 442 , 258 P.3d 43 (2011).

2019In re Marriage of Fahey, 164 Wn.

2018Because the e-mail referenced at the beginning of the fiduciary duty hearing, which purported to limit the hearing to that one issue, is not part of the record on appeal, we cannot evaluate the merits of the sisters' assigned error. -29- No. 76835-2-1/30 Arden v. Forsberg & Umlaut P.S., 193 Wn.

2018App. 731, 746 , 373 P.3d 320 (2016).

2016Id.

2014App. 693 , 697 -98, 958 P. 2d 319 ( 1998) ( invoking RAP 1. 2( c) and considering the assigned error in a consolidated appeal where one appellant challenged the instruction at trial and the other did not).

1987State v. Blight, 89 Wn.2d 38, 46-47 , 569 P.2d 1129 (1977).

1987State v. Blight, 89 Wn.2d 38, 46-47 , 569 P.2d 1129 (1977).

1985Orwick v. Seattle, 103 Wn.2d 249, 256 , 692 P.2d 793 (1984). 1 Aetna Life and Casualty Company Aetna asserts that since the settlement agreement between the Kageles and the Currys states the Currys are not liable and did not obligate the Currys to pay anything, then it, the insurer, is not obligated to pay anything.

1985Orwick v. Seattle, 103 Wn.2d 249, 256 , 692 P.2d 793 (1984). 1 Aetna Life and Casualty Company Aetna asserts that since the settlement agreement between the Kageles and the Currys states the Currys are not liable and did not obligate the Currys to pay anything, then it, the insurer, is not obligated to pay anything.

1981The assignee then cites the general rule, "a right to damages for breach of contract is assignable, even though the contract contained a prohibition of assignment." (Footnotes omitted.) 3 S. Williston, Contracts § 412, at 46-47 (3d ed. 1960); Fuller v. Favorite Theaters Co., 119 Utah 570 , 230 P.2d 335 (1951).

1981The assignee then cites the general rule, "a right to damages for breach of contract is assignable, even though the contract contained a prohibition of assignment." (Footnotes omitted.) 3 S. Williston, Contracts § 412, at 46-47 (3d ed. 1960); Fuller v. Favorite Theaters Co., 119 Utah 570 , 230 P.2d 335 (1951).

1976The Court of Appeals, Division Two, in Kubista v. Romaine, 14 Wn.

1972Since the jury verdict was for plaintiffs, we consider this assigned error only as it bears upon plaintiffs’ remaining contention that a new trial should be granted on the issue of damages only. *518 As stated Hughey v. Winthrop Motor Co., 61 Wn.2d 227 , 377 P.2d 640 (1963), at 229: Contributory negligence is an affirmative defense and the burden of proving it rests on the defendant.

1972Since the jury verdict was for plaintiffs, we consider this assigned error only as it bears upon plaintiffs’ remaining contention that a new trial should be granted on the issue of damages only. *518 As stated Hughey v. Winthrop Motor Co., 61 Wn.2d 227 , 377 P.2d 640 (1963), at 229: Contributory negligence is an affirmative defense and the burden of proving it rests on the defendant.

1971In support of this assigned error defendant relies upon the recent case of State v. Golladay, 78 Wn.2d 121, 138 , 470 P.2d 191 (1970), where the court stated: [T]he rule sustaining an information which charges a crime to have been committed in two or more ways, cannot be employed to sustain a conviction, when the evidence is totally insufficient to warrant an instruction on one of the methods charged.

1971In support of this assigned error defendant relies upon the recent case of State v. Golladay, 78 Wn.2d 121, 138 , 470 P.2d 191 (1970), where the court stated: [T]he rule sustaining an information which charges a crime to have been committed in two or more ways, cannot be employed to sustain a conviction, when the evidence is totally insufficient to warrant an instruction on one of the methods charged.