procedural due process violation (Washington) · Go Syfert
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procedural due process violation in Washington

51 Washington opinions name it 2 courts 1976–2025 14 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 (15)

CaseFollowedCited
Paul A. Wright, on Behalf of All Similarly Situated Persons v. Chase Rivelandgreen
ca9 · 2000 · cited in 2 Washington opinions naming this issue, 2014–2014
2 sentences

2014Wright v. Riveland, 219 F.3d 905, 913 (9th Cir. 2000) (quoting Portman, 995 F.2d at 904 ).

2014Wright v. Riveland, 219 F.3d 905, 913 ( 9th Cir. 2000) ( quoting Portman, 995 F. 2d at 904 ).

22
In re the Detention of McCuistiongreen
wash · 2010 · cited in 2 Washington opinions naming this issue, 2011–2011
2 sentences

2011But the McCuistion dissent asserted that a procedural due process analysis applies in SVP challenges where the question involves the adequacy of procedural safeguards and distinguished substantive due process violations as those prohibiting government actions "`regardless of the fairness of the procedures used to implement them.'" 169 Wash.2d at 657, 238 P.3d 1147 (Owens, J., dissenting) (internal quotation marks omitted) (quoting In re Pers.

2011But the McCuistion dissent asserted that a procedural due process analysis applies in SVP challenges where the question involves the adequacy of procedural safeguards and distinguished substantive due process violations as those prohibiting government actions “ ‘regardless of the fairness of the procedures used to implement them.’ ” 169 Wn.2d at 657 (Owens, J., dissenting) (internal quotation marks omitted) (quoting In re Pers.

22
Mathews v. Eldridgegreen
scotus · 1976 · cited in 12 Washington opinions naming this issue, 2006–2025
2 sentences

2025The essence behind the procedural due process requirement is that an individual “‘in jeopardy of serious loss [be given] notice of the case against him and opportunity to meet it.’” Mathews v. Eldridge, 424 U.S. 319, 348-49 , 96 S. Ct. 893 , 47 L.

2025The essence behind the procedural due process requirement is that an individual “‘in jeopardy of serious loss [be given] notice of the case against him and opportunity to meet it.’” Mathews v. Eldridge, 424 U.S. 319, 348-49 , 96 S. Ct. 893 , 47 L.

112
Durland v. San Juan Countygreen
wash · 2014 · cited in 2 Washington opinions naming this issue, 2017–2020
2 sentences

2020“To prevail in a § 1983 action alleging deprivation of procedural due process, a plaintiff must prove that the conduct complained of deprived the plaintiff of a cognizable property interest without due process.” Durland, 182 Wn.2d at 70 . 11 No. 37051-8-III Webb v. WSU Procedural Due Process “‘A procedural due process claim has two distinct elements: (1) a deprivation of a constitutionally protected liberty or property interest, and (2) a denial of adequate procedural protections.’” Roybal v. Toppenish Sch.

2017See Durland v. San Juan County, 182 Wn.2d 55, 70 , 340 P.3d 191 (2014); Greenhalgh v. Dep’t of Corr., 180 Wn.

12
Nickum v. City of Bainbridge Islandgreen
washctapp · 2009 · cited in 1 Washington opinions naming this issue, 2024–2024
1 sentence

2024App. 366, 383 , 223 P.3d 1172 (2009) (“LUPA time limits also apply to due process claims.”).

11
Nickum v. City of Bainbridge Islandgreen
washctapp · 2009 · cited in 1 Washington opinions naming this issue, 2024–2024
1 sentence

2024App. 784, 798-99 , 133 P.3d 475 (2006) (holding that the petitioners’ due process challenge failed where they failed to appeal within 21 days of the building permit’s issuance even when they complained of lack of notice under the procedural due process clause), review denied, 159 Wn.2d 1005 (2007); Nickum v. City of Bainbridge Island, 153 Wn.

11
Carey v. Piphusgreen
scotus · 1978 · cited in 1 Washington opinions naming this issue, 2023–2023
2 sentences

2023See Carey v. Piphus, 435 U.S. 247, 266 , 98 S. Ct. 1042 , 55 L.

2023See Carey v. Piphus, 435 U.S. 247, 266 , 98 S. Ct. 1042 , 55 L.

11
Didlake v. Stategreen
washctapp · 2015 · cited in 1 Washington opinions naming this issue, 2021–2021
1 sentence

2021See Didlake v. State, 186 Wn.

11
Robert Roybal v. Toppenish School Districtgreen
ca9 · 2017 · cited in 1 Washington opinions naming this issue, 2020–2020
1 sentence

2020Dist., 871 F.3d 927, 931 (9th Cir. 2017) (quoting Brewster v. Bd. of Educ. of Lynwood Unified Sch.

11
City of Bellevue v. Leegreen
wash · 2009 · cited in 1 Washington opinions naming this issue, 2019–2019
11
City of Bellevue v. Leegreen
wash · 2009 · cited in 1 Washington opinions naming this issue, 2019–2019
2 sentences

2019Under Mathews, courts consider three factors in determining whether the process afforded to an individual was sufficient to satisfy the due process clause: First, the private interest that will be affected by the official action; second,the risk ofan erroneous deprivation ofsuch interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail. 424 U.S. at 33

2019Fields had the opportunity to request reconsideration by the licensing supervisor, to appeal her disqualification to the Office of Administrative Hearings, and to challenge her disqualification in superior court as a violation of her substantive due process rights. 3 The fact that she was not able to challenge the constitutionality of this rule within the administrative process itself is not a procedural due process violation. ¶ 49 Under Mathews , courts consider three factors in determining whether the process afforded to an individual was sufficient to satisfy the due process clause: First,

11
Bellevue School District v. E.S.green
wash · 2011 · cited in 1 Washington opinions naming this issue, 2018–2018
11
Bellevue School Dist. v. Esgreen
wash · 2011 · cited in 1 Washington opinions naming this issue, 2018–2018
11
Searcy v. Simmonsgreen
ca10 · 2002 · cited in 1 Washington opinions naming this issue, 2014–2014
11
City of Spokane v. Douglassgreen
wash · 1990 · cited in 1 Washington opinions naming this issue, 2000–2000
11

Distinguished, questioned or overruled (9)

CaseNegativeCited
Matter of Personal Restraint of Youngred
wash · 1993 · cited in 1 Washington opinions naming this issue, 2015–2015
11
State v. Greenegreen
wash · 1999 · cited in 1 Washington opinions naming this issue, 2015–2015
11
In re the Detention of Thorellgreen
wash · 2003 · cited in 1 Washington opinions naming this issue, 2015–2015
11
State v. Copelandgreen
wash · 1996 · cited in 1 Washington opinions naming this issue, 2015–2015
11
In Re Detention of Thorellgreen
wash · 2003 · cited in 1 Washington opinions naming this issue, 2015–2015
11
State v. Brousseaugreen
wash · 2011 · cited in 1 Washington opinions naming this issue, 2015–2015
11
State v. Brousseaugreen
wash · 2011 · cited in 1 Washington opinions naming this issue, 2015–2015
11
State v. Greenegreen
wash · 1999 · cited in 1 Washington opinions naming this issue, 2015–2015
11
State v. Copelandgreen
wash · 1996 · cited in 1 Washington opinions naming this issue, 2015–2015
11

Also cited on this issue (39)

CaseCitedYears
Motley-Motley, Inc. v. Pollution Control Hearings Board green
washctapp · 2005
2 sentences

2025“To establish a procedural due process violation, the party must establish that he or she has been deprived of notice and opportunity to be heard prior to a final, not tentative, determination.” Motley-Motley, Inc. v. Pollution Control Hr’gs Bd., 127 Wn.

2017"Procedural due process requires notice and an opportunity to be heard prior to final agency action."49 "To establish a procedural due process violation, the party must establish that he or she has been deprived of notice and opportunity to be heard prior to a final, not tentative, determination."50 An agency violates substantive due process when its decision is "irrational, arbitrary and capricious" or "was tainted by improper motive."51 46 WAC 192-340-020; RCW 50.12.080. 47 RCW 50.12.080. 48 AR at 1040 (Finding of Fact 4.26). 49 Motley-Motley, Inc. v. State, 127 Wn.

62007–2025
Nelson v. Colorado green
scotus · 2017
2 sentences

2025Nelson concerned a procedural due process challenge to a state statute requiring individuals with invalidated convictions to prove their innocence to recover funds paid to the State. 581 U.S. at 132-34 .

2024But Nelson v. Colorado performed a procedural due process analysis, so its reasoning does not support a substantive due process claim. 581 U.S. at 134-35 .

52024–2025
cluster 392722 green
ca4 · 1981
2 sentences

2025Id. (citing Pullman Power Prods., Inc. v. Marshall, 655 F.2d 41 , 44 (4th Cir. 1981)).

2005Pullman Power Prods., Inc. v. Marshall, 655 F.2d 41 , 44 (4th Cir. 1981).

32005–2025
Motley-Motley, Inc. v. State green
washctapp · 2005
2 sentences

2025App. 62 , 81, 110 P.3d 812 (2005).

2025Id. (citing Pullman Power Prods., Inc. v. Marshall, 655 F.2d 41 , 44 (4th Cir. 1981)).

22017–2025
Sheldon Portman v. County of Santa Clara Bob Diridon green
ca9 · 1993
2 sentences

2014Wright v. Riveland, 219 F.3d 905, 913 (9th Cir. 2000) (quoting Portman, 995 F.2d at 904 ).

2014Wright v. Riveland, 219 F.3d 905, 913 ( 9th Cir. 2000) ( quoting Portman, 995 F. 2d at 904 ).

22014–2014
United States v. Salerno green
scotus · 1987
2 sentences

2013Salerno, 481 U.S. 739 .

2013Salerno, 481 U.S. 739 .

22013–2013
In re the Personal Restraint of Bush green
wash · 2008
2 sentences

2011Restraint of Bush, 164 Wash.2d 697, 706 , 193 P.3d 103 (2008)).

2011Restraint of Bush, 164 Wn.2d 697, 706 , 193 P.3d 103 (2008)).

22011–2011
In Re Bush green
wash · 2008
2 sentences

2011Restraint of Bush, 164 Wash.2d 697, 706 , 193 P.3d 103 (2008)).

2011Restraint of Bush, 164 Wn.2d 697, 706 , 193 P.3d 103 (2008)).

22011–2011
Sheep Mountain Cattle Co. v. Department of Ecology green
washctapp · 1986
2 sentences

2005App. 427, 431 , 726 P.2d 55 (1986). ¶47 In Sheep Mountain, we found a procedural due process violation because the earlier version of RCW 90.14.130 “failed to provide any due process prior to a termination order by DOE.” Sheep Mountain, 45 Wn.

2005App. 427, 431 , 726 P.2d 55 (1986). ¶47 In Sheep Mountain, we found a procedural due process violation because the earlier version of RCW 90.14.130 “failed to provide any due process prior to a termination order by DOE.” Sheep Mountain, 45 Wn.

22005–2005
State v. Dixon green
wash · 1971
2 sentences

1978See Blondheim v. State, supra; State v. Dixon, 78 Wn.2d 796, 805-06 , 479 P.2d 931 (1971).

1978See Blondheim v. State, supra; State v. Dixon, 78 Wn.2d 796, 805-06 , 479 P.2d 931 (1971).

21976–1978
Joint Anti-Fascist Refugee Committee v. McGrath green
scotus · 1951
2 sentences

2025Ed. 2d 18 (1976) (brackets in original) (quoting Joint Anti-Fascist Refugee Comm. v. McGrath, 341 U.S. 123, 171-172 , 71 S.Ct. 624 , 95 L.

2025Ed. 2d 18 (1976) (brackets in original) (quoting Joint Anti-Fascist Refugee Comm. v. McGrath, 341 U.S. 123, 171-172 , 71 S.Ct. 624 , 95 L.

12025–2025
Asche v. Bloomquist green
washctapp · 2006
1 sentence

2024App. 784, 798-99 , 133 P.3d 475 (2006) (holding that the petitioners’ due process challenge failed where they failed to appeal within 21 days of the building permit’s issuance even when they complained of lack of notice under the procedural due process clause), review denied, 159 Wn.2d 1005 (2007); Nickum v. City of Bainbridge Island, 153 Wn.

12024–2024
In re Welfare of M.B. green
wash · 2020
2 sentences

2022In re Welfare of M.B., 195 Wn.2d 859, 877 , 467 P.3d 969 (2020).

2022In re Welfare of M.B., 195 Wn.2d 859, 877 , 467 P.3d 969 (2020).

12022–2022
Burrell v. Department of Social & Health Services green
wash · 1999
1 sentence

2021In re Dependency of K.S.C., 137 Wn.2d 918, 931 , 976 P.2d 113 (1999) (Washington’s termination statutes do not require a court to consider dependency guardianship as an alternative to termination where no petition has been filed). 14 No. 80429-4-I/15 III.

12021–2021
Washington Independent Telephone Ass'n v. Washington Utilities & Transportation Commission green
wash · 2003
1 sentence

2021Comm’n, 149 Wn.2d 17, 24 , 65 P.3d 319 (2003)). 8 No. 81236-0-I/9 evaluating an alleged procedural due process violation, we weigh “(1) the private interest impacted by the government action; (2) ‘the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards,’ and (3) the government interest, including the additional burden that added procedural safeguards would entail.”32 Here, the first Mathews factor favors Ren because he has a fundamental interest in parenting his daughters.33 The third M

12021–2021
State v. Stout green
wash · 2007
1 sentence

2021Ed. 2d 18 (1976), to show due process requires opening and closing arguments. 2 No. 54373-7-II flexible concept.” In re Det. of Stout, 159 Wn.2d 357, 370 , 150 P.3d 86 (2007).

12021–2021
In Re Dependency of KSC green
wash · 1999
1 sentence

2021In re Dependency of K.S.C., 137 Wn.2d 918, 931 , 976 P.2d 113 (1999) (Washington’s termination statutes do not require a court to consider dependency guardianship as an alternative to termination where no petition has been filed). 14 No. 80429-4-I/15 III.

12021–2021
Washington Independent Telephone Association v. Washington Utilities and Transportation Commission neutral
wash · 2003
1 sentence

2021Comm’n, 149 Wn.2d 17, 24 , 65 P.3d 319 (2003)). 8 No. 81236-0-I/9 evaluating an alleged procedural due process violation, we weigh “(1) the private interest impacted by the government action; (2) ‘the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards,’ and (3) the government interest, including the additional burden that added procedural safeguards would entail.”32 Here, the first Mathews factor favors Ren because he has a fundamental interest in parenting his daughters.33 The third M

12021–2021
In Re Detention of Stout green
wash · 2007
1 sentence

2021Ed. 2d 18 (1976), to show due process requires opening and closing arguments. 2 No. 54373-7-II flexible concept.” In re Det. of Stout, 159 Wn.2d 357, 370 , 150 P.3d 86 (2007).

12021–2021
In re the Welfare of R.H. green
washctapp · 2013
2 sentences

2021App. at 673 (to show a procedural due process violation from denial of a continuance, a parent must demonstrate specific prejudice or that the outcome of trial would have been different) (citing In re Welfare of R.H., 176 Wn.

2021App. 419, 425 , 309 P.3d 620 (2013)). 10 No. 81236-0-I/11 witnesses on both sides whose “live testimony” would not be beneficial to the case.38 And when Ren’s counsel told the court that he was unavailable for one of the scheduled trial days because he was moving, the trial court accommodated his schedule.

12021–2021
In Re Boot green
wash · 1996
12018–2018
State v. Cornejo green
wash · 1996
12018–2018
Islam v. STATE, DEPT. OF EARLY LEARNING green
washctapp · 2010
12017–2017
Sintra, Inc. v. City of Seattle green
wash · 1992
12017–2017
Smith v. State neutral
washctapp · 2006
12017–2017
Islam v. Department of Early Learning green
washctapp · 2010
12017–2017
Greenhalgh v. Department of Corrections neutral
washctapp · 2014
12017–2017
In re the Personal Restraint of Price neutral
washctapp · 2010
12015–2015
Johnson v. Department of Fish & Wildlife neutral
washctapp · 2013
12015–2015
Kelley v. Pierce County green
washctapp · 2014
12015–2015
State v. McCuistion neutral
wash · 2010
12011–2011
City of Redmond v. Moore green
wash · 2004
12006–2006
City of Redmond v. Moore green
wash · 2004
12006–2006
State v. Storhoff green
wash · 1997
12005–2005
State v. Hovrud green
washctapp · 1991
11995–1995
Burien Bark Supply v. King County green
wash · 1986
11995–1995
Withrow v. Larkin green
scotus · 1975
11981–1981
Board of Curators of the University of Missouri v. Horowitz green
scotus · 1978
11979–1979
Wong v. Regents of University of California green
calctapp · 1971
11979–1979

Statutes the citing opinions construe

WA § Wash. Rev. Code § 34.05.570 (16) WA § Wash. Rev. Code § 2.06.040 (14) USC § 42u.s.c.1983 (8) WA § Wash. Rev. Code § 4.84.350 (5) WA § Wash. Rev. Code § 90.14.130 (5) WA § Wash. Rev. Code § 90.14.140 (5) WA § Wash. Rev. Code § 10.01.160 (4) WA § Wash. Rev. Code § 34.05.425 (4) WA § Wash. Rev. Code § 69.50.4013 (4) WA § Wash. Rev. Code § 9.94A.030 (4) WA § Wash. Rev. Code § 90.14.160 (4) WA § Wash. Rev. Code § 13.34.020 (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

IL 104 (1976–2026) TX 74 (1979–2025) CA 66 (1963–2024) WI 55 (1972–2025) PA 52 (1958–2025) WA 51 (1976–2025) OH 46 (1991–2026) MN 40 (1986–2025) CT 38 (1976–2026) NM 38 (1989–2026) NJ 29 (1972–2026) MI 29 (1978–2025) CO 29 (1988–2026) KS 28 (2002–2026) FL 28 (1983–2025) IA 25 (1979–2022) ID 24 (1990–2024) ME 20 (1995–2024) IN 19 (1976–2026) MO 18 (1976–2019) NY 17 (1979–2026) AZ 16 (1981–2019) UT 14 (2004–2026) NH 13 (1987–2025) MA 13 (1992–2022) VA 13 (1971–2025) WV 13 (1978–2018) NC 11 (1984–2024) MS 11 (1997–2021) AL 11 (1989–2025) LA 11 (1972–2018) MD 11 (1999–2013) MT 10 (2000–2016) GA 10 (1995–2023) TN 9 (1998–2023) VT 9 (1999–2025) RI 9 (1994–2015) DE 8 (1989–2025) OK 8 (1982–2022) SC 8 (1997–2025) SD 8 (2001–2018) OR 7 (1999–2014) DC 6 (1982–2007) HI 6 (1982–2015) NV 5 (1995–2021) AR 5 (1999–2025) KY 4 (2012–2026) NE 4 (1989–2020) AK 4 (2013–2023) WY 3 (2006–2020) ND 2 (2019–2025) VI 2 (2015–2025)

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.

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