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6 Washington opinions name it 1 courts 2010–2016 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 |
|---|---|---|
Waller v. Georgiagreen2 sentences2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] Bone-Club, 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club's "`five-step closure test'" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 15 2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] Bone-Club, 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club's "`five-step closure test'" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 15 | 2 | 2 |
State v. Brightmangreen2 sentences2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club' s "five-step closure test" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 152 Wash.2d at 2010See also Brightman, 155 Wash.2d at 515 n. 5, 122 P.3d 150 . | 2 | 2 |
State v. Brightmangreen2 sentences2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club' s "five-step closure test" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 152 Wash.2d at 2010See also Brightman, 155 Wash.2d at 515 n. 5, 122 P.3d 150 . | 2 | 2 |
In re the Personal Restraint of Orangegreen2 sentences2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club' s "five-step closure test" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 152 Wash.2d at 2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] Bone-Club, 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club's "`five-step closure test'" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 15 | 2 | 2 |
Seattle Times Co. v. Ishikawagreen2 sentences2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] Bone-Club, 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club's "`five-step closure test'" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 15 2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] Bone-Club, 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club's "`five-step closure test'" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 15 | 2 | 2 |
In Re Orangegreen2 sentences2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club' s "five-step closure test" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 152 Wash.2d at 2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] Bone-Club, 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club's "`five-step closure test'" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 15 | 2 | 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. Bone-Club
green
2 sentences2015A trial court may close a courtroom only if closure is warranted under the five- part test set forth in Bone -Club, 128 Wn.2d at 258 - 59. 2013State v. Wise, 176 Wn. d 1, 16 n. ,288 P. d 1113 (2012). 2 9 3 7 No. 42292 1 II - - these rights are not absolute; a trial court may close a courtroom if closure is warranted under the five part test set forth in State v. Bone Club, 128 Wn.2d 254 , 906 P. d 325 (1995), Seattle - - 2 and Times Co. v. Ishikawa, 97 Wn. d 30, 640 P. d 716 (1982).Whether the closure of a proceeding 2 2 violates article I,section 10 or section 22 of the Washington Constitution is a question of law reviewed de novo. | 4 | 2010–2015 |
State v. Bone-Club
green
2 sentences2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club' s "five-step closure test" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 152 Wash.2d at 2010Bone-Club adopted a five part analysis designed to protect a criminal defendant's right to a public trial. [4] Bone-Club, 128 Wash.2d at 258-60 , 906 P.2d 325 ; see also Seattle Times Co. v. Ishikawa, 97 Wash.2d 30, 36-39 , 640 P.2d 716 (1982) (setting forth five part analysis under the Washington State Constitution article I, section 10). ¶ 10 Our Supreme Court has explained that Bone-Club's "`five-step closure test'" is essentially a restatement and adoption of the federal closure criteria expressed in Waller v. Georgia, 467 U.S. 39 , 104 S.Ct. 2210 , 81 L.Ed.2d 31 (1984). [5] See Orange, 15 | 2 | 2010–2010 |
United States v. Chong in Kim
green
1 sentence2016The court finds that based on the five part test in United States v. Kim[, 25 F.3d 1426 (9th Cir. 1994)], Officer Sales was required to read defendant his Miranda rights after he was ordered to sit or be pepper sprayed as he was “in custody” at that time. | 1 | 2016–2016 |
Arnold v. Melani
green
1 sentence2015Deutsche Bank asks that we invoke our equitable powers in a similar manner that "transcends the mechanical application of property rules."2 Jd. at 501 (citing Arnold v. Melani, 75 Wn.2d 143 , 449 P.2d 800 (1968)); Brief of Appellant at 15. | 1 | 2015–2015 |
State v. Momah
green
1 sentence2010As we explained in Paumier, "[O]ur Supreme Court [in State v. Momah, 167 Wash.2d 140 , 217 P.3d 321 (2009),] seemed to back away from its earlier articulation in Orange that application of the Bone-Club guidelines is required and that the failure to so employ them when closing the courtroom is reversible error." 155 Wash.App. at 680 , 230 P.3d 212 . ¶ 11 Momah purportedly relied on Waller in concluding that a new trial was not warranted where the trial court closed voir dire without applying the Bone-Club criteria. | 1 | 2010–2010 |
State v. Paumier
green
1 sentence2010As we explained in Paumier, "[O]ur Supreme Court [in State v. Momah, 167 Wash.2d 140 , 217 P.3d 321 (2009),] seemed to back away from its earlier articulation in Orange that application of the Bone-Club guidelines is required and that the failure to so employ them when closing the courtroom is reversible error." 155 Wash.App. at 680 , 230 P.3d 212 . ¶ 11 Momah purportedly relied on Waller in concluding that a new trial was not warranted where the trial court closed voir dire without applying the Bone-Club criteria. | 1 | 2010–2010 |
State v. Momah
green
1 sentence2010As we explained in Paumier, "[O]ur Supreme Court [in State v. Momah, 167 Wash.2d 140 , 217 P.3d 321 (2009),] seemed to back away from its earlier articulation in Orange that application of the Bone-Club guidelines is required and that the failure to so employ them when closing the courtroom is reversible error." 155 Wash.App. at 680 , 230 P.3d 212 . ¶ 11 Momah purportedly relied on Waller in concluding that a new trial was not warranted where the trial court closed voir dire without applying the Bone-Club criteria. | 1 | 2010–2010 |
State v. Paumier
green
1 sentence2010As we explained in Paumier, "[O]ur Supreme Court [in State v. Momah, 167 Wash.2d 140 , 217 P.3d 321 (2009),] seemed to back away from its earlier articulation in Orange that application of the Bone-Club guidelines is required and that the failure to so employ them when closing the courtroom is reversible error." 155 Wash.App. at 680 , 230 P.3d 212 . ¶ 11 Momah purportedly relied on Waller in concluding that a new trial was not warranted where the trial court closed voir dire without applying the Bone-Club criteria. | 1 | 2010–2010 |
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.