lowest standard (Washington) · Go Syfert
← Washington issues

lowest standard in Washington

6 Washington opinions name it 2 courts 2009–2026 4 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 (2)

CaseFollowedCited
Nguyen v. Department of Healthgreen
wash · 2001 · cited in 3 Washington opinions naming this issue, 2009–2023
2 sentences

2023Further, she avers that “to the extent the proceeding is considered quasi criminal as to professional licensure, the lowest standard of proof should not be applied.” Indeed, our Supreme Court in Nguyen reiterated that a “loss of a professional license is more than a monetary loss; it is a loss of a person’s livelihood and loss of a reputation.” Nguyen, 144 Wn.2d at 527 (quoting Johnson v. Bd. of Governors, 1996 OK 41 , 1346, 913 P.2d 1339 (1996)).

2009Nguyen, 144 Wn.2d at 529 (citations omitted). ¶19 The dancers also cite Ongom v. Department of Health, Office of Professional Standards, 159 Wn.2d 132, 142 , 148 P.3d 1029 (2006), cert. denied, 550 U.S. 905 (2007), where our Supreme Court reversed the suspension of a nursing assistant’s license where the agency relied on a preponderance standard.

13
Addington v. Texasgreen
scotus · 1979 · cited in 2 Washington opinions naming this issue, 2023–2026
2 sentences

2026By contrast, the highest standard of proof, “beyond a reasonable doubt,” applies in criminal cases because “the interests of the defendant are of such magnitude” that the burden of proof must “exclude as nearly as possible the likelihood of an erroneous judgment.” Id. at 424, 423 .

2026The lowest standard of proof, a “mere preponderance of the evidence,” applies in civil cases for monetary damages between private parties, in which “society has a minimal concern.” Addington, 441 U.S. at 423 .

12

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 (6)

CaseCitedYears
Ongom v. Dept. of Health red
wash · 2006
2 sentences

2009Nguyen, 144 Wash.2d at 529 , 29 P.3d 689 (internal citations omitted). ¶ 19 The dancers also cite Ongom v. Department of Health, Office of Professional Standards, 159 Wash.2d 132, 142 , 148 P.3d 1029 (2006), cert. denied, ___ U.S. ___, 127 S.Ct. 2115 , 167 L.Ed.2d 815 (2007), where our Supreme Court reversed the suspension of a nursing assistant's license where the agency relied on a preponderance standard.

2009Nguyen, 144 Wn.2d at 529 (citations omitted). ¶19 The dancers also cite Ongom v. Department of Health, Office of Professional Standards, 159 Wn.2d 132, 142 , 148 P.3d 1029 (2006), cert. denied, 550 U.S. 905 (2007), where our Supreme Court reversed the suspension of a nursing assistant’s license where the agency relied on a preponderance standard.

22009–2009
Washington State Department of Health v. Ongom green
scotus · 2007
2 sentences

2009Nguyen, 144 Wash.2d at 529 , 29 P.3d 689 (internal citations omitted). ¶ 19 The dancers also cite Ongom v. Department of Health, Office of Professional Standards, 159 Wash.2d 132, 142 , 148 P.3d 1029 (2006), cert. denied, ___ U.S. ___, 127 S.Ct. 2115 , 167 L.Ed.2d 815 (2007), where our Supreme Court reversed the suspension of a nursing assistant's license where the agency relied on a preponderance standard.

2009Nguyen, 144 Wn.2d at 529 (citations omitted). ¶19 The dancers also cite Ongom v. Department of Health, Office of Professional Standards, 159 Wn.2d 132, 142 , 148 P.3d 1029 (2006), cert. denied, 550 U.S. 905 (2007), where our Supreme Court reversed the suspension of a nursing assistant’s license where the agency relied on a preponderance standard.

22009–2009
Ongom v. Department of Health red
wash · 2006
2 sentences

2009Nguyen, 144 Wash.2d at 529 , 29 P.3d 689 (internal citations omitted). ¶ 19 The dancers also cite Ongom v. Department of Health, Office of Professional Standards, 159 Wash.2d 132, 142 , 148 P.3d 1029 (2006), cert. denied, ___ U.S. ___, 127 S.Ct. 2115 , 167 L.Ed.2d 815 (2007), where our Supreme Court reversed the suspension of a nursing assistant's license where the agency relied on a preponderance standard.

2009Nguyen, 144 Wn.2d at 529 (citations omitted). ¶19 The dancers also cite Ongom v. Department of Health, Office of Professional Standards, 159 Wn.2d 132, 142 , 148 P.3d 1029 (2006), cert. denied, 550 U.S. 905 (2007), where our Supreme Court reversed the suspension of a nursing assistant’s license where the agency relied on a preponderance standard.

22009–2009
In re Pers. Restraint of Ali green
wash · 2020
2 sentences

2025Restraint of Ali, 196 Wn.2d 220, 243 , 474 P.3d 507 (2020) (Petitioner established prejudice by showing that evidence establishing mitigating qualities of youth was presented to the sentencing judge and the sentencing judge imposed the lowest sentence it believed was available.), cert. denied, 141 S. Ct. 1754 (2021).

2025Restraint of Ali, 196 Wn.2d 220, 243 , 474 P.3d 507 (2020) (Petitioner established prejudice by showing that evidence establishing mitigating qualities of youth was presented to the sentencing judge and the sentencing judge imposed the lowest sentence it believed was available.), cert. denied, 141 S. Ct. 1754 (2021).

12025–2025
Johnson v. Board of Governors of Registered Dentists green
okla · 1996
1 sentence

2023Further, she avers that “to the extent the proceeding is considered quasi criminal as to professional licensure, the lowest standard of proof should not be applied.” Indeed, our Supreme Court in Nguyen reiterated that a “loss of a professional license is more than a monetary loss; it is a loss of a person’s livelihood and loss of a reputation.” Nguyen, 144 Wn.2d at 527 (quoting Johnson v. Bd. of Governors, 1996 OK 41 , 1346, 913 P.2d 1339 (1996)).

12023–2023
Nguyen v. STATE HEALTH MED. QUALITY ASSUR. green
wash · 2001
1 sentence

2009Nguyen, 144 Wash.2d at 529 , 29 P.3d 689 (internal citations omitted). ¶ 19 The dancers also cite Ongom v. Department of Health, Office of Professional Standards, 159 Wash.2d 132, 142 , 148 P.3d 1029 (2006), cert. denied, ___ U.S. ___, 127 S.Ct. 2115 , 167 L.Ed.2d 815 (2007), where our Supreme Court reversed the suspension of a nursing assistant's license where the agency relied on a preponderance standard.

12009–2009

Where else courts name it

PA 8 (1923–2025) WA 6 (2009–2026) MO 3 (2002–2014) CA 3 (2013–2025) FL 2 (1964–1993)

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.

← Caselaw search · G Cite Topics · Brief Check