reasonable expectations test in Washington

2018App. 502, 509 , 728 P.2d 597 (1986). 27 Id. 25 Scott 148 Wn.2d at 711 . 8 No. 75847-1-1/9 conduct."29 "'Reasonable expectations' are those spoken and unspoken understandings on which the founders of a venture rely when commencing the venture."39 "Application of the reasonable expectations test is most appropriate in situations where the complaining shareholder was one of the original participants in the venture—one who would have committed capital and resources."31 The second oppression test is defined as "burdensome, harsh and wrongful conduct; a lack of probity and fair dealing in the affair

2018App. 502, 509 , 728 P.2d 597 (1986). 27 Id. 25 Scott 148 Wn.2d at 711 . 8 No. 75847-1-1/9 conduct."29 "'Reasonable expectations' are those spoken and unspoken understandings on which the founders of a venture rely when commencing the venture."39 "Application of the reasonable expectations test is most appropriate in situations where the complaining shareholder was one of the original participants in the venture—one who would have committed capital and resources."31 The second oppression test is defined as "burdensome, harsh and wrongful conduct; a lack of probity and fair dealing in the affair

2019But our Supreme Court "has on several occasions specifically declined to adopt the doctrine of reasonable expectations, under which the insured's subjective expectation of coverage determines the insurer's liability." Boeing, 113 Wn.2d at 894 ; see Quadrant, 154 Wn.2d at 172 ("[E]xpectations of the insured cannot override the plain language of the contract.").

2018App. 873, 889 , 167 P.3d 610 (2007)(citing it at 709). 39 Scott, 148 Wn.2d at 711 . 31 Id. 32 Id.(quoting Roblee v. Roblee, 68 Wn.

2018App. 69, 76 , 841 P.2d 1289 (1992)). 33 Id. at 712. 9 No. 75847-1-1/10 "These two tests are not mutually exclusive and one or both may be used in the same case, depending on the facts."34 "Under both tests, the complaining shareholder has the burden of proof, by a preponderance of the evidence, to establish the requisite jurisdictional facts and the equitable grounds for dissolution."35 As a threshold matter, the court properly applied the reasonable expectations test because Lucas and Daniel co-founded Gravity and there is evidence in the record as to their reasonable expectations.36 To suppo

2018App. 502, 509 , 728 P.2d 597 (1986). 27 Id. 25 Scott 148 Wn.2d at 711 . 8 No. 75847-1-1/9 conduct."29 "'Reasonable expectations' are those spoken and unspoken understandings on which the founders of a venture rely when commencing the venture."39 "Application of the reasonable expectations test is most appropriate in situations where the complaining shareholder was one of the original participants in the venture—one who would have committed capital and resources."31 The second oppression test is defined as "burdensome, harsh and wrongful conduct; a lack of probity and fair dealing in the affair

2018App. at 894 (citing Interlake Porsche, 45 Wn.

2018App. 873, 889 , 167 P.3d 610 (2007)(citing it at 709). 39 Scott, 148 Wn.2d at 711 . 31 Id. 32 Id.(quoting Roblee v. Roblee, 68 Wn.

2018In Scott v. Trans-System, Inc., our Supreme Court determined the reasonable expectations test should not be applied when "there is no indication in the record as to what the reasonable expectations of the parties were or whether [the complaining shareholder] invested any of his own money to facilitate the incorporation and development of[the company]."33 29 McCormick v. Dunn & Black, P.S., 140 Wn.

2018App. 69, 76 , 841 P.2d 1289 (1992)). 33 Id. at 712. 9 No. 75847-1-1/10 "These two tests are not mutually exclusive and one or both may be used in the same case, depending on the facts."34 "Under both tests, the complaining shareholder has the burden of proof, by a preponderance of the evidence, to establish the requisite jurisdictional facts and the equitable grounds for dissolution."35 As a threshold matter, the court properly applied the reasonable expectations test because Lucas and Daniel co-founded Gravity and there is evidence in the record as to their reasonable expectations.36 To suppo

2007Scott, 148 Wash.2d at 711 , 64 P.3d 1 .

1994Ed. 2d 576 , 88 S. Ct. 507 (1967)] are solely dispositive, but rather, each serves as a factor [that may be used] in determining whether the entry onto the property unconstitutionally intruded into a person’s 'private affairs’.” State v. Crandall, 39 Wn.

1994For purposes of Const, art. 1, § 7, "Neither the open fields doctrine of Oliver , which looks to the nature of the property viewed, nor the reasonable expectations test of Katz [v. United States, 389 U.S. 347 , 19 L.

1994For purposes of Const, art. 1, § 7, "Neither the open fields doctrine of Oliver , which looks to the nature of the property viewed, nor the reasonable expectations test of Katz [v. United States, 389 U.S. 347 , 19 L.