Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
46 Washington opinions name it 2 courts 1909–2025 6 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 |
|---|---|---|
In Re Markelgreen2 sentences2023Restraint of Markel, 154 Wn.2d 262, 274 , 111 P.3d 249 (2005) (“Under this sentencing scheme, a ‘same criminal conduct’ finding is an exception to the default rule that all convictions must count separately.”); State v. Lopez, 142 Wn. App. 341, 351 , 174 P.3d 1216 (2007) (“In determining a defendant’s offender score under the [SRA], two or more current offenses and prior offenses are presumed to count separately unless the trial court finds that the current offenses encompass the same criminal conduct.”). 2023Restraint of Markel, 154 Wn.2d 262, 274 , 111 P.3d 249 (2005) (“Under this sentencing scheme, a ‘same criminal conduct’ finding is an exception to the default rule that all convictions must count separately.”); State v. Lopez, 142 Wn. App. 341, 351 , 174 P.3d 1216 (2007) (“In determining a defendant’s offender score under the [SRA], two or more current offenses and prior offenses are presumed to count separately unless the trial court finds that the current offenses encompass the same criminal conduct.”). | 2 | 2 |
Department of Social & Health Services v. Browngreen2 sentences2017In re C.R.B., 62 Wn. 2014For this basis, I rely on In re Dependency of C.R.B., 62 Wn. App. at 618-19, in which we held that testimony, during a default hearing, that parrots the statutory — requirements of termination and corresponding findings of fact are not sufficient. | 2 | 2 |
In Re Dissolution & Winding Up of KeyTronicsgreen2 sentences2015As the Supreme Court of Nebraska observed, applying the RUPA, the indicia of co-ownership, which include profit sharing and loss sharing, “are only that; they are not all necessary to establish a partnership relationship, and no single indicium of co-ownership is either necessary or sufficient to prove co-ownership.” In re Dissolution & Winding Up of KeyTronics, 274 Neb. 936 , 744 N.W.2d 425, 441 (2008). ¶63 In Stuart v. Overland Medical Center, 510 S.W.2d 494, 497-98 (Mo. Ct. App. 1974), a court applying the UPA, the predecessor to the RUPA, held that an economic arrangement under which profe 2015As the Supreme Court of Nebraska observed, applying the RUPA, the indicia of co-ownership, which include profit sharing and loss sharing, “are only that; they are not all necessary to establish a partnership relationship, and no single indicium of co-ownership is either necessary or sufficient to prove co-ownership.” In re Dissolution & Winding Up of KeyTronics, 274 Neb. 936 , 744 N.W.2d 425, 441 (2008). ¶63 In Stuart v. Overland Medical Center, 510 S.W.2d 494, 497-98 (Mo. Ct. App. 1974), a court applying the UPA, the predecessor to the RUPA, held that an economic arrangement under which profe | 2 | 2 |
State v. Smithgreen2 sentences2010See RCW 5.60.020 (“Every person of sound mind and discretion . . . may be a witness in any action, or proceeding.”); ER 601 (“Every person is competent to be a witness except as otherwise provided by statute or by court rule.”); see also State v. Smith, 97 Wn.2d 801, 803 , 650 P.2d 201 (1982) (“Where there has been no such adjudication [of insanity], the burden is on the party opposing the witness to prove incompetence.”). 2010See RCW 5.60.020 (“Every person of sound mind and discretion . . . may be a witness in any action, or proceeding.”); ER 601 (“Every person is competent to be a witness except as otherwise provided by statute or by court rule.”); see also State v. Smith, 97 Wn.2d 801, 803 , 650 P.2d 201 (1982) (“Where there has been no such adjudication [of insanity], the burden is on the party opposing the witness to prove incompetence.”). | 2 | 2 |
Commercial Courier Service, Inc. v. Millergreen2 sentences2003See Commercial Courier Serv., Inc. v. Miller, 13 Wash.App. 98, 105-07 , 533 P.2d 852 (1975) (defendant disregarded summons because he thought it was only a bluff). 2003See Commercial Courier Serv., Inc. v. Miller, 13 Wn. | 2 | 2 |
Spokane County v. Stategreen2 sentences1999See, e.g., Mahler v. Szucs, 135 Wash.2d 398 , 957 P.2d 632 , 966 P.2d 305 (1998); Scott Fetzer Co. v. Weeks, 122 Wash.2d 141 , 859 P.2d 1210 (1993); see, generally, Philip A. Talmadge, Attorney Fees in Washington: Annotated Statutes, Cases and Commentary at 293-97 (Charles P. Siner & Cutler and Nylander eds., rev. ed. 1995). 1999See, e.g., Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 , 966 P.2d 305 (1998); Scott Fetzer Co. v. Weeks, 122 Wn.2d 141 , 859 P.2d 1210 (1993); see, generally, Philip A. Talmadge, Attorney Pees in Washington: Annotated Statutes, Cases and Commentary at 293-97 (Charles P. Siner ed., rev. ed. 1995). | 2 | 2 |
Mahler v. Szucsred2 sentences1999See, e.g., Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 , 966 P.2d 305 (1998); Scott Fetzer Co. v. Weeks, 122 Wn.2d 141 , 859 P.2d 1210 (1993); see, generally, Philip A. Talmadge, Attorney Pees in Washington: Annotated Statutes, Cases and Commentary at 293-97 (Charles P. Siner ed., rev. ed. 1995). 1999See, e.g., Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 , 966 P.2d 305 (1998); Scott Fetzer Co. v. Weeks, 122 Wn.2d 141 , 859 P.2d 1210 (1993); see, generally, Philip A. Talmadge, Attorney Pees in Washington: Annotated Statutes, Cases and Commentary at 293-97 (Charles P. Siner ed., rev. ed. 1995). | 2 | 2 |
Tesoro Refining & Marketing v. State, Dorgreen2 sentences2024Co. v. Dep’t of Revenue, 164 Wn.2d 310, 319 , 190 P.3d 28 (2008) (“As a default rule, the word ‘or’ does not mean ‘and’ unless legislative intent clearly indicates to the contrary.”). 2024Co. v. Dep’t of Revenue, 164 Wn.2d 310, 319 , 190 P.3d 28 (2008) (“As a default rule, the word ‘or’ does not mean ‘and’ unless legislative intent clearly indicates to the contrary.”). | 1 | 2 |
State v. Grantgreen2 sentences2000State v. Grant, 89 Wash.2d at 684, 575 P.2d 210 . 2000Id. at 684 . | 1 | 2 |
State v. Lopezgreen2 sentences2023Restraint of Markel, 154 Wn.2d 262, 274 , 111 P.3d 249 (2005) (“Under this sentencing scheme, a ‘same criminal conduct’ finding is an exception to the default rule that all convictions must count separately.”); State v. Lopez, 142 Wn. App. 341, 351 , 174 P.3d 1216 (2007) (“In determining a defendant’s offender score under the [SRA], two or more current offenses and prior offenses are presumed to count separately unless the trial court finds that the current offenses encompass the same criminal conduct.”). 2023Restraint of Markel, 154 Wn.2d 262, 274 , 111 P.3d 249 (2005) (“Under this sentencing scheme, a ‘same criminal conduct’ finding is an exception to the default rule that all convictions must count separately.”); State v. Lopez, 142 Wn. App. 341, 351 , 174 P.3d 1216 (2007) (“In determining a defendant’s offender score under the [SRA], two or more current offenses and prior offenses are presumed to count separately unless the trial court finds that the current offenses encompass the same criminal conduct.”). | 1 | 1 |
Cox v. Spanglergreen2 sentences2020See Cox v. Spangler, 141 Wn.2d 431, 446 , 5 P.3d 1265 (2000) (noting that joint liability applies when there is either concert of action or independent torts uniting to cause a single injury). 2020See Cox v. Spangler, 141 Wn.2d 431, 446 , 5 P.3d 1265 (2000) (noting that joint liability applies when there is either concert of action or independent torts uniting to cause a single injury). | 1 | 1 |
State v. Kinggreen1 sentence2016Id. at 488; accord State v. King, 149 Wn. | 1 | 1 |
Stuart v. Overland Medical Centergreen1 sentence2015As the Supreme Court of Nebraska observed, applying the RUPA, the indicia of co-ownership, which include profit sharing and loss sharing, “are only that; they are not all necessary to establish a partnership relationship, and no single indicium of co-ownership is either necessary or sufficient to prove co-ownership.” In re Dissolution & Winding Up of KeyTronics, 274 Neb. 936 , 744 N.W.2d 425, 441 (2008). ¶63 In Stuart v. Overland Medical Center, 510 S.W.2d 494, 497-98 (Mo. Ct. App. 1974), a court applying the UPA, the predecessor to the RUPA, held that an economic arrangement under which profe | 1 | 1 |
| Klettke v. Klettkegreen | 1 | 1 |
| Barksdale v. Peoples Financial Corp. of Alpharettagreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Stein v. Waddell
neutral
2 sentences1918In Tacoma Water Supply Co. v. Dumermuth, 51 Wash. 609 , 99 Pac. 741 , the court said: “After the respondents acquired their deed from the state, their obligation to convey and the-obligation on the part of the purchaser, to pay the purchase price became mutual, concurrent and dependent, and neither party could thereafter put the other in default or claim a forfeiture without first tendering performance on his part; and this, whether the contract contained a forfeiture clause or not.” See, also, Mudgett v. Clay, 5 Wash. 103 , 31 Pac. 424 ; Underwood v. Tew, 7 Wash. 297 , 34 Pac. 1100 ; Stein v. 1918In Tacoma Water Supply Co. v. Dumermuth, 51 Wash. 609 , 99 Pac. 741 , the court said: “After the respondents acquired their deed from the state, their obligation to convey and the-obligation on the part of the purchaser, to pay the purchase price became mutual, concurrent and dependent, and neither party could thereafter put the other in default or claim a forfeiture without first tendering performance on his part; and this, whether the contract contained a forfeiture clause or not.” See, also, Mudgett v. Clay, 5 Wash. 103 , 31 Pac. 424 ; Underwood v. Tew, 7 Wash. 297 , 34 Pac. 1100 ; Stein v. | 3 | 1909–1918 |
Mudgett v. Clay
neutral
2 sentences1918In Tacoma Water Supply Co. v. Dumermuth, 51 Wash. 609 , 99 Pac. 741 , the court said: “After the respondents acquired their deed from the state, their obligation to convey and the-obligation on the part of the purchaser, to pay the purchase price became mutual, concurrent and dependent, and neither party could thereafter put the other in default or claim a forfeiture without first tendering performance on his part; and this, whether the contract contained a forfeiture clause or not.” See, also, Mudgett v. Clay, 5 Wash. 103 , 31 Pac. 424 ; Underwood v. Tew, 7 Wash. 297 , 34 Pac. 1100 ; Stein v. 1918In Tacoma Water Supply Co. v. Dumermuth, 51 Wash. 609 , 99 Pac. 741 , the court said: “After the respondents acquired their deed from the state, their obligation to convey and the-obligation on the part of the purchaser, to pay the purchase price became mutual, concurrent and dependent, and neither party could thereafter put the other in default or claim a forfeiture without first tendering performance on his part; and this, whether the contract contained a forfeiture clause or not.” See, also, Mudgett v. Clay, 5 Wash. 103 , 31 Pac. 424 ; Underwood v. Tew, 7 Wash. 297 , 34 Pac. 1100 ; Stein v. | 3 | 1909–1918 |
Underwood v. Tew
neutral
2 sentences1918In Tacoma Water Supply Co. v. Dumermuth, 51 Wash. 609 , 99 Pac. 741 , the court said: “After the respondents acquired their deed from the state, their obligation to convey and the-obligation on the part of the purchaser, to pay the purchase price became mutual, concurrent and dependent, and neither party could thereafter put the other in default or claim a forfeiture without first tendering performance on his part; and this, whether the contract contained a forfeiture clause or not.” See, also, Mudgett v. Clay, 5 Wash. 103 , 31 Pac. 424 ; Underwood v. Tew, 7 Wash. 297 , 34 Pac. 1100 ; Stein v. 1918In Tacoma Water Supply Co. v. Dumermuth, 51 Wash. 609 , 99 Pac. 741 , the court said: “After the respondents acquired their deed from the state, their obligation to convey and the-obligation on the part of the purchaser, to pay the purchase price became mutual, concurrent and dependent, and neither party could thereafter put the other in default or claim a forfeiture without first tendering performance on his part; and this, whether the contract contained a forfeiture clause or not.” See, also, Mudgett v. Clay, 5 Wash. 103 , 31 Pac. 424 ; Underwood v. Tew, 7 Wash. 297 , 34 Pac. 1100 ; Stein v. | 3 | 1909–1918 |
Brand v. DEPT. OF LABOR & INDUSTRIES
green
2 sentences2009In his concurring opinion in Brand v. Department of Labor & Industries, 139 Wn.2d 659 , 989 P.2d 1111 (1999), Justice Talmadge referred to the lodestar approach as “the default principle” for calculating attorney fees in Washington. 2009In his concurring opinion in Brand v. Department of Labor & Industries, 139 Wn.2d 659 , 989 P.2d 1111 (1999), Justice Talmadge referred to the lodestar approach as “the default principle” for calculating attorney fees in Washington. | 2 | 2009–2009 |
Chevron Oil Co. v. Huson
red
2 sentences2009Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S. Ct. 349 , 30 L. 2009Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S. Ct. 349 , 30 L. | 2 | 2009–2009 |
Mullane v. Central Hanover Bank & Trust Co.
green
2 sentences2008Olympic Forest Prods., Inc., 82 Wash.2d at 422 , 511 P.2d 1002 (quoting Mullane, 339 U.S. at 314 , 70 S.Ct. 652 ). ¶ 17 We disagree with Nightrunners that its status as a foreign business entity entitles it to special notice and explanation. 2008Olympic Forest Prods., Inc., 82 Wn.2d at 422 (quoting Mullane, 339 U.S. at 314 ). ¶17 We disagree with Nightrunners that its status as a foreign business entity entitles it to special notice and explanation. | 2 | 2008–2008 |
Olympic Forest Products, Inc. v. Chaussee Corp.
green
2 sentences2008Olympic Forest Prods., Inc., 82 Wash.2d at 422 , 511 P.2d 1002 (quoting Mullane, 339 U.S. at 314 , 70 S.Ct. 652 ). ¶ 17 We disagree with Nightrunners that its status as a foreign business entity entitles it to special notice and explanation. 2008Olympic Forest Prods., Inc., 82 Wn.2d at 422 (quoting Mullane, 339 U.S. at 314 ). ¶17 We disagree with Nightrunners that its status as a foreign business entity entitles it to special notice and explanation. | 2 | 2008–2008 |
Thompson v. St. Regis Paper Company
green
2 sentences2002Ford, therefore, falls under the default rule: an employer can discharge an at-will employee for "no cause, good cause or even cause morally wrong without fear of liability." Thompson , 102 Wash.2d at 226 , 685 P.2d 1081 . 2002Ford, therefore, falls under the default rule: an employer can discharge an at-will employee for “no cause, good cause or even cause morally wrong without fear of liability.” Thompson , 102 Wn.2d at 226 . | 2 | 2002–2002 |
Scott Fetzer Co. v. Weeks
green
2 sentences1999See, e.g., Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 , 966 P.2d 305 (1998); Scott Fetzer Co. v. Weeks, 122 Wn.2d 141 , 859 P.2d 1210 (1993); see, generally, Philip A. Talmadge, Attorney Pees in Washington: Annotated Statutes, Cases and Commentary at 293-97 (Charles P. Siner ed., rev. ed. 1995). 1999See, e.g., Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 , 966 P.2d 305 (1998); Scott Fetzer Co. v. Weeks, 122 Wn.2d 141 , 859 P.2d 1210 (1993); see, generally, Philip A. Talmadge, Attorney Pees in Washington: Annotated Statutes, Cases and Commentary at 293-97 (Charles P. Siner ed., rev. ed. 1995). | 2 | 1999–1999 |
Gregory v. Ashcroft
green
1 sentence2025As noted, the clear statement federalism rule requires Congress to make its intent “‘unmistakably clear’ when enacting statutes that would alter the usual constitutional balance between the Federal Government and the States.” Hayden, 449 F.3d at 323 (internal quotation marks omitted) (quoting Gregory, 501 U.S. at 460 ). | 1 | 2025–2025 |
DeNoskoff v. Scott
green
1 sentence2024Politoff, 36 Wn. App. at 426-27 . | 1 | 2024–2024 |
Park Pet Shop, Inc. v. City of Chicago
green
1 sentence2021In similar instances, at least one federal circuit court of appeals has held that Pike “is not the default standard of review for any state or local law that affects interstate commerce.” Park Pet Shop, 872 F.3d at 502 (citing Nat’l Paint, 45 F.3d at 1131 ). | 1 | 2021–2021 |
Ctr. for Envtl. Law & Policy v. Dep't of Ecology
green
2 sentences2021Law & Policy v. Dep’t of Ecology, 196 Wn.2d 17 , 33, 468 P.3d 1064 (2020) (alteration in original) (quoting Tesoro Ref. & Mktg. 2021Law & Policy v. Dep’t of Ecology, 196 Wn.2d 17 , 33, 468 P.3d 1064 (2020) (alteration in original) (quoting Tesoro Ref. & Mktg. | 1 | 2021–2021 |
National Paint & Coatings Association v. City of Chicago
green
1 sentence2021In similar instances, at least one federal circuit court of appeals has held that Pike “is not the default standard of review for any state or local law that affects interstate commerce.” Park Pet Shop, 872 F.3d at 502 (citing Nat’l Paint, 45 F.3d at 1131 ). | 1 | 2021–2021 |
Bowers v. Transamerica Title Insurance
green
1 sentence2020Id. at 597 . | 1 | 2020–2020 |
Thorndike v. Hesperian Orchards, Inc.
green
1 sentence2017Hesperian, 54 Wn.2d at 575 . 3 No. 34050-3-111 Secco v. Secco-dissent must be undertaken to serve someone who has been resisting service should be rejected as a matter of public policy. 2 Viewing this record in a light most favorable to the judgment below, as I think we should be doing, we have the following facts: (1) Mr. Secco eight times evaded service by people he knew were trying to serve dissolution paperwork; (2) Mr. Secco received the documents in the mail; (3) Mr. Secco did not appear in the action; (4) Mr. Secco was even served with notice of the default hearing, but did not contact | 1 | 2017–2017 |
Johnson v. Cash Store
green
2 sentences2014App. 833, 848-49 , 68 P.3d 1099 (2003). 13 jd, at 839. 14 jd, at 848. 15 Id. 2014In Johnson v. Cash Store, Division Three reached a similar conclusion regarding the entry of a default judgment.12 There, the Cash Store's manager was personally served with a summons and complaint.13 "Because she thought the documents were irrelevant to Cash Store business, [the manager] explained, she never informed the company's administration or its legal counsel that she had received them."14 The manager also did not respond to the notice of the default hearing, and there was nothing in the record to explain what she did with that notice.15 12 116 Wn. | 1 | 2014–2014 |
| COSMOPOLITAN ENG. GROUP v. Ondeo Degremont, Inc. green | 1 | 2014–2014 |
| State, Dept. of Ecology v. Campbell & Gwinn green | 1 | 2014–2014 |
| Nast v. Michels green | 1 | 2013–2013 |
| Harper v. Virginia Department of Taxation green | 1 | 2009–2009 |
| Seattle-First National Bank v. Tabert green | 1 | 2009–2009 |
| Ulmer v. Ford Motor Co. green | 1 | 2009–2009 |
| Little v. King green | 1 | 2007–2007 |
| Widicus v. Southwestern Electric Cooperative, Inc. green | 1 | 2007–2007 |
| Norton v. Brown green | 1 | 2003–2003 |
| Reynolds v. Insurance Co. of North America neutral | 1 | 1999–1999 |
| O'BRIEN v. Shearson Hayden Stone, Inc. green | 1 | 1999–1999 |
| Birenbaum v. Option Care, Inc. green | 1 | 1999–1999 |
| White v. White green | 1 | 1979–1979 |
| Brim v. Struthers green | 1 | 1979–1979 |
| Yeck v. Department of Labor & Industries neutral | 1 | 1970–1970 |
| Christy v. Baiocchi green | 1 | 1934–1934 |
| Lewis v. Wellard neutral | 1 | 1934–1934 |
| Bendon v. Parfit neutral | 1 | 1934–1934 |
| Tacoma Water Supply Co. v. Dumermuth neutral | 1 | 1918–1918 |
| Katz v. Hathaway neutral | 1 | 1918–1918 |
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.
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.