44 Washington opinions name it 1 courts 2000–2025 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.
| Case | Followed | Cited |
|---|---|---|
In re the Disciplinary Proceeding Against Kuvaragreen2 sentences2025In an initial “attempt to provide an objective standard,” we “adopted five factors to consider when determining the appropriate sanction for 19 In re Disciplinary Proceeding Against Wallstrom, No. 202,188-3 lawyer misconduct,” sometimes called the “Noble factors.”6 Kuvara, 149 Wn.2d at 256 (citing Noble, 100 Wn.2d at 95-96 ). 2025Following our adoption of the ABA Standards, we continued to refine our analysis, recognizing that ‘“[i]nconsistent sanctions, either within a jurisdiction or among jurisdictions, cast doubt on the efficiency and the basic fairness of all disciplinary systems.’” Kuvara, 149 Wn.2d at 257 (quoting ABA, STANDARDS FOR 6 The Noble factors were “(1) the purposes of attorney discipline, (2) proportionality of the sanction to the misconduct, (3) the effect of the sanction on the attorney, (4) whether the Board’s recommendation is supported by the record, and (5) the extent of agreement among the membe | 8 | 22 |
In Re Noblegreen2 sentences2025In an initial “attempt to provide an objective standard,” we “adopted five factors to consider when determining the appropriate sanction for 19 In re Disciplinary Proceeding Against Wallstrom, No. 202,188-3 lawyer misconduct,” sometimes called the “Noble factors.”6 Kuvara, 149 Wn.2d at 256 (citing Noble, 100 Wn.2d at 95-96 ). 2024See In re Disciplinary Proceeding Against Noble, 100 Wn.2d 88, 95 , 667 P.2d 608 (1983) (setting forth proportionality as one of five factors to consider); In re Disciplinary Proceeding Against Kuvara, 149 Wn.2d 237, 256 , 66 P.3d 1057 (2003) (getting rid of several Noble factors but retaining proportionality). | 5 | 28 |
Matter of Disciplinary Proceeding Against Kuvaragreen2 sentences2024See In re Disciplinary Proceeding Against Noble, 100 Wn.2d 88, 95 , 667 P.2d 608 (1983) (setting forth proportionality as one of five factors to consider); In re Disciplinary Proceeding Against Kuvara, 149 Wn.2d 237, 256 , 66 P.3d 1057 (2003) (getting rid of several Noble factors but retaining proportionality). 2006See In re Disciplinary Proceeding Against Kuvara, 149 Wn.2d 237, 259 , 66 P.3d 1057 (2003) (holding that the court would “retain the Noble factors of proportionality and degree of unanimity, but discard the remaining three as redundant due to the existence of similar provisions in the Standards and the ELC”); In re Disciplinary Proceeding Against Noble, 100 Wn.2d 88, 95-96 , 667 P.2d 608 (1983) (identifying five factors to be considered in determining appropriate sanction). ¶25 The determination of the presumptive sanction is straightforward. | 4 | 15 |
In re the Disciplinary Proceeding Against Schwimmergreen2 sentences2021Noble, 100 Wn.2d at 95-96 ; In re Disciplinary Proceeding Against Schwimmer, 153 Wn.2d 752, 758 , 108 P.3d 761 (2005). 2008Under our current jurisprudence, the two Noble factors that should be considered are “(1) proportionality of the sanction to the misconduct and (2) the extent of agreement among the members of the Disciplinary Board.” Id. at 764 . | 2 | 9 |
In re the Disciplinary Proceeding Against Millergreen2 sentences2004In re Disciplinary Proceeding Against Noble, 100 Wn.2d 88 , 667 P.2d 608 (1983); see Miller, 149 Wn.2d at 275 n.17, 278 n.20. 2004In re Disciplinary Proceeding Against Noble, 100 Wn.2d 88 , 667 P.2d 608 (1983); see Miller, 149 Wn.2d at 275 n.17, 278 n.20. | 2 | 2 |
In Re the Disciplinary Proceeding Against Hankingreen2 sentences2003Compare In re Disciplinary Proceedings Against Huddleston, 137 Wash.2d 560 , 974 P.2d 325 (1999) (applying only the Standards ), with Hankin, 116 Wash.2d at 310 , 804 P.2d 30 (applying both the Standards and the Noble factors). 2003Compare In re Disciplinary Proceeding Against Huddleston, 137 Wn.2d 560 , 974 P.2d 325 (1999) (applying only the Standards), with Hankin, 116 Wn.2d at 310 (applying both the Standards and the Noble factors). | 2 | 2 |
In re the Disciplinary Proceeding Against Huddlestongreen2 sentences2003Compare In re Disciplinary Proceedings Against Huddleston, 137 Wash.2d 560 , 974 P.2d 325 (1999) (applying only the Standards ), with Hankin, 116 Wash.2d at 310 , 804 P.2d 30 (applying both the Standards and the Noble factors). 2003Compare In re Disciplinary Proceeding Against Huddleston, 137 Wn.2d 560 , 974 P.2d 325 (1999) (applying only the Standards), with Hankin, 116 Wn.2d at 310 (applying both the Standards and the Noble factors). | 2 | 2 |
In Re Disciplinary Proceedings Against Huddlestongreen2 sentences2003Compare In re Disciplinary Proceedings Against Huddleston, 137 Wash.2d 560 , 974 P.2d 325 (1999) (applying only the Standards ), with Hankin, 116 Wash.2d at 310 , 804 P.2d 30 (applying both the Standards and the Noble factors). 2003Compare In re Disciplinary Proceeding Against Huddleston, 137 Wn.2d 560 , 974 P.2d 325 (1999) (applying only the Standards), with Hankin, 116 Wn.2d at 310 (applying both the Standards and the Noble factors). | 2 | 2 |
Matter of Disciplinary Proceeding Against Schwimmergreen2 sentences2008Under our current jurisprudence, the two Noble factors that should be considered are "(1) proportionality of the sanction to the misconduct and (2) the extent of agreement among the members of the Disciplinary Board." Id. at 764, 108 P.3d 761 . 2008Under our current jurisprudence, the two Noble factors that should be considered are "(1) proportionality of the sanction to the misconduct and (2) the extent of agreement among the members of the Disciplinary Board." Id. at 764, 108 P.3d 761 . | 1 | 6 |
In re Disciplinary Proc. Against Kelleygreen2 sentences2025Yet, we retained the Noble factors of “proportionality and unanimity,” reasoning these were still necessary “to achieve not only consistency but fundamental fairness.” Kelley, 3 Wn.3d at 550 n.9; Kuvara, 149 Wn.2d at 258 . 2025Yet, we retained the Noble factors of “proportionality and unanimity,” reasoning these were still necessary “to achieve not only consistency but fundamental fairness.” Kelley, 3 Wn.3d at 550 n.9; Kuvara, 149 Wn.2d at 258 . | 1 | 1 |
In re the Disciplinary Proceeding Against Brothersgreen1 sentence2005See Brothers, 149 Wn.2d at 587 . ¶67 Neither of the two remaining Noble factors, proportionality or unanimity, convinces us that we should impose a different sanction. | 1 | 1 |
In Re Disciplinary Proceeding Millergreen2 sentences2004In re Disciplinary Proceeding Against Noble, 100 Wash.2d 88 , 667 P.2d 608 (1983); See Miller, 149 Wash.2d at 275 n. 17, 278 n. 20, 66 P.3d 1069 . [10] Dynan argues that appropriate conclusions of law may not be reached because the hearing officer did not appropriately set out her findings of fact. 2004In re Disciplinary Proceeding Against Noble, 100 Wash.2d 88 , 667 P.2d 608 (1983); See Miller, 149 Wash.2d at 275 n. 17, 278 n. 20, 66 P.3d 1069 . [10] Dynan argues that appropriate conclusions of law may not be reached because the hearing officer did not appropriately set out her findings of fact. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In re the Disciplinary Proceeding Against Boelter
green
2 sentences2000In addition to the ABA Standards, we are directed to the formal, if not “redundant” (In re Discipline of Boelter, 139 Wn.2d 81, 103 , 985 P.2d 328 (1999)) Noble factors enumerated above. 2000In addition to the ABA Standards, we are directed to the formal, if not "redundant" ( In re Disciplinary Proceeding Against Boelter, 139 Wash.2d 81, 103 , 985 P.2d 328 (1999)) Noble factors enumerated above. | 6 | 2000–2003 |
In Re Boelter
green
2 sentences2000In addition to the ABA Standards, we are directed to the formal, if not “redundant” (In re Discipline of Boelter, 139 Wn.2d 81, 103 , 985 P.2d 328 (1999)) Noble factors enumerated above. 2000In addition to the ABA Standards, we are directed to the formal, if not "redundant" ( In re Disciplinary Proceeding Against Boelter, 139 Wash.2d 81, 103 , 985 P.2d 328 (1999)) Noble factors enumerated above. | 5 | 2000–2003 |
In re the Disciplinary Proceeding Against Tasker
green
2 sentences2005Kuvara, 149 Wn.2d at 259 . ¶31 Schwimmer points only to In re Disciplinary Proceeding Against Tasker, 141 Wn.2d 557 , 9 P.3d 822 (2000), to support his claim of disproportionality. 2005Kuvara, 149 Wash.2d at 259 , 66 P.3d 1057 . ¶ 31 Schwimmer points only to In re Disciplinary Proceeding Against Tasker, 141 Wash.2d 557 , 9 P.3d 822 (2000), to support his claim of disproportionality. | 4 | 2003–2005 |
In Re Disciplinary Proceeding Against Tasker
green
2 sentences2005Kuvara, 149 Wn.2d at 259 . ¶31 Schwimmer points only to In re Disciplinary Proceeding Against Tasker, 141 Wn.2d 557 , 9 P.3d 822 (2000), to support his claim of disproportionality. 2005Kuvara, 149 Wash.2d at 259 , 66 P.3d 1057 . ¶ 31 Schwimmer points only to In re Disciplinary Proceeding Against Tasker, 141 Wash.2d 557 , 9 P.3d 822 (2000), to support his claim of disproportionality. | 4 | 2003–2005 |
In Re Disciplinary Proc. Against Cohen
green
2 sentences2009In re Disciplinary Proceeding Against Cohen, 150 Wash.2d 744, 754 , 82 P.3d 224 (2004). ¶ 24 If raised, we must consider two Noble factors before imposing a sanction. 2009In re Disciplinary Proceeding Against Cohen, 150 Wn.2d 744, 754 , 82 P.3d 224 (2004). ¶24 If raised, we must consider two Noble factors before imposing a sanction. | 2 | 2009–2009 |
In re the Disciplinary Proceeding Against Holcomb
green
2 sentences2009In re Disciplinary Proceeding Against Holcomb, 162 Wn.2d 563, 592 , 173 P.3d 898 (2007). 2009In re Disciplinary Proceeding Against Holcomb, 162 Wn.2d 563, 592 , 173 P.3d 898 (2007). | 2 | 2009–2009 |
In re the Disciplinary Proceeding Against Eugster
green
2 sentences2009Eugster, 166 Wn.2d at 315 (citing Schwimmer, 153 Wn.2d at 764 (citing Kuvara, 149 Wn.2d 237 )). 2009Eugster, 166 Wn.2d at 315 (citing Schwimmer, 153 Wn.2d at 764 (citing Kuvara, 149 Wn.2d 237 )). | 2 | 2009–2009 |
IN re the Disciplinary Proceeding Against Cohen
green
2 sentences2009In re Disciplinary Proceeding Against Cohen, 150 Wash.2d 744, 754 , 82 P.3d 224 (2004). ¶ 24 If raised, we must consider two Noble factors before imposing a sanction. 2009In re Disciplinary Proceeding Against Cohen, 150 Wn.2d 744, 754 , 82 P.3d 224 (2004). ¶24 If raised, we must consider two Noble factors before imposing a sanction. | 2 | 2009–2009 |
In Re Disciplinary Proceeding Against Holcomb
green
2 sentences2009In re Disciplinary Proceeding Against Holcomb, 162 Wn.2d 563, 592 , 173 P.3d 898 (2007). 2009In re Disciplinary Proceeding Against Holcomb, 162 Wn.2d 563, 592 , 173 P.3d 898 (2007). | 2 | 2009–2009 |
In re the Disciplinary Proceeding against Dann
green
2 sentences2003Although this court is not bound by the Board's recommendation, as "`the only body to hear the full range of disciplinary matters, the [Disciplinary] Board has the opportunity to develop unique experience and perspective in the administration of sanctions.'" Dann, 136 Wash.2d at 84 , 960 P.2d 416 (quoting In re Disciplinary Proceeding Against Noble, 100 Wash.2d 88, 94 , 667 P.2d 608 (1983)). 2003Although this court is not bound by the Board’s recommendation, as “ ‘the only body to hear the full range of disciplinary matters, the [Disciplinary] Board has the opportunity to develop unique experience and perspective in the administration of sanctions.’ ” Dann, 136 Wn.2d at 84 (quoting In re Disciplinary Proceeding Against Noble, 100 Wn.2d 88, 94 , 667 P.2d 608 (1983)). | 2 | 2003–2003 |
MATTER OF DISCIPLINE PROCEEDING AGAINST McLENDON
green
2 sentences2000The WSBA is no doubt correct that one of the purposes of lawyer discipline — deterring other attorney misconduct (In re Discipline of McLendon, 120 Wn.2d 761, 774 , 845 P.2d 1006 (1993)) — might be served by disbarring Tasker {Noble Factor 1). 2000The WSBA is no doubt correct that one of the purposes of lawyer discipline — deterring other attorney misconduct (In re Discipline of McLendon, 120 Wn.2d 761, 774 , 845 P.2d 1006 (1993)) — might be served by disbarring Tasker {Noble Factor 1). | 2 | 2000–2000 |
In re the Disciplinary Proceeding Against Preszler
green
2 sentences2025Preszler, 169 Wn.2d at 18 ; see generally Kelley, 3 Wn.3d 541 ; In re Disciplinary Proceeding Against Huynh, 3 Wn.3d 648, 685-87 , 555 P.3d 398 (2024). 7 The “superfluous” Noble factors are “the purpose of attorney discipline,” “the effect of the sanction on the attorney,” and “that in order for the Board’s recommendation to be upheld, it must be supported by the record.” Kuvara, 149 Wn.2d at 257-58 . 21 In re Disciplinary Proceeding Against Wallstrom, No. 202,188-3 Thus, since this court adopted the ABA Standards over 30 years ago, we have carefully refined our sanctions analysis to provide c 2025Preszler, 169 Wn.2d at 18 ; see generally Kelley, 3 Wn.3d 541 ; In re Disciplinary Proceeding Against Huynh, 3 Wn.3d 648, 685-87 , 555 P.3d 398 (2024). 7 The “superfluous” Noble factors are “the purpose of attorney discipline,” “the effect of the sanction on the attorney,” and “that in order for the Board’s recommendation to be upheld, it must be supported by the record.” Kuvara, 149 Wn.2d at 257-58 . 21 In re Disciplinary Proceeding Against Wallstrom, No. 202,188-3 Thus, since this court adopted the ABA Standards over 30 years ago, we have carefully refined our sanctions analysis to provide c | 1 | 2025–2025 |
In re Disciplinary Proc. Against Huynh
green
2 sentences2025Preszler, 169 Wn.2d at 18 ; see generally Kelley, 3 Wn.3d 541 ; In re Disciplinary Proceeding Against Huynh, 3 Wn.3d 648, 685-87 , 555 P.3d 398 (2024). 7 The “superfluous” Noble factors are “the purpose of attorney discipline,” “the effect of the sanction on the attorney,” and “that in order for the Board’s recommendation to be upheld, it must be supported by the record.” Kuvara, 149 Wn.2d at 257-58 . 21 In re Disciplinary Proceeding Against Wallstrom, No. 202,188-3 Thus, since this court adopted the ABA Standards over 30 years ago, we have carefully refined our sanctions analysis to provide c 2025Preszler, 169 Wn.2d at 18 ; see generally Kelley, 3 Wn.3d 541 ; In re Disciplinary Proceeding Against Huynh, 3 Wn.3d 648, 685-87 , 555 P.3d 398 (2024). 7 The “superfluous” Noble factors are “the purpose of attorney discipline,” “the effect of the sanction on the attorney,” and “that in order for the Board’s recommendation to be upheld, it must be supported by the record.” Kuvara, 149 Wn.2d at 257-58 . 21 In re Disciplinary Proceeding Against Wallstrom, No. 202,188-3 Thus, since this court adopted the ABA Standards over 30 years ago, we have carefully refined our sanctions analysis to provide c | 1 | 2025–2025 |
In re the Disciplinary Proceeding Against Dynan
green
2 sentences2024“The court will adopt the Board’s recommended sanction unless the sanction is not 22 No. 202153-1 proportionate or the Board was not unanimous in its decision.” Dynan, 152 Wn.2d at 623 . 2024“The court will adopt the Board’s recommended sanction unless the sanction is not 22 No. 202153-1 proportionate or the Board was not unanimous in its decision.” Dynan, 152 Wn.2d at 623 . | 1 | 2024–2024 |
In Re Disciplinary Proceeding Eugster
green
2 sentences2009Eugster, 166 Wash.2d at 315 , 209 P.3d 435 (citing Schwimmer, 153 Wash.2d at 764 , 108 P.3d 761 (citing Kuvara, 149 Wash.2d 237 , 66 P.3d *905 1057)). 2009Eugster, 166 Wash.2d at 315 , 209 P.3d 435 (citing Schwimmer, 153 Wash.2d at 764 , 108 P.3d 761 (citing Kuvara, 149 Wash.2d 237 , 66 P.3d *905 1057)). | 1 | 2009–2009 |
MATTER OF DISCIPLINARY PROCEEDING AGAINST McKEAN
green
1 sentence2006See Kuvara, 149 Wn.2d at 257 -59 (citing In re Disciplinary Proceeding Against Noble, 100 Wn.2d 88, 95-96 , 667 P.2d 608 (1983)). ¶57 Proportionality: Poole offers several cases to persuade this court that the Board’s imposition of a one-year suspension in this case is “grossly disproportionate” to analogous discipline cases, relying principally on Carmick, Boelter, Dynan, and McKean (In re Disciplinary Proceeding Against McKean, 148 Wn.2d 849 , 64 P.3d 1226 (2003)). | 1 | 2006–2006 |
In re the Disciplinary Proceeding Against McKean
green
1 sentence2006See Kuvara, 149 Wn.2d at 257 -59 (citing In re Disciplinary Proceeding Against Noble, 100 Wn.2d 88, 95-96 , 667 P.2d 608 (1983)). ¶57 Proportionality: Poole offers several cases to persuade this court that the Board’s imposition of a one-year suspension in this case is “grossly disproportionate” to analogous discipline cases, relying principally on Carmick, Boelter, Dynan, and McKean (In re Disciplinary Proceeding Against McKean, 148 Wn.2d 849 , 64 P.3d 1226 (2003)). | 1 | 2006–2006 |
Matter of Dann
green
1 sentence2003Although this court is not bound by the Board's recommendation, as "`the only body to hear the full range of disciplinary matters, the [Disciplinary] Board has the opportunity to develop unique experience and perspective in the administration of sanctions.'" Dann, 136 Wash.2d at 84 , 960 P.2d 416 (quoting In re Disciplinary Proceeding Against Noble, 100 Wash.2d 88, 94 , 667 P.2d 608 (1983)). | 1 | 2003–2003 |
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.