Washington: Supreme Court citation practice | Citation rule(s)


Examples from State v. Cannon, 147 Wash. 2d 41, 50 P.3d 627 (2002)

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Complying with the implied consent statute, RCW 46.20.308, Trooper Bosman submitted a sworn "Report of Breath/Blood Test for Alcohol" to the Department of Licensing (DOL). The DOL suspended Respondent Cannon's driving privileges for 90 days. She requested a formal adjudicative hearing before the Department. On September 13, 2001 the DOL held an administrative hearing by telephone to determine whether suspension of Respondent Cannon's driving privileges should be upheld.

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Respondent Cannon appealed to the Whatcom County Superior Court. On November 26, 2001 the trial court, the Honorable Steven J. Mura, suppressed Respondent's breath test results and reversed her license suspension, holding that the breath test did not meet the state toxicologist's precision and accuracy standards under newly amended WAC 448-13-040 and 448-13-060. In reaching that conclusion the trial court stated "WAC 448-13-040 and 448-13-060 require the proponent of the breath test to prove that the thermometer used in the subject breath test was certified as required by WAC 448-13-035 before the breath test can be considered valid."

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The basic foundational requirements for admission of breath test results were first established in State v. Baker, 56 Wn.2d 846, 852, 355 P.2d 806 (1960). When the BAC Verifier DataMaster replaced the Breathalyzer machine, a similar set of foundational requirements were adopted, ultimately codified in chapter 448-12 WAC, the precursor to the current WAC regulations in chapter 448-13 WAC. The new machine, and its supporting protocols, were challenged but approved in State v. Ford, 110 Wn.2d 827, 755 P.2d 806 (1988) and State v. Straka, 116 Wn.2d 859, 810 P.2d 888 (1991).

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WAC 448-13-010 articulates the reasons for the rules governing breath testing: (1) to inform "the public of the administrative aspects of the state's breath alcohol test program" and (2) to practice those principles accepted in the scientific community. Walk v. Dep't of Licensing, 95 Wn. App. 653, 657, 976 P.2d 185 (1999).

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Wash. Gen. R. 14, http://www.courts.wa.gov/court_rules/?fa=court_rules.display&set=GR&ruleid=gagr14.

14. Format for Pleadings and Other Papers

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(d) Citation Format. Citations shall conform with the format prescribed by the Reporter of Decisions. (See Appendix 1.)

The opening brief of appellant shall contain:

(a) A table of contents and table of authorities with cases alphabetically arranged. Citations of all authorities shall include the year thereof.


Note: While a prior rule more explicitly requiring that citations in a brief conform to the form used in the current volumes of the Washington Reports has been rescinded, the style sheet of the state's Office of Reporter of Decisions, referred to above, continues to be a useful guide. The Bluebook is largely incorporated by reference, modified by a set of local abbreviations in the Appendix 1 to Rule 14(d), http://www.courts.wa.gov/appellate_trial_courts/supreme/?fa=atc_supreme.style.

A 2004 order of the Washington Supreme Court directs the publisher of Washington appellate decisions to add paragraph numbers to them. Order No. 25700-B-447, http://www.courts.wa.gov/appellate_trial_courts/supreme/?fa=atc_supreme.paraOrder. The order authorizes but does not require the use of those paragraph numbers for pinpoint citations. "After an opinion is published in the official reports, a pinpoint citation should be made to page numbers in the official reports, to paragraph numbers from the official reports, or to both." Id.