Case Citator › Washington v. Los Angeles County Sheriff's Department

Washington v. Los Angeles County Sheriff's Department

Is it still good law? What later courts have actually done to this case.

Declined by some courts
Court
Ninth Circuit
Citation
833 F.3d 1048
Decided
Confirmed treatments
1
Flagged citations read
60 of 60
Citing cases (total)
60
Treatment dates
2021
Declined by some courts
At least one reviewed court has declined to follow this case. No reviewed court has overruled it. Declined to follow: the Third Circuit rejected Washington v. Los Angeles County Sheriff's Department's approach to dismissals combining civil rights and habeas claims under the Prison Litigation Reform Act. All 60 flagged citations have been read, and the confirmed treatment is listed below.
More on how this was screened

Many later district court opinions continued to apply Washington's separate rule permitting dismissal when an affirmative defense is obvious from the complaint.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

60 later cases cite Washington v. Los Angeles County Sheriff's Department; 60 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Washington v. Los Angeles County Sheriff's Department?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Declined to follow

  • The Third Circuit rejected Washington's rule that a complaint dismissed under both Heck and Preiser is a mixed dismissal that cannot count as a PLRA strike.

    Garrett v. Murphy · Third Circuit · filed

    While habeas proceedings are not civil actions under the PLRA, we reject the Ninth Circuit’s conclusion that dismissals under both Heck and Preiser are therefore “mixed” dismissals that do not count as strikes.
    Read the full opinion on CourtListener →

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