Case Citator › State v. Saintcalle

State v. Saintcalle

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

Abrogated
Court
Supreme Court of Washington
Citation
178 Wash. 2d 34
Decided
Confirmed treatments
1
Flagged citations read
30 of 30
Citing cases (total)
30
Treatment dates
2017
Abrogated
A reviewed court treats this case as abrogated by later authority. State v. Saintcalle was abrogated in part on other grounds by City of Seattle v. Erickson. After all 30 flagged citations were read, the confirmed change to Washington's first step of the Batson analysis is listed below.
More on how this was screened

Erickson required a prima facie finding when a party strikes the sole member of a cognizable racial group, replacing the discretion that Saintcalle had left in place. Later opinions continue to cite Saintcalle for its discussion of implicit bias and other points.

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.

30 later cases cite State v. Saintcalle; 30 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 State v. Saintcalle?

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

Abrogated

  • The Washington Supreme Court replaced the discretionary first step of the Batson analysis that Saintcalle had left in place with a rule requiring a prima facie finding when the sole member of a cognizable racial group is struck.

    City of Seattle v. Erickson · Supreme Court of Washington · filed

    In Saintcalle, we lamented the inadequate state of our Batson inquiry but declined to alter it because neither party had raised the issue. Here, the circumstance is different. Erickson explicitly advocates for a change to the Batson test. Both parties have briefed the issue and placed it squarely before us. ... We first find that Erickson has made a prima facie case of discrimination. We further take this opportunity to alter the Batson framework and adopt the bright-line rule described in the Rhone dissent.
    Read the full opinion on CourtListener →

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