§44.1.3 Historical Development
| Jurisdiction | Washington |
§44.1.3HISTORICAL DEVELOPMENT
Prior to the adoption of CR 44.1 in 1967 and the 1981 amendment to RCW 5.24.040, Washington courts required statutes of sister states to be specifically pleaded and sister-state court decisions pleaded as factual allegations. Allen v. Saccomanno, 40 Wn.2d 283, 285, 242 P.2d 747 (1952); Martin Bros. v. Nettleton, 138 Wash. 102, 106, 244 P. 386 (1926); Lowry v. Moore, 16 Wash. 476, 479, 48 P. 238 (1897). This in haec verba (literally "in the same words") pleading requirement meant "[applicable foreign statutes should be set forth with their citations, and decisional...
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