Mutual Sales Agency, Inc. v. Hori

1 Citing case

  1. Indoor Billboard/Washington, Inc. v. Integra Telecom of Washington, Inc.

    162 Wn. 2d 59 (Wash. 2007)   Cited 279 times   2 Legal Analyses
    Holding that, to satisfy the causation element, a CPA plaintiff must "establish that but for the defendant's unfair or deceptive act or practice the plaintiff's injury would not have occurred"

    ΒΆ64 Indoor Billboard is correct that Washington courts have generally applied the voluntary payment doctrine only in the contract context. See, e.g., Hawkinson v. Conniff, 53 Wn.2d 454, 459-60, 334 P.2d 540 (1959); Shields v. Schorno, 51 Wn.2d 737, 739, 321 P.2d 905 (1958); Speckert, 6 Wn.2d at 40; Maxwell v. Provident Mut. Life Ins. Co. of Phila., 180 Wash. 560, 575-76, 41 P.2d 147 (1935); Mut. Sales Agency, Inc. v. Hori, 145 Wash. 236, 240-41, 259 P. 712 (1927). One Washington case from the Court of Appeals considered applying the doctrine in a CPA context, although it did not reach the issue because it decided the defendant did not engage in an unfair or deceptive practice.