In keeping with this month's theme of Curtain, I decided to approach the topic as if I was a patron looking for information on Washington cases regarding curtains or, more specifically, a complaint for wrongful death resulting from entanglement in mini-blind cords.
One of my go-to resources is the Causes of Action set or, as I like to refer to it, 1,001 Reasons to Sue Someone. Unfortunately, a check of the index in print did not find any relevant entries under "Curtains," "Blinds" or "Window Coverings." Undaunted, I switched to WestlawNext, which includes Causes of Action. I started by limiting my searches just to the Causes of Action set, but again no luck.
I expanded my search to Washington and related "Federal" using a search on the terms [strangulation window blind cord], but still didn't see anything promising. In fact, I found that I was getting criminal cases that included strangulation with window blinds - yikes!
In an attempt to remove some of the false hits, I changed the search to ["wrongful death" window blind cord] and expanded the jurisdiction to "All State & Federal." This resulted in more than 22,000 total results, but using the faceted search options, I was able to limit this to "Secondary Sources" and a more manageable 95 results.
Many of the secondary sources in the results list are not included in our WestlawNext subscription, but one that is available is American Jurisprudence Pleading and Practice Forms Annotated. In the "Products Liability" chapter, section 75 is "Complaint, petition, or declaration-Wrongful death-Plaintiff's minor child strangled by cord of defectively and dangerously designed mini-blind window covering ...," which appears to be a good fit for our imaginary reference question. A handy feature of WestlawNext is that even if a search result is out of plan, there is usually enough information listed to look up the citation in the print version.
My next task was to see if I could find trial documents from any Washington cases. Again using the faceted search options, I clicked on "Trial Court Documents," then I selected Washington from the "Jurisdiction" filter. There was limited information listed for a complaint filed in 2012 by the Estate of Gavin O'Bryant. A few searches later, I located the case docket (12-2-08102-4 - Snohomish County) on the Washington Courts website. Snohomish County Superior Court pleadings are available for purchase via the Washington Digital Archives website: http://www.digitalarchives.wa.gov/Collections/TitleInfo/1836.
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