Volume 38 — Washington Appellate Reports

<bold>[1] Judgment — Summary Judgment — Review — In General.</bold> An appellate court reviewing a summary judgment engages in the same inquiry as the trial court, <italic>i.e.,</italic> it resolves all disputed facts and reasonable inferences therefrom in favor of the nonmoving party and determines whether reasonable persons could reach different conclusions. <bold>[2] Physicians and Surgeons — Psychiatrists — Standard of Care.</bold> A psychiatrist must exercise that degree of care which a reasonably prudent psychiatrist would exercise under the same or similar circumstances. <bold>[3] Physicians and Surgeons — Relationship With Patient —</bold> <bold>Nature.</bold> The physician-patient relationship is fiduciary in character, and a physician must exercise scrupulous good faith in dealing with his patients. <bold>[4] Damages — Difficulty of Ascertainment — Effect.</bold> The fact that damages resulting from tortious conduct cannot be calculated with mathematical certainty does not preclude recovery for the injury.

<bold>[1] Contempt — Due Process — Indirect Contempt.</bold> Due process requires that a person charged with contempt for activity committed outside the court's presence be given notice of the charge, a reasonable opportunity to prepare a defense, and a hearing. The person does not waive his due process rights by admitting his contumacious activity in court.

<bold>[1] Statutes — Construction — Conformity With Common Law —</bold> <bold>Presumption.</bold> In the absence of an indication of a legislative intent to change the common law, legislation is presumed to be consistent with prior judicial decisions. <bold>[2] Juveniles — Criminal Law — Jurisdiction — Adult or Juvenile</bold> <bold>— Critical Date.</bold> The jurisdiction of the juvenile court is strictly construed. The superior court has jurisdiction of any case when the trial occurs after the offender's 18th birthday. <bold>[3] Juveniles — Criminal Law — Jurisdiction — Prior Juvenile</bold> <bold>Extension — Effect.</bold> The extension of juvenile court jurisdiction as a result of a prior unrelated crime does not affect the exercise of adult jurisdiction for a later offense.