context: Courts outside Washington State that have considered the question have concluded not only that a request for attorney's fees should be viewed as a request for affirmative relief, but also that a request for attorney's fees waives an objection to in personam jurisdiction.
citation_a.signal: no signal
citation_a.identifier: 662 P.2d 1178, 1182
citation_a.parenthetical: holding that a Texas court had personal jurisdiction over a Kansas resident who, after objecting to the Texas court's jurisdiction, filed a motion for attorney's fees
citation_a.sentence: Associate Discount Corp. v. Haviland, 218 So.2d 59, 61-62 (La.Ct.App.1969) (“By asking for attorney’s fees, the defendant did affirmatively invoke the jurisdiction of the court, and therefore ... made a general appearance, and subjected himself to the jurisdiction of the court....”); Forbess v. George Morgan Pontiac Co., 135 So.2d 594, 598 (La.Ct.App.1961) (holding that request for attorney’s fees (and damages to attached property) in a motion to dissolve a writ of attachment — said to be “totally unnecessary to the inquiry of the jurisdiction” — “constituted a submission by defendant to the exercise of jurisdiction over it personally by the court”); In re Marriage of Adler, 271 Ill.App.3d 469, 208 Ill.Dec. 31, 34, 648 N.E.2d 953, 956 (1995); Johnson v. Johnson, 233 Kan. 198, 662 P.2d 1178, 1182 (1983) (holding that a Texas court had personal jurisdiction over a Kansas resident who, after objecting to the Texas court’s jurisdiction, filed a motion for attorney’s fees).
citation_b.signal: see
citation_b.identifier: 238 So.2d 780, 784
citation_b.parenthetical: approving view that a pleading was an appearance because it requested attorney's fees
citation_b.sentence: See Mid-City Inv. Co. v. Young, 238 So.2d 780, 784 (La.Ct.App.1970) (approving view that a pleading was an appearance because it requested attorney’s fees).