King v. Olympic Pipeline stands for the position that if there is both a civil and criminal case stemming from the same incident, the defendant may request that the civil matter be stayed until the criminal case is resolved. This can occur in a domestic violence incident where criminal charges are filed, and there may also be a civil protection order or personal injury law suit pending that was filed by the victim. In a criminal case, a defendant has a 5th amendment right to not testify and incriminate themselves, so the logic being resolve the criminal case first, and then turn to the civil case second. However, in the recent decision of Smith v. Smith, the court ruled that this is not always the case. In the decision, the court denied the Defendant’s request to stay the civil case until the criminal case was resolved because the court found that the Olympic Pipeline factors weighed against the defendant.