establishment defense (Ohio) · Go Syfert
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establishment defense in Ohio

42 Ohio opinions name it 2 courts 1953–2025 11 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (19)

CaseFollowedCited
State v. Filiaggigreen
ohio · 1999 · cited in 2 Ohio opinions naming this issue, 2001–2001
2 sentences

2001"The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts." State v. Thomas (1982), 70 Ohio St.2d 79 , syllabus; see, also, State v. Filiaggi (1999), 86 Ohio St.3d 230 , 243 .

2001"The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts." State v. Thomas (1982), 70 Ohio St.2d 79 , syllabus; see, also, State v. Filiaggi (1999), 86 Ohio St.3d 230 , 243 .

22
State v. Thomasgreen
ohio · 1982 · cited in 29 Ohio opinions naming this issue, 1983–2025
2 sentences

2025“The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts.” State v. Thomas, 70 Ohio St.2d 79 (1982). {¶ 35} At trial, the jury heard testimony from three expert witnesses; Dr. Bromberg testified on behalf of Duran.

2025He told the jury that the R-CRAS test was not a scientific instrument because it was subjective, and he stated, “I almost never saw that test applied to a forensic sanity, at the time of the offense, evaluation.” Trial Tr. at 643. {¶ 45} “The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts.” Thomas, 70 Ohio St.2d 79 .

129
State v. Self, Unpublished Decision (3-17-2005)green
ohioctapp · 2005 · cited in 2 Ohio opinions naming this issue, 2014–2025
2 sentences

2025Consequently, if there is competing evidence of a defendant’s ability to ascertain the wrongfulness of the act(s), and “the record demonstrates that the jury considered the insanity defense, a reviewing court should defer -15- to the jury’s interpretation of the evidence.” State v. Self, 2005-Ohio-1259, ¶ 13 (4th Dist.).

2014Ross No. 04CA2767, 2005-Ohio-1259, ¶ 13 , quoting State v. Thomas, 70 Ohio St.2d 79 , 434 N.E.2d 1356 (1982), syllabus.

12
State v. Martingreen
ohioctapp · 1983 · cited in 2 Ohio opinions naming this issue, 2005–2025
2 sentences

2025State v. Cochran, 2017-Ohio-216, ¶ 51 (2d Dist.). -7- “The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts.” State v. Thomas, 70 Ohio St.2d 79 (1982). {¶ 21} When an appellate court reviews whether a conviction is against the manifest weight of the evidence, “[t]he court, reviewing the entire record, weighs the evidence and all reasonable inferences, considers the credibility of the witnesses and determines whether in resolving conflicts in the evidence

2005State v. Garrow (1995), 103 Ohio App.3d 368 , 370-71 ; State v. Martin (1983), 20 Ohio App.3d 172 , 175 . {¶ 13} "The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts." State v. Thomas (1982), 70 Ohio St.2d 79 , syllabus.

12
Everson v. Board of Ed. of Ewinggreen
scotus · 1947 · cited in 2 Ohio opinions naming this issue, 1976–2014
2 sentences

2014See Everson v. Board of Education of Ewing, 330 U.S. 1, 15-16 (1947) (finding that the establishment clause protects religious belief as well as 11 disbelief).2 The privilege does not allow a parent to attempt to control the child’s every exposure to anything remotely religious or spiritual.

1976See, e. g., Abington School District v. Schempp, supra; Everson v. Board of Edn. (1947), 330 U. S. 1 ; Cantwell v. Connecticut (1940), 310 U. S. 296 .

12
State v. Thompkinsred
ohio · 1997 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025State v. Cochran, 2017-Ohio-216, ¶ 51 (2d Dist.). -7- “The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts.” State v. Thomas, 70 Ohio St.2d 79 (1982). {¶ 21} When an appellate court reviews whether a conviction is against the manifest weight of the evidence, “[t]he court, reviewing the entire record, weighs the evidence and all reasonable inferences, considers the credibility of the witnesses and determines whether in resolving conflicts in the evidence

11
State v. Cochrangreen
ohioctapp · 2017 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025State v. Cochran, 2017-Ohio-216, ¶ 51 (2d Dist.). -7- “The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts.” State v. Thomas, 70 Ohio St.2d 79 (1982). {¶ 21} When an appellate court reviews whether a conviction is against the manifest weight of the evidence, “[t]he court, reviewing the entire record, weighs the evidence and all reasonable inferences, considers the credibility of the witnesses and determines whether in resolving conflicts in the evidence

11
Tilsen v. Bensongreen
conn · 2023 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024Specifically, the portion of the ketubah that stated, "the parties 'agreed to divorce [or, separate from] one another according to custom all the days of their life [i.e., as a continuing obligation] according to Torah law as is the manner of Jewish people.'" Id. at 767. {¶ 30} Like Kimberly and S.E. in the case at bar, the husband in Tilsen argued that: (1) the enforcement of the ketubah would not violate the First Amendment's establishment clause; and (2) failing to enforce the ketubah would violate his rights under the First Amendment's free exercise clause.

11
State v. Quarterman (Slip Opinion)green
ohio · 2014 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See State v. Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, ¶ 19 .

2024See State v. Quarterman, 140 Ohio St.3d 464 , 2014-Ohio-4034 , 19 N.E.3d 900, ¶ 19 .

11
United States v. Scottgreen
scotus · 1978 · cited in 1 Ohio opinions naming this issue, 2023–2023
1 sentence

2023See Scott, 437 U.S. at 91, 98 , and n. 11, or whether Appellant has simply been convicted through a judicial process which is defective in some fundamental respect.

11
Office of Disciplinary Counsel v. Fowerbaughgreen
ohio · 1995 · cited in 1 Ohio opinions naming this issue, 2016–2016
2 sentences

2016See Disciplinary Counsel v. Fowerbaugh, 74 Ohio St.3d 187 , 658 N.E.2d 237 (1995).

2016See Disciplinary Counsel v. Fowerbaugh, 74 Ohio St.3d 187 , 658 N.E.2d 237 (1995).

11
Isaiah Brown v. Polk County, Iowa, a Municipal Corporation Ray Sears, Former County Administrator for Polk County and Polk County Board of Supervisorsgreen
ca8 · 1995 · cited in 1 Ohio opinions naming this issue, 2013–2013
2 sentences

2013Moriches Union Free School Dist., 508 U.S. 384, 395 , 113 S.Ct. 2141 , 124 L.Ed.2d 352 (1993) (rejecting school district’s Establishment Clause defense because its “posited fears of an Establishment Clause violation are unfounded”); Brown v. Polk Cty., Iowa, 61 F.3d 650, 659 (8th Cir.1995) (baseless fear of Establishment Clause violation could not justify county’s order for public employee to remove Bible from his desk). {¶ 89} In this case, we must reject the district’s justification because the inconspicuous presence of Freshwater’s personal Bible posed no threat to the Establishment Clause

2013Moriches Union Free School Dist., 508 U.S. 384, 395 , 113 S.Ct. 2141 , 124 L.Ed.2d 352 (1993) (rejecting school district’s Establishment Clause defense because its “posited fears of an Establishment Clause violation are unfounded”); Brown v. Polk Cty., Iowa, 61 F.3d 650, 659 (8th Cir.1995) (baseless fear of Establishment Clause violation could not justify county’s order for public employee to remove Bible from his desk). {¶ 89} In this case, we must reject the district’s justification because the inconspicuous presence of Freshwater’s personal Bible posed no threat to the Establishment Clause

11
Peter S. Helland v. South Bend Community School Corporationgreen
ca7 · 1996 · cited in 1 Ohio opinions naming this issue, 2013–2013
2 sentences

2013Bd. of Edn. of Westside Community Schools v. Mergens, 496 U.S. 226, 250 , 110 S.Ct. 2356 , 110 L.Ed.2d 191 (1990) (“schools do not endorse everything they fail to censor”); see also Helland v. S. Bend Community School Corp., 93 F.3d 327, 331 (7th Cir.1996) (in Establishment Clause challenge, school’s concern was with teacher reading Bible aloud to students, not with teacher merely carrying Bible with him).

2013Bd. of Edn. of Westside Community Schools v. Mergens, 496 U.S. 226, 250 , 110 S.Ct. 2356 , 110 L.Ed.2d 191 (1990) (“schools do not endorse everything they fail to censor”); see also Helland v. S. Bend Community School Corp., 93 F.3d 327, 331 (7th Cir.1996) (in Establishment Clause challenge, school’s concern was with teacher reading Bible aloud to students, not with teacher merely carrying Bible with him).

11
Board of Ed. of Westside Community Schools (Dist. 66) v. Mergensgreen
scotus · 1990 · cited in 1 Ohio opinions naming this issue, 2013–2013
2 sentences

2013Bd. of Edn. of Westside Community Schools v. Mergens, 496 U.S. 226, 250 , 110 S.Ct. 2356 , 110 L.Ed.2d 191 (1990) (“schools do not endorse everything they fail to censor”); see also Helland v. S. Bend Community School Corp., 93 F.3d 327, 331 (7th Cir.1996) (in Establishment Clause challenge, school’s concern was with teacher reading Bible aloud to students, not with teacher merely carrying Bible with him).

2013Bd. of Edn. of Westside Community Schools v. Mergens, 496 U.S. 226, 250 , 110 S.Ct. 2356 , 110 L.Ed.2d 191 (1990) (“schools do not endorse everything they fail to censor”); see also Helland v. S. Bend Community School Corp., 93 F.3d 327, 331 (7th Cir.1996) (in Establishment Clause challenge, school’s concern was with teacher reading Bible aloud to students, not with teacher merely carrying Bible with him).

11
Warnock v. Archergreen
ca8 · 2004 · cited in 1 Ohio opinions naming this issue, 2013–2013
2 sentences

2013See Hudson v. Palmer, 468 U.S. 517, 547 , 104 S.Ct. 3194 , 82 L.Ed.2d 393 (1984), fn. 13 (Stevens, J., concurring in part and dissenting in part) (“possession of * * * personal property relating to religious observance, such as a Bible or a crucifix, is surely protected by the Free Exercise Clause”); Warnock v. Archer, 380 F.3d 1076, 1082 (8th Cir.2004) (personal religious effects in school superintendent’s office, including Bible, were protected by Free Exercise Clause). {¶ 88} Because the First Amendment protected Freshwater’s conduct, we must determine whether the school had a legitimate ju

2013See Hudson v. Palmer, 468 U.S. 517, 547 , 104 S.Ct. 3194 , 82 L.Ed.2d 393 (1984), fn. 13 (Stevens, J., concurring in part and dissenting in part) (“possession of * * * personal property relating to religious observance, such as a Bible or a crucifix, is surely protected by the Free Exercise Clause”); Warnock v. Archer, 380 F.3d 1076, 1082 (8th Cir.2004) (personal religious effects in school superintendent’s office, including Bible, were protected by Free Exercise Clause). {¶ 88} Because the First Amendment protected Freshwater’s conduct, we must determine whether the school had a legitimate ju

11
Hudson v. Palmergreen
scotus · 1984 · cited in 1 Ohio opinions naming this issue, 2013–2013
2 sentences

2013See Hudson v. Palmer, 468 U.S. 517, 547 , 104 S.Ct. 3194 , 82 L.Ed.2d 393 (1984), fn. 13 (Stevens, J., concurring in part and dissenting in part) (“possession of * * * personal property relating to religious observance, such as a Bible or a crucifix, is surely protected by the Free Exercise Clause”); Warnock v. Archer, 380 F.3d 1076, 1082 (8th Cir.2004) (personal religious effects in school superintendent’s office, including Bible, were protected by Free Exercise Clause). {¶ 88} Because the First Amendment protected Freshwater’s conduct, we must determine whether the school had a legitimate ju

2013See Hudson v. Palmer, 468 U.S. 517, 547 , 104 S.Ct. 3194 , 82 L.Ed.2d 393 (1984), fn. 13 (Stevens, J., concurring in part and dissenting in part) (“possession of * * * personal property relating to religious observance, such as a Bible or a crucifix, is surely protected by the Free Exercise Clause”); Warnock v. Archer, 380 F.3d 1076, 1082 (8th Cir.2004) (personal religious effects in school superintendent’s office, including Bible, were protected by Free Exercise Clause). {¶ 88} Because the First Amendment protected Freshwater’s conduct, we must determine whether the school had a legitimate ju

11
Nichol v. Arin Intermediate Unit 28green
pawd · 2003 · cited in 1 Ohio opinions naming this issue, 2013–2013
2 sentences

2013“Merely employing an individual * * * who unobtrusively displays [his] religious adherence is not tantamount to government endorsement of that religion * * *.” Nichol v. ARIN Intermediate Unit 28, 268 F.Supp.2d 536, 554 (W.D.Pa.2003) (policy prohibiting elementary school teachers and employees from wearing religious jewelry deemed offensive to Free Exercise Clause); see also Draper v. Logan Cty.

2013“Merely employing an individual * * * who unobtrusively displays [his] religious adherence is not tantamount to government endorsement of that religion * * *." Nichol v. ARIN Intermediate Unit 28, 268 F.Supp.2d 536, 554 (W.D.Pa.2003) (policy prohibiting elementary school teachers and employees from wearing religious jewelry deemed offensive to Free Exercise Clause); see also Draper v. Logan Cty.

11
Abington School Dist. v. Schemppgreen
· 1963 · cited in 1 Ohio opinions naming this issue, 1976–1976
11
East Ohio Gas Co. v. City of Akrongreen
ohio · 1966 · cited in 1 Ohio opinions naming this issue, 1975–1975
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (17)

CaseCitedYears
State v. Brown green
ohio · 1983
2 sentences

2006In State v. Johnson, supra, citing State v. Curry (1989), 45 Ohio St.3d 109 , 543 N.E.2d 1228 , and State v. Brown (1983), 5 Ohio St.3d 133 , 449 N.E.2d 449 , we stated, "Thus, if the record demonstrates that the trial court, as the trier of fact, considered the insanity defense, the reviewing court should defer to the trial court's interpretation of the evidence.

2006In State v. Johnson, supra, citing State v. Curry (1989), 45 Ohio St.3d 109 , 543 N.E.2d 1228 , and State v. Brown (1983), 5 Ohio St.3d 133 , 449 N.E.2d 449 , we stated, "Thus, if the record demonstrates that the trial court, as the trier of fact, considered the insanity defense, the reviewing court should defer to the trial court's interpretation of the evidence.

31999–2006
Fred Siegel Co., L.P.A. v. Arter & Hadden green
ohio · 1999
2 sentences

2021Siegel, 85 Ohio St.3d 171 at 180 . - 41 - Clermont CA2020-06-031 find that Alliance's conduct was fair and reasonable under the circumstances.

2017Fred Siegel Co., L.P.A. v. Arter & Hadden, 85 Ohio St.3d 171 , 1999-Ohio-260 , 707 N.E.2d 853 .

22017–2021
State v. Curry green
ohio · 1989
2 sentences

2006In State v. Johnson, supra, citing State v. Curry (1989), 45 Ohio St.3d 109 , 543 N.E.2d 1228 , and State v. Brown (1983), 5 Ohio St.3d 133 , 449 N.E.2d 449 , we stated, "Thus, if the record demonstrates that the trial court, as the trier of fact, considered the insanity defense, the reviewing court should defer to the trial court's interpretation of the evidence.

2001"The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of fact." State v. Curry (1989), 45 Ohio St.3d 109 , 114 , quoting State v. Thomas (1982), 70 Ohio St.2d 79 , 80 .

22001–2006
State v. Petrie green
ohioctapp · 2016
1 sentence

2024“When expert witnesses differ in their opinions regarding the insanity defense,” the finder of fact “must make a credibility determination when deciding which experts to believe.” State v. Petrie, 2016-Ohio-4941 , 69 N.E.3d 150 , ¶ 5 (9th Dist.), citing State v. Murphy, 4th Dist.

12024–2024
Avitzur v. Avitzur green
ny · 1983
1 sentence

2024This renders the present case distinct from [Avitzur v. Avitzur, 58 N.Y.2d 108 (1983)], in which—under the majority's view of the record—the contested portion of the ketubah was more akin to a typical arbitration clause, insofar as it facially required only the submission of the case to the specific Beth Din and did not require the court to discern and enforce what Jewish law requires with respect to property - 13 - Warren CA2023-08-064 division and financial support upon dissolution. * * * Making that determination, especially in the presence of conflicting rabbinical opinions, would render t

12024–2024
Smith v. Null green
ohioctapp · 2001
2 sentences

2023Thus, he suggests the claimed Establishment Clause violation should result in the reversal of his sentence. {¶ 14} The Establishment Clause of the First Amendment to the United States Constitution states that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof * * *.” This clause “prohibits the government's aiding one religion, preferring one religion over another, or aiding all religions.” Smith v. Null, 143 Ohio App.3d 264, 267 , 757 N.E.2d 1200 (4th Dist.2001). {¶ 15} Loftis does not cite, and we cannot find, any authority to support

2023Thus, he suggests the claimed Establishment Clause violation should result in the reversal of his sentence. {¶ 14} The Establishment Clause of the First Amendment to the United States Constitution states that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof * * *.” This clause “prohibits the government's aiding one religion, preferring one religion over another, or aiding all religions.” Smith v. Null, 143 Ohio App.3d 264, 267 , 757 N.E.2d 1200 (4th Dist.2001). {¶ 15} Loftis does not cite, and we cannot find, any authority to support

12023–2023
State v. Cantrall green
ohioctapp · 2017
1 sentence

2022I am aware that “‘[t]he weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of fact.’” Cantrall, 2017-Ohio- 7399, 96 N.E.3d 1089, at ¶ 53 , quoting State v. Thomas, 70 Ohio St.2d 79, 80 , 434 N.E.2d 1356 (1982).

12022–2022
United States v. Bailey green
ca2 · 2011
1 sentence

2017Here, the warrant particularly described Defendant [and the defendant’s vehicle] as a specific person [and item] to be searched.” United States v. Perez, 6th Cir. No. 14-3794, 2015 U.S. App. LEXIS 18614 (Oct. 23, 2015). {¶32} Mason has not established that the “claims in the motion would justify relief and are supported by factual allegations,” or the elements essential for the establishment of a claim under Bailey, 652 F.3d 197 (2d Cir.2011).

12017–2017
Fred Siegel Co., L.P.A. v. Arter & Hadden green
ohio · 1999
1 sentence

2017Fred Siegel Co., L.P.A. v. Arter & Hadden, 85 Ohio St.3d 171 , 1999-Ohio-260 , 707 N.E.2d 853 .

12017–2017
State v. Armstrong green
ohioctapp · 2003
1 sentence

2017A criminal defendant who pleads not guilty by reason of insanity must prove by a preponderance of the evidence “that at the time of the commission of the offense, the person did not know, as a result of a severe mental disease or 8 defect, the wrongfulness of the person’s acts.” R.C. 2901.01(A)(14); R.C. 2901.05(A). “‘The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts.’” State v. Armstrong, 152 Ohio App.3d 579 , 2003-Ohio-2154 , ¶ 17 (9th Dist.), quoti

12017–2017
Lamb's Chapel v. Center Moriches Union Free School District green
scotus · 1993
2 sentences

2013Moriches Union Free School Dist., 508 U.S. 384, 395 , 113 S.Ct. 2141 , 124 L.Ed.2d 352 (1993) (rejecting school district’s Establishment Clause defense because its “posited fears of an Establishment Clause violation are unfounded”); Brown v. Polk Cty., Iowa, 61 F.3d 650, 659 (8th Cir.1995) (baseless fear of Establishment Clause violation could not justify county’s order for public employee to remove Bible from his desk). {¶ 89} In this case, we must reject the district’s justification because the inconspicuous presence of Freshwater’s personal Bible posed no threat to the Establishment Clause

2013Moriches Union Free School Dist., 508 U.S. 384, 395 , 113 S.Ct. 2141 , 124 L.Ed.2d 352 (1993) (rejecting school district’s Establishment Clause defense because its “posited fears of an Establishment Clause violation are unfounded”); Brown v. Polk Cty., Iowa, 61 F.3d 650, 659 (8th Cir.1995) (baseless fear of Establishment Clause violation could not justify county’s order for public employee to remove Bible from his desk). {¶ 89} In this case, we must reject the district’s justification because the inconspicuous presence of Freshwater’s personal Bible posed no threat to the Establishment Clause

12013–2013
Rosenberger v. Rector & Visitors of University of Virginia green
scotus · 1995
1 sentence

2013Simply allowing a teacher to keep his personal Bible on his desk would not have a religious purpose, would not advance religion, and would not excessively entangle government with religion. 29 SUPREME COURT OF OHIO 132 L.Ed.2d 700 (1995).

12013–2013
State v. Garrow green
ohioctapp · 1995
1 sentence

2005State v. Garrow (1995), 103 Ohio App.3d 368 , 370-71 ; State v. Martin (1983), 20 Ohio App.3d 172 , 175 . {¶ 13} "The weight to be given the evidence and the credibility of the witnesses concerning the establishment of the defense of insanity in a criminal proceeding are primarily for the trier of the facts." State v. Thomas (1982), 70 Ohio St.2d 79 , syllabus.

12005–2005
Lemon v. Kurtzman red
scotus · 1971
12002–2002
United States v. Evelio Mota and Juan Flores green
ca5 · 1979
11983–1983
Cantwell v. Connecticut green
scotus · 1940
11976–1976
Clark v. Swartz neutral
ohioctapp · 1927
11953–1953

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2901.01 (16) OH § Ohio Rev. Code § 2901.05 (13) OH § Ohio Rev. Code § 2903.01 (6) OH § Ohio Rev. Code § 2903.02 (5) OH § Ohio Rev. Code § 2903.11 (5) OH § Ohio Rev. Code § 2945.371 (5) OH § Ohio Rev. Code § 2901.22 (4) OH § Ohio Rev. Code § 2929.14 (4) OH § Ohio Rev. Code § 2945.37 (4) OH § Ohio Rev. Code § 2945.40 (4) OH § Ohio Rev. Code § 2923.02 (3) OH § Ohio Rev. Code § 2953.08 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 89 (1921–2025) NY 53 (1861–2026) FL 43 (1938–2026) OH 42 (1953–2025) WA 42 (1895–2026) MI 39 (1909–2020) IL 39 (1887–2021) PA 39 (1917–2024) NJ 37 (1897–2019) WI 31 (1844–2020) MA 29 (1910–2018) TX 28 (1912–2023) MD 24 (1914–2023) CO 24 (1892–2015) CT 22 (1923–2025) OR 22 (1895–2025) MN 17 (1926–2016) AL 16 (1868–2015) AR 15 (1908–2021) OK 14 (1913–2024) IA 13 (1877–2018) NM 12 (1888–2015) LA 12 (1917–2000) TN 12 (1917–2013) GA 11 (1925–2023) NE 10 (1886–2003) AZ 10 (1960–2016) MO 10 (1906–2011) KS 10 (1901–1996) KY 9 (1899–2023) MS 8 (1950–2005) UT 8 (1986–2022) IN 8 (1942–2005) VA 8 (1925–2015) ME 7 (1844–2006) ID 7 (1890–1996) NC 7 (1874–2011) MT 6 (1878–2012) SC 5 (1846–2021) VT 5 (1979–2017) DC 5 (1982–1997) HI 5 (1987–2020) ND 4 (1895–1986) AK 4 (1979–2022) NV 4 (1959–2022) WV 4 (1950–2014) NH 4 (1967–1995) RI 2 (1919–1980) DE 2 (1974–1990) PR 2 (1942–1956)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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