twofold test (Connecticut) · Go Syfert
← Connecticut issues

twofold test in Connecticut

37 Connecticut opinions name it 3 courts 1982–2015 0 in the last five years

The cases below were cited by Connecticut 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 (3)

CaseFollowedCited
State v. Harrisongreen
conn · 1979 · cited in 6 Connecticut opinions naming this issue, 1982–1998
2 sentences

1998“The accessory statute, [General Statutes] § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intend to commit the offense with which he is charged.” (Emphasis in original.) State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979).

1998“The accessory statute, [General Statutes] § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intend to commit the offense with which he is charged.” (Emphasis in original.) State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979).

26
Board of Pardons v. Freedom of Information Commissiongreen
conn · 1989 · cited in 4 Connecticut opinions naming this issue, 1991–2015
2 sentences

2015Such a personal stake in the outcome of the controversy . . . provides the requisite assurance of concrete adverseness and diligent advocacy. ‘‘As long as there is some direct injury for which the plaintiff seeks redress, the injury that is alleged need not be great . . . [and] need not be primarily eco- nomic. . . . ‘‘In appeals pursuant to § 1-21i (d), we have translated these general principles into a twofold test for aggrievement that requires a showing of: (1) a specific personal and legal interest in the subject matter of the [commission] decision; and (2) a special and injurious effect

2015Such a personal stake in the outcome of the controversy . . . provides the requisite assurance of concrete adverseness and diligent advocacy. ‘‘As long as there is some direct injury for which the plaintiff seeks redress, the injury that is alleged need not be great . . . [and] need not be primarily eco- nomic. . . . ‘‘In appeals pursuant to § 1-21i (d), we have translated these general principles into a twofold test for aggrievement that requires a showing of: (1) a specific personal and legal interest in the subject matter of the [commission] decision; and (2) a special and injurious effect

14
Rosenblit v. Danahergreen
conn · 1988 · cited in 1 Connecticut opinions naming this issue, 1991–1991
2 sentences

1991See also Rosenblit v. Danaher, 206 Conn. 125 , 149 , 537 A.2d 145 (1988), which points out that a twofold analysis is required: first, whether the defendant has transacted business under the statutory standard of General Statutes 52-59b (a)(1); and if so, whether subjecting the nonresident to our courts offends the constitutional minimum contact standard of International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed 95 (1945); Lombard Bros., Inc. v. General Asset Management Co., 190 Conn. 245 , 250 , 460 A.2d 481 (1983).

1991See also Rosenblit v. Danaher, 206 Conn. 125 , 149 , 537 A.2d 145 (1988), which points out that a twofold analysis is required: first, whether the defendant has transacted business under the statutory standard of General Statutes 52-59b (a)(1); and if so, whether subjecting the nonresident to our courts offends the constitutional minimum contact standard of International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed 95 (1945); Lombard Bros., Inc. v. General Asset Management Co., 190 Conn. 245 , 250 , 460 A.2d 481 (1983).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (30)

CaseCitedYears
Hall v. Planning Commission green
conn · 1980
2 sentences

2002Hall v. Planning Commission , 181 Conn. 442 , 444 (1980).

2001Primerica v. Planning Zoning Commission , 211 Conn. 85 , 93 (1989); Hall v. Planning Commission , 181 Conn. 442 , 444 (1980).

131985–2002
Primerica v. Planning & Zoning Commission green
conn · 1989
2 sentences

2001Primerica v. Planning Zoning Commission , 211 Conn. 85 , 93 (1989); Hall v. Planning Commission , 181 Conn. 442 , 444 (1980).

2000Hall v. Planning Commission, 181 Conn. 442 , 444 (1980; Primerica v. Planning Zoning Commission, 211 Conn. 85 , 93 (1989).

101991–2001
Cannavo Enterprises, Inc. v. Burns green
conn · 1984
2 sentences

2000Hall v. Planning Commission , 181 Conn. 442 , 444 (1980); Cannovo Enterprises v. Burns , 194 Conn. 43 , 47 (1984).

2000Cannavo Enterprises, Inc. v. Burns , 194 Conn. 43 ,47 (1984); Gregorio v. Zoning Board of Appeals , 155 Conn. 422 , 425-26 (1967).

31998–2000
State v. Uribe green
connappct · 1988
2 sentences

1992State v. Cruz, 28 Conn. App. 575, 578 , 611 A.2d 457 (1992); State v. Uribe, 14 Conn. App. 388, 392-93 , 540 A.2d 1081 (1988).

1992State v. Cruz, 28 Conn. App. 575, 578 , 611 A.2d 457 (1992); State v. Uribe, 14 Conn. App. 388, 392-93 , 540 A.2d 1081 (1988).

21992–1992
State v. Cruz green
connappct · 1992
2 sentences

1992State v. Cruz, 28 Conn. App. 575, 578 , 611 A.2d 457 (1992); State v. Uribe, 14 Conn. App. 388, 392-93 , 540 A.2d 1081 (1988).

1992State v. Cruz, 28 Conn. App. 575, 578 , 611 A.2d 457 (1992); State v. Uribe, 14 Conn. App. 388, 392-93 , 540 A.2d 1081 (1988).

21992–1992
State v. Haddad green
conn · 1983
2 sentences

1983We adopted this view in State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979): “The accessory statute, § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intends to commit the offense with which he is charged.” (Emphasis in original.) In State v. Haddad, 189 Conn. 383, 399 , 456 A.2d 316 (1983), we reaffirmed this position by applying to an accomplice the statutory definition that “[a] person acts ‘intentionally’ with respect to a result or to conduct described by a statute defining an offen

1983We adopted this view in State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979): “The accessory statute, § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intends to commit the offense with which he is charged.” (Emphasis in original.) In State v. Haddad, 189 Conn. 383, 399 , 456 A.2d 316 (1983), we reaffirmed this position by applying to an accomplice the statutory definition that “[a] person acts ‘intentionally’ with respect to a result or to conduct described by a statute defining an offen

21983–1987
Gregorio v. Zoning Board of Appeals green
conn · 1967
1 sentence

2000Cannavo Enterprises, Inc. v. Burns , 194 Conn. 43 ,47 (1984); Gregorio v. Zoning Board of Appeals , 155 Conn. 422 , 425-26 (1967).

12000–2000
Windham Taxpayers Ass'n v. Board of Selectmen green
conn · 1995
2 sentences

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

11998–1998
United Cable Television Services Corp. v. Department of Public Utility Control green
conn · 1995
2 sentences

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

11998–1998
Lodge v. Arett Sales Corp. green
conn · 1998
1 sentence

1998Lodge v. Arett Sales Corp. , 246 Conn. 563 , 575-76 CT Page 14789 (1998); Jaworski v. Kiernan , 241 Conn. 399 , 405-06 (1997).

11998–1998
Connecticut Resources Recovery Authority v. Planning & Zoning Commission green
conn · 1997
1 sentence

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

11998–1998
Connecticut Resources Recovery Authority v. Planning & Zoning Commission green
conn · 1997
1 sentence

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

11998–1998
Med-Trans of Connecticut, Inc. v. Department of Public Health & Addiction Services green
conn · 1997
2 sentences

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

11998–1998
Jaworski v. Kiernan green
conn · 1997
1 sentence

1998Lodge v. Arett Sales Corp. , 246 Conn. 563 , 575-76 CT Page 14789 (1998); Jaworski v. Kiernan , 241 Conn. 399 , 405-06 (1997).

11998–1998
State v. Foshay green
connappct · 1987
2 sentences

1998In State v. Foshay, 12 Conn. App. 1, 23-24 , 530 A.2d 611 (1987), and State v. Fudge, 20 Conn. App. 665, 670 , 569 A.2d 1145 , cert. denied, 214 Conn. 807 , 573 A.2d 321 (1990), the trial court considered claims identical to the one presented here.

1998In State v. Foshay, 12 Conn. App. 1, 23-24 , 530 A.2d 611 (1987), and State v. Fudge, 20 Conn. App. 665, 670 , 569 A.2d 1145 , cert. denied, 214 Conn. 807 , 573 A.2d 321 (1990), the trial court considered claims identical to the one presented here.

11998–1998
State v. Fudge neutral
connappct · 1990
2 sentences

1998In State v. Foshay, 12 Conn. App. 1, 23-24 , 530 A.2d 611 (1987), and State v. Fudge, 20 Conn. App. 665, 670 , 569 A.2d 1145 , cert. denied, 214 Conn. 807 , 573 A.2d 321 (1990), the trial court considered claims identical to the one presented here.

1998In State v. Foshay, 12 Conn. App. 1, 23-24 , 530 A.2d 611 (1987), and State v. Fudge, 20 Conn. App. 665, 670 , 569 A.2d 1145 , cert. denied, 214 Conn. 807 , 573 A.2d 321 (1990), the trial court considered claims identical to the one presented here.

11998–1998
DiBonaventura v. Zoning Board of Appeals green
connappct · 1991
1 sentence

1998Cannavo Enterprises, Inc. v. Burns, 194 Conn. 43 , 47 (1984); Hall v. Planning Commission, 181 Conn. 442 , 444 (1980); Primerica v. Planning Zoning Commission, 211 Conn. 85 , 92-93 (1989); DiBonaventura v. Zoning Board of Appeals, 24 Conn. App. 369 , 374 (1991).

11998–1998
Connecticut Resources Recovery Authority v. Planning & Zoning Commission neutral
connappct · 1997
2 sentences

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

1998Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision ....’” Med-Trans of Connecticut, Inc. v. Dept. of Public Health & Addiction Services, 242 Conn. 152, 158-59 , 699 A.2d 142 (1997); United Cable Television Services Corp. v. Dept. of Public Utility Control, 235 Conn. 334, 342-43 , 663 A.2d 1011 (1995). “ ‘Mere status as a party or a participant in the proceedings below does not in and of itself constitute aggrievement for the purposes of appellate review.’ ” Connecticut Re

11998–1998
State v. Teart green
conn · 1976
2 sentences

1995The accessory statute, § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intend to commit the offense with which he is charged.” (Citations omitted; emphasis in original; internal quotation marks omitted.) State v. Wideman, 36 Conn. App. 190, 202-203 , 650 A.2d 571 (1994), cert. denied, 232 Conn. 903 , 653 A.2d 192 (1995); see also State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979); State v. Teart, 170 Conn. 332, 336 , 365 A.2d 1200 (1976).

1995The accessory statute, § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intend to commit the offense with which he is charged.” (Citations omitted; emphasis in original; internal quotation marks omitted.) State v. Wideman, 36 Conn. App. 190, 202-203 , 650 A.2d 571 (1994), cert. denied, 232 Conn. 903 , 653 A.2d 192 (1995); see also State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979); State v. Teart, 170 Conn. 332, 336 , 365 A.2d 1200 (1976).

11995–1995
State v. Wideman green
conn · 1995
1 sentence

1995The accessory statute, § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intend to commit the offense with which he is charged.” (Citations omitted; emphasis in original; internal quotation marks omitted.) State v. Wideman, 36 Conn. App. 190, 202-203 , 650 A.2d 571 (1994), cert. denied, 232 Conn. 903 , 653 A.2d 192 (1995); see also State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979); State v. Teart, 170 Conn. 332, 336 , 365 A.2d 1200 (1976).

11995–1995
State v. Davis green
conn · 1995
1 sentence

1995The accessory statute, § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intend to commit the offense with which he is charged.” (Citations omitted; emphasis in original; internal quotation marks omitted.) State v. Wideman, 36 Conn. App. 190, 202-203 , 650 A.2d 571 (1994), cert. denied, 232 Conn. 903 , 653 A.2d 192 (1995); see also State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979); State v. Teart, 170 Conn. 332, 336 , 365 A.2d 1200 (1976).

11995–1995
State v. Wideman green
connappct · 1994
2 sentences

1995The accessory statute, § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intend to commit the offense with which he is charged.” (Citations omitted; emphasis in original; internal quotation marks omitted.) State v. Wideman, 36 Conn. App. 190, 202-203 , 650 A.2d 571 (1994), cert. denied, 232 Conn. 903 , 653 A.2d 192 (1995); see also State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979); State v. Teart, 170 Conn. 332, 336 , 365 A.2d 1200 (1976).

1995The accessory statute, § 53a-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intend to commit the offense with which he is charged.” (Citations omitted; emphasis in original; internal quotation marks omitted.) State v. Wideman, 36 Conn. App. 190, 202-203 , 650 A.2d 571 (1994), cert. denied, 232 Conn. 903 , 653 A.2d 192 (1995); see also State v. Harrison, 178 Conn. 689, 694 , 425 A.2d 111 (1979); State v. Teart, 170 Conn. 332, 336 , 365 A.2d 1200 (1976).

11995–1995
State v. Crump green
conn · 1986
2 sentences

1992“The accessory statute, § 53-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intended to commit the offense with which he is charged. . . .” (Citations omitted; internal quotation marks omitted.) State v. Crump, 201 Conn. 489, 495 , 518 A.2d 378 (1986).

1992“The accessory statute, § 53-8, sets forth the element of intent as a twofold requirement: that the accessory have the intent to aid the principal and that in so aiding he intended to commit the offense with which he is charged. . . .” (Citations omitted; internal quotation marks omitted.) State v. Crump, 201 Conn. 489, 495 , 518 A.2d 378 (1986).

11992–1992
Lombard Brothers, Inc. v. General Asset Management Co. green
conn · 1983
2 sentences

1991See also Rosenblit v. Danaher, 206 Conn. 125 , 149 , 537 A.2d 145 (1988), which points out that a twofold analysis is required: first, whether the defendant has transacted business under the statutory standard of General Statutes 52-59b (a)(1); and if so, whether subjecting the nonresident to our courts offends the constitutional minimum contact standard of International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed 95 (1945); Lombard Bros., Inc. v. General Asset Management Co., 190 Conn. 245 , 250 , 460 A.2d 481 (1983).

1991See also Rosenblit v. Danaher, 206 Conn. 125 , 149 , 537 A.2d 145 (1988), which points out that a twofold analysis is required: first, whether the defendant has transacted business under the statutory standard of General Statutes 52-59b (a)(1); and if so, whether subjecting the nonresident to our courts offends the constitutional minimum contact standard of International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed 95 (1945); Lombard Bros., Inc. v. General Asset Management Co., 190 Conn. 245 , 250 , 460 A.2d 481 (1983).

11991–1991
International Shoe Co. v. Washington green
scotus · 1945
2 sentences

1991See also Rosenblit v. Danaher, 206 Conn. 125 , 149 , 537 A.2d 145 (1988), which points out that a twofold analysis is required: first, whether the defendant has transacted business under the statutory standard of General Statutes 52-59b (a)(1); and if so, whether subjecting the nonresident to our courts offends the constitutional minimum contact standard of International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed 95 (1945); Lombard Bros., Inc. v. General Asset Management Co., 190 Conn. 245 , 250 , 460 A.2d 481 (1983).

1991See also Rosenblit v. Danaher, 206 Conn. 125 , 149 , 537 A.2d 145 (1988), which points out that a twofold analysis is required: first, whether the defendant has transacted business under the statutory standard of General Statutes 52-59b (a)(1); and if so, whether subjecting the nonresident to our courts offends the constitutional minimum contact standard of International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed 95 (1945); Lombard Bros., Inc. v. General Asset Management Co., 190 Conn. 245 , 250 , 460 A.2d 481 (1983).

11991–1991
Zartolas v. Nisenfeld green
conn · 1981
2 sentences

1991Zartolas v. Nisenfeld, 184 Conn. 471 , 474-75 , 440 A.2d 179 (1981), holds that the execution of a warranty deed concerning property in this state by nonresidents constitutes the transaction of business in this state.

1991Zartolas v. Nisenfeld, 184 Conn. 471 , 474-75 , 440 A.2d 179 (1981), holds that the execution of a warranty deed concerning property in this state by nonresidents constitutes the transaction of business in this state.

11991–1991
Zoning Board of Appeals v. Freedom of Information Commission green
conn · 1986
11989–1989
Local 1303 & Local 1378 of Council No. 4 v. Freedom of Information Commission green
conn · 1983
2 sentences

1989Zoning Board of Appeals v. Freedom of Information Commission, 198 Conn. 498, 502 , 503 A.2d 1161 (1986); Local 1303 & Local 1378 v. Freedom of Information Commission, 191 Conn. 173, 176 , 463 A.2d 613 (1983).

1989Zoning Board of Appeals v. Freedom of Information Commission, 198 Conn. 498, 502 , 503 A.2d 1161 (1986); Local 1303 & Local 1378 v. Freedom of Information Commission, 191 Conn. 173, 176 , 463 A.2d 613 (1983).

11989–1989
Katz v. United States green
scotus · 1967
11983–1983
Pandolphe's Auto Parts, Inc. v. Town of Manchester green
conn · 1980
11982–1982

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 53a-8 (8) CT § Conn. Gen. Stat. § 53a-48 (5)

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

CT 37 (1982–2015) CA 27 (1955–2021) IL 26 (1974–2025) LA 26 (1975–2023) PA 22 (1980–2025) OH 22 (1966–2023) NY 17 (1978–2025) NC 15 (1954–2024) AL 15 (1987–2014) OR 11 (1971–1985) HI 11 (1982–2025) MD 11 (1925–2018) ND 8 (1983–2012) TX 8 (1982–2014) WA 7 (1983–2013) NJ 7 (1970–1995) AK 7 (1973–2009) MO 6 (1881–2018) WI 6 (1976–2013) MI 6 (1972–2008) SD 6 (1986–2008) DC 6 (1975–2011) FL 6 (1977–1993) NM 5 (1974–2014) MA 5 (1982–2013) IN 4 (1981–2002) CO 4 (1975–2021) NH 4 (2003–2007) IA 4 (2008–2022) KY 3 (1955–2017) AZ 3 (1985–1993) WV 3 (1985–2007) KS 2 (2010–2015) VT 2 (1991–2002) DE 2 (1980–2016) TN 2 (1979–2014) UT 2 (1989–1997) OK 2 (1982–1982) MS 2 (2020–2022)

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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