cited rule (Illinois) · Go Syfert
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cited rule in Illinois

37 Illinois opinions name it 2 courts 1916–2026 7 in the last five years

The cases below were cited by Illinois 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 (11)

CaseFollowedCited
People v. Sorensongreen
ill · 2001 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007See People v. Sorenson, 196 Ill. 2d 425 , 752 N.E.2d 1078 (2001) (challenge to frisk only); People v. Galvin, 127 Ill. 2d 153, 164 , 535 N.E.2d 837 (1989) (stop valid, search not valid); People v. Rivera, 272 Ill.

2007See People v. Sorenson, 196 Ill. 2d 425 , 752 N.E.2d 1078 (2001) (challenge to frisk only); People v. Galvin, 127 Ill. 2d 153, 164 , 535 N.E.2d 837 (1989) (stop valid, search not valid); People v. Rivera, 272 Ill.

22
Wottowa Insurance Agency, Inc. v. Bockgreen
ill · 1984 · cited in 2 Illinois opinions naming this issue, 2003–2003
2 sentences

2003Wottowa Insurance Agency, Inc. v. Bock, 104 Ill. 2d 311, 316 , 472 N.E.2d 411, 413 (1984).

2003Wottowa Insurance Agency, Inc. v. Bock, 104 Ill. 2d 311, 316 , 472 N.E.2d 411, 413 (1984).

22
People v. Nevittgreen
ill · 1990 · cited in 2 Illinois opinions naming this issue, 1993–1994
2 sentences

1994It is settled law that absent plain error, "[b]oth a trial objection and a written post-trial motion raising the issue are required for alleged errors that could have been raised during trial.” (Emphasis in original.) (People v. Enoch (1988), 122 Ill. 2d 176, 186 ; see also People v. Nevitt (1990), 135 Ill. 2d 423 ; People v. Adams (1985), 109 Ill. 2d 102 .) Furthermore, the mere referral to a cited error in a post-trial motion as prejudicial or erroneous, without factual detail, is insufficient to preserve an issue on appeal.

1993It is settled law that absent plain error, "/b]oth a trial objection and a written post-trial motion raising the issue are required for alleged errors that could have been raised during trial.” (Emphasis in original.) (People v. Enoch (1988), 122 Ill. 2d 176, 186 ; see also People v. Nevitt (1990), 135 Ill. 2d 423 ; People v. Adams (1985), 109 Ill. 2d 102 .) Furthermore, the mere referral to a cited error in a post-trial motion as prejudicial or erroneous, without factual detail, is insufficient to preserve an issue on appeal.

22
People v. Shumgreen
ill · 1987 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007King, 66 Ill.2d at 566 , 6 Ill.Dec. 891 , 363 N.E.2d 838 . *678 Although we agree with the cited principle, we find the case at bar more akin to People v. Shum, 117 Ill.2d 317, 363 , 111 Ill.Dec. 546 , 512 N.E.2d 1183 (1987), where the supreme court distinguished its holding in King and found that separate convictions based on one act are proper when there are multiple victims of that act.

2007King, 66 Ill.2d at 566 , 6 Ill.Dec. 891 , 363 N.E.2d 838 . *678 Although we agree with the cited principle, we find the case at bar more akin to People v. Shum, 117 Ill.2d 317, 363 , 111 Ill.Dec. 546 , 512 N.E.2d 1183 (1987), where the supreme court distinguished its holding in King and found that separate convictions based on one act are proper when there are multiple victims of that act.

12
People v. Taylorgreen
ill · 1984 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025The court cited the rule that “ ‘there is no indication that the possibility of rehabilitating an offender was to be given greater weight and consideration than the seriousness of the offense in determining a proper penalty.’ ” Id. (quoting People v. Taylor, 102 Ill. 2d 201, 206 (1984)). ¶ 35 In People v. Walsh, 2022 IL App (1st) 210786, ¶¶ 38-41 , this court affirmed the denial of leave to file a successive postconviction petition in part on the basis that a 35-year sentence imposed on an 18-year-old offender convicted of first degree murder did not shock the moral sense of the community.

11
People v. Odumuyiwagreen
illappct · 1989 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021App. 3d 294, 300 (2007), quoting People v. Odumuyiwa, 188 Ill.

11
People v. Cartergreen
illappct · 2021 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021First, the court cited the principle that the appellant “ ‘ “has the burden of providing a sufficiently complete record on appeal so that the reviewing court is fully informed regarding the issues to be resolved” ’ ” and that, “ ‘ “in the absence of such a record on appeal, it is presumed that [the] trial court’s judgment conforms to the law and has a sufficient factual basis.” ’ ” 2019 IL App (1st) 170803, ¶ 44 (quoting People v. Moore, 377 Ill.

11
People v. Mooregreen
illappct · 2007 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021First, the court cited the principle that the appellant “ ‘ “has the burden of providing a sufficiently complete record on appeal so that the reviewing court is fully informed regarding the issues to be resolved” ’ ” and that, “ ‘ “in the absence of such a record on appeal, it is presumed that [the] trial court’s judgment conforms to the law and has a sufficient factual basis.” ’ ” 2019 IL App (1st) 170803, ¶ 44 (quoting People v. Moore, 377 Ill.

11
Sullivan v. Edward Hospitalgreen
ill · 2004 · cited in 1 Illinois opinions naming this issue, 2008–2008
11
Boatmen's National Bank v. Martingreen
ill · 1993 · cited in 1 Illinois opinions naming this issue, 2003–2003
11
People v. Carlsongreen
ill · 1980 · cited in 1 Illinois opinions naming this issue, 1996–1996
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (36)

CaseCitedYears
People v. Enoch green
ill · 1988
2 sentences

1996(People v. Enoch (1988), 122 Ill. 2d 176, 186 , 522 N.E.2d 1124 ; see also People v. Carlson (1980), 79 Ill. 2d 564, 576 .) Moreover, it is insufficient to merely refer to a cited error in a post-trial motion without factual detail.

1996(People v. Enoch (1988), 122 Ill. 2d 176, 186 , 522 N.E.2d 1124 ; see also People v. Carlson (1980), 79 Ill. 2d 564, 576 .) Moreover, it is insufficient to merely refer to a cited error in a post-trial motion without factual detail.

41993–1996
People v. Medeiros green
illappct · 1993
2 sentences

1996App. 3d 139, 140 , 618 N.E.2d 1065 .) Specific objections are required to ensure that the trial court was adequately apprised of the cited error.

1994After a careful review of the record, we conclude that the State is correct and that this issue is not cognizable on appeal. el Addressing this issue, our supreme court has held that, absent plain error, "/b]oth a trial objection and a written post-trial motion raising the issue are required for alleged errors that could have been raised during trial.” (Emphasis in original.) (People v. Enoch (1988), 122 Ill. 2d 176, 186 , 522 N.E.2d 1124 .) "Furthermore, it is not sufficient to merely refer to a cited error in a post-trial motion as 'prejudicial,’ 'inflammatory’ or 'erroneous’ without factual

31994–1996
People v. Phillips green
illappct · 1989
2 sentences

1993People v. Phillips (1989), 186 Ill.

1993(People v. Phillips (1989), 186 Ill.

31993–1993
People v. Dorsey green
ill · 2021
2 sentences

2024The court also cited section 5-4.5-115(b) (730 ILCS 5/5-4.5-115(b) (West 2022)) of the Code, the statute governing parole for individuals who commit an offense under the age of 21, and it provided a summary of the evolving law on juvenile sentencing, including summaries of Miller, People v. Holman, 2017 IL 120655 , People v. Buffer, 2019 IL 122327 , People v. Dorsey, 2021 IL 123010 , and Jones v. Mississippi, 593 U.S.__, __, 141 S. Ct. 1307 (2021). ¶ 31 The court then concluded that Aguilar was 17 years old when he shot and killed the victim and that it was “not an impetuous act.” It reasoned

2024The court also cited section 5-4.5-115(b) (730 ILCS 5/5-4.5-115(b) (West 2022)) of the Code, the statute governing parole for individuals who commit an offense under the age of 21, and it provided a summary of the evolving law on juvenile sentencing, including summaries of Miller, People v. Holman, 2017 IL 120655 , People v. Buffer, 2019 IL 122327 , People v. Dorsey, 2021 IL 123010 , and Jones v. Mississippi, 593 U.S.__, __, 141 S. Ct. 1307 (2021). ¶ 31 The court then concluded that Aguilar was 17 years old when he shot and killed the victim and that it was “not an impetuous act.” It reasoned

22024–2024
People v. Holman red
ill · 2017
2 sentences

2024The court also cited section 5-4.5-115(b) (730 ILCS 5/5-4.5-115(b) (West 2022)) of the Code, the statute governing parole for individuals who commit an offense under the age of 21, and it provided a summary of the evolving law on juvenile sentencing, including summaries of Miller, People v. Holman, 2017 IL 120655 , People v. Buffer, 2019 IL 122327 , People v. Dorsey, 2021 IL 123010 , and Jones v. Mississippi, 593 U.S.__, __, 141 S. Ct. 1307 (2021). ¶ 31 The court then concluded that Aguilar was 17 years old when he shot and killed the victim and that it was “not an impetuous act.” It reasoned

2024The court also cited section 5-4.5-115(b) (730 ILCS 5/5-4.5-115(b) (West 2022)) of the Code, the statute governing parole for individuals who commit an offense under the age of 21, and it provided a summary of the evolving law on juvenile sentencing, including summaries of Miller, People v. Holman, 2017 IL 120655 , People v. Buffer, 2019 IL 122327 , People v. Dorsey, 2021 IL 123010 , and Jones v. Mississippi, 593 U.S.__, __, 141 S. Ct. 1307 (2021). ¶ 31 The court then concluded that Aguilar was 17 years old when he shot and killed the victim and that it was “not an impetuous act.” It reasoned

22024–2024
Jones v. Mississippi green
scotus · 2021
2 sentences

2024The court also cited section 5-4.5-115(b) (730 ILCS 5/5-4.5-115(b) (West 2022)) of the Code, the statute governing parole for individuals who commit an offense under the age of 21, and it provided a summary of the evolving law on juvenile sentencing, including summaries of Miller, People v. Holman, 2017 IL 120655 , People v. Buffer, 2019 IL 122327 , People v. Dorsey, 2021 IL 123010 , and Jones v. Mississippi, 593 U.S.__, __, 141 S. Ct. 1307 (2021). ¶ 31 The court then concluded that Aguilar was 17 years old when he shot and killed the victim and that it was “not an impetuous act.” It reasoned

2024The court also cited section 5-4.5-115(b) (730 ILCS 5/5-4.5-115(b) (West 2022)) of the Code, the statute governing parole for individuals who commit an offense under the age of 21, and it provided a summary of the evolving law on juvenile sentencing, including summaries of Miller, People v. Holman, 2017 IL 120655 , People v. Buffer, 2019 IL 122327 , People v. Dorsey, 2021 IL 123010 , and Jones v. Mississippi, 593 U.S.__, __, 141 S. Ct. 1307 (2021). ¶ 31 The court then concluded that Aguilar was 17 years old when he shot and killed the victim and that it was “not an impetuous act.” It reasoned

22024–2024
People v. Buffer green
ill · 2019
2 sentences

2024The court also cited section 5-4.5-115(b) (730 ILCS 5/5-4.5-115(b) (West 2022)) of the Code, the statute governing parole for individuals who commit an offense under the age of 21, and it provided a summary of the evolving law on juvenile sentencing, including summaries of Miller, People v. Holman, 2017 IL 120655 , People v. Buffer, 2019 IL 122327 , People v. Dorsey, 2021 IL 123010 , and Jones v. Mississippi, 593 U.S.__, __, 141 S. Ct. 1307 (2021). ¶ 31 The court then concluded that Aguilar was 17 years old when he shot and killed the victim and that it was “not an impetuous act.” It reasoned

2024The court also cited section 5-4.5-115(b) (730 ILCS 5/5-4.5-115(b) (West 2022)) of the Code, the statute governing parole for individuals who commit an offense under the age of 21, and it provided a summary of the evolving law on juvenile sentencing, including summaries of Miller, People v. Holman, 2017 IL 120655 , People v. Buffer, 2019 IL 122327 , People v. Dorsey, 2021 IL 123010 , and Jones v. Mississippi, 593 U.S.__, __, 141 S. Ct. 1307 (2021). ¶ 31 The court then concluded that Aguilar was 17 years old when he shot and killed the victim and that it was “not an impetuous act.” It reasoned

22024–2024
Aleckson v. Village of Round Lake Park green
ill · 1997
2 sentences

2011However, the cited rule applies only when no conflict in appellate court districts exist. "[W]hen conflicts arise amongst the districts, the circuit court is bound by the decisions of the appellate court of the district in which it sits." Aleckson v. Village of Round Lake Park, 176 Ill.2d 82, 92 , 223 Ill.Dec. 451 , 679 N.E.2d 1224 (1997); Bryant, 224 Ill.2d at 478 , 309 Ill.Dec. 826 , 865 N.E.2d 189 .

2011However, the cited rule applies only when no conflict in appellate court districts exist. "[W]hen conflicts arise amongst the districts, the circuit court is bound by the decisions of the appellate court of the district in which it sits." Aleckson v. Village of Round Lake Park, 176 Ill.2d 82, 92 , 223 Ill.Dec. 451 , 679 N.E.2d 1224 (1997); Bryant, 224 Ill.2d at 478 , 309 Ill.Dec. 826 , 865 N.E.2d 189 .

22011–2011
Delgado v. Board of Election Commissioners green
ill · 2007
2 sentences

2011However, the cited rule applies only when no conflict in appellate court districts exist. "[W]hen conflicts arise amongst the districts, the circuit court is bound by the decisions of the appellate court of the district in which it sits." Aleckson v. Village of Round Lake Park, 176 Ill.2d 82, 92 , 223 Ill.Dec. 451 , 679 N.E.2d 1224 (1997); Bryant, 224 Ill.2d at 478 , 309 Ill.Dec. 826 , 865 N.E.2d 189 .

2011However, the cited rule applies only when no conflict in appellate court districts exist. "[W]hen conflicts arise amongst the districts, the circuit court is bound by the decisions of the appellate court of the district in which it sits." Aleckson v. Village of Round Lake Park, 176 Ill.2d 82, 92 , 223 Ill.Dec. 451 , 679 N.E.2d 1224 (1997); Bryant, 224 Ill.2d at 478 , 309 Ill.Dec. 826 , 865 N.E.2d 189 .

22011–2011
People v. Rivera green
illappct · 1995
2 sentences

2007See People v. Sorenson, 196 Ill.2d 425 , 256 Ill.Dec. 836 , 752 N.E.2d 1078 (2001) (challenge to frisk only); People v. Galvin, 127 Ill.2d 153, 164 , 129 Ill.Dec. 72 , 535 N.E.2d 837 (1989) (stop valid, search not valid); People v. Rivera, 272 Ill.App.3d 502, 506-07 , 209 Ill.Dec. 111 , 650 N.E.2d 1084 (1995) (stop justified, search not justified).

2007See People v. Sorenson, 196 Ill. 2d 425 , 752 N.E.2d 1078 (2001) (challenge to frisk only); People v. Galvin, 127 Ill. 2d 153, 164 , 535 N.E.2d 837 (1989) (stop valid, search not valid); People v. Rivera, 272 Ill.

22007–2007
People v. Galvin green
ill · 1989
2 sentences

2007See People v. Sorenson, 196 Ill. 2d 425 , 752 N.E.2d 1078 (2001) (challenge to frisk only); People v. Galvin, 127 Ill. 2d 153, 164 , 535 N.E.2d 837 (1989) (stop valid, search not valid); People v. Rivera, 272 Ill.

2007See People v. Sorenson, 196 Ill. 2d 425 , 752 N.E.2d 1078 (2001) (challenge to frisk only); People v. Galvin, 127 Ill. 2d 153, 164 , 535 N.E.2d 837 (1989) (stop valid, search not valid); People v. Rivera, 272 Ill.

22007–2007
People v. Wright green
ill · 1998
2 sentences

2001The defendant relies on People v. Wright, 183 Ill. 2d 16 (1998), for his contention that we should reject any nexus between illegal drug activity and a reasonable belief that a suspect is armed and dangerous.

2001The defendant relies on People v. Wright , 183 Ill. 2d 16 (1998), for his contention that we should reject any nexus between illegal drug activity and a reasonable belief that a suspect is armed and dangerous.

22001–2001
State Farm Mutual Automobile Insurance v. Universal Underwriters Group green
ill · 1998
2 sentences

2000In Universal Underwriters , the supreme court construed the very section of the Code, if not the specific language, 182 Ill. 2d at 244 , 695 N.E.2d 850 .

2000In Universal Underwriters, the supreme court construed the very section of the Code, if not the specific language (Universal Underwriters, 182 Ill. 2d at 244 , 695 N.E.2d at 850 ).

22000–2000
People v. Adams green
ill · 1985
2 sentences

1994It is settled law that absent plain error, "[b]oth a trial objection and a written post-trial motion raising the issue are required for alleged errors that could have been raised during trial.” (Emphasis in original.) (People v. Enoch (1988), 122 Ill. 2d 176, 186 ; see also People v. Nevitt (1990), 135 Ill. 2d 423 ; People v. Adams (1985), 109 Ill. 2d 102 .) Furthermore, the mere referral to a cited error in a post-trial motion as prejudicial or erroneous, without factual detail, is insufficient to preserve an issue on appeal.

1993It is settled law that absent plain error, "/b]oth a trial objection and a written post-trial motion raising the issue are required for alleged errors that could have been raised during trial.” (Emphasis in original.) (People v. Enoch (1988), 122 Ill. 2d 176, 186 ; see also People v. Nevitt (1990), 135 Ill. 2d 423 ; People v. Adams (1985), 109 Ill. 2d 102 .) Furthermore, the mere referral to a cited error in a post-trial motion as prejudicial or erroneous, without factual detail, is insufficient to preserve an issue on appeal.

21993–1994
Stevenson v. Newsome green
scotus · 1986
2 sentences

1993Ed. 2d 730 , 106 S. Ct. 1476 .) Furthermore, it is not sufficient to merely refer to a cited error in a post-trial motion as “prejudicial,” “inflammatory” or “erroneous” without factual detail; doing so is inadequate to preserve an issue on appeal.

1993Ed. 2d 730 , 106 S. Ct. 1476 .) Furthermore, merely referring to a cited error in a post-trial motion as "prejudicial” or "erroneous,” without factual detail, is insufficient to preserve an issue on appeal.

21993–1993
Wickham v. Byrne green
ill · 2002
1 sentence

2026While Kocal does state the cited standard, it is related to a prior statute involving parental visitation that has since been repealed and does not apply to step-parent visitation cases. ¶ 62 A circuit court’s determination that a fit parent’s decision regarding non-parent visitation is or is not harmful to the child’s mental, physical, or emotional health will not be disturbed on 4 Megan cites to Wickham v. Byrne, 199 Ill. 2d 309 (2002) throughout the case to attempt to argue that the step-parent visitation statute is unconstitutional.

12026–2026
People v. Walsh green
illappct · 2022
1 sentence

2025The court cited the rule that “ ‘there is no indication that the possibility of rehabilitating an offender was to be given greater weight and consideration than the seriousness of the offense in determining a proper penalty.’ ” Id. (quoting People v. Taylor, 102 Ill. 2d 201, 206 (1984)). ¶ 35 In People v. Walsh, 2022 IL App (1st) 210786, ¶¶ 38-41 , this court affirmed the denial of leave to file a successive postconviction petition in part on the basis that a 35-year sentence imposed on an 18-year-old offender convicted of first degree murder did not shock the moral sense of the community.

12025–2025
People v. Streeter green
illappct · 2024
1 sentence

2025While the offender in that case was convicted on a theory of accountability, the evidence showed he had coerced a 14-year-old to commit a gang-related shooting on his behalf. ¶ 36 In People v. Streeter, 2024 IL App (1st) 191825 -UB, ¶ 87, and People v. Bracey, 2024 IL App (1st) 231356-U , ¶ 18, this court found arguments similar to those petitioner makes here to be frivolous or patently without merit in the context of affirming first-stage summary dismissal of initial postconviction petitions.

12025–2025
People v. Hill green
illappct · 2022
1 sentence

2025The court cited the rule that “ ‘there is no indication that the possibility of rehabilitating an offender was to be given greater weight and consideration than the seriousness of the offense in determining a proper penalty.’ ” Id. (quoting People v. Taylor, 102 Ill. 2d 201, 206 (1984)). ¶ 35 In People v. Walsh, 2022 IL App (1st) 210786, ¶¶ 38-41 , this court affirmed the denial of leave to file a successive postconviction petition in part on the basis that a 35-year sentence imposed on an 18-year-old offender convicted of first degree murder did not shock the moral sense of the community.

12025–2025
People v. Artis green
ill · 2009
1 sentence

2025Artis, 232 Ill. 2d at 164 .

12025–2025
Loyola Academy v. S & S Roof Maintenance, Inc. green
ill · 1992
1 sentence

2023They argued that plaintiff previously litigated his direct negligence claim against the School and that the additional counts plaintiff sought to add were untimely. ¶ 33 Plaintiff replied on November 19, 2022, arguing that the additional counts were not time barred and that he should be permitted to revive his direct negligence claim against the school because he previously withdrew the claim on his own accord and it was not “previously litigated,” as defendants had argued. ¶ 34 The circuit court entered an order on December 20, 2022, denying plaintiff’s motion for leave to file a third amende

12023–2023
People v. Miller green
illappct · 2004
1 sentence

2013The court cited the principle from the Karo concurring opinion, contextualizing it as follows: “[W]hen a guest in a private home has a private container to which the homeowner has no right of access, the homeowner lacks the power to give effective consent to a search of the closed container.” Id. at 986 .

12013–2013
People v. King green
ill · 1977
12007–2007
Elmore v. Blume green
illappct · 1975
11994–1994
People v. David green
illappct · 1986
11993–1993
Hofeld v. Nationwide Life Insurance green
ill · 1975
11988–1988
Bain v. BENEFIT TRUST LIFE INSUR. CO. green
illappct · 1984
11988–1988
Gonzalez v. Danaher green
illappct · 1975
11988–1988
Chalmers v. City of Chicago green
ill · 1982
11986–1986
Kagann v. BOARD OF FIRE & POLICE COMM'RS green
illappct · 1975
11977–1977
People v. Lonzo green
ill · 1974
11976–1976
Gage v. Lyons neutral
ill · 1891
11975–1975
The People v. Raddatz green
ill · 1949
11974–1974
People v. Taylor green
illappct · 1965
11974–1974
Chicago Title & Trust Co. v. Cohen green
illappct · 1936
11943–1943
Strange v. Cleveland, Cincinnati, Chicago & St. Louis Railway Co. green
ill · 1910
11916–1916

Statutes the citing opinions construe

IL § 730 ILCS 5/5-8-1 (4) IL § 720 ILCS 5/9-1 (3) IL § 725 ILCS 5/122-1 (3) IL § 730 ILCS 5/5-4.5-105 (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 63 (1950–2023) WA 48 (1959–2025) TX 44 (1936–2023) FL 38 (1944–2019) IL 37 (1916–2026) NJ 29 (1944–2026) NY 28 (1892–2024) LA 23 (1969–2015) AL 21 (1949–2006) MI 17 (1938–2020) OK 17 (1941–2003) MO 16 (1962–2022) PA 15 (1958–2023) OH 12 (1981–2025) NC 9 (1975–2021) GA 9 (1909–2018) MS 8 (1994–2026) TN 8 (1966–2017) AZ 8 (1962–2021) IA 7 (1939–2020) MT 7 (1969–1992) CO 7 (1957–2023) KS 7 (1910–2024) CT 7 (1992–2023) WY 6 (1923–2018) KY 6 (2007–2023) VA 6 (1988–2022) IN 6 (1876–2017) AR 6 (1938–2001) MD 5 (1976–1999) WI 5 (1984–2025) SD 4 (1952–2023) ME 4 (1938–2000) UT 4 (1956–2017) SC 4 (1949–2012) MN 4 (1974–2016) MA 4 (1967–2009) RI 4 (1968–2005) VT 4 (1974–2026) DE 3 (1963–2019) WV 3 (2010–2018) OR 2 (1995–2000) HI 2 (1960–2022) PR 2 (1962–1970) NE 2 (1953–2020) NV 2 (1923–1989)

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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