consideration clause (Missouri) · Go Syfert
← Missouri issues

consideration clause in Missouri

37 Missouri opinions name it 2 courts 1876–2024 2 in the last five years

The cases below were cited by Missouri 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 (15)

CaseFollowedCited
Clanton v. Teledyne Neoshogreen
moctapp · 1998 · cited in 2 Missouri opinions naming this issue, 2006–2006
2 sentences

2006Preliminarily, we observe that “ ‘[t]he fundamental rule of statutory interpretation is to ascertain the intent of the legislature from the language used, to give effect to that intent if possible, and to consider the words used in their plain and ordinary meaning.’ ” Clanton v. Teledyne Neosho, 960 S.W.2d 532, 534 (Mo.App.1998) (citation omitted).

2006Preliminarily, we observe that "`[t]he fundamental rule of statutory interpretation is to ascertain the intent of the legislature from the language used, to give effect to that intent if possible, and to consider the words used in their plain and ordinary meaning.'" Clanton v. Teledyne Neosho, 960 S.W.2d 532, 534 (Mo.App.1998) (citation omitted).

22
State of Missouri v. Sylvester Portergreen
mo · 2014 · cited in 1 Missouri opinions naming this issue, 2024–2024
2 sentences

2024The doctrine was abolished on the basis that it required “appellate courts to engage in credibility determinations that are properly left to judges and juries sitting as triers of fact.” Id. at 213 ; see also State v. Pilant, 437 S.W.3d 838, 839 (Mo. App. S.D. 2014) (recognizing the Supreme Court of Missouri abolished the doctrine of destructive contradictions in Porter, because, among other reasons, it requires an appellate court “to act as the finder of fact”; the holding in Porter precludes this Court’s consideration of the doctrine and, therefore, limits its review of the appellant’s point

2024The doctrine was abolished on the basis that it required “appellate courts to engage in credibility determinations that are properly left to judges and juries sitting as triers of fact.” Id. at 213 ; see also State v. Pilant, 437 S.W.3d 838, 839 (Mo. App. S.D. 2014) (recognizing the Supreme Court of Missouri abolished the doctrine of destructive contradictions in Porter, because, among other reasons, it requires an appellate court “to act as the finder of fact”; the holding in Porter precludes this Court’s consideration of the doctrine and, therefore, limits its review of the appellant’s point

11
STATE OF MISSOURI, Plaintiff-Respondent v. MATTHEW G. PILANTgreen
moctapp · 2014 · cited in 1 Missouri opinions naming this issue, 2024–2024
2 sentences

2024The doctrine was abolished on the basis that it required “appellate courts to engage in credibility determinations that are properly left to judges and juries sitting as triers of fact.” Id. at 213 ; see also State v. Pilant, 437 S.W.3d 838, 839 (Mo. App. S.D. 2014) (recognizing the Supreme Court of Missouri abolished the doctrine of destructive contradictions in Porter, because, among other reasons, it requires an appellate court “to act as the finder of fact”; the holding in Porter precludes this Court’s consideration of the doctrine and, therefore, limits its review of the appellant’s point

2024Like this Court in Porter and Pilant, this Court limits its review of Point II to “the sufficiency of the evidence under our general standard of review for such challenges.” Pilant, 437 S.W.3d at 839 .

11
SPRINGLEAF FINANCIAL SERVICES, INC. v. BENNIE A. SHULL, Defendant-Respondent.green
moctapp · 2016 · cited in 1 Missouri opinions naming this issue, 2022–2022
1 sentence

2022Additionally, a key consideration under the waiver doctrine is to avoid requiring the parties “to litigate the same underlying facts before two separate tribunals,” which has been held to be “antagonistic to judicial economy, the purposes of arbitration, and common sense.” Millennium, 562 $.W.3d at 378-79 (citing Lewallen, 487 F.3d at 1094 ); Springleaf, 500 S.W.3d at 281 (noting duplication of efforts and inconsistent judgments may be indicative of waiver).

11
Nelson v. Waxmangreen
mo · 2000 · cited in 1 Missouri opinions naming this issue, 2020–2020
1 sentence

2020“We review the trial court's ruling in closing argument for an abuse of discretion.” Nelson v. Waxman, 9 S.W.3d 601, 606 (Mo. banc 2000) (internal citation omitted); see also Travelers Commercial Cas.

11
Fleshner v. Pepose Vision Institute, P.C.green
mo · 2010 · cited in 1 Missouri opinions naming this issue, 2020–2020
1 sentence

2020Fleshner v. Pepose Vision Inst., P.C., 304 S.W.3d 81, 94 (Mo. banc 2010) (providing that the consideration of factors such as race is equally “reprehensible” even where an employer has other reasons for its decision).

11
Arthur Fels Bond & Mortgage Co. v. Pollockgreen
· 1941 · cited in 1 Missouri opinions naming this issue, 2014–2014
1 sentence

2014Co. v. Pollock, 149 S.W.2d 356, 359 (Mo. 1941) (“inadequacy does not constitute a failure of consideration”). 5 Even if courts (in hindsight) continue to indulge the now-preempted notion that arbitration is always “bad” for the employee and “good” for the employer, it does not follow that any employee agreeing to arbitrate her claims has made a bad bargain when viewed at the time the promise is made, as a consideration analysis demands.

11
Lake Cable, Inc. v. Trittlergreen
moctapp · 1996 · cited in 1 Missouri opinions naming this issue, 2001–2001
1 sentence

2001A finding of consideration does not depend on “the existence of a consideration clause or a money payment.” Lake Cable, Inc. v. Trittler, 914 S.W.2d 431, 434 (Mo.App.1996).

11
Halupa v. Halupagreen
moctapp · 1997 · cited in 1 Missouri opinions naming this issue, 1999–1999
1 sentence

1999Halupa v. Halupa, 943 S.W.2d 272, 278 (Mo.App.1997).

11
In Re Marriage of Reedgreen
moctapp · 1988 · cited in 1 Missouri opinions naming this issue, 1994–1994
1 sentence

1994In re Marriage of Reed, 762 S.W.2d 78, 85 (Mo.App.1988).

11
Stotzenberger v. Perkinsgreen
· 1933 · cited in 1 Missouri opinions naming this issue, 1976–1976
2 sentences

1976Stotzenberger v. Perkins, 332 Mo. 391 , 58 S.W.2d 983, 986 [2] (1933); 154 A.L.R. 11 .

1976Stotzenberger v. Perkins, 332 Mo. 391 , 58 S.W.2d 983, 986 [2] (1933); 154 A.L.R. 11 .

11
The People v. Pagegreen
ill · 1937 · cited in 1 Missouri opinions naming this issue, 1975–1975
2 sentences

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

11
Commonwealth v. Colandrogreen
pa · 1911 · cited in 1 Missouri opinions naming this issue, 1975–1975
2 sentences

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

11
State v. Steensengreen
njsuperctappdiv · 1955 · cited in 1 Missouri opinions naming this issue, 1975–1975
2 sentences

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

11
McNaulty v. Stategreen
texcrimapp · 1939 · cited in 1 Missouri opinions naming this issue, 1975–1975
2 sentences

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State v. Uptegrovegreen
moctapp · 2011 · cited in 1 Missouri opinions naming this issue, 2024–2024
1 sentence

2024The doctrine was abolished on the basis that it required “appellate courts to engage in credibility determinations that are properly left to judges and juries sitting as triers of fact.” Id. at 213 ; see also State v. Pilant, 437 S.W.3d 838, 839 (Mo. App. S.D. 2014) (recognizing the Supreme Court of Missouri abolished the doctrine of destructive contradictions in Porter, because, among other reasons, it requires an appellate court “to act as the finder of fact”; the holding in Porter precludes this Court’s consideration of the doctrine and, therefore, limits its review of the appellant’s point

11

Also cited on this issue (46)

CaseCitedYears
Fontaine v. Boatmens' Savings Institution neutral
· 1874
2 sentences

1909As to the parties to a deed, the consideration clause is only in the nature of a receipt and is open to explanations and contradictions, not for the purpose of defeating the deed as a conveyance, but for the purpose of showing the true consideration. [Fontaine v. Boatmen’s Savings Institution, 57 Mo. 552 ; Wood v. Broadley, 76 Mo. 33 .] Generally, however, the recital in the consideration clause is not evidence of the amount paid, or the value of the premises as to third persons.” As there was no proof of the amount of the consideration paid by the plaintiff or by Henry to the defendant, we th

1886As to the parties to a deed, the consideration clause is ;prima facie evidence, but it has the force and effect only óf a receipt, and is open to explanation and contradiction, not for the purpose of defeating the deed as a conveyance, but for the purpose of showing the true consideration. 57 Mo. 552 ; 76 Mo. 33 .

31886–1909
Hollocher v. Hollocher neutral
mo · 1876
2 sentences

1904Thus in O’Day v. Conn, 131 Mo. l. c. 327, it was said: “It is now well settled that ‘not only the amount of the consideration may be questioned by oral testimony, but the parties are not estopped from showing the character of the consideration to be different from that stated. ’ ’ ’ [Hollocher v. Hollocher, 62 Mo. 267 ; Fontaine v. Bank, 57 Mo. 552 ; Henderson v. Henderson’s Exrs., 13 Mo. 151 ; McCrea v. Purmort, 16 Wend. 465 ; Laudman v. Ingram, 49 Mo. 212 ; Jackson v. Railroad, 54 Mo. App. 642 ; Squier v. Evans, 127 Mo. 514 .] The evidence offered by plaintiff and admitted by tlie court had

1886Liebke v. Knapp, 79 Mo. 27 ; Fontaine v. Boatmen’s Sa vings Institution, 57 Mo. 561; Hollocher v. Hollocher, 62 Mo. 267 ; Baile v. Insurance Co., 73 Mo. 371 Hall v. Morgan, 79 Mo. 51 .

31883–1904
Henderson v. Henderson's Executors neutral
mo · 1850
2 sentences

1904Thus in O’Day v. Conn, 131 Mo. l. c. 327, it was said: “It is now well settled that ‘not only the amount of the consideration may be questioned by oral testimony, but the parties are not estopped from showing the character of the consideration to be different from that stated. ’ ’ ’ [Hollocher v. Hollocher, 62 Mo. 267 ; Fontaine v. Bank, 57 Mo. 552 ; Henderson v. Henderson’s Exrs., 13 Mo. 151 ; McCrea v. Purmort, 16 Wend. 465 ; Laudman v. Ingram, 49 Mo. 212 ; Jackson v. Railroad, 54 Mo. App. 642 ; Squier v. Evans, 127 Mo. 514 .] The evidence offered by plaintiff and admitted by tlie court had

1876Henderson’s Ex’rs ( 13 Mo. 151 ), it was observed, “ how far the ordinary clause in a deed, acknowledging the receipt of the purchase money, ought to preclude all parol evidence to show the real consideration, either as to amount or character, is a question upon which the decisions have not been uniform.

21876–1904
Rhonda J. Lewallen v. Green Tree Servicing, L.L.C. U.S. Bank Trust National Association, as Trustee for Conseco Finance Home Equity Loan Trust green
ca8 · 2007
1 sentence

2022Additionally, a key consideration under the waiver doctrine is to avoid requiring the parties “to litigate the same underlying facts before two separate tribunals,” which has been held to be “antagonistic to judicial economy, the purposes of arbitration, and common sense.” Millennium, 562 $.W.3d at 378-79 (citing Lewallen, 487 F.3d at 1094 ); Springleaf, 500 S.W.3d at 281 (noting duplication of efforts and inconsistent judgments may be indicative of waiver).

12022–2022
Morrow v. Hallmark Cards, Inc. green
moctapp · 2008
2 sentences

2014Morrow is Irrelevant In an effort to avoid the obvious and unavoidable conclusions of a consideration analysis focusing on the multifaceted exchange of promises between her and Bristol Care regarding her promotion to facility administrator, Ms. Baker relies heavily on Morrow v. Hallmark Cards, Inc., 273 S.W.3d 15 (Mo.App.2008).

2014Morrow is Irrelevant In an effort to avoid the obvious and unavoidable conclusions of a consideration analysis focusing on the multifaceted exchange of promises between her and Bristol Care regarding her promotion to facility administrator, Ms. Baker relies heavily on Morrow v. Hallmark Cards, Inc., 273 S.W.3d 15 (Mo. App. 2008).

12014–2014
Stowe v. Spence green
mo · 2001
1 sentence

2011The court in Petry employed the Michel four-factor best interest test, which was overruled in Stowe, 41 S.W.3d at 469 ; however, the consideration of such factors still would be consistent with an analysis that requires the trial court to consider "all relevant factors.”

12011–2011
Cook v. State neutral
oklacrimapp · 1927
2 sentences

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

11975–1975
State v. Burris green
iowa · 1922
1 sentence

1975The court quoted Commonwealth v. Colandro, 231 Pa. 343 , 80 A. 571, 576 (1911), “‘The-practical effect of such cross-examination may well have been to brand the defendant as a bad man, and to cause the jurors to approach a consideration of his defense from that standpoint, or at least to raise doubts in their minds in passing upon his character evidence.’ ” See also Cook v. State, 36 Okl.Cr. 285 , 253 P. 1029 (1927); McNaulty v. State, 138 Tex.Cr.R. 317 , 135 S.W.2d 987, 988 (1939); People v. Page, 365 Ill. 524 , 6 N.E.2d 845, 847 [2-5] (1937); State v. Burris, 194 Iowa 628 , 190 N.W. 38 (1922

11975–1975
Payne v. Smith green
mo · 1959
1 sentence

1968The appellant also cites a list of contributory negligence cases, instances of contributory negligence as a matter of law (Roux v. Pettus, Mo. App., 293 S.W.2d 144 ; Payne v. Smith, Mo., 322 S.W.2d 764 ) but it is not necessary here to enter upon a consideration of the doctrine of contributory negligence and its rationale.

11968–1968
Roux v. Pettus green
moctapp · 1956
1 sentence

1968The appellant also cites a list of contributory negligence cases, instances of contributory negligence as a matter of law (Roux v. Pettus, Mo. App., 293 S.W.2d 144 ; Payne v. Smith, Mo., 322 S.W.2d 764 ) but it is not necessary here to enter upon a consideration of the doctrine of contributory negligence and its rationale.

11968–1968
State Ex Rel. Equitable Life Assurance Society of the United States v. Allen neutral
· 1940
1 sentence

1949The question of what causes of action are included (that is the question of the power of the agent to receive service) is a matter of substantive right." [ 345 Mo. 671 , 136 S.W.2d 311 ] (Italics ours).

11949–1949
Soukup v. Employers' Liability Assurance Corp. green
· 1937
1 sentence

1944Corporation, 108 S.W.2d 86 , l.c. 92.] To the above we should add: Courts are not permitted to exercise their inventive powers for the purpose of creating an ambiguity where none exists. [State ex rel. v. Shain et al., 166 S.W.2d 484 , l.c. 487.] In the case at bar, while the provision for term insurance does not appear in the consideration clause, it is stated in said clause that the contract is "subject to the conditions herein;" and immediately below the consideration clause, on the front page of the policy, in large type, appears a statement directing attention to conditions affecting the

11944–1944
State Ex Rel. Mutual Benefit Health & Accident Ass'n v. Shain green
mo · 1942
1 sentence

1944Corporation, 108 S.W.2d 86 , l.c. 92.] To the above we should add: Courts are not permitted to exercise their inventive powers for the purpose of creating an ambiguity where none exists. [State ex rel. v. Shain et al., 166 S.W.2d 484 , l.c. 487.] In the case at bar, while the provision for term insurance does not appear in the consideration clause, it is stated in said clause that the contract is "subject to the conditions herein;" and immediately below the consideration clause, on the front page of the policy, in large type, appears a statement directing attention to conditions affecting the

11944–1944
Edwards County v. White County green
ill · 1877
1 sentence

1929In Edwards County v. White County, 85 Ill. 390 , a county boundary line was considered.

11929–1929
Edwards v. Latimer green
mo · 1904
11928–1928
Goodman v. Griffith neutral
mo · 1911
11915–1915
Third National Bank v. St. Charles Savings Bank green
· 1912
11915–1915
McDaniel v. United Railways Co. green
· 1912
11915–1915
Laclede Laundry Co. v. Freudenstein neutral
moctapp · 1913
11915–1915
Versteeg v. Wabash Railroad neutral
· 1913
11914–1914
Green v. State green
ala · 1907
11913–1913
Patterson v. Cappon neutral
wis · 1905
11913–1913
Gore v. Brockman neutral
moctapp · 1909
11912–1912
Trent v. Lechtman Printing Co. neutral
moctapp · 1910
11912–1912
Raymond v. White neutral
mich · 1899
11910–1910
Giles v. Bradley neutral
nysupct · 1801
11910–1910
Rice v. Kansas Pacific Railway green
· 1876
11909–1909
George v. Chicago, Rock Island & Pacific Railway Co. green
mo · 1908
11909–1909
Shickle v. Watts green
mo · 1887
11907–1907
Van Cleve v. Berkey green
mo · 1898
11907–1907
Berry v. Rood green
mo · 1902
11907–1907
Laudman v. Ingram neutral
mo · 1872
11904–1904
Squier v. Evans neutral
mo · 1895
11904–1904
Witbeck v. . Waine green
ny · 1858
11904–1904
Dobyns v. Rice neutral
moctapp · 1886
11904–1904
Holt v. Holt neutral
moctapp · 1894
11904–1904
Armstrong v. Agricultural Insurance green
ny · 1892
11903–1903
Devens v. Mechanics & Traders' Insurance green
· 1880
11903–1903
Brink v. . Hanover Fire Ins. Co. green
ny · 1880
11903–1903
Goodwin v. Massachusetts Mutual Life Insurance neutral
ny · 1878
11903–1903

Where else courts name it

CA 119 (1856–2026) NY 105 (1843–2025) IL 104 (1883–2026) CT 74 (1941–2026) OH 68 (1903–2026) AL 67 (1855–2015) PA 65 (1923–2026) TX 64 (1884–2025) IN 45 (1857–2026) MI 42 (1908–2023) MO 37 (1876–2024) TN 35 (1986–2022) OR 34 (1888–2026) FL 32 (1879–2021) NJ 32 (1951–2022) VA 31 (1919–2026) GA 30 (1898–2021) NC 29 (1883–2021) WA 28 (1895–2025) KY 28 (1858–2026) LA 24 (1937–2024) MA 24 (1860–2023) MD 23 (1909–2016) AR 20 (1909–2026) CO 20 (1890–2025) WI 19 (1892–2022) MN 18 (1887–2018) SC 16 (1941–2022) ID 16 (1932–2019) UT 14 (1901–2025) NM 13 (1939–2021) WV 13 (1904–2026) IA 12 (1876–2021) RI 12 (1971–2014) OK 12 (1919–2010) MS 10 (1909–2025) AZ 10 (1989–2023) DC 9 (1988–2008) MT 9 (1929–2020) NE 9 (1906–2025) KS 9 (1963–2022) WY 7 (1912–2025) ME 6 (1969–2023) DE 6 (1962–2018) VT 6 (1850–2023) AK 4 (1986–2020) NH 3 (1984–2013) HI 3 (1920–2013) NV 3 (2013–2022) ND 3 (1919–2001) SD 2 (1959–2019) PR 2 (1916–1954)

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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