terms standard (New Jersey) · Go Syfert
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terms standard in New Jersey

36 New Jersey opinions name it 4 courts 1903–2026 4 in the last five years

The cases below were cited by New Jersey 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 (16)

CaseFollowedCited
Proformance Insurance v. Jonesgreen
nj · 2005 · cited in 3 New Jersey opinions naming this issue, 2019–2026
2 sentences

2026Co. v. Jones, 185 N.J. 406, 412 (2005) (quoting Matits v. Nationwide Mut.

2021Co. v. Jones, 185 N.J. 406, 412 (2005), (quoting Matits, 33 N.J. 496 -97) (emphasis added).

33
United States v. Katzgreen
ca5 · 1999 · cited in 3 New Jersey opinions naming this issue, 2003–2022
2 sentences

2022We cannot conclude that such evaluations are always, in the terms of the standard test, "beyond the ken of the average juror[,]" . . . or that experts are invariably better equipped than laypersons are to make the judgment based on appearance alone. [Id. at 594 (citation omitted).] "Like any other fact, age is, of course, for the determination of the jury. " State v. Carlone, 109 N.J.L. 208, 211 (Sup. Ct. 1932). "[W]hether the age of a model in a child pornography prosecution can be determined by a lay jury without the assistance of expert testimony . . . must be determined on a case by case b

2021Such a case-by-case analysis may include where the children appear to fit along the spectrum of ages: "Like any other fact, age is, of course, for the determination of the jury." State v. Carlone, 109 N.J.L. 208, 211 , 160 A. 551, 552 (Sup. Ct. 1932). "[W]hether the age of a model in a child pornography prosecution can be determined by a lay jury without the assistance of expert testimony . . . must be determined on a case by case basis." United States v. Katz, 178 F.3d 368, 373 (5th Cir. 1999).

33
State v. Carlonegreen
nj · 1932 · cited in 3 New Jersey opinions naming this issue, 2003–2022
2 sentences

2022We cannot conclude that such evaluations are always, in the terms of the standard test, "beyond the ken of the average juror[,]" . . . or that experts are invariably better equipped than laypersons are to make the judgment based on appearance alone. [Id. at 594 (citation omitted).] "Like any other fact, age is, of course, for the determination of the jury. " State v. Carlone, 109 N.J.L. 208, 211 (Sup. Ct. 1932). "[W]hether the age of a model in a child pornography prosecution can be determined by a lay jury without the assistance of expert testimony . . . must be determined on a case by case b

2021Such a case-by-case analysis may include where the children appear to fit along the spectrum of ages: "Like any other fact, age is, of course, for the determination of the jury." State v. Carlone, 109 N.J.L. 208, 211 , 160 A. 551, 552 (Sup. Ct. 1932). "[W]hether the age of a model in a child pornography prosecution can be determined by a lay jury without the assistance of expert testimony . . . must be determined on a case by case basis." United States v. Katz, 178 F.3d 368, 373 (5th Cir. 1999).

33
Matits v. Nationwide Mutual Insurancegreen
nj · 1960 · cited in 14 New Jersey opinions naming this issue, 1966–2019
2 sentences

2019The rule provides that when a driver has permission to use a motor vehicle in the first instance, any subsequent use short of theft or the like while it remains in his possession, though not within the contemplation of the parties, is a permissive use within the terms of a standard omnibus clause in an automobile insurance policy. [ Matits , 33 N.J. at 496 -97 , 166 A.2d 345 .] In implementing the initial permission doctrine, New Jersey courts have refused to enforce insurance provisions that attempted to circumvent the permissive user rule by excluding categories of permissive users from a po

2019The rule provides that when a driver has permission to use a motor vehicle in the first instance, any subsequent use short of theft or the like while it remains in his possession, though not within the contemplation of the parties, is a permissive use within the terms of a standard omnibus clause in an automobile insurance policy. [ Matits , 33 N.J. at 496 -97 , 166 A.2d 345 .] In implementing the initial permission doctrine, New Jersey courts have refused to enforce insurance provisions that attempted to circumvent the permissive user rule by excluding categories of permissive users from a po

214
DeHanes v. Rothmangreen
nj · 1999 · cited in 2 New Jersey opinions naming this issue, 2003–2021
2 sentences

2021We cannot conclude that such evaluations are always, in the terms of the standard test, "beyond the ken of the average juror[,]" DeHanes v. Rothman, 158 N.J. 90, 100 , 727 A.2d 8, 13 (1999), or that experts are invariably better equipped than laypersons are to make the judgment based on appearance alone. [Id. at 583-84 (alterations in original) (emphasis added).] We further noted in May the capacity of laypersons to approximate the ages of children is highly dependent on the facts and circumstances.

2021We cannot conclude that such evaluations are always, in the terms of the standard test, "beyond the ken of the average juror[,]" DeHanes v. Rothman, 158 N.J. 90, 100 , 727 A.2d 8, 13 (1999), or that experts are invariably better equipped than laypersons are to make the judgment based on appearance alone. [Id. at 583-84 (alterations in original) (emphasis added).] We further noted in May the capacity of laypersons to approximate the ages of children is highly dependent on the facts and circumstances.

22
Selected Risks Insurance Co. v. Zullogreen
nj · 1966 · cited in 2 New Jersey opinions naming this issue, 1970–1984
2 sentences

1984Co. v. Zullo, 48 N.J. 362, 373 (1966), held that an insurance policy "which purports to have a more restrictive omnibus coverage is automatically amended to conform to the statutory standard." Our Supreme Court has made it clear that restrictions on the initial permission rule in an attempt to limit automobile coverage run contrary to the public policy expressed in our compulsory insurance laws.

1970In Matits v. Nationwide Mutual Insurance Company, 33 N.J. 488 (1960), it was held that "if a person is given permission to use a motor vehicle in the first instance, any subsequent *130 use short of theft or the like while it remains in his possession, though not within the contemplation of the parties, is a permissive use within the terms of a standard omnibus clause in an automobile insurance policy." N.J.S.A. 39:6-46(a) "is substantially the same as that of the standard omnibus clause construed in Matits * * * and therefore extends coverage in accordance with the initial permission rule." S

22
State v. Johnsongreen
nj · 1966 · cited in 1 New Jersey opinions naming this issue, 2020–2020
1 sentence

2020Court Rules, comment on R. 1:7-3 (2020) (citing State v. Johnson, 46 N.J. 289, 291 (1966)).

11
Knorr v. Smealgreen
nj · 2003 · cited in 1 New Jersey opinions naming this issue, 2017–2017
1 sentence

2017Because "[w]aiver is the voluntary and intentional relinquishment of a known right," Knorr v. Smeal, 178 N.J. 169, 177 (2003), there cannot be a clear and unambiguous agreement to waive without a "mutual understanding" of the terms of the waiver.

11
United States Department of Energy v. Ohiored
scotus · 1992 · cited in 1 New Jersey opinions naming this issue, 1993–1993
2 sentences

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

11
Ruckelshaus v. Sierra Clubgreen
scotus · 1983 · cited in 1 New Jersey opinions naming this issue, 1993–1993
2 sentences

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

11
Sunset Beach Amusement Corp. v. Belkgreen
nj · 1960 · cited in 1 New Jersey opinions naming this issue, 1979–1979
1 sentence

1979Our Supreme Court adopted the policy that except in situations set forth within the terms of the rule "each litigant shall bear the expenses of prosecuting and defending his individual interests." Sunset Beach Amusement Corp. v. Belk, 33 N.J. 162, 167 (1960).

11
State v. Frankelgreen
njsuperctappdiv · 1956 · cited in 1 New Jersey opinions naming this issue, 1961–1961
1 sentence

1961See 354 U.S., at pp. 491-492; 77 S.Ct., at pp. 1312-1313, 1 L.Ed. 2 d, at pp. 1510-1511; cf. United States v. Petrillo, 332 U.S. 1, 7 , 67 S.Ct. 1538 , 91 L.Ed. 1877, 1883 (1947); Boyce Motor Lines v. United States, 342 U.S. 337, 340 , 72 S.Ct. 329 , 96 L.Ed. 367, 371 (1952); State v. Joas, 34 N.J. 179, 185 (1961); State v. Frankel, 42 N.J.

11
State v. Joasgreen
nj · 1961 · cited in 1 New Jersey opinions naming this issue, 1961–1961
11
Boyce Motor Lines, Inc. v. United Statesgreen
scotus · 1952 · cited in 1 New Jersey opinions naming this issue, 1961–1961
11
United States v. Petrillogreen
scotus · 1947 · cited in 1 New Jersey opinions naming this issue, 1961–1961
11
Hodgson v. Applegategreen
nj · 1959 · cited in 1 New Jersey opinions naming this issue, 1960–1960
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (22)

CaseCitedYears
Verriest v. Ina Underwriters Insurance green
nj · 1995
2 sentences

2005Under this rule, “if a person is given permission to use a motor vehicle in the first instance, any subsequent use short of theft or the like while it remains in his possession, though not within the contemplation of the parties, is a permissive use within the terms of a standard omnibus clause in an automobile liability insurance policy.” Id. at 411 , 662 A.2d 967 (quoting Matits v. Nationwide Mut.

2005Under this rule, “if a person is given permission to use a motor vehicle in the first instance, any subsequent use short of theft or the like while it remains in his possession, though not within the contemplation of the parties, is a permissive use within the terms of a standard omnibus clause in an automobile liability insurance policy.” Id. at 411 , 662 A.2d 967 (quoting Matits v. Nationwide Mut.

31996–2005
Schuncke v. Pennsylvania Threshermen & Farmers' Mutual Casualty Insurance green
nj · 1964
2 sentences

1977Co., 33 N.J. 488 (1960), where this Court, after reviewing various approaches taken by other jurisdictions for determining the coverage available to persons other than the named insured under such a provision, adopted the broadest and most liberal approach, known as the "initial permission rule." The Court formulated this rule in these words: * * * [I]f a person is given permission to use a motor vehicle in the first instance, any subsequent use short of theft or the like while it remains in his possession, though not within the contemplation of the parties, is a permissive use within the term

1977That opinion reduced the problem of coverage available to persons other than the named insured to two fact issues: (1) whether permission had been given to use the car, and (2) whether the use constituted "theft or the like." 42 N.J. at 413 .

31966–1977
State v. May green
njsuperctappdiv · 2003
1 sentence

2022Thus, if A-3414-18 8 the "disputed images . . . depict either very young child-models or older 'models of sufficient maturity,'" expert testimony is not required "because a layperson can plainly make the determination whether the person so depicted is younger than sixteen." May, 362 N.J.

12022–2022
Patricia Atalese v. U.S. Legal Services Group, L.P. (072314) green
nj · 2014
2 sentences

2017Atalese, supra, 219 N.J. at 446-47 .

2017Atalese, supra, 219 N.J. at 446-47 .

12017–2017
Mancini v. EDS ON BEHALF OF THE NEW JERSEY AUTOMOBILE FULL INSURANCE UNDERWRITING ASSOCIATION green
nj · 1993
2 sentences

2008Mancini v. EDS, 132 N.J. 330, 334 , 625 A. 2d 484 (1993).

2008Mancini v. EDS, 132 N.J. 330, 334 , 625 A. 2d 484 (1993).

12008–2008
French v. Hernandez green
nj · 2005
2 sentences

2006Moreover, “[a]s long as the initial use of the vehicle is with the consent, express or implied, of the insured, any subsequent changes in the character or scope of the use ... do not require the additional specific consent of the insured.” French v. Hernandez, 184 N.J. 144, 152 , 875 A.2d 943 (2005) (quoting Verriest v. INA Underwriters Ins.

2006Moreover, “[a]s long as the initial use of the vehicle is with the consent, express or implied, of the insured, any subsequent changes in the character or scope of the use ... do not require the additional specific consent of the insured.” French v. Hernandez, 184 N.J. 144, 152 , 875 A.2d 943 (2005) (quoting Verriest v. INA Underwriters Ins.

12006–2006
United States v. Nordic Village, Inc. red
scotus · 1992
2 sentences

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

11993–1993
McMahon v. United States green
scotus · 1951
2 sentences

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

11993–1993
cluster 518773 green
ca3 · 1989
2 sentences

1993The Secretary argues that the terms of Section 1702's "sue and be *621 sued" clause should not prevail over the terms of the immunity waiver contained in Section 702 of the APA, and that allowing the Secretary to be sued under the APA in state court would be "inconsistent with the scheme of the APA." The Secretary essentially relies on a Sixth Circuit decision resolving this same issue in Federal National Mortgage Association v. LeCrone, supra, 868 F. 2d 190 .

1993The Secretary argues that the terms of Section 1702's "sue and be *621 sued" clause should not prevail over the terms of the immunity waiver contained in Section 702 of the APA, and that allowing the Secretary to be sued under the APA in state court would be "inconsistent with the scheme of the APA." The Secretary essentially relies on a Sixth Circuit decision resolving this same issue in Federal National Mortgage Association v. LeCrone, supra, 868 F. 2d 190 .

11993–1993
McMahon v. United States green
scotus · 1951
1 sentence

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

11993–1993
Harman v. Southern Ry. green
· 1905
1 sentence

1993See United States Dep't of Energy v. Ohio, supra, 503 U.S. at ___, 112 S.Ct. 1627, 1633 , 118 L.Ed. 2d at 266 ; United States v. Nordic Village, supra, 503 U.S. at ___, 112 S.Ct. 1011, 1014-15 , 117 L.Ed. 2d at 187-88 ; see also Ruckelshaus v. Sierra Club, 463 U.S. 680, 685 , 103 S.Ct. 3274, 3277-78 , 77 L.Ed. 2d 938, 944 (1983); McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17, 19 , 96 L.Ed. 26, 30 , reh'g denied, 342 U.S. 899 , 72 S.Ct. 228 , 96 L.Ed. 673 (1951).

11993–1993
Shaer Shoe Corp. v. Granite State Alarm, Inc. green
nh · 1970
2 sentences

1975Cases cited by Telephone Co. in support of this argument are authority for upholding the limitation of liability insofar as ADT is concerned; but the proposition espoused by Telephone Co. is that its own liability is likewise curtailed. *163 Shaer Shoe Corp. v. Granite State Alarm, Inc., 110 N.H. 132 , 262 A. 2d 285 (Sup. Ct. 1970); Wedner v. Fidelity Security Systems, 307 A. 2d 429 (Pa. Super.

1975Cases cited by Telephone Co. in support of this argument are authority for upholding the limitation of liability insofar as ADT is concerned; but the proposition espoused by Telephone Co. is that its own liability is likewise curtailed. *163 Shaer Shoe Corp. v. Granite State Alarm, Inc., 110 N.H. 132 , 262 A. 2d 285 (Sup. Ct. 1970); Wedner v. Fidelity Security Systems, 307 A. 2d 429 (Pa. Super.

11975–1975
Wedner v. Fidelity Security Sytems, Inc. green
pasuperct · 1973
1 sentence

1975Cases cited by Telephone Co. in support of this argument are authority for upholding the limitation of liability insofar as ADT is concerned; but the proposition espoused by Telephone Co. is that its own liability is likewise curtailed. *163 Shaer Shoe Corp. v. Granite State Alarm, Inc., 110 N.H. 132 , 262 A. 2d 285 (Sup. Ct. 1970); Wedner v. Fidelity Security Systems, 307 A. 2d 429 (Pa. Super.

11975–1975
Gronquist v. Transit Casualty Company green
njsuperctappdiv · 1969
1 sentence

1970In Matits v. Nationwide Mutual Insurance Company, 33 N.J. 488 (1960), it was held that "if a person is given permission to use a motor vehicle in the first instance, any subsequent *130 use short of theft or the like while it remains in his possession, though not within the contemplation of the parties, is a permissive use within the terms of a standard omnibus clause in an automobile insurance policy." N.J.S.A. 39:6-46(a) "is substantially the same as that of the standard omnibus clause construed in Matits * * * and therefore extends coverage in accordance with the initial permission rule." S

11970–1970
Danek v. Hommer green
nj · 1954
1 sentence

1965Super. 68 ( App. Div. 1953), affirmed 15 N.J. 573 (1954), leads to the inescapable conclusion that Kowalsky qualifies as an additional insured under the terms of the clause in the Nationwide policy which includes "any person while using the automobile and any person or organization legally responsible for the use thereof." In Danek the court stated: "The conclusion to be drawn from these statements is that the duty to defend comes into being when the complaint states a claim constituting a risk insured against.

11965–1965
Hanover Ins. Co. v. Franke green
njsuperctappdiv · 1962
1 sentence

1963Co. v. Franke, 75 N.J.

11963–1963
Nicholas v. Independence Indemnity Co. neutral
nj · 1933
1 sentence

1962Super. 373 ( App. Div. 1960)), or the alternative "conversion" rule (see 7 Appleman, Insurance, 169-181 (1942)), held: "* * * if a person is given permission to use a motor vehicle in the first instance, any subsequent use short of theft or the like while it remains in his possession, though not within the contemplation of the parties, is a permissive use within the terms of a standard omnibus clause in an automobile liability insurance policy." *73 Nevertheless, the trial court concluded that the cases relied upon by plaintiff, Penza v. The Century Indemnity Co., 119 N.J.L. 446 ( E. & A. 1937

11962–1962
Penza v. Century Indemnity Co. of Hartford green
nj · 1938
1 sentence

1962Super. 373 ( App. Div. 1960)), or the alternative "conversion" rule (see 7 Appleman, Insurance, 169-181 (1942)), held: "* * * if a person is given permission to use a motor vehicle in the first instance, any subsequent use short of theft or the like while it remains in his possession, though not within the contemplation of the parties, is a permissive use within the terms of a standard omnibus clause in an automobile liability insurance policy." *73 Nevertheless, the trial court concluded that the cases relied upon by plaintiff, Penza v. The Century Indemnity Co., 119 N.J.L. 446 ( E. & A. 1937

11962–1962
Hodgson v. Applegate green
njsuperctappdiv · 1959
11960–1960
Heater v. Van Auken neutral
njch · 1861
11931–1931
Hewitt v. Green neutral
njch · 1910
11926–1926
Morrison v. City of Lawrence neutral
mass · 1867
11903–1903

Where else courts name it

TX 107 (1890–2025) CA 78 (1863–2026) PA 76 (1891–2025) IL 60 (1883–2026) NY 54 (1851–2026) NJ 36 (1903–2026) FL 23 (1957–2026) OR 22 (1923–2022) MA 20 (1921–2025) MO 19 (1887–2012) WI 19 (1950–2024) TN 19 (1985–2025) AL 17 (1867–2013) OH 17 (1871–2025) IA 15 (1915–2025) CO 14 (1899–2009) WA 14 (1925–2017) UT 14 (1997–2024) MD 13 (1871–2023) CT 13 (1921–2024) LA 13 (1929–2026) NC 13 (1892–2019) NE 11 (1927–2014) AZ 11 (1917–2020) MI 10 (1896–2024) KY 9 (1935–2024) VA 8 (1900–2023) SC 7 (1935–2025) MN 7 (1878–2024) GA 7 (1907–2007) NV 7 (1909–2013) IN 7 (1892–1999) HI 7 (1915–2024) SD 6 (1934–2016) ID 6 (1989–2017) DC 6 (1987–2024) WV 5 (1911–2016) VT 5 (1856–1925) NM 5 (1963–2014) MS 5 (1994–2014) AK 5 (1981–2021) RI 5 (1981–2006) ME 5 (1943–2002) KS 5 (1911–1994) ND 4 (1901–2005) AR 3 (1978–1994) OK 3 (1913–1960) MT 3 (1922–1944) WY 3 (1927–2023) DE 3 (1971–2024) NH 2 (1860–2025)

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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