sentence clause (South Carolina) · Go Syfert
← South Carolina issues

sentence clause in South Carolina

33 South Carolina opinions name it 2 courts 1975–2025 4 in the last five years

The cases below were cited by South Carolina 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 (18)

CaseFollowedCited
McGill v. Mooregreen
sc · 2009 · cited in 8 South Carolina opinions naming this issue, 2010–2017
2 sentences

2017Res. v. Town of McClellanville, 345 S.C. 617, 623 , 550 S.E.2d 299 , 302–03 (2001) (finding that whether the language of a contract is ambiguous is a question of law for the court); Williams, 409 S.C. at 595 , 762 S.E.2d at 710 ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause." (quoting McGill, 381 S.C. at 185 , 672 S.E.2d at 574 )); id. ("Whether a contract is ambiguous is to be determined from examining the entire contract, not by reviewing isolated portions of the contract."); Dawsey, 371 S.C. at 356 , 638 S.E.2d at

2017Res. v. Town of McClellanville, 345 S.C. 617, 623 , 550 S.E.2d 299 , 302–03 (2001) (finding that whether the language of a contract is ambiguous is a question of law for the court); Williams, 409 S.C. at 595 , 762 S.E.2d at 710 ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause." (quoting McGill, 381 S.C. at 185 , 672 S.E.2d at 574 )); id. ("Whether a contract is ambiguous is to be determined from examining the entire contract, not by reviewing isolated portions of the contract."); Dawsey, 371 S.C. at 356 , 638 S.E.2d at

58
Falkosky v. Allstate Insurancegreen
scctapp · 1993 · cited in 2 South Carolina opinions naming this issue, 1999–1999
2 sentences

1999Co., 311 S.C. 369, 371 , 429 S.E.2d 194, 196 (Ct.App.), modified, 312 S.C. 210 , 439 S.E.2d 836 (1993) (internal citations omitted).

1999Co., 311 S.C. 369, 371 , 429 S.E.2d 194, 196 (Ct.App.), modified, 312 S.C. 210 , 439 S.E.2d 836 (1993) (internal citations omitted).

22
Silver v. Aabstract Pools & Spas, Inc.green
scctapp · 2008 · cited in 3 South Carolina opinions naming this issue, 2010–2013
2 sentences

2013As to Wilson's assertions the special referee erred in holding he failed to notify Butler of his intent not to renew the lease and the doctrine of laches bars Butler's claim: Silver v. Aabstract Pools & Spas, Inc., 376 S.C. 585, 591 , 658 S.E.2d 539, 542 (Ct. App. 2008) (holding whether the language of a contract is ambiguous is a question of law to be determined by the court by examining the entire contract and not merely whether certain phrases taken in isolation could be interpreted in more than one way, and stating "[o]ne may not, by pointing out a single sentence or clause, create an ambi

2013As to Wilson's assertions the special referee erred in holding he failed to notify Butler of his intent not to renew the lease and the doctrine of laches bars Butler's claim: Silver v. Aabstract Pools & Spas, Inc., 376 S.C. 585, 591 , 658 S.E.2d 539, 542 (Ct. App. 2008) (holding whether the language of a contract is ambiguous is a question of law to be determined by the court by examining the entire contract and not merely whether certain phrases taken in isolation could be interpreted in more than one way, and stating "[o]ne may not, by pointing out a single sentence or clause, create an ambi

13
South Carolina Department of Natural Resources v. Town of McClellanvillegreen
sc · 2001 · cited in 2 South Carolina opinions naming this issue, 2012–2017
2 sentences

2017Res. v. Town of McClellanville, 345 S.C. 617, 623 , 550 S.E.2d 299 , 302–03 (2001) (finding that whether the language of a contract is ambiguous is a question of law for the court); Williams, 409 S.C. at 595 , 762 S.E.2d at 710 ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause." (quoting McGill, 381 S.C. at 185 , 672 S.E.2d at 574 )); id. ("Whether a contract is ambiguous is to be determined from examining the entire contract, not by reviewing isolated portions of the contract."); Dawsey, 371 S.C. at 356 , 638 S.E.2d at

2017Res. v. Town of McClellanville, 345 S.C. 617, 623 , 550 S.E.2d 299 , 302–03 (2001) (finding that whether the language of a contract is ambiguous is a question of law for the court); Williams, 409 S.C. at 595 , 762 S.E.2d at 710 ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause." (quoting McGill, 381 S.C. at 185 , 672 S.E.2d at 574 )); id. ("Whether a contract is ambiguous is to be determined from examining the entire contract, not by reviewing isolated portions of the contract."); Dawsey, 371 S.C. at 356 , 638 S.E.2d at

12
Madden v. BENT PALM INVESTMENTS, LLCgreen
scctapp · 2010 · cited in 1 South Carolina opinions naming this issue, 2025–2025
2 sentences

2025See Snow v. Smith, 416 S.C. 72, 85 , 784 S.E.2d 242, 248 (Ct. App. 2016) ("When a deed is unambiguous, any attempt to determine the grantor's intent when reserving the easement must be limited to the deed itself, and using extrinsic evidence to contradict the plain language of the deed is improper."); Madden v. Bent Palm Invs., LLC, 386 S.C. 459, 465 , 688 S.E.2d 597, 600 (Ct. App. 2010) ("A party may not create an ambiguity by reading a single sentence or clause, but rather the contract and the language used must be considered as a whole."); Klutts Resort Realty, Inc. v. Down'Round Dev.

2025See Snow v. Smith, 416 S.C. 72, 85 , 784 S.E.2d 242, 248 (Ct. App. 2016) ("When a deed is unambiguous, any attempt to determine the grantor's intent when reserving the easement must be limited to the deed itself, and using extrinsic evidence to contradict the plain language of the deed is improper."); Madden v. Bent Palm Invs., LLC, 386 S.C. 459, 465 , 688 S.E.2d 597, 600 (Ct. App. 2010) ("A party may not create an ambiguity by reading a single sentence or clause, but rather the contract and the language used must be considered as a whole."); Klutts Resort Realty, Inc. v. Down'Round Dev.

11
Snow v. Smithgreen
scctapp · 2016 · cited in 1 South Carolina opinions naming this issue, 2025–2025
2 sentences

2025See Snow v. Smith, 416 S.C. 72, 85 , 784 S.E.2d 242, 248 (Ct. App. 2016) ("When a deed is unambiguous, any attempt to determine the grantor's intent when reserving the easement must be limited to the deed itself, and using extrinsic evidence to contradict the plain language of the deed is improper."); Madden v. Bent Palm Invs., LLC, 386 S.C. 459, 465 , 688 S.E.2d 597, 600 (Ct. App. 2010) ("A party may not create an ambiguity by reading a single sentence or clause, but rather the contract and the language used must be considered as a whole."); Klutts Resort Realty, Inc. v. Down'Round Dev.

2025See Snow v. Smith, 416 S.C. 72, 85 , 784 S.E.2d 242, 248 (Ct. App. 2016) ("When a deed is unambiguous, any attempt to determine the grantor's intent when reserving the easement must be limited to the deed itself, and using extrinsic evidence to contradict the plain language of the deed is improper."); Madden v. Bent Palm Invs., LLC, 386 S.C. 459, 465 , 688 S.E.2d 597, 600 (Ct. App. 2010) ("A party may not create an ambiguity by reading a single sentence or clause, but rather the contract and the language used must be considered as a whole."); Klutts Resort Realty, Inc. v. Down'Round Dev.

11
Klutts Resort Realty, Inc. v. Down'Round Development Corp.green
sc · 1977 · cited in 1 South Carolina opinions naming this issue, 2025–2025
2 sentences

2025Corp., 268 S.C. 80, 88 , 232 S.E.2d 20, 24 (1977) ("[W]here instruments are executed at the same time, by the same parties, for the same purpose, and in the course of the same transaction, the courts will consider and construe the instruments together.").

2025Corp., 268 S.C. 80, 88 , 232 S.E.2d 20, 24 (1977) ("[W]here instruments are executed at the same time, by the same parties, for the same purpose, and in the course of the same transaction, the courts will consider and construe the instruments together.").

11
Simmons v. Stategreen
sc · 1975 · cited in 1 South Carolina opinions naming this issue, 2023–2023
2 sentences

2023In Simmons v. State, this Court indirectly distinguished constitutional PCR claims and claims that the parties could have addressed before trial, during trial, or on direct appeal. 264 S.C. 417, 423 , 215 S.E.2d 883, 885 (1975) ("Errors in a petitioner's trial which could have been reviewed on appeal may not be asserted for the first time, or reasserted, in post-conviction proceedings." (citations omitted)).

2023In Simmons v. State, this Court indirectly distinguished constitutional PCR claims and claims that the parties could have addressed before trial, during trial, or on direct appeal. 264 S.C. 417, 423 , 215 S.E.2d 883, 885 (1975) ("Errors in a petitioner's trial which could have been reviewed on appeal may not be asserted for the first time, or reasserted, in post-conviction proceedings." (citations omitted)).

11
South Carolina Farm Bureau Mutual Insurance v. Dawseygreen
scctapp · 2006 · cited in 1 South Carolina opinions naming this issue, 2017–2017
2 sentences

2017Res. v. Town of McClellanville, 345 S.C. 617, 623 , 550 S.E.2d 299 , 302–03 (2001) (finding that whether the language of a contract is ambiguous is a question of law for the court); Williams, 409 S.C. at 595 , 762 S.E.2d at 710 ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause." (quoting McGill, 381 S.C. at 185 , 672 S.E.2d at 574 )); id. ("Whether a contract is ambiguous is to be determined from examining the entire contract, not by reviewing isolated portions of the contract."); Dawsey, 371 S.C. at 356 , 638 S.E.2d at

2017Res. v. Town of McClellanville, 345 S.C. 617, 623 , 550 S.E.2d 299 , 302–03 (2001) (finding that whether the language of a contract is ambiguous is a question of law for the court); Williams, 409 S.C. at 595 , 762 S.E.2d at 710 ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause." (quoting McGill, 381 S.C. at 185 , 672 S.E.2d at 574 )); id. ("Whether a contract is ambiguous is to be determined from examining the entire contract, not by reviewing isolated portions of the contract."); Dawsey, 371 S.C. at 356 , 638 S.E.2d at

11
Williams v. Government Employees Insurancegreen
sc · 2014 · cited in 1 South Carolina opinions naming this issue, 2017–2017
2 sentences

2017Res. v. Town of McClellanville, 345 S.C. 617, 623 , 550 S.E.2d 299 , 302–03 (2001) (finding that whether the language of a contract is ambiguous is a question of law for the court); Williams, 409 S.C. at 595 , 762 S.E.2d at 710 ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause." (quoting McGill, 381 S.C. at 185 , 672 S.E.2d at 574 )); id. ("Whether a contract is ambiguous is to be determined from examining the entire contract, not by reviewing isolated portions of the contract."); Dawsey, 371 S.C. at 356 , 638 S.E.2d at

2017Res. v. Town of McClellanville, 345 S.C. 617, 623 , 550 S.E.2d 299 , 302–03 (2001) (finding that whether the language of a contract is ambiguous is a question of law for the court); Williams, 409 S.C. at 595 , 762 S.E.2d at 710 ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause." (quoting McGill, 381 S.C. at 185 , 672 S.E.2d at 574 )); id. ("Whether a contract is ambiguous is to be determined from examining the entire contract, not by reviewing isolated portions of the contract."); Dawsey, 371 S.C. at 356 , 638 S.E.2d at

11
Futch v. McAllister Towing of Georgetown, Inc.green
sc · 1999 · cited in 1 South Carolina opinions naming this issue, 2015–2015
2 sentences

2015As to whether the trial court erred in denying Gregorie's motion for summary judgment: Futch v. McAllister Towing of Georgetown, Inc., 335 S.C. 598, 613 , 518 S.E.2d 591, 598 (1999) (noting an appellate court need not address appellant's remaining issues when its determination of a prior issue is dispositive).

2015As to whether the trial court erred in denying Gregorie's motion for summary judgment: Futch v. McAllister Towing of Georgetown, Inc., 335 S.C. 598, 613 , 518 S.E.2d 591, 598 (1999) (noting an appellate court need not address appellant's remaining issues when its determination of a prior issue is dispositive).

11
Stevens Aviation, Inc. v. Dyncorp International LLCgreen
scctapp · 2011 · cited in 1 South Carolina opinions naming this issue, 2015–2015
2 sentences

2015Owners Ass'n v. Pelzer, 292 S.C. 343, 347 , 356 S.E.2d 411, 414 (Ct. App. 1987))); McGill v. Moore, 381 S.C. 179, 185 , 672 S.E.2d 571, 574 (2009) ("The cardinal rule of contract interpretation is to ascertain and give legal effect to the parties' intentions as determined by the contract language."); id. ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause."); Stevens Aviation, Inc. v. DynCorp Int'l LLC, 394 S.C. 300, 307-08 , 715 S.E.2d 655, 659 (Ct. App. 2011) ("To incorporate the terms of extrinsic material, a contract

2015Owners Ass'n v. Pelzer, 292 S.C. 343, 347 , 356 S.E.2d 411, 414 (Ct. App. 1987))); McGill v. Moore, 381 S.C. 179, 185 , 672 S.E.2d 571, 574 (2009) ("The cardinal rule of contract interpretation is to ascertain and give legal effect to the parties' intentions as determined by the contract language."); id. ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause."); Stevens Aviation, Inc. v. DynCorp Int'l LLC, 394 S.C. 300, 307-08 , 715 S.E.2d 655, 659 (Ct. App. 2011) ("To incorporate the terms of extrinsic material, a contract

11
Seabrook Island Property Owners Ass'n v. Pelzergreen
scctapp · 1987 · cited in 1 South Carolina opinions naming this issue, 2015–2015
2 sentences

2015Owners Ass'n v. Pelzer, 292 S.C. 343, 347 , 356 S.E.2d 411, 414 (Ct. App. 1987))); McGill v. Moore, 381 S.C. 179, 185 , 672 S.E.2d 571, 574 (2009) ("The cardinal rule of contract interpretation is to ascertain and give legal effect to the parties' intentions as determined by the contract language."); id. ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause."); Stevens Aviation, Inc. v. DynCorp Int'l LLC, 394 S.C. 300, 307-08 , 715 S.E.2d 655, 659 (Ct. App. 2011) ("To incorporate the terms of extrinsic material, a contract

2015Owners Ass'n v. Pelzer, 292 S.C. 343, 347 , 356 S.E.2d 411, 414 (Ct. App. 1987))); McGill v. Moore, 381 S.C. 179, 185 , 672 S.E.2d 571, 574 (2009) ("The cardinal rule of contract interpretation is to ascertain and give legal effect to the parties' intentions as determined by the contract language."); id. ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause."); Stevens Aviation, Inc. v. DynCorp Int'l LLC, 394 S.C. 300, 307-08 , 715 S.E.2d 655, 659 (Ct. App. 2011) ("To incorporate the terms of extrinsic material, a contract

11
Southern Atlantic Financial Services, Inc. v. Middletongreen
sc · 2003 · cited in 1 South Carolina opinions naming this issue, 2011–2011
2 sentences

2011Inc. v. Middleton, 356 S.C. 444, 447 , 590 S.E.2d 27, 29 (2003) (finding a contract should be read as a whole document so that “one may *22 not, by pointing out a single sentence or clause, create an ambiguity”).

2011Inc. v. Middleton, 356 S.C. 444, 447 , 590 S.E.2d 27, 29 (2003) (finding a contract should be read as a whole document so that “one may *22 not, by pointing out a single sentence or clause, create an ambiguity”).

11
Yarborough v. Phoenix Mutual Life Insurancegreen
sc · 1976 · cited in 1 South Carolina opinions naming this issue, 2011–2011
2 sentences

2011Co., 266 S.C. 584, 592 , 225 S.E.2d 344, 348 (1976).

2011Co., 266 S.C. 584, 592 , 225 S.E.2d 344, 348 (1976).

11
State v. Gastergreen
sc · 2002 · cited in 1 South Carolina opinions naming this issue, 2010–2010
2 sentences

2010We affirm[1] pursuant to Rule 220(b)(1), SCACR, and the following authority: State v. Gaster , 349 S.C. 545, 552 , 564 S.E.2d 87, 91 (2002) (holding constitutional issues must be raised to and ruled upon by the trial court in order to preserve the issues for appellate review).

2010We affirm[1] pursuant to Rule 220(b)(1), SCACR, and the following authority: State v. Gaster , 349 S.C. 545, 552 , 564 S.E.2d 87, 91 (2002) (holding constitutional issues must be raised to and ruled upon by the trial court in order to preserve the issues for appellate review).

11
State v. Allengreen
sc · 2006 · cited in 1 South Carolina opinions naming this issue, 2009–2009
2 sentences

2009"The determination of whether to revoke probation in whole or in part rests within the sound discretion of the trial court." State v. Allen , 370 S.C. 88, 94 , 634 S.E.2d 653, 655 (2006); S.C.

2009"The determination of whether to revoke probation in whole or in part rests within the sound discretion of the trial court." State v. Allen , 370 S.C. 88, 94 , 634 S.E.2d 653, 655 (2006); S.C.

11
Farr v. Duke Power Companygreen
sc · 1975 · cited in 1 South Carolina opinions naming this issue, 1989–1989
1 sentence

1989“Whether a contract is ambiguous is to be determined from the entire contract and not from isolated portions of the contract.” Farr v. Duke Power Co., 265 S. C. 356, 362, 218 S. E. (2d) 431, 433 (1975). “[I]n construing an insurance contract, all of its provisions should be considered, and one may not, by pointing out a single sentence or clause, create an ambiguity.” Yarborough v. Phoenix Mut.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
Schulmeyer v. State Farm Fire & Casualty Co. green
sc · 2003
2 sentences

2024Schulmeyer, 353 S.C. at 495 , 579 S.E.2d at 134 .

2024Schulmeyer, 353 S.C. at 495 , 579 S.E.2d at 134 .

72003–2024
Braswell v. Faircloth Ex Rel. Estate of Lynch green
scctapp · 1989
2 sentences

1999Id. at 342 , 387 S.E.2d at 709 .

1999Id. at 342 , 387 S.E.2d at 709 .

31993–1999
Lazerson v. Hilton Head Hospital, Inc. neutral
sc · 1994
2 sentences

1999Co., 311 S.C. 369, 371 , 429 S.E.2d 194, 196 (Ct.App.), modified, 312 S.C. 210 , 439 S.E.2d 836 (1993) (internal citations omitted).

1999Co., 311 S.C. 369, 371 , 429 S.E.2d 194, 196 (Ct.App.), modified, 312 S.C. 210 , 439 S.E.2d 836 (1993) (internal citations omitted).

21999–1999
Falkosky v. Allstate Insurance Company neutral
sc · 1993
2 sentences

1999Co., 311 S.C. 369, 371 , 429 S.E.2d 194, 196 (Ct.App.), modified, 312 S.C. 210 , 439 S.E.2d 836 (1993) (internal citations omitted).

1999Co., 311 S.C. 369, 371 , 429 S.E.2d 194, 196 (Ct.App.), modified, 312 S.C. 210 , 439 S.E.2d 836 (1993) (internal citations omitted).

21999–1999
Auto-Owners Insurance v. Benjamin green
scctapp · 2015
2 sentences

2023"An insurance contract is read as a whole document so that 'one may not, by pointing out a single sentence or clause, create an ambiguity.'" Id. at 144 , 781 S.E.2d at 141 (quoting Beaufort Cnty.

2023"An insurance contract is read as a whole document so that 'one may not, by pointing out a single sentence or clause, create an ambiguity.'" Id. at 144 , 781 S.E.2d at 141 (quoting Beaufort Cnty.

12023–2023
Stevens Aviation, Inc. v. DynCorp International LLC green
sc · 2014
2 sentences

2015Owners Ass'n v. Pelzer, 292 S.C. 343, 347 , 356 S.E.2d 411, 414 (Ct. App. 1987))); McGill v. Moore, 381 S.C. 179, 185 , 672 S.E.2d 571, 574 (2009) ("The cardinal rule of contract interpretation is to ascertain and give legal effect to the parties' intentions as determined by the contract language."); id. ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause."); Stevens Aviation, Inc. v. DynCorp Int'l LLC, 394 S.C. 300, 307-08 , 715 S.E.2d 655, 659 (Ct. App. 2011) ("To incorporate the terms of extrinsic material, a contract

2015Owners Ass'n v. Pelzer, 292 S.C. 343, 347 , 356 S.E.2d 411, 414 (Ct. App. 1987))); McGill v. Moore, 381 S.C. 179, 185 , 672 S.E.2d 571, 574 (2009) ("The cardinal rule of contract interpretation is to ascertain and give legal effect to the parties' intentions as determined by the contract language."); id. ("A contract is read as a whole document so that one may not create an ambiguity by pointing out a single sentence or clause."); Stevens Aviation, Inc. v. DynCorp Int'l LLC, 394 S.C. 300, 307-08 , 715 S.E.2d 655, 659 (Ct. App. 2011) ("To incorporate the terms of extrinsic material, a contract

12015–2015
Hansen Ex Rel. Hansen v. United Services Automobile Ass'n green
scctapp · 2002
2 sentences

2012Id. at 68 , 565 S.E.2d at 117 . “[I]n construing an insurance contract, all of its provisions should be considered, and one may not, by pointing out a single sentence or clause, create an ambiguity.” Id. (alteration by court) (internal quotations marks omitted).

2012Id. at 68 , 565 S.E.2d at 117 . “[I]n construing an insurance contract, all of its provisions should be considered, and one may not, by pointing out a single sentence or clause, create an ambiguity.” Id. (alteration by court) (internal quotations marks omitted).

12012–2012
Rochin v. California green
scotus · 1952
2 sentences

1975However, upon an examination of all of the alleged errors in combination and separately and a consideration of the whole course of the proceedings in accordance with the standard of review as required by Rochin v. California , 342 U.S. 165 , 72 S.Ct. 205 , 96 L.Ed. 183 (1952), it is clear that the alleged errors here present issues of constitutional dimension properly reviewable under the Post-Conviction Procedures Act which is available to: "(a) Any person who has been convicted of, or sentenced for, a crime and who claims: "(1) That the conviction or the sentence was in violation of the Cons

1975However, upon an examination of all of the alleged errors in combination and separately and a consideration of the whole course of the proceedings in accordance with the standard of review as required by Rochin v. California , 342 U.S. 165 , 72 S.Ct. 205 , 96 L.Ed. 183 (1952), it is clear that the alleged errors here present issues of constitutional dimension properly reviewable under the Post-Conviction Procedures Act which is available to: "(a) Any person who has been convicted of, or sentenced for, a crime and who claims: "(1) That the conviction or the sentence was in violation of the Cons

11975–1975

Statutes the citing opinions construe

SC § S.C. Code Ann. § 38-77-140 (3) SC § S.C. Code Ann. § 56-9-20 (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

AL 132 (1890–2025) TN 106 (1976–2025) OH 95 (1992–2026) PA 93 (1919–2026) IL 92 (1909–2026) CA 84 (1898–2026) FL 72 (1947–2016) IN 64 (1880–2020) NC 38 (1796–2025) WA 37 (1918–2025) TX 34 (1927–2024) LA 33 (1917–2018) SC 33 (1975–2025) AZ 26 (1963–2024) MS 24 (1969–2018) GA 23 (1917–2021) NE 21 (1904–2021) NY 20 (1848–2023) MI 17 (1977–2023) IA 17 (1899–2021) MN 17 (1987–2025) KS 14 (1916–2025) NJ 14 (1951–2021) MA 13 (1988–2025) ID 12 (1971–2024) RI 12 (1977–2017) OR 12 (1917–2026) MT 12 (1923–2021) MO 11 (1905–2020) MD 11 (1973–2020) CO 11 (1910–2025) CT 11 (1943–2023) WI 9 (1964–2008) NH 8 (1976–2013) SD 7 (1989–2015) AK 7 (1969–2024) UT 6 (2006–2015) NM 6 (1960–2020) OK 5 (1969–2021) ME 5 (1982–2026) KY 5 (1925–2024) AR 5 (1977–1987) HI 4 (1999–2018) DE 3 (1942–2022) WY 3 (1935–1997) NV 3 (2014–2020) VA 2 (1946–2025) VI 2 (2014–2017) ND 2 (2006–2020)

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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