Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
202 Illinois opinions name it 2 courts 1880–2026 18 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.
| Case | Followed | Cited |
|---|---|---|
The PEOPLE v. Scalesgreen2 sentences2016“Our supreme court has held that ‘[t]he constitutional right to not be twice put in jeopardy for the same offense is a personal privilege which may be [forfeited]’ where the accused ‘does not raise the defense of former jeopardy before judgment in the trial court.’ ” People v. Brown, 2015 IL App (1st) 134049, ¶ 26 , 36 N.E.3d 306 (quoting People v. Scales, 18 -8- Ill. 2d 283, 285, 164 N.E.2d 76, 77 (1960) (failure to raise the defense of double jeopardy before judgment in the trial court forfeits the defense)). 2016“Our supreme court has held that ‘[t]he constitutional right to not be twice put in jeopardy for the same offense is a personal privilege which may be [forfeited]’ where the accused ‘does not raise the defense of former jeopardy before judgment in the trial court.’ ” -5- People v. Brown, 2015 IL App (1st) 134049, ¶ 26 , 36 N.E.3d 306 (quoting People v. Scales, 18 Ill. 2d 283, 285 , 164 N.E.2d 76, 77 (1960) (failure to raise the defense of double jeopardy before judgment in the trial court forfeits the defense)). | 7 | 12 |
Underground Contractors Ass'n v. City of Chicagogreen2 sentences2025The second part is the party seeking the declaration must not merely have a curiosity or concern about the outcome of the case but must “possess a personal claim, status, or right which is capable of being affected.” Id. at 375-76 . ¶ 41 The burden of proving a lack of standing falls on Cherry Valley (see Rowe v. Raoul, 2023 IL 129248, ¶ 22 ), and Cherry Valley has not met this burden. 2022Although we have not found any definitions of “jointly interested,” an “interested party” is one who possesses “a personal claim, status, or right which is capable of being affected.” Underground Contractors Ass’n v. City of Chicago, 66 Ill. 2d 371, 375-76 (1977). | 5 | 38 |
People v. Bannistergreen2 sentences2025Here, however, defendant does not argue the evidence was insufficient, and he specifically asks for a retrial. “ ‘It is firmly established that the constitutional right to not be twice put in jeopardy for the same offense is a personal privilege which may be forfeited.’ ” Id. (quoting People v. Bannister, 378 Ill. 2023“It is firmly established that the constitutional right to not be twice put in jeopardy for the same offense is a personal privilege which may be forfeited.” People v. Bannister, 378 Ill. | 4 | 4 |
Messenger v. Edgargreen2 sentences2014App. 3d 404, 406 (1987). " '[I]nterested' does not mean merely having a curiosity about or a concern for the outcome of the controversy [citation]; rather, the party requesting the declaration must possess a personal claim, status, or right that is capable of being affected by the grant of such relief [citation]." Messenger v. Edgar, 157 Ill. 2d at 171 . ¶ 34 The Commission has relied on these basic principles regarding declaratory relief in its interpretation of section 200.220(a). 2014App. 3d 404, 406 (1987). " '[I]nterested' does not mean merely having a curiosity about or a concern for the outcome of the controversy [citation]; rather, the party requesting the declaration must possess a personal claim, status, or right that is capable of being affected by the grant of such relief [citation]." Messenger v. Edgar, 157 Ill. 2d at 171 . ¶ 34 The Commission has relied on these basic principles regarding declaratory relief in its interpretation of section 200.220(a). | 2 | 9 |
Greer v. Illinois Housing Development Authoritygreen2 sentences1994(See 735 ILCS 5/2-701 (West 1992) (standing to pursue declaratory judgment action).) To be "interested," one "must possess a personal claim, status, or right which is capable of being affected. [Citations.]" Underground Contractors Association v. City of Chicago (1977), 66 Ill.2d 371, 376 , 5 Ill.Dec. 827 , 362 N.E.2d 298 ; see also Greer v. Illinois Housing Development Authority (1988), 122 Ill.2d 462, 492-93 , 120 Ill.Dec. 531 , 524 N.E.2d 561 . 1994(See 735 ILCS 5/2— 701 (West 1992) (standing to pursue declaratory judgment action).) To be "interested,” one "must possess a personal claim, status, or right which is capable of being affected. [Citations.]” Underground Contractors Association v. City of Chicago (1977), 66 Ill. 2d 371, 376 ; see also Greer v. Illinois Housing Development Authority (1988), 122 Ill. 2d 462, 492-93 . | 2 | 7 |
Weinstein v. Daleygreen2 sentences2013See Weinstein v. Daley, 85 Ill. 1978App. 2d 470 , 229 N.E.2d 357 , the court reviewed the policy considerations underlying the discretion vested in local liquor control commissioners by the Act: “A license is purely, a personal privilege to do what would otherwise be unlawful and hence carries with it no vested property right. [Citations.] The provisions of the Dram Shop Act are to be liberally construed to the end that the health, safety, and welfare of the people of the state shall be protected. | 2 | 3 |
Harris Bank of Roselle v. Village of Mettawagreen2 sentences2023Harris Bank of Roselle, 243 Ill. 2023See Harris Bank of Roselle, 243 Ill. | 2 | 2 |
Scachitti v. UBS Financial Servicesgreen2 sentences2020(West 2016)), which is a qui tam statute that confers standing on a relator to sue for fraud resulting in pecuniary injury to the State (Scachitti v. UBS Financial Services, 215 Ill. 2d 484, 508 (2005)). ¶4 The meaning of “interested person” and the nonpecuniary nature of the State’s interest present two questions in this appeal regarding a relator’s standing to sue under the Act: (1) whether a relator must have a personal claim, status, or right related to the qui tam action to qualify as an “interested person” and (2) whether a relator may bring a claim on behalf of the State for a violation 2020(West 2016)), which is a qui tam statute that confers standing on a relator to sue for fraud resulting in pecuniary injury to the State (Scachitti v. UBS Financial Services, 215 Ill. 2d 484, 508 (2005)). ¶4 The meaning of “interested person” and the nonpecuniary nature of the State’s interest present two questions in this appeal regarding a relator’s standing to sue under the Act: (1) whether a relator must have a personal claim, status, or right related to the qui tam action to qualify as an “interested person” and (2) whether a relator may bring a claim on behalf of the State for a violation | 2 | 2 |
| People v. Minkgreen | 2 | 2 |
| Vanderbilt v. Vanderbiltgreen | 2 | 2 |
| Martin-Trigona v. Roderickgreen | 2 | 2 |
| People v. Homesgreen | 2 | 2 |
| Forsberg v. City of Chicagogreen | 2 | 2 |
| Seymour v. O. S. Richardson Fueling Co.green | 2 | 2 |
cluster 496608green2 sentences1998Koch Refining, 831 F.2d at 1348-49 . 1994A general claim, according to the court, is a claim common to all the creditors which could be asserted by any one of them, while a personal claim is one which is had only by specific creditors. ( Koch Refining, 831 F.2d at 1349 .) The Koch Refining court found the alter ego claim there to be a general claim and thus properly brought by the trustee pursuant to his creditor status. | 1 | 5 |
Couch v. United Statesgreen2 sentences2002In Couch v. United States, 409 U.S. 322, 329 , 93 S.Ct. 611, 616 , 34 L.Ed.2d 548 (1973), they held: "It is important to reiterate that the Fifth Amendment privilege is a personal privilege: it adheres basically to the person, not to information that may incriminate him. 2002Ed. 2d 548, 554 , 93 S. Ct. 611, 616 (1973), it held: “It is important to reiterate that the Fifth Amendment privilege is a personal privilege: it adheres basically to the person, not to information that may incriminate him. | 1 | 4 |
Outboard Marine Corp. v. Liberty Mutual Insurancegreen2 sentences2018Outboard Marine Corp. v. Liberty Mutual Insurance Co., 154 Ill. 2d 90, 102 (1992). ¶ 16 The “ ‘widely recognized tort’ ” of tortious interference with testamentary expectancy does not contest the validity of the will; it is a personal claim against an individual tortfeasor. 2017Outboard Marine Corp. v. Liberty Mutual Insurance Co. , 154 Ill. 2d 90 , 102, 180 Ill.Dec. 691 , 607 N.E.2d 1204 (1992). ¶ 16 The " 'widely recognized tort' " of tortious interference with testamentary expectancy does not contest the validity of the will; it is a personal claim against an individual tortfeasor. | 1 | 2 |
Shriners Hospitals for Children v. Baumangreen2 sentences2018In re Estate of Ellis, 236 Ill. 2d 45, 52 (2009). 2017In re Estate of Ellis , 236 Ill. 2d 45 , 52, 337 Ill.Dec. 678 , 923 N.E.2d 237 (2009). | 1 | 2 |
Evanston Hospital v. Cranegreen2 sentences2018Evanston Hospital v. Crane, 254 Ill. 2017Evanston Hospital v. Crane , 254 Ill. | 1 | 2 |
| Johnson v. United Statesgreen | 1 | 2 |
| Allstate Insurance Co. v. Elkinsgreen | 1 | 2 |
| First of America Bank-Northeast Illinois, N.A. v. Bociangreen | 1 | 1 |
| Mendez v. City of Chicagogreen | 1 | 1 |
| People v. Jaudongreen | 1 | 1 |
| People v. Jenningsgreen | 1 | 1 |
| Bank of New York Mellon v. Deanegreen | 1 | 1 |
| People v. Oliveragreen | 1 | 1 |
| United States v. Sorrentinogreen | 1 | 1 |
| Kluk v. Langgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Illinois Gamefowl Breeders Ass'n v. Block
green
2 sentences2004Rather, the party seeking relief must possess a personal claim, status, or right which is capable of being affected."'" Flynn, 199 Ill.2d at 437 , 264 Ill.Dec. 710 , 771 N.E.2d at 418 , quoting Gamefowl Breeders, 75 Ill.2d at 450-51 , 27 Ill.Dec. 465 , 389 N.E.2d 529 . 2004Rather, the party seeking relief must possess a personal claim, status, or right which is capable of being affected."'" Flynn, 199 Ill.2d at 437 , 264 Ill.Dec. 710 , 771 N.E.2d at 418 , quoting Gamefowl Breeders, 75 Ill.2d at 450-51 , 27 Ill.Dec. 465 , 389 N.E.2d 529 . | 11 | 1981–2004 |
Commercial Casualty Insurance v. Consolidated Stone Co.
green
2 sentences2014But the locality of a lawsuit–the place where judicial authority may be exercised–though defined by legislation relates to the convenience of the litigants and as such is subject to their disposition.’ (Emphasis supplied.) The Court further stated that venue is a personal privilege conferred by statute and may be asserted or waived at the litigant’s election, citing Commercial Casualty Insurance Co. v. Consolidated Stone Co. (1929), 278 U.S. 177, 179 . 2014But the locality of a lawsuit–the place where judicial authority may be exercised–though defined by legislation relates to the convenience of the litigants and as such is subject to their disposition.’ (Emphasis supplied.) The Court further stated that venue is a personal privilege conferred by statute and may be asserted or waived at the litigant’s election, citing Commercial Casualty Insurance Co. v. Consolidated Stone Co. (1929), 278 U.S. 177, 179 . | 4 | 1975–2014 |
Sharma v. Zollar
green
2 sentences2003Second, the party seeking the declaration must be interested in the controversy and must possess a personal claim, status or right which is capable of being affected. [Citations.] To have standing, one must have sustained, or be in immediate danger of sustaining, a direct injury. [Citation.] The actual controversy requirement of standing cannot be satisfied where the underlying issues of the case are moot or premature. [Citation.] An issue is considered moot where events occur which make it impossible for the court to grant effectual relief. [Citations.] When it becomes apparent that an opinio 2003Second, the party seeking the declaration must be interested in the controversy and must possess a personal claim, status or right which is capable of being affected. [Citations.] To have standing, one must have sustained, or be in immediate danger of sustaining a direct injury. [Citation.] The actual controversy requirement of standing cannot be satisfied where the underlying issues of the case are moot or premature. [Citation.] An issue is considered moot where events occur which make it impossible for the court to grant effectual relief. [Citations.] When it becomes apparent that an opinion | 4 | 2003–2008 |
People v. Davis
green
2 sentences2007The supreme court held that the order was merely voidable because double jeopardy is “a personal privilege which may be waived.” Davis, 156 Ill. 2d at 157 . 2007The supreme court held that the order was merely voidable because double jeopardy is "a personal privilege which may be waived." Davis, 156 Ill.2d at 157 , 189 Ill.Dec. 49 , 619 N.E.2d 750 . | 4 | 2002–2007 |
Flynn v. Ryan
green
2 sentences2004Rather, the party seeking relief must possess a personal claim, status, or right which is capable of being affected."'" Flynn, 199 Ill.2d at 437 , 264 Ill.Dec. 710 , 771 N.E.2d at 418 , quoting Gamefowl Breeders, 75 Ill.2d at 450-51 , 27 Ill.Dec. 465 , 389 N.E.2d 529 . 2004Rather, the party seeking relief must possess a personal claim, status, or right which is capable of being affected."'" Flynn, 199 Ill.2d at 437 , 264 Ill.Dec. 710 , 771 N.E.2d at 418 , quoting Gamefowl Breeders, 75 Ill.2d at 450-51 , 27 Ill.Dec. 465 , 389 N.E.2d 529 . | 4 | 2004–2005 |
People v. Adams
green
2 sentences2002Adams, 283 Ill.App.3d at 524 , 218 Ill.Dec. 805 , 669 N.E.2d 1331 ." People v. DeSantis, 319 Ill.App.3d 795, 801-02 , 253 Ill.Dec. 227 , 745 N.E.2d 1 (2001). 2002Adams, 283 Ill. | 4 | 2000–2002 |
Cable Television & Communications Ass'n v. Ameritech Corp.
green
2 sentences2001An association does not have standing to sue on behalf of its members, even those members allegedly affected by the challenged action, “unless it has been or will be directly injured and therefore has a personal claim related to its own property, or that it has suffered or will suffer injury to a substantive legally protected interest in its individual capacity.” Cable Television & Communications Ass’n of Illinois v. Ameritech Corp., 288 Ill. 2001An association does not have standing to sue on behalf of its members, even those members allegedly affected by the challenged action, "unless it has been or will be directly injured and therefore has a personal claim related to its own property, or that it has suffered or will suffer injury to a substantive legally protected interest in its individual capacity." Cable Television & Communications Ass'n of Illinois v. Ameritech Corp. , 288 Ill. | 4 | 1999–2001 |
People v. Murrell
green
2 sentences1984However, the court in French did not discuss our supreme court’s decision in People v. Murrell (1975), 60 Ill. 2d 287 , which held that defense counsel’s statement waiving the defendant’s right to a jury trial in defendant’s presence constitutes a valid jury waiver. ( 60 Ill. 2d 287, 290-92 .) Although a personal waiver by the defendant is preferred, it is not constitutionally required, nor do the rules or statutes mandate it. ( 60 Ill. 2d 287, 291 .) As in Murrell, defendant has not argued that he wanted or that he was deprived of a jury trial. 1984However, the court in French did not discuss our supreme court’s decision in People v. Murrell (1975), 60 Ill. 2d 287 , which held that defense counsel’s statement waiving the defendant’s right to a jury trial in defendant’s presence constitutes a valid jury waiver. ( 60 Ill. 2d 287, 290-92 .) Although a personal waiver by the defendant is preferred, it is not constitutionally required, nor do the rules or statutes mandate it. ( 60 Ill. 2d 287, 291 .) As in Murrell, defendant has not argued that he wanted or that he was deprived of a jury trial. | 4 | 1977–1984 |
Arnold Chapman v. First Index, Incorporated
green
2 sentences2021Id. at 786 . ¶ 32 On appeal, the Chapman court acknowledged that “many courts, [the Seventh Circuit] included, have applied the label ‘moot’ when a plaintiff declines an offer that would satisfy his entire demand.” Id. 2021Id. at 786 . ¶ 32 On appeal, the Chapman court acknowledged that “many courts, [the Seventh Circuit] included, have applied the label ‘moot’ when a plaintiff declines an offer that would satisfy his entire demand.” Id. | 3 | 2020–2021 |
Village of Chatham v. County of Sangamon
green
2 sentences2013Rather, the party seeking relief must possess a personal claim, status, or right which is capable of being affected. [Citations.] The dispute must, therefore, touch the legal relations of parties who stand in a position adverse to one another.’ ” Village of Chatham, 216 Ill. 2d at 420 (quoting Underground Contractors Ass’n v. City of Chicago, 66 Ill. 2d 371, 375-76 (1977)). ¶ 11 All parties acknowledge that the assistant Public Access Counselor’s letter is a nonbinding opinion. 2009Rather, the party seeking relief must possess a personal claim, status, or right which is capable of being affected. [Citations.] The dispute must, therefore, touch the legal relations of parties who stand in a position adverse to one another.’ ” (Emphasis added.) Village of Chatham, 216 Ill. 2d at 420 , quoting Underground Contractors Ass’n v. City of Chicago, 66 Ill. 2d 371, 375-376 (1977). | 3 | 2009–2013 |
Humphries v. District of Columbia
green
2 sentences2007Such jurisdiction is not defined by the propriety of the court's judgments. `There are many rights belonging to litigants-rights which a court may not properly deny, and yet which if denied do not oust the jurisdiction or render *685 the proceedings absolutely null and void.' ( Humphries v. District of Columbia (1899), 174 U.S. 190, 194 , 19 S.Ct. 637, 639 , 43 L.Ed. 944, 945 .) Significantly, this court has held that the constitutional right to not be twice put in jeopardy for the same offense is a personal privilege which may be waived. 2007Such jurisdiction is not defined by the propriety of the court's judgments. `There are many rights belonging to litigants-rights which a court may not properly deny, and yet which if denied do not oust the jurisdiction or render *685 the proceedings absolutely null and void.' ( Humphries v. District of Columbia (1899), 174 U.S. 190, 194 , 19 S.Ct. 637, 639 , 43 L.Ed. 944, 945 .) Significantly, this court has held that the constitutional right to not be twice put in jeopardy for the same offense is a personal privilege which may be waived. | 3 | 1993–2007 |
People v. Wilson
green
2 sentences1950(Foster v. Illinois, 332 U.S. 134 ; Betts v. Brady, 316 U.S. 455 ; People v. Wilson, 399 Ill. 437 .) In short, where the record in a non-capital case, as here, is silent and does not show that the accused.states, upon oath, that he was indigent and asked that counsel be appointed, he is deemed to have waived a personal privilege and has not been denied a constitutional right, and, in particular, he has not been denied due process of law. 1949Stat. 1943, chap. 38, par. 730,) the court is required to provide counsel for defendant only when he shall state on oath that he is unable to procure counsel, and in People v. Ross, 400 Ill. 237 , referring to the case of People v. Wilson, 399 Ill. 437 , we pointed out that, in noncapital cases where the record is silent and the accused did not on oath state that he was indigent and ask that counsel be appointed, he may be considered "to have waived a personal privilege and he has not been denied a constitutional right, nor has he been denied due process of law. | 3 | 1948–1950 |
Hem v. Allen
neutral
2 sentences1943In Seymour v. Richardson Fueling Co., 205 Ill. 77, 83, 84 , it is said: ‘The rule that, where a money judgment is a unit as to all the defendants, the judgment must be against all or none, does not apply where a personal defense (such as a discharge in bankruptcy) is established as to one or more of the defendants.’ And in Hem v. Allen, 179 Ill. 1934In Seymour v. Richardson Fueling Co., 205 Ill. 77, 83, 84 , it is said: “The rule that, where a money judgment is a unit as to all the defendants, the judgment must be against all or none, does not apply where a personal defense (such as a discharge in bankruptcy) is established as to one or more of the defendants.” And in Hem v. Allen, 179 Ill. | 3 | 1917–1943 |
Howard G. Reamer v. George Beall, United States Attorney, and James M. Kramon, Assistant Unitedstates Attorney
green
2 sentences2021Id. ¶ 44 In Reamer v. Beall, 506 F.2d 1345 (4th Cir. 1974) (per curiam), cert. denied, 420 U.S. 955 (1975), the sole employee and stockholder of a professional corporation was found in contempt for failing to obey a jury subpoena for the production of certain corporate records. 2021Id. - 16 - No. 1-20-0584 ¶ 44 In Reamer v. Beall, 506 F.2d 1345 (4th Cir. 1974) (per curiam), cert. denied, 420 U.S. 955 (1975), the sole employee and stockholder of a professional corporation was found in contempt for failing to obey a jury subpoena for the production of certain corporate records. | 2 | 2021–2021 |
Reamer v. Beall
green
2 sentences2021Id. ¶ 44 In Reamer v. Beall, 506 F.2d 1345 (4th Cir. 1974) (per curiam), cert. denied, 420 U.S. 955 (1975), the sole employee and stockholder of a professional corporation was found in contempt for failing to obey a jury subpoena for the production of certain corporate records. 2021Id. - 16 - No. 1-20-0584 ¶ 44 In Reamer v. Beall, 506 F.2d 1345 (4th Cir. 1974) (per curiam), cert. denied, 420 U.S. 955 (1975), the sole employee and stockholder of a professional corporation was found in contempt for failing to obey a jury subpoena for the production of certain corporate records. | 2 | 2021–2021 |
State of Illinois ex rel. Leibowitz v. Family Vision Care, LLC
green
2 sentences2020The court held (1) a former employee- whistleblower with personal, nonpublic information of possible wrongdoing qualifies as an “interested person” under the Act and need not allege a personal claim, status, or right related to the proceedings and (2) the State need not suffer -2- money damages to partially assign its claim to a relator under the Act. 2019 IL App (1st) 180697 , ¶¶ 30, 37. 2020The court held (1) a former employee- whistleblower with personal, nonpublic information of possible wrongdoing qualifies as an “interested person” under the Act and need not allege a personal claim, status, or right related to the proceedings and (2) the State need not suffer -2- money damages to partially assign its claim to a relator under the Act. 2019 IL App (1st) 180697 , ¶¶ 30, 37. | 2 | 2020–2020 |
Sinoying Logistics Pte Ltd. v. Yi Da Xin Trading Corporation
green
2 sentences2017Sinoying, 619 F.3d 207, 213-14 . ¶ 40 We believe Illinois courts have a similar responsibility and conclude that the trial court acted appropriately when it sua sponte raised the issue of personal jurisdiction over Quezada. 2017Sinoying, 619 F.3d at 213-14 . ¶ 40 We believe Illinois courts have a similar responsibility and conclude that the trial court acted appropriately when it sua sponte raised the issue of personal jurisdiction over Quezada. | 2 | 2017–2017 |
| People v. Brown green | 2 | 2016–2016 |
| Colorcraft Corp. v. Department of Revenue green | 2 | 2013–2013 |
| Markus v. Chicago Title & Trust Co. green | 2 | 2007–2007 |
| People v. Dieterman green | 2 | 2007–2007 |
| People v. Woodall green | 2 | 2003–2004 |
| Kerr Steamship Co. v. Chicago Title & Trust Co. green | 2 | 2001–2001 |
| Hines v. Dresser Industries, Inc. green | 2 | 1999–1999 |
| First of America Bank, Rockford, N.A. v. Netsch green | 2 | 1998–1998 |
| In Re Estate of Longeway green | 2 | 1994–1994 |
| Welsh v. Estate of Welsh neutral | 2 | 1989–1989 |
| Peaslee Gaulbert Paint & Varnish Co. v. Lumpkin neutral | 2 | 1989–1989 |
| The People v. Liechron green | 2 | 1960–1989 |
| Conley v. Rust green | 2 | 1975–1989 |
| McCarthy v. United States green | 2 | 1974–1984 |
| Hoyt v. McLaughlin neutral | 2 | 1975–1977 |
| Nechi v. Daley green | 2 | 1967–1975 |
| Boerner v. Thompson neutral | 2 | 1966–1967 |
| Great Atlantic & Pacific Tea Co. v. Mayor of Danville green | 2 | 1963–1966 |
| Auditor General v. Board of Supervisors green | 2 | 1956–1956 |
| Cartwright v. Cartwright neutral | 2 | 1905–1937 |
| Sparhawk v. Yerkes green | 2 | 1923–1923 |
| Byers v. First National Bank neutral | 2 | 1880–1883 |
| Rowe v. Raoul green | 1 | 2025–2025 |
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.
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.