adjudication claim (Connecticut) · Go Syfert
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adjudication claim in Connecticut

32 Connecticut opinions name it 3 courts 1988–2024 1 in the last five years

The cases below were cited by Connecticut 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 (14)

CaseFollowedCited
State v. Salmongreen
conn · 1999 · cited in 3 Connecticut opinions naming this issue, 2001–2009
2 sentences

2009“An otherwise interlocutory order is appealable in two circumstances: (1) where the order or action terminates a separate and distinct proceeding, or (2) where the order or action so concludes the rights of the parties that further proceedings cannot affect them.” Id., 31 . “[T]he Curcio standard precludes any provisional, tentative or conditional adjudication, and it focuses on the completion of all steps necessary for the adjudication of the claim, short of execution or enforcement.” CFM of Connecticut, Inc. v. Chowdhury, 239 Conn. 375, 400 , 685 A.2d 1108 (1996), overruled in part on other

2009“An otherwise interlocutory order is appealable in two circumstances: (1) where the order or action terminates a separate and distinct proceeding, or (2) where the order or action so concludes the rights of the parties that further proceedings cannot affect them.” Id., 31 . “[T]he Curcio standard precludes any provisional, tentative or conditional adjudication, and it focuses on the completion of all steps necessary for the adjudication of the claim, short of execution or enforcement.” CFM of Connecticut, Inc. v. Chowdhury, 239 Conn. 375, 400 , 685 A.2d 1108 (1996), overruled in part on other

23
Bricklin v. Stengol Corp.green
conn · 1984 · cited in 2 Connecticut opinions naming this issue, 1988–1996
2 sentences

1996Prior to 1988 "[t]here [were] only three ways to establish an employer's liability: first, by the CT Page 8716 employer's failure to contest liability within twenty days of receiving notice of the injury as required by General Statutes § 31-297 (b); see Bush v. Quality Bakers of America, 2 Conn. App. 363 , 479 A.2d 820 , cert. denied, 194 Conn. 804 , 482 A.2d 709 (1984), and cases cited therein; second, by the commissioner's approval of a written voluntary agreement entered into by the employer and employee pursuant to General Statutes § 31-296 ; and third, where the employer contests liabilit

1988There are only three ways to fix an employer’s liability: first, by the employer’s failure to contest liability within twenty days of receiving notice of the injury as required by General Statutes § 31-297 (b); see Bush v. Quality Bakers of America, 2 Conn. App. 363, 479 A.2d 820 , cert, denied, 194 Conn. 804 , 482 A.2d 709 (1984), and cases cited therein; second, by the commissioner’s approval of a written voluntary agreement entered into by the employer and employee pursuant to General Statutes § 31-296; and third, where the employer contests liability and the parties fail to reach an agreem

22
Filipetti v. Filipettigreen
conn · 1984 · cited in 2 Connecticut opinions naming this issue, 1988–1996
2 sentences

1996Prior to 1988 "[t]here [were] only three ways to establish an employer's liability: first, by the CT Page 8716 employer's failure to contest liability within twenty days of receiving notice of the injury as required by General Statutes § 31-297 (b); see Bush v. Quality Bakers of America, 2 Conn. App. 363 , 479 A.2d 820 , cert. denied, 194 Conn. 804 , 482 A.2d 709 (1984), and cases cited therein; second, by the commissioner's approval of a written voluntary agreement entered into by the employer and employee pursuant to General Statutes § 31-296 ; and third, where the employer contests liabilit

1988There are only three ways to fix an employer’s liability: first, by the employer’s failure to contest liability within twenty days of receiving notice of the injury as required by General Statutes § 31-297 (b); see Bush v. Quality Bakers of America, 2 Conn. App. 363, 479 A.2d 820 , cert, denied, 194 Conn. 804 , 482 A.2d 709 (1984), and cases cited therein; second, by the commissioner’s approval of a written voluntary agreement entered into by the employer and employee pursuant to General Statutes § 31-296; and third, where the employer contests liability and the parties fail to reach an agreem

22
Bush v. Quality Bakers of Americagreen
connappct · 1984 · cited in 2 Connecticut opinions naming this issue, 1988–1996
2 sentences

1996Prior to 1988 "[t]here [were] only three ways to establish an employer's liability: first, by the CT Page 8716 employer's failure to contest liability within twenty days of receiving notice of the injury as required by General Statutes § 31-297 (b); see Bush v. Quality Bakers of America, 2 Conn. App. 363 , 479 A.2d 820 , cert. denied, 194 Conn. 804 , 482 A.2d 709 (1984), and cases cited therein; second, by the commissioner's approval of a written voluntary agreement entered into by the employer and employee pursuant to General Statutes § 31-296 ; and third, where the employer contests liabilit

1996Prior to 1988 "[t]here [were] only three ways to establish an employer's liability: first, by the CT Page 8716 employer's failure to contest liability within twenty days of receiving notice of the injury as required by General Statutes § 31-297 (b); see Bush v. Quality Bakers of America, 2 Conn. App. 363 , 479 A.2d 820 , cert. denied, 194 Conn. 804 , 482 A.2d 709 (1984), and cases cited therein; second, by the commissioner's approval of a written voluntary agreement entered into by the employer and employee pursuant to General Statutes § 31-296 ; and third, where the employer contests liabilit

22
Whipple v. Fullergreen
conn · 1836 · cited in 2 Connecticut opinions naming this issue, 1991–1994
2 sentences

1994Whipple v. Fuller, 11 Conn. 582, 586 (1836).” DeLaurentis v. New Haven, supra, 220 Conn. 256 n.16 .

1991Whipple v. Fuller, 11 Conn. 582, 586 (1836).

22
Mora v. Aetna Life & Casualty Insurancegreen
connappct · 1988 · cited in 4 Connecticut opinions naming this issue, 1993–1998
2 sentences

1996"There are only three ways to establish an employer's liability: first, by the employer's failure to contest liability within twenty days of receiving notice of the injury as required by General Statutes § 31-297 (b); . . . second, by the commissioner's approval of a written voluntary agreement entered into by the employer and employee pursuant to General Statutes § 31-296 ; and third, where the employer contests liability and the parties fail to reach an agreement, by the adjudication of the claim by the workers' compensation commissioner and the granting of an award to the plaintiff." (Citat

1996"There are only three ways to establish an employer's liability: first, by the employer's failure to contest liability within twenty days of receiving notice of the injury as required by General Statutes § 31-297 (b); . . . second, by the commissioner's approval of a written voluntary agreement entered into by the employer and employee pursuant to General Statutes § 31-296 ; and third, where the employer contests liability and the parties fail to reach an agreement, by the adjudication of the claim by the workers' compensation commissioner and the granting of an award to the plaintiff." (Citat

14
CFM of Connecticut, Inc. v. Chowdhurygreen
conn · 1996 · cited in 3 Connecticut opinions naming this issue, 1997–2009
2 sentences

2009“An otherwise interlocutory order is appealable in two circumstances: (1) where the order or action terminates a separate and distinct proceeding, or (2) where the order or action so concludes the rights of the parties that further proceedings cannot affect them.” Id., 31 . “[T]he Curcio standard precludes any provisional, tentative or conditional adjudication, and it focuses on the completion of all steps necessary for the adjudication of the claim, short of execution or enforcement.” CFM of Connecticut, Inc. v. Chowdhury, 239 Conn. 375, 400 , 685 A.2d 1108 (1996), overruled in part on other

2009“An otherwise interlocutory order is appealable in two circumstances: (1) where the order or action terminates a separate and distinct proceeding, or (2) where the order or action so concludes the rights of the parties that further proceedings cannot affect them.” Id., 31 . “[T]he Curcio standard precludes any provisional, tentative or conditional adjudication, and it focuses on the completion of all steps necessary for the adjudication of the claim, short of execution or enforcement.” CFM of Connecticut, Inc. v. Chowdhury, 239 Conn. 375, 400 , 685 A.2d 1108 (1996), overruled in part on other

13
State v. Wellsgreen
connappct · 2009 · cited in 1 Connecticut opinions naming this issue, 2010–2010
2 sentences

2010Thus, although the Appellate Court was correct that the trial court’s unchallenged finding regarding the defendant’s possession of narcotics provided a sufficient basis for an adjudication of a violation of probation, irrespective of whether the defendant had committed the assault; see State v. Wells, 112 Conn. App. 147, 156 , 962 A.2d 810 (2009); the Appellate Court failed to recognize that the defendant’s briefing on those claims also addressed the dispositional phase of the violation of probation proceeding. 3 See State v. Preston, 286 Conn. 367, 375-76 , 944 A.2d 276 (2008) (“[Revocation o

2010Thus, although the Appellate Court was correct that the trial court’s unchallenged finding regarding the defendant’s possession of narcotics provided a sufficient basis for an adjudication of a violation of probation, irrespective of whether the defendant had committed the assault; see State v. Wells, 112 Conn. App. 147, 156 , 962 A.2d 810 (2009); the Appellate Court failed to recognize that the defendant’s briefing on those claims also addressed the dispositional phase of the violation of probation proceeding. 3 See State v. Preston, 286 Conn. 367, 375-76 , 944 A.2d 276 (2008) (“[Revocation o

11
State v. Gordongreen
conn · 1981 · cited in 1 Connecticut opinions naming this issue, 2005–2005
2 sentences

2005See State v. Gordon, 185 Conn. 402, 414-15 , 441 A.2d 119 (1981), cert. denied, 455 U.S. 989 , 102 S. Ct. 1612 , 71 L.

2005See State v. Gordon, 185 Conn. 402, 414-15 , 441 A.2d 119 (1981), cert. denied, 455 U.S. 989 , 102 S. Ct. 1612 , 71 L.

11
Leicht v. Floridagreen
scotus · 1982 · cited in 1 Connecticut opinions naming this issue, 2005–2005
1 sentence

2005See State v. Gordon, 185 Conn. 402, 414-15 , 441 A.2d 119 (1981), cert. denied, 455 U.S. 989 , 102 S. Ct. 1612 , 71 L.

11
Siegel v. United Statesgreen
scotus · 1982 · cited in 1 Connecticut opinions naming this issue, 2005–2005
1 sentence

2005See State v. Gordon, 185 Conn. 402, 414-15 , 441 A.2d 119 (1981), cert. denied, 455 U.S. 989 , 102 S. Ct. 1612 , 71 L.

11
State v. Johnsongreen
connappct · 1987 · cited in 1 Connecticut opinions naming this issue, 2002–2002
2 sentences

2002See State v. Johnson, 11 Conn. App. 251, 256 , 527 A.2d 250 (1987) (“[Probation revocation is a blemish on [the defendant’s] prison record which will affect his job opportunities and his standing in the community because it connotes wrongdoing and intractability and is ‘a burden analogous and in addition to his criminal stigma.

2002See State v. Johnson, 11 Conn. App. 251, 256 , 527 A.2d 250 (1987) (“[Probation revocation is a blemish on [the defendant’s] prison record which will affect his job opportunities and his standing in the community because it connotes wrongdoing and intractability and is ‘a burden analogous and in addition to his criminal stigma.

11
Orsi v. Senatoregreen
conn · 1994 · cited in 1 Connecticut opinions naming this issue, 2001–2001
2 sentences

2001See id.; see also Orsi v. Senatore, 230 Conn. 459, 469-70 , 645 A.2d 986 (1994) (remanding to trial court to determine standing of foster parent to file declaratory judgment action on behalf of minor child represented by court-appointed guardian).

2001See id.; see also Orsi v. Senatore, 230 Conn. 459, 469-70 , 645 A.2d 986 (1994) (remanding to trial court to determine standing of foster parent to file declaratory judgment action on behalf of minor child represented by court-appointed guardian).

11
Coollick v. Town of Windhamgreen
connappct · 1986 · cited in 1 Connecticut opinions naming this issue, 1988–1988
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (18)

CaseCitedYears
New Haven Savings Bank v. LaPlace green
conn · 2001
2 sentences

2019Thus, res judicata may operate to preclude a claim decided in a previous proceeding within the same case.... [F]or purposes of res judicata, a judgment will ordinarily be considered final if it is not tentative, provisional, or contingent and represents the completion of all steps in the adjudication of the claim by the court, short of any steps by way of execution or enforcement that may be consequent upon the particular kind of adjudication." (Citations omitted; internal quotation marks omitted.) Honan v. Dimyan , 63 Conn. App. 702 , 707-708, 778 A.2d 989 , cert. denied, 258 Conn. 942 , 786

2018Thus, res judicata may operate to preclude a claim decided in a previous proceeding within the same case.... [F]or purposes of res judicata, a judgment will ordinarily be considered final if it is not tentative, provisional, or contingent and represents the completion of all steps in the adjudication of the claim by the court, short of any steps by way of execution or enforcement that may be consequent upon the particular kind of adjudication." (Citations omitted; internal quotation marks omitted.) Honan v. Dimyan , 63 Conn. App. 702 , 706-708, 778 A.2d 989 , cert. denied, 258 Conn. 942 , 786

32007–2019
Honan v. Dimyan green
conn · 2001
2 sentences

2019Thus, res judicata may operate to preclude a claim decided in a previous proceeding within the same case.... [F]or purposes of res judicata, a judgment will ordinarily be considered final if it is not tentative, provisional, or contingent and represents the completion of all steps in the adjudication of the claim by the court, short of any steps by way of execution or enforcement that may be consequent upon the particular kind of adjudication." (Citations omitted; internal quotation marks omitted.) Honan v. Dimyan , 63 Conn. App. 702 , 707-708, 778 A.2d 989 , cert. denied, 258 Conn. 942 , 786

2018Thus, res judicata may operate to preclude a claim decided in a previous proceeding within the same case.... [F]or purposes of res judicata, a judgment will ordinarily be considered final if it is not tentative, provisional, or contingent and represents the completion of all steps in the adjudication of the claim by the court, short of any steps by way of execution or enforcement that may be consequent upon the particular kind of adjudication." (Citations omitted; internal quotation marks omitted.) Honan v. Dimyan , 63 Conn. App. 702 , 706-708, 778 A.2d 989 , cert. denied, 258 Conn. 942 , 786

32007–2019
Honan v. Dimyan green
connappct · 2001
2 sentences

2019Thus, res judicata may operate to preclude a claim decided in a previous proceeding within the same case.... [F]or purposes of res judicata, a judgment will ordinarily be considered final if it is not tentative, provisional, or contingent and represents the completion of all steps in the adjudication of the claim by the court, short of any steps by way of execution or enforcement that may be consequent upon the particular kind of adjudication." (Citations omitted; internal quotation marks omitted.) Honan v. Dimyan , 63 Conn. App. 702 , 707-708, 778 A.2d 989 , cert. denied, 258 Conn. 942 , 786

2019Thus, res judicata may operate to preclude a claim decided in a previous proceeding within the same case.... [F]or purposes of res judicata, a judgment will ordinarily be considered final if it is not tentative, provisional, or contingent and represents the completion of all steps in the adjudication of the claim by the court, short of any steps by way of execution or enforcement that may be consequent upon the particular kind of adjudication." (Citations omitted; internal quotation marks omitted.) Honan v. Dimyan , 63 Conn. App. 702 , 707-708, 778 A.2d 989 , cert. denied, 258 Conn. 942 , 786

32007–2019
DeLaurentis v. City of New Haven green
conn · 1991
2 sentences

1999Malice in this context means acting "for a purpose other than that of recovering the proper adjudication of the claim on which [the proceedings] are based." 3 Restatement (Second) Torts § 676; DeLaurentis v. New Haven , 220 Conn. 225 , f.n. 16 at 256.

1995Thus, in the context of a vexatious suit action, the defendant lacks probable cause if he lacks a reasonable, good faith belief in the facts alleged and the validity of the claim asserted." Furthermore, a defendant in a CT Page 2073 vexatious litigation suit is said to have acted with malice "if he acted primarily for an improper purpose; that is, for a purpose other than that of securing the proper adjudication of the claim on which [the proceedings] are based" (Internal quotation marks omitted.) Id., 256 n. 16.

31995–1999
State v. Curcio green
conn · 1983
2 sentences

2009“An otherwise interlocutory order is appealable in two circumstances: (1) where the order or action terminates a separate and distinct proceeding, or (2) where the order or action so concludes the rights of the parties that further proceedings cannot affect them.” Id., 31 . “[T]he Curcio standard precludes any provisional, tentative or conditional adjudication, and it focuses on the completion of all steps necessary for the adjudication of the claim, short of execution or enforcement.” CFM of Connecticut, Inc. v. Chowdhury, 239 Conn. 375, 400 , 685 A.2d 1108 (1996), overruled in part on other

1996State v. Curcio, 191 Conn. 27 , 463 A.2d 566 (1983), provides the standard by which to gauge the finality, for purposes of appeal, of an order like that of Judge Susco.

21996–2009
Board of Education v. State Board of Education green
conn · 1998
2 sentences

2001Board of Education v. State Board of Education, 243 Conn. 772, 778 , 709 A.2d 510 (1998).

2001Board of Education v. State Board of Education, 243 Conn. 772, 778 , 709 A.2d 510 (1998).

22001–2001
Northeast Building Supply, LLC v. Morrill green
connappct · 2024
1 sentence

2024As com- ment (c) to § 674 of the Restatement explains, ‘‘one who continues a civil proceeding that has properly been begun or one who takes an active part in its continuation east Building Supply, LLC v. Morrill, 224 Conn. App. 137 , 154 n.9, 312 A.3d 138 (2024). 17 The elements of a claim for wrongful use of civil proceedings under § 674 of the Restatement (Second) of Torts are similar to those of the tort of vexatious litigation.

12024–2024
In the Interest of: N.C., Appeal of: Commonwealth green
pa · 2014
2 sentences

2019Although the victim, who was four years old at the time of the adjudication hearing, was found competent by the juvenile court to testify; id., at 480 , 105 A.3d 1199 ; she was unable on direct examination to verbalize any responses to questions about the juvenile or his alleged contacts with her, although she did nod or shake her head in response to a few preliminary questions.

2019Although the victim, who was four years old at the time of the adjudication hearing, was found competent by the juvenile court to testify; id., at 480 , 105 A.3d 1199 ; she was unable on direct examination to verbalize any responses to questions about the juvenile or his alleged contacts with her, although she did nod or shake her head in response to a few preliminary questions.

12019–2019
State v. Preston green
conn · 2008
2 sentences

2010Thus, although the Appellate Court was correct that the trial court’s unchallenged finding regarding the defendant’s possession of narcotics provided a sufficient basis for an adjudication of a violation of probation, irrespective of whether the defendant had committed the assault; see State v. Wells, 112 Conn. App. 147, 156 , 962 A.2d 810 (2009); the Appellate Court failed to recognize that the defendant’s briefing on those claims also addressed the dispositional phase of the violation of probation proceeding. 3 See State v. Preston, 286 Conn. 367, 375-76 , 944 A.2d 276 (2008) (“[Revocation o

2010Thus, although the Appellate Court was correct that the trial court’s unchallenged finding regarding the defendant’s possession of narcotics provided a sufficient basis for an adjudication of a violation of probation, irrespective of whether the defendant had committed the assault; see State v. Wells, 112 Conn. App. 147, 156 , 962 A.2d 810 (2009); the Appellate Court failed to recognize that the defendant’s briefing on those claims also addressed the dispositional phase of the violation of probation proceeding. 3 See State v. Preston, 286 Conn. 367, 375-76 , 944 A.2d 276 (2008) (“[Revocation o

12010–2010
Cayer Enterprises, Inc. v. DiMasi green
connappct · 2004
2 sentences

2007Put another way, “[application of the doctrine of res judicata requires that there be a previous judgment on the merits.” Cayer Enterprises, Inc. v. DiMasi, 84 Conn. App. 190, 193 , 852 A.2d 758 (2004).

2007Put another way, “[application of the doctrine of res judicata requires that there be a previous judgment on the merits.” Cayer Enterprises, Inc. v. DiMasi, 84 Conn. App. 190, 193 , 852 A.2d 758 (2004).

12007–2007
Mulligan v. Rioux green
conn · 1994
1 sentence

2003Malicious prosecution was not pursued in Collins because in all likelihood the malice component could not be established; in Mulligan v. Rioux , 229 Conn. 716 (1994), the court said: "In a malicious prosecution action, "the defendant is said to have acted with `malice' if he (or she) acted primarily for an improper CT Page 1059 purpose; that is, "for a purpose other than securing the proper adjudication of the claim on which (the proceedings) are based."' Id., p. 732.

12003–2003
In re Juvenile Appeal (83-CD) green
conn · 1983
2 sentences

1997ADJUDICATION The standard of proof in a temporary custody proceeding is a "fair preponderance of the evidence." In re Juvenile Appeal (83-CD), 189 Conn. 276 , 283 , 455 A.2d 1313 (1983).

1997ADJUDICATION The standard of proof in a temporary custody proceeding is a "fair preponderance of the evidence." In re Juvenile Appeal (83-CD), 189 Conn. 276 , 283 , 455 A.2d 1313 (1983).

11997–1997
Calfee v. Usman green
conn · 1992
1 sentence

1997Calfee v. Usman , 224 Conn. 29 , 37 (1992).

11997–1997
Rotz v. Middlesex Mutual Assurance Co., No. Cv930307488 (Jan. 27, 1995) neutral
connsuperct · 1995
1 sentence

1995Claims for intentional tort, bad faith and breach of contract against an insurer have been allowed only where the claimant alleged that the insurer's obligation to pay benefits arose pursuant to either a decision by the commissioner; Rotz v. Middlesex Mutual, 13 Conn. L.

11995–1995
In re Luis C. green
conn · 1989
11991–1991
State v. Golding green
conn · 1989
2 sentences

1991He nonetheless claims that he is entitled to an adjudication of this claim on the basis of State v. Evans, 165 Conn. 61 , 327 A.2d 576 (1973), and State v. Golding, 213 Conn. 233 , 567 A.2d 823 (1989).

1991He nonetheless claims that he is entitled to an adjudication of this claim on the basis of State v. Evans, 165 Conn. 61 , 327 A.2d 576 (1973), and State v. Golding, 213 Conn. 233 , 567 A.2d 823 (1989).

11991–1991
State v. Evans green
conn · 1973
2 sentences

1991He nonetheless claims that he is entitled to an adjudication of this claim on the basis of State v. Evans, 165 Conn. 61 , 327 A.2d 576 (1973), and State v. Golding, 213 Conn. 233 , 567 A.2d 823 (1989).

1991He nonetheless claims that he is entitled to an adjudication of this claim on the basis of State v. Evans, 165 Conn. 61 , 327 A.2d 576 (1973), and State v. Golding, 213 Conn. 233 , 567 A.2d 823 (1989).

11991–1991
Michaels v. York green
connsuperct · 1974
1 sentence

1991OPINION Since the original sentencing court was without authority to suspend the sentence after a part had been served and thereafter commit the petitioner to a period of probation, it follows that he could not thereafter be found in violation of such probation and returned to prison." "Because the original sentence in this case was fatally defective, any further commitment for violation of probation is illegal." Michaels v. York, 31 Conn. Sup. 350 , 352 (1974).

11991–1991

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 51-199 (5) USC § 42u.s.c.1983 (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

TX 377 (1911–2026) CA 175 (1893–2026) IL 138 (1896–2026) PA 135 (1851–2026) NE 90 (1897–2025) OH 81 (1923–2026) LA 76 (1976–2025) NC 61 (1906–2026) NY 56 (1886–2026) AZ 56 (1968–2026) AR 53 (1925–2024) MI 47 (1938–2025) UT 42 (1983–2025) MO 41 (1872–2025) KY 34 (1964–2026) GA 34 (1923–2023) CT 32 (1988–2024) OR 28 (1892–2024) KS 25 (1898–2026) MT 24 (1986–2025) ME 23 (1979–2026) IA 21 (1890–2023) OK 20 (1914–2023) MS 19 (1935–2023) IN 16 (1886–2016) WA 16 (1898–2021) AK 11 (2000–2023) NM 11 (1900–2023) RI 11 (1994–2020) TN 10 (1948–2026) WV 10 (1901–2026) FL 10 (1968–2025) SD 9 (1942–1993) MN 9 (1917–2015) VA 8 (1913–2018) NJ 7 (1957–2024) MA 7 (1938–2022) MD 7 (1978–2020) HI 7 (1986–2009) AL 7 (2002–2024) DC 5 (1990–2010) CO 5 (2007–2025) ND 4 (1994–2021) DE 4 (1959–2019) WY 2 (2018–2021) NV 2 (2016–2017) VT 2 (1980–2005) ID 2 (2014–2014)

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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