establishment clause (Wisconsin) · Go Syfert
← Wisconsin issues

establishment clause in Wisconsin

31 Wisconsin opinions name it 3 courts 1844–2020 0 in the last five years

The cases below were cited by Wisconsin 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
State v. Konrathgreen
wis · 1998 · cited in 4 Wisconsin opinions naming this issue, 2020–2020
2 sentences

2020Jackson v. Benson, 218 Wis. 2d 835 , 854 n.4, 578 N.W.2d 602 (1998); see also State v. Konrath, 218 Wis. 2d 290 , 305 n.15, 577 N.W.2d 601 (1998) ("[T]he United States Supreme Court has not consistently applied the 'no set of circumstances' language."). 11 No. 2019AP614-LV & 2019AP622.rfd ¶178 The majority claims this test is nonetheless appropriate as an exercise of judicial modesty that will avoid judicial overstepping into the legislature's prerogative.

2020Jackson v. Benson, 218 Wis. 2d 835 , 854 n.4, 578 N.W.2d 602 (1998); see also State v. Konrath, 218 Wis. 2d 290 , 305 n.15, 577 N.W.2d 601 (1998) ("[T]he United States Supreme Court has not consistently applied the 'no set of circumstances' language."). 11 No. 2019AP614-LV & 2019AP622.rfd ¶178 The majority claims this test is nonetheless appropriate as an exercise of judicial modesty that will avoid judicial overstepping into the legislature's prerogative.

44
Lemon v. Kurtzmanred
scotus · 1971 · cited in 7 Wisconsin opinions naming this issue, 1973–2009
2 sentences

2009She argues, for example, that giving religious employers an exemption from non-discrimination laws "dangerously encroaches upon the Establishment Clause's prohibition against furthering religion." Ostlund further asserts that the three-part Establishment Clause test announced by the Supreme Court in Lemon v. Kurtzman, 403 U.S. 602 , 91 S.Ct. 2105 , 29 L.Ed.2d 745 (1971), should govern our determination of whether application of the WFEA here violates CCS's constitutional rights. [11] Though at times mentioning the Free Exercise Clause, Ostlund argues that the only relevant question here is whe

2009She argues, for example, that giving religious employers an exemption from non-discrimination laws "dangerously encroaches upon the Establishment Clause's prohibition against furthering religion." Ostlund further asserts that the three-part Establishment Clause test announced by the Supreme Court in Lemon v. Kurtzman, 403 U.S. 602 , 91 S.Ct. 2105 , 29 L.Ed.2d 745 (1971), should govern our determination of whether application of the WFEA here violates CCS's constitutional rights. [11] Though at times mentioning the Free Exercise Clause, Ostlund argues that the only relevant question here is whe

37
Schmidt v. Bishopgreen
nysd · 1991 · cited in 3 Wisconsin opinions naming this issue, 1995–1997
2 sentences

1997Id. at 329 (quoting Schmidt v. Bishop, 779 F. Supp. 321, 332 (S.D.N.Y. 1991).

1996Any award of damages would have a chilling effect leading indirectly to state control over the future conduct of affairs of a religious denomination, a result violative of the text and history of the establishment clause." Id. at 329 , 533 N.W.2d at 791 (quoting Schmidt v. Bishop, 779 F. Supp. 321, 332 (S.D.N.Y. 1991)).

33
Committee for Public Education & Religious Liberty v. Nyquistgreen
scotus · 1973 · cited in 4 Wisconsin opinions naming this issue, 1978–1986
2 sentences

1986But see Committee for Public Ed. Religious Lib. v. Nyquist , 413 U.S. 756 , 783 n. 39 (1973) (striking down a New York statute providing for payment out of public funds for maintenance and repair for private schools, tuition reimbursement to private school pupils and income tax benefits to parents of children attending private school), and Sloan v. Lemon , 413 U.S. 825 (1973) (holding that a Pennsylvania statute providing for reimbursement of tuition paid by parents who send their children to nonpublic schools had the impermissible effect of advancing religion and was, therefore, unconstitutio

1979In Cummins , the majority found no Establishment Clause violation in the federal religious accommodation requirements, 29 C.F.R. sec. 1605.1 (1974) and 42 U.S.C. sec. 2000e(j) utilizing the three-pronged test of Committee for Public Education v. Nyquist, 413 U.S. 756, 773 (1973).

14
Ralph L. Minker v. Baltimore Annual Conference of United Methodist Church and Bishop Joseph A. Yeakelgreen
cadc · 1990 · cited in 1 Wisconsin opinions naming this issue, 2012–2012
1 sentence

2012The Minker court cites Serbian Eastern Orthodox Diocese for the proposition that "courts may not consider provisions whose enforcement would require 'a searching and therefore impermissible inquiry' into church doctrine." Minker v. Baltimore Area Annual Conference of United Methodist Church, 894 F.2d 1354, 1360 (D.C.

11
Stately v. Indian Community School of Milwaukee, Inc.green
wied · 2004 · cited in 1 Wisconsin opinions naming this issue, 2009–2009
1 sentence

2009Therefore, even if the dissenters are not comfortable with a school choice program that does not completely insulate children in religious schools from religion, the Supreme Court has spoken: There is no Establishment Clause violation. [30] In addition to those discussed in supra ¶¶ 50-54, see, e.g., EEOC v. Hosanna-Tabor Evangelical Lutheran Church & Sch., 582 F.Supp.2d 881 (E.D.Mich.2008) (holding that the ministerial exception applied to a kindergarten teacher who taught at a Lutheran school offering a "Christ-centered education" and where she received the title of "commissioned minister" f

11
Equal Employment Opportunity Commission v. Fremont Christian Schoolgreen
ca9 · 1986 · cited in 1 Wisconsin opinions naming this issue, 2008–2008
1 sentence

2008Other courts treat it as derived from the establishment clause, see, e.g., EEOC v. Fremont Christian Sch., 781 F.2d 1362, 1369 (9th Cir. 1986), or from both clauses.

11
National Labor Relations Board v. Catholic Bishopgreen
scotus · 1979 · cited in 1 Wisconsin opinions naming this issue, 2008–2008
1 sentence

2008See generally Catholic Bishop, 440 U.S. 490 .

11
Richard Tomic v. Catholic Diocese of Peoriagreen
ca7 · 2006 · cited in 1 Wisconsin opinions naming this issue, 2008–2008
1 sentence

2008See, e.g., Tomic v. Catholic Diocese of Peoria, 442 F.3d 1036, 1042 (7th Cir. 2006); see also Shawn Meyer Eikenberry, Thou Shalt Not Sue the Church: Denying Court Access to Ministerial Employees, 74 IND.

11
Roppolo v. Mooregreen
lactapp · 1994 · cited in 1 Wisconsin opinions naming this issue, 1995–1995
2 sentences

1995Schmidt v. Bishop, 779 F. Supp. 321, 332 (S.D.N.Y., 1991); see also Roppolo v. Moore, 644 So. 2d 206, 208 (La.

1995Schmidt v. Bishop, 779 F. Supp. 321, 332 (S.D.N.Y., 1991); see also Roppolo v. Moore, 644 So. 2d 206, 208 (La.

11
Edwards v. Aguillardgreen
scotus · 1987 · cited in 1 Wisconsin opinions naming this issue, 1991–1991
1 sentence

1991See Edwards v. Aguillard, 482 U.S. 578, 583 (1987). [5] The Wisconsin Supreme Court has applied the United States Supreme Court's interpretation of the requirements of the establishment clause to article I, section 18, of the Wisconsin Constitution.

11
Stone v. Grahamgreen
scotus · 1981 · cited in 1 Wisconsin opinions naming this issue, 1986–1986
2 sentences

1986Stone v. Graham , 449 U.S. 39 , 40-41 (1980).

1986See Stone , 449 U.S. at 41 .

11
Widmar v. Vincentgreen
scotus · 1981 · cited in 1 Wisconsin opinions naming this issue, 1986–1986
11
Wallace v. Jaffreegreen
scotus · 1985 · cited in 1 Wisconsin opinions naming this issue, 1986–1986
1 sentence

1986See Wallace , 105 S.Ct. at 2490 . *Page 87 However, the majority opinion suggests in passing that a simple moment for "silent meditation" may be constitutional if the state does not endorse prayer as the preferred activity for that time.

11
Walz v. Tax Comm'n of City of New Yorkgreen
scotus · 1970 · cited in 1 Wisconsin opinions naming this issue, 1979–1979
11
Hunt v. McNairgreen
scotus · 1973 · cited in 1 Wisconsin opinions naming this issue, 1979–1979
11

Distinguished, questioned or overruled (2)

CaseNegativeCited
Committee for Public Education & Religious Liberty v. Nyquistgreen
scotus · 1973 · cited in 4 Wisconsin opinions naming this issue, 1978–1986
2 sentences

1986But see Committee for Public Ed. Religious Lib. v. Nyquist , 413 U.S. 756 , 783 n. 39 (1973) (striking down a New York statute providing for payment out of public funds for maintenance and repair for private schools, tuition reimbursement to private school pupils and income tax benefits to parents of children attending private school), and Sloan v. Lemon , 413 U.S. 825 (1973) (holding that a Pennsylvania statute providing for reimbursement of tuition paid by parents who send their children to nonpublic schools had the impermissible effect of advancing religion and was, therefore, unconstitutio

1979In Cummins , the majority found no Establishment Clause violation in the federal religious accommodation requirements, 29 C.F.R. sec. 1605.1 (1974) and 42 U.S.C. sec. 2000e(j) utilizing the three-pronged test of Committee for Public Education v. Nyquist, 413 U.S. 756, 773 (1973).

14
Sloan v. Lemongreen
scotus · 1973 · cited in 1 Wisconsin opinions naming this issue, 1986–1986
1 sentence

1986But see Committee for Public Ed. Religious Lib. v. Nyquist , 413 U.S. 756 , 783 n. 39 (1973) (striking down a New York statute providing for payment out of public funds for maintenance and repair for private schools, tuition reimbursement to private school pupils and income tax benefits to parents of children attending private school), and Sloan v. Lemon , 413 U.S. 825 (1973) (holding that a Pennsylvania statute providing for reimbursement of tuition paid by parents who send their children to nonpublic schools had the impermissible effect of advancing religion and was, therefore, unconstitutio

11

Also cited on this issue (37)

CaseCitedYears
Jackson v. Benson green
· 1998
2 sentences

2020Jackson v. Benson, 218 Wis. 2d 835 , 854 n.4, 578 N.W.2d 602 (1998); see also State v. Konrath, 218 Wis. 2d 290 , 305 n.15, 577 N.W.2d 601 (1998) ("[T]he United States Supreme Court has not consistently applied the 'no set of circumstances' language."). 11 No. 2019AP614-LV & 2019AP622.rfd ¶178 The majority claims this test is nonetheless appropriate as an exercise of judicial modesty that will avoid judicial overstepping into the legislature's prerogative.

2020Jackson v. Benson, 218 Wis. 2d 835 , 854 n.4, 578 N.W.2d 602 (1998); see also State v. Konrath, 218 Wis. 2d 290 , 305 n.15, 577 N.W.2d 601 (1998) ("[T]he United States Supreme Court has not consistently applied the 'no set of circumstances' language."). 11 No. 2019AP614-LV & 2019AP622.rfd ¶178 The majority claims this test is nonetheless appropriate as an exercise of judicial modesty that will avoid judicial overstepping into the legislature's prerogative.

42020–2020
Wolman v. Walter red
scotus · 1977
2 sentences

1978In Wolman v. Walter , 433 U.S. 229 , 53 L.Ed.2d 714 , 97 S.Ct. 2593 (1977), the Court held that to use public funds to provide instructional materials and equipment on the premises of parochial schools would violate the establishment clause.

1978In Wolman v. Walter , 433 U.S. 229 , 53 L.Ed.2d 714 , 97 S.Ct. 2593 (1977), the Court held that to use public funds to provide instructional materials and equipment on the premises of parochial schools would violate the establishment clause.

21978–1986
Equal Employment Opportunity Commission v. Hosanna-Tabor Evangelical Lutheran Church & School green
mied · 2008
2 sentences

2009Therefore, even if the dissenters are not comfortable with a school choice program that does not completely insulate children in religious schools from religion, the Supreme Court has spoken: There is no Establishment Clause violation. [30] In addition to those discussed in supra ¶¶ 50-54, see, e.g., EEOC v. Hosanna-Tabor Evangelical Lutheran Church & Sch., 582 F.Supp.2d 881 (E.D.Mich.2008) (holding that the ministerial exception applied to a kindergarten teacher who taught at a Lutheran school offering a "Christ-centered education" and where she received the title of "commissioned minister" f

2009In addition to those discussed in supra ¶¶ 50-54, see, e.g., EEOC v. Hosanna-Tabor Evangelical Lutheran Church & Sch., 582 F. Supp. 2d 881 (E.D.

12009–2009
Porth v. Roman Catholic Diocese green
michctapp · 1995
2 sentences

2009Therefore, even if the dissenters are not comfortable with a school choice program that does not completely insulate children in religious schools from religion, the Supreme Court has spoken: There is no Establishment Clause violation. [30] In addition to those discussed in supra ¶¶ 50-54, see, e.g., EEOC v. Hosanna-Tabor Evangelical Lutheran Church & Sch., 582 F.Supp.2d 881 (E.D.Mich.2008) (holding that the ministerial exception applied to a kindergarten teacher who taught at a Lutheran school offering a "Christ-centered education" and where she received the title of "commissioned minister" f

2009Therefore, even if the dissenters are not comfortable with a school choice program that does not completely insulate children in religious schools from religion, the Supreme Court has spoken: There is no Establishment Clause violation. [30] In addition to those discussed in supra ¶¶ 50-54, see, e.g., EEOC v. Hosanna-Tabor Evangelical Lutheran Church & Sch., 582 F.Supp.2d 881 (E.D.Mich.2008) (holding that the ministerial exception applied to a kindergarten teacher who taught at a Lutheran school offering a "Christ-centered education" and where she received the title of "commissioned minister" f

12009–2009
Guy Demarco v. Holy Cross High School green
ca2 · 1993
1 sentence

2009Therefore, even if the dissenters are not comfortable with a school choice program that does not completely insulate children in religious schools from religion, the Supreme Court has spoken: There is no Establishment Clause violation. [30] In addition to those discussed in supra ¶¶ 50-54, see, e.g., EEOC v. Hosanna-Tabor Evangelical Lutheran Church & Sch., 582 F.Supp.2d 881 (E.D.Mich.2008) (holding that the ministerial exception applied to a kindergarten teacher who taught at a Lutheran school offering a "Christ-centered education" and where she received the title of "commissioned minister" f

12009–2009
Redhead v. Conference of Seventh-Day Adventists green
nyed · 2006
1 sentence

2009Therefore, even if the dissenters are not comfortable with a school choice program that does not completely insulate children in religious schools from religion, the Supreme Court has spoken: There is no Establishment Clause violation. [30] In addition to those discussed in supra ¶¶ 50-54, see, e.g., EEOC v. Hosanna-Tabor Evangelical Lutheran Church & Sch., 582 F.Supp.2d 881 (E.D.Mich.2008) (holding that the ministerial exception applied to a kindergarten teacher who taught at a Lutheran school offering a "Christ-centered education" and where she received the title of "commissioned minister" f

12009–2009
Equal Employment Opportunity Commission v. Tree of Life Christian Schools green
ohsd · 1990
1 sentence

2009Therefore, even if the dissenters are not comfortable with a school choice program that does not completely insulate children in religious schools from religion, the Supreme Court has spoken: There is no Establishment Clause violation. [30] In addition to those discussed in supra ¶¶ 50-54, see, e.g., EEOC v. Hosanna-Tabor Evangelical Lutheran Church & Sch., 582 F.Supp.2d 881 (E.D.Mich.2008) (holding that the ministerial exception applied to a kindergarten teacher who taught at a Lutheran school offering a "Christ-centered education" and where she received the title of "commissioned minister" f

12009–2009
Guinan v. Roman Catholic Archdiocese of Indianapolis green
insd · 1998
1 sentence

2009Therefore, even if the dissenters are not comfortable with a school choice program that does not completely insulate children in religious schools from religion, the Supreme Court has spoken: There is no Establishment Clause violation. [30] In addition to those discussed in supra ¶¶ 50-54, see, e.g., EEOC v. Hosanna-Tabor Evangelical Lutheran Church & Sch., 582 F.Supp.2d 881 (E.D.Mich.2008) (holding that the ministerial exception applied to a kindergarten teacher who taught at a Lutheran school offering a "Christ-centered education" and where she received the title of "commissioned minister" f

12009–2009
Rayburn v. General Conference Of Seventh-Day Adventists green
ca4 · 1985
1 sentence

2008I. 4 Although we used the phrase "ministerial or ecclesiastical" throughout Jocz v. LIRC, 196 Wis. 2d 273 , 538 N.W.2d 588 (Ct. App. 1995), we simplify in this opinion by using only the term "ministerial." 5 The court in Rayburn v. General Conf. of Seventh-Day Adventists, 772 F.2d 1164 , 1169-71 (4th Cir. 1985), undertook a separate analysis under the establishment clause and concluded that clause also precluded the lawsuit. 6 Title VII, 42 U.S.C. 2000e-2000e-17, prohibits discrimination based on race, color, religion, sex, or national origin.

12008–2008
Jocz v. Labor & Industry Review Commission green
wisctapp · 1995
2 sentences

2008I. 4 Although we used the phrase "ministerial or ecclesiastical" throughout Jocz v. LIRC, 196 Wis. 2d 273 , 538 N.W.2d 588 (Ct. App. 1995), we simplify in this opinion by using only the term "ministerial." 5 The court in Rayburn v. General Conf. of Seventh-Day Adventists, 772 F.2d 1164 , 1169-71 (4th Cir. 1985), undertook a separate analysis under the establishment clause and concluded that clause also precluded the lawsuit. 6 Title VII, 42 U.S.C. 2000e-2000e-17, prohibits discrimination based on race, color, religion, sex, or national origin.

2008I. 4 Although we used the phrase "ministerial or ecclesiastical" throughout Jocz v. LIRC, 196 Wis. 2d 273 , 538 N.W.2d 588 (Ct. App. 1995), we simplify in this opinion by using only the term "ministerial." 5 The court in Rayburn v. General Conf. of Seventh-Day Adventists, 772 F.2d 1164 , 1169-71 (4th Cir. 1985), undertook a separate analysis under the establishment clause and concluded that clause also precluded the lawsuit. 6 Title VII, 42 U.S.C. 2000e-2000e-17, prohibits discrimination based on race, color, religion, sex, or national origin.

12008–2008
Pritzlaff v. Archdiocese of Milwaukee green
wis · 1995
2 sentences

1996Any award of damages would have a chilling effect leading indirectly to state control over the future conduct of affairs of a religious denomination, a result violative of the text and history of the establishment clause." Id. at 329 , 533 N.W.2d at 791 (quoting Schmidt v. Bishop, 779 F. Supp. 321, 332 (S.D.N.Y. 1991)).

1996Any award of damages would have a chilling effect leading indirectly to state control over the future conduct of affairs of a religious denomination, a result violative of the text and history of the establishment clause." Id. at 329 , 533 N.W.2d at 791 (quoting Schmidt v. Bishop, 779 F. Supp. 321, 332 (S.D.N.Y. 1991)).

11996–1996
American Motors Corp. v. Department of Industry, Labor & Human Relations green
wisctapp · 1979
2 sentences

1988Consequently, it has employed the tests enunciated by the United States Supreme Court in construing the requirements of the establishment clause to determine whether specific state laws or actions are violative of either constitutional provision. *Page 71 American Motors Corp. v. ILHR Dept. , 93 Wis.2d 14 , 29 , 286 N.W.2d 847 (1979) (citations omitted).

1988Consequently, it has employed the tests enunciated by the United States Supreme Court in construing the requirements of the establishment clause to determine whether specific state laws or actions are violative of either constitutional provision. *Page 71 American Motors Corp. v. ILHR Dept. , 93 Wis.2d 14 , 29 , 286 N.W.2d 847 (1979) (citations omitted).

11988–1988
Tilton v. Richardson green
scotus · 1971
1 sentence

1987As stated in Nusbaum , 64 Wis.2d at 325 , quoting Tilton v. Richardson , 403 U.S. at 682 : "Individual projects can be properly evaluated if and when challenges arise with respect to particular recipients and some evidence is then presented to show that the institution does in fact possess these characteristics." Therefore, I also express no opinion as to whether any particular grant recipient or applicant falls within the scope of this prohibition since that is a factual determination which must be made by the board through the application process.

11987–1987
State Ex Rel. Warren v. Nusbaum green
wis · 1974
1 sentence

1987As stated in Nusbaum , 64 Wis.2d at 325 , quoting Tilton v. Richardson , 403 U.S. at 682 : "Individual projects can be properly evaluated if and when challenges arise with respect to particular recipients and some evidence is then presented to show that the institution does in fact possess these characteristics." Therefore, I also express no opinion as to whether any particular grant recipient or applicant falls within the scope of this prohibition since that is a factual determination which must be made by the board through the application process.

11987–1987
Opinion No. Oag 86-78, (1978) neutral
wisag · 1978
1 sentence

1986Thus, this arrangement is distinguishable from the leasing of classrooms in parochial schools by public school districts in order to provide educational programs under Title I of Elementary and Secondary Education Act to parochial school students, which I *Page 263 previously advised your predecessor was prohibited by the establishment clause of the United States Constitution and article I , section 18 of the Wisconsin Constitution. 67 Op. Att'y Gen. 283 (1978).

11986–1986
Aguilar v. Felton red
scotus · 1985
1 sentence

1986Entanglement In the second case, Aquilar v. Felton , 105 S.Ct. 3232 (1985), the Court held that a program in which New York City used Title I funds to pay salaries of public school employes to teach in parochial schools violated the establishment clause.

11986–1986
Rankins v. Commission on Professional Competence of the Ducor Union School District green
cal · 1979
11979–1979
Zorach v. Clauson green
scotus · 1952
11979–1979
State Ex Rel. Warren v. Nusbaum green
wis · 1972
11979–1979
State Ex Rel. Reynolds v. Nusbaum green
wis · 1962
11979–1979
New York Times Co. v. Sullivan green
scotus · 1964
11979–1979
Maine Human Rights Commission v. Local 1361, United Paperworkers International Union AFL-CIO green
me · 1978
11979–1979
Griggs v. Duke Power Co. green
scotus · 1971
11979–1979
State Ex Rel. Wisconsin Health Facilities Authority v. Lindner green
wis · 1979
11979–1979
Gillette v. United States green
scotus · 1971
11979–1979
Hardison v. Trans World Airlines green
mowd · 1974
11979–1979
Wondzell v. Alaska Wood Products, Inc. green
alaska · 1978
11979–1979
Meek v. Pittenger red
scotus · 1975
11978–1978
Everson v. Board of Ed. of Ewing green
scotus · 1947
11969–1969
Will of Gudde v. Fasting green
wis · 1951
11967–1967
Matthews v. Capital Fire Insurance neutral
wis · 1902
11964–1964
Klix v. Nieman green
wis · 1887
11914–1914
Gorr v. Mittlestaedt neutral
wis · 1897
11914–1914
Cook v. Rice Lake Milling & Power Co. neutral
wis · 1911
11914–1914
Flood v. Pragoff green
kyctapp · 1881
11887–1887
State ex rel. Wood v. Baker green
wis · 1875
11880–1880
Russell v. Swan green
mass · 1820
11844–1844

Statutes the citing opinions construe

WI § Wis. Stat. § 802.06 (5) WI § Wis. Stat. § 10.06 (4) WI § Wis. Stat. § 108.14 (4) WI § Wis. Stat. § 15.04 (4) WI § Wis. Stat. § 15.347 (4) WI § Wis. Stat. § 16.85 (4) WI § Wis. Stat. § 227.01 (4) WI § Wis. Stat. § 227.05 (4) WI § Wis. Stat. § 227.11 (4) WI § Wis. Stat. § 227.112 (4) WI § Wis. Stat. § 227.19 (4) WI § Wis. Stat. § 227.26 (4)

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

CA 89 (1921–2025) NY 53 (1861–2026) FL 43 (1938–2026) OH 42 (1953–2025) WA 42 (1895–2026) MI 39 (1909–2020) IL 39 (1887–2021) PA 39 (1917–2024) NJ 37 (1897–2019) WI 31 (1844–2020) MA 29 (1910–2018) TX 28 (1912–2023) MD 24 (1914–2023) CO 24 (1892–2015) CT 22 (1923–2025) OR 22 (1895–2025) MN 17 (1926–2016) AL 16 (1868–2015) AR 15 (1908–2021) OK 14 (1913–2024) IA 13 (1877–2018) NM 12 (1888–2015) LA 12 (1917–2000) TN 12 (1917–2013) GA 11 (1925–2023) NE 10 (1886–2003) AZ 10 (1960–2016) MO 10 (1906–2011) KS 10 (1901–1996) KY 9 (1899–2023) MS 8 (1950–2005) UT 8 (1986–2022) IN 8 (1942–2005) VA 8 (1925–2015) ME 7 (1844–2006) ID 7 (1890–1996) NC 7 (1874–2011) MT 6 (1878–2012) SC 5 (1846–2021) VT 5 (1979–2017) DC 5 (1982–1997) HI 5 (1987–2020) ND 4 (1895–1986) AK 4 (1979–2022) NV 4 (1959–2022) WV 4 (1950–2014) NH 4 (1967–1995) RI 2 (1919–1980) DE 2 (1974–1990) PR 2 (1942–1956)

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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