pleading standard (Wisconsin) · Go Syfert
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pleading standard in Wisconsin

31 Wisconsin opinions name it 2 courts 1979–2026 8 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 (21)

CaseFollowedCited
Data Key Partners v. Permira Advisors LLCgreen
wis · 2014 · cited in 6 Wisconsin opinions naming this issue, 2018–2025
2 sentences

2025See Data Key Partners v. Permira Advisers LLC, 2014 WI 86, ¶¶37-38 , 356 Wis. 2d 665 , 849 N.W.2d 693 (citing favorably to the liberal pleading standard set forth in the eponymous Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), decision).

2025See Data Key Partners v. Permira Advisers LLC, 2014 WI 86, ¶¶37-38 , 356 Wis. 2d 665 , 849 N.W.2d 693 (citing favorably to the liberal pleading standard set forth in the eponymous Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), decision).

36
Bell Atlantic Corp. v. Twomblygreen
scotus · 2007 · cited in 4 Wisconsin opinions naming this issue, 2013–2025
2 sentences

2025See Data Key Partners v. Permira Advisers LLC, 2014 WI 86, ¶¶37-38 , 356 Wis. 2d 665 , 849 N.W.2d 693 (citing favorably to the liberal pleading standard set forth in the eponymous Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), decision).

2019Id. , ¶21 ; see also Strid , 111 Wis. 2d at 422 -23 , 331 N.W.2d 350 ("It is the sufficiency of the facts alleged that control the determination of whether a claim for relief is properly plead."). ¶7 The defendants argue that by setting out the pleading standard employed by the United States Supreme Court in Bell Atlantic Corp. v. Twombly , 550 U.S. 544 , 127 S. Ct. 1955 , 167 L.Ed.2d 929 (2007), we changed Wisconsin's pleading standard to a heightened "plausibility" standard.

34
Friends of Kenwood v. Greengreen
wisctapp · 2000 · cited in 2 Wisconsin opinions naming this issue, 2025–2025
2 sentences

2025STAT. § 802.03(2) “is designed to protect defendants whose reputation could be harmed by lightly made charges of wrongdoing involving moral turpitude, to 13 No. 2023AP1379 minimize strike suits, and to discourage the filing of suits in the hope of turning up relevant information during discovery.” Friends of Kenwood v. Green, 2000 WI App 217, ¶14 , 239 Wis. 2d 78 , 619 N.W.2d 271 (cleaned up).

2025See Friends of Kenwood, 239 Wis. 2d 78, ¶14 .

22
Strid v. Conversegreen
wis · 1983 · cited in 2 Wisconsin opinions naming this issue, 2019–2024
2 sentences

2024The parties agree that § 802.03 is not at issue in this case. 6 In Cattau, our supreme court clarified that Data Key is consistent with and did not overrule the pleading standard articulated in Strid v. Converse, 111 Wis. 2d 418 , 331 N.W.2d 350 (1983).

2024The parties agree that § 802.03 is not at issue in this case. 6 In Cattau, our supreme court clarified that Data Key is consistent with and did not overrule the pleading standard articulated in Strid v. Converse, 111 Wis. 2d 418 , 331 N.W.2d 350 (1983).

12
Patrick Fur Farm, Inc. v. United Vaccines, Inc.green
wisctapp · 2005 · cited in 1 Wisconsin opinions naming this issue, 2026–2026
2 sentences

2026See Patrick Fur Farm, Inc. v. United Vaccines, Inc., 2005 WI App 190 , ¶8 n.1, 286 Wis. 2d 774 , 703 N.W.2d 707 (stating that this court decides cases on the narrowest possible grounds). ¶16 In order to satisfy the heightened pleading requirement under WIS.

2026See Patrick Fur Farm, Inc. v. United Vaccines, Inc., 2005 WI App 190 , ¶8 n.1, 286 Wis. 2d 774 , 703 N.W.2d 707 (stating that this court decides cases on the narrowest possible grounds). ¶16 In order to satisfy the heightened pleading requirement under WIS.

11
Siva Truck Leasing, Inc. v. Kurman Distributorsgreen
wisctapp · 1991 · cited in 1 Wisconsin opinions naming this issue, 2024–2024
2 sentences

2024RULE 809.19(1)(e); see also Siva Truck Leasing, Inc. v. Kurman Dists., 166 Wis. 2d 58 , 70 n.32, 479 N.W.2d 542 (Ct. App. 1991) (“The reviewing court need not sift the record for facts which support counsel’s contention.”). 6 No. 2023AP1405 such manner as can be readily understood by a person making a reasonable effort to do so.” See FREMONT CODE § 30-2(B), (E); see also State v. Pettit, 171 Wis. 2d 627, 646 , 492 N.W.2d 633 (Ct. App. 1992) (this court need not address undeveloped arguments). ¶15 At bottom, the Village appears to be arguing that it did not need to comply with FREMONT CODE § 30

2024RULE 809.19(1)(e); see also Siva Truck Leasing, Inc. v. Kurman Dists., 166 Wis. 2d 58 , 70 n.32, 479 N.W.2d 542 (Ct. App. 1991) (“The reviewing court need not sift the record for facts which support counsel’s contention.”). 6 No. 2023AP1405 such manner as can be readily understood by a person making a reasonable effort to do so.” See FREMONT CODE § 30-2(B), (E); see also State v. Pettit, 171 Wis. 2d 627, 646 , 492 N.W.2d 633 (Ct. App. 1992) (this court need not address undeveloped arguments). ¶15 At bottom, the Village appears to be arguing that it did not need to comply with FREMONT CODE § 30

11
Louis Pagoudis v. Marcus Keidlgreen
wis · 2023 · cited in 1 Wisconsin opinions naming this issue, 2024–2024
2 sentences

2024See Pagoudis v. Keidl, 2023 WI 27, ¶4 , 406 Wis. 2d 542 , 988 N.W.2d 606 .

2024See Pagoudis v. Keidl, 2023 WI 27, ¶4 , 406 Wis. 2d 542 , 988 N.W.2d 606 .

11
State v. Pettitgreen
wisctapp · 1992 · cited in 1 Wisconsin opinions naming this issue, 2024–2024
2 sentences

2024RULE 809.19(1)(e); see also Siva Truck Leasing, Inc. v. Kurman Dists., 166 Wis. 2d 58 , 70 n.32, 479 N.W.2d 542 (Ct. App. 1991) (“The reviewing court need not sift the record for facts which support counsel’s contention.”). 6 No. 2023AP1405 such manner as can be readily understood by a person making a reasonable effort to do so.” See FREMONT CODE § 30-2(B), (E); see also State v. Pettit, 171 Wis. 2d 627, 646 , 492 N.W.2d 633 (Ct. App. 1992) (this court need not address undeveloped arguments). ¶15 At bottom, the Village appears to be arguing that it did not need to comply with FREMONT CODE § 30

2024RULE 809.19(1)(e); see also Siva Truck Leasing, Inc. v. Kurman Dists., 166 Wis. 2d 58 , 70 n.32, 479 N.W.2d 542 (Ct. App. 1991) (“The reviewing court need not sift the record for facts which support counsel’s contention.”). 6 No. 2023AP1405 such manner as can be readily understood by a person making a reasonable effort to do so.” See FREMONT CODE § 30-2(B), (E); see also State v. Pettit, 171 Wis. 2d 627, 646 , 492 N.W.2d 633 (Ct. App. 1992) (this court need not address undeveloped arguments). ¶15 At bottom, the Village appears to be arguing that it did not need to comply with FREMONT CODE § 30

11
State v. Howellgreen
wis · 2007 · cited in 1 Wisconsin opinions naming this issue, 2021–2021
2 sentences

2021See Howell, 301 Wis. 2d 350, ¶¶28, 75 .

2021See Howell, 301 Wis. 2d 350, ¶¶26-29, 73-77 .

11
Tim Torres Enterprises, Inc. v. Linscottgreen
wisctapp · 1987 · cited in 1 Wisconsin opinions naming this issue, 2020–2020
1 sentence

2020See Tim Torres Enters., Inc., 142 Wis. 2d at 72 ("The broad remedial 29 No. 2017AP2361 scope of sec. 100.18 and its protective purpose make it similar to the remedial provisions of the federal antitrust laws in that to eliminate or rectify a wrong the traditional standards of proof may be relaxed if necessary."). ¶83 Accordingly, we conclude that the heightened pleading standard set forth by Wis. Stat. § 802.03 (2) for claims of fraud does not apply to claims made under Wis. Stat. § 100.18 . ¶84 We therefore apply general pleading standards to determine if Hinrichs' complaint states a claim.

11
Allen v. Standard Oil Co.green
ohio · 1982 · cited in 1 Wisconsin opinions naming this issue, 2019–2019
2 sentences

2019The nature of the allegations determines whether an insurer is bound to defend." See id. at 499 (emphasis added).

2019Id. at 499-500 . ¶26 If anything, then, Standard Oil supports the circuit court's partial denial of summary judgment in this case.

11
Ala, Inc. v. Ccair, Inc.green
ca3 · 1994 · cited in 1 Wisconsin opinions naming this issue, 2014–2014
1 sentence

2014It further reasoned that if "an unanswered affirmative defense appears on [the] face" of the complaint, the shareholder claimant had to "plead around the business judgment rule." Tower Air, 416 F.3d at 238 (citing ALA, Inc. v. CCAIR, Inc., 29 F.3d 855, 859 (3d Cir. 1994)).46 Tower Air was decided prior to Twombly, 550 U.S. 544 , and Iqbal, 555 U.S. 1030 , regarding the federal pleading standard necessary to survive a motion to dismiss under Rule 12(b)(6).

11
Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unitgreen
scotus · 1993 · cited in 1 Wisconsin opinions naming this issue, 2014–2014
1 sentence

2014In Tower Air, the trial court dismissed the complaint, requiring the claimant to allege specific facts upon which the claim is based. ¶127 The Third Circuit rejected the trial court's position, stating that the trial court "erroneously preempted discovery on certain claims by imposing a heightened pleading standard not required by [the] Federal Rule[s] of Civil Procedure" by requiring the shareholder to plead specific facts.44 The Third Circuit distinguished between Delaware's heightened pleading requirements and the relaxed pleading standards of the federal courts that "do not require a claim

11
cluster 791140green
ca3 · 2005 · cited in 1 Wisconsin opinions naming this issue, 2014–2014
2 sentences

2014In Tower Air, the trial court dismissed the complaint, requiring the claimant to allege specific facts upon which the claim is based. ¶127 The Third Circuit rejected the trial court's position, stating that the trial court "erroneously preempted discovery on certain claims by imposing a heightened pleading standard not required by [the] Federal Rule[s] of Civil Procedure" by requiring the shareholder to plead specific facts.44 The Third Circuit distinguished between Delaware's heightened pleading requirements and the relaxed pleading standards of the federal courts that "do not require a claim

2014In Tower Air, the trial court dismissed the complaint, requiring the claimant to allege specific facts upon which the claim is based. ¶127 The Third Circuit rejected the trial court's position, stating that the trial court "erroneously preempted discovery on certain claims by imposing a heightened pleading standard not required by [the] Federal Rule[s] of Civil Procedure" by requiring the shareholder to plead specific facts.44 The Third Circuit distinguished between Delaware's heightened pleading requirements and the relaxed pleading standards of the federal courts that "do not require a claim

11
State v. Bangertgreen
wis · 1986 · cited in 1 Wisconsin opinions naming this issue, 2012–2012
1 sentence

2012See Bangert, 131 Wis. 2d at 274-75 .

11
Kett v. Community Credit Plan, Inc.green
wis · 1999 · cited in 1 Wisconsin opinions naming this issue, 2008–2008
1 sentence

2008Nuvell maintains that an affirmative act requirement is suggested by the following language in Kett , "if the customer does not waive the improper venue, the court lacks jurisdiction other than to dismiss the action," Kett, 228 Wis. 2d at 16 (citation omitted), and by the supreme court's rejection of the pleading-waiver rule in All Star Rent A Car and Mikrut . ¶ 16.

11
Johnson v. Johnsongreen
wisctapp · 1993 · cited in 1 Wisconsin opinions naming this issue, 2000–2000
2 sentences

2000See Johnson v. Johnson, 179 Wis. 2d 574, 580 , 508 N.W.2d 19 (Ct. App. 1993); Fritsch v. St.

2000See Johnson v. Johnson, 179 Wis. 2d 574, 580 , 508 N.W.2d 19 (Ct. App. 1993); Fritsch v. St.

11
Heinritz v. Lawrence Universitygreen
wisctapp · 1995 · cited in 1 Wisconsin opinions naming this issue, 1997–1997
11
Prah v. Marettigreen
wis · 1982 · cited in 1 Wisconsin opinions naming this issue, 1994–1994
11
National Steel Service Center, Inc. v. Wollin Silos & Equipment, Inc.green
wis · 1979 · cited in 1 Wisconsin opinions naming this issue, 1992–1992
11
In Re Recall Petition of Carlsongreen
wisctapp · 1988 · cited in 1 Wisconsin opinions naming this issue, 1989–1989
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (17)

CaseCitedYears
State Ex Rel. Kalal v. Circuit Court for Dane County green
wis · 2004
1 sentence

2025Kalal, 271 Wis. 2d 633 , ¶¶47- 48 (explaining that “a statute is ambiguous if it is capable of being understood by reasonably well-informed persons in two or more senses” and that “[i]f a statute is ambiguous, the reviewing court turns to the scope, history, context, and purpose of that statute” (citations omitted)). ¶29 The heightened pleading requirement for averments of fraud in WIS.

12025–2025
Kolupar v. Wilde Pontiac Cadillac, Inc. green
wis · 2004
2 sentences

2020STAT. § 802.03(2), and that the facts alleged by the Hickethiers were insufficient.5 4 “Chapter 218 of the Wisconsin Statutes regulates the automobile business in many respects.” Kolupar v. Wilde Pontiac Cadillac, Inc., 2004 WI 112, ¶18 , 275 Wis. 2d 1 , 683 N.W.2d 58 . 5 WISCONSIN STAT. § 802.03(2) provides: “In all averments of fraud or mistake, the circumstances constituting fraud or mistake shall be stated with particularity.

2020STAT. § 802.03(2), and that the facts alleged by the Hickethiers were insufficient.5 4 “Chapter 218 of the Wisconsin Statutes regulates the automobile business in many respects.” Kolupar v. Wilde Pontiac Cadillac, Inc., 2004 WI 112, ¶18 , 275 Wis. 2d 1 , 683 N.W.2d 58 . 5 WISCONSIN STAT. § 802.03(2) provides: “In all averments of fraud or mistake, the circumstances constituting fraud or mistake shall be stated with particularity.

12020–2020
Kohlbeck v. Reliance Const. Co., Inc. green
wisctapp · 2002
2 sentences

2020We conclude instead that the Hickethiers’ claims were properly dismissed even under the ordinary pleading standards. ¶12 “We review de novo a circuit court’s decision granting a party’s motion to dismiss for failure to state a claim.” Kohlbeck v. Reliance Const. Co., 2002 WI App 142, ¶9 , 256 Wis. 2d 235 , 647 N.W.2d 277 .7 “When determining whether a complaint states a claim upon which relief may be granted, courts must ‘accept as true all facts well-pleaded in the complaint and the reasonable inferences therefrom.’” Cattau v. National Ins.

2020We conclude instead that the Hickethiers’ claims were properly dismissed even under the ordinary pleading standards. ¶12 “We review de novo a circuit court’s decision granting a party’s motion to dismiss for failure to state a claim.” Kohlbeck v. Reliance Const. Co., 2002 WI App 142, ¶9 , 256 Wis. 2d 235 , 647 N.W.2d 277 .7 “When determining whether a complaint states a claim upon which relief may be granted, courts must ‘accept as true all facts well-pleaded in the complaint and the reasonable inferences therefrom.’” Cattau v. National Ins.

12020–2020
Strickland v. Washington green
scotus · 1984
1 sentence

2019The standard for pleading a claim of ineffective assistance of counsel ¶27 Wisconsin courts apply the United States Supreme Court's two-pronged Strickland v. Washington , 466 U.S. 668 (1984), test to analyze claims of ineffective assistance of counsel in criminal cases.

12019–2019
Wingra Redi-Mix, Inc. v. State Historical Society of Wisconsin neutral
wis · 2018
2 sentences

2019Bd. , 2018 WI 54 , ¶1, 381 Wis. 2d 601 , 912 N.W. 392 . ¶4 To explain further, the pleading standard we set out in Data Key is *759 consistent with the pleading standard in Strid , and is grounded in Wis. Stat. § 802.02 (1)(a)'s (2017-18) requirement that a complaint contain "[a] short and plain statement of the claim, identifying the transaction or occurrence or series of transactions or occurrences out of which the claim arises and showing that the pleader is entitled to relief." When determining whether a complaint states a claim upon which relief may be granted, courts must "accept as true

2019Bd. , 2018 WI 54 , ¶1, 381 Wis. 2d 601 , 912 N.W. 392 . ¶4 To explain further, the pleading standard we set out in Data Key is *759 consistent with the pleading standard in Strid , and is grounded in Wis. Stat. § 802.02 (1)(a)'s (2017-18) requirement that a complaint contain "[a] short and plain statement of the claim, identifying the transaction or occurrence or series of transactions or occurrences out of which the claim arises and showing that the pleader is entitled to relief." When determining whether a complaint states a claim upon which relief may be granted, courts must "accept as true

12019–2019
State v. Maltese Lavele Williams green
wis · 2015
2 sentences

2019State v. Williams , 2015 WI 75 , ¶74, 364 Wis. 2d 126 , 867 N.W.2d 736 .

2019State v. Williams , 2015 WI 75 , ¶74, 364 Wis. 2d 126 , 867 N.W.2d 736 .

12019–2019
State v. Allen green
wis · 2004
2 sentences

2018For instance, the affidavit stated: "There was a time during the plea hearing when there was a break and my attorney convinced me that I should just go forward with the plea and say that I understood what was going on because either way the punishment would be the same." The affidavit also asserted: "I just went along with the plea on Count 2 because even though I didn't understand what was really going on, my attorney convinced me to follow through with the game plan." ¶18 We are not convinced that Willis's motion satisfied the pleading standard required for a Nelson/Bentley claim: adequately

2018For instance, the affidavit stated: "There was a time during the plea hearing when there was a break and my attorney convinced me that I should just go forward with the plea and say that I understood what was going on because either way the punishment would be the same." The affidavit also asserted: "I just went along with the plea on Count 2 because even though I didn't understand what was really going on, my attorney convinced me to follow through with the game plan." ¶18 We are not convinced that Willis's motion satisfied the pleading standard required for a Nelson/Bentley claim: adequately

12018–2018
ESTATE OF SUSTACHE v. American Family Mutual Insurance Company green
wis · 2008
1 sentence

2018This, the court concluded, was insufficient. "[T]he negligent supervision *433 claim against Mustafa can qualify as an occurrence only if facts exist showing that Mustafa's own conduct accidentally caused Talley's injuries." Id. , ¶16. ¶ 69 Why wouldn't Mr. Talley's allegations be enough?

12018–2018
Ashcroft v. Iqbal green
scotus · 2009
1 sentence

2013The cited article explains that Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), and Ashcroft v. Iqbal, 556 U.S. 662 (2009), may be viewed as heightening the pleading standard under the federal rules of procedure; observes that it is "yet unclear what effect, if any, the heightened pleading standard may have on [Fed.

12013–2013
Village of Trempealeau v. Mikrut green
wis · 2004
2 sentences

2008In All Star Rent A Car v. Wisconsin Dep't of Transportation, 2006 WI 85, ¶¶ 54-58 , 292 Wis. 2d 615 , 716 N.W.2d 506 , the supreme court reaffirmed its rejection of the pleading-waiver rule stated in Village of Trempealeau v. Mikrut, 2004 WI 79, ¶ 23 , 273 Wis. 2d 76 , 681 N.W.2d 190 , and held that the Department of Transportation did not waive improper venue under § 227.53 by twice appearing in court before raising the objection.

2008In All Star Rent A Car v. Wisconsin Dep't of Transportation, 2006 WI 85, ¶¶ 54-58 , 292 Wis. 2d 615 , 716 N.W.2d 506 , the supreme court reaffirmed its rejection of the pleading-waiver rule stated in Village of Trempealeau v. Mikrut, 2004 WI 79, ¶ 23 , 273 Wis. 2d 76 , 681 N.W.2d 190 , and held that the Department of Transportation did not waive improper venue under § 227.53 by twice appearing in court before raising the objection.

12008–2008
All Star Rent a Car, Inc. v. Wisconsin Department of Transportation green
wis · 2006
2 sentences

2008In All Star Rent A Car v. Wisconsin Dep't of Transportation, 2006 WI 85, ¶¶ 54-58 , 292 Wis. 2d 615 , 716 N.W.2d 506 , the supreme court reaffirmed its rejection of the pleading-waiver rule stated in Village of Trempealeau v. Mikrut, 2004 WI 79, ¶ 23 , 273 Wis. 2d 76 , 681 N.W.2d 190 , and held that the Department of Transportation did not waive improper venue under § 227.53 by twice appearing in court before raising the objection.

2008In All Star Rent A Car v. Wisconsin Dep't of Transportation, 2006 WI 85, ¶¶ 54-58 , 292 Wis. 2d 615 , 716 N.W.2d 506 , the supreme court reaffirmed its rejection of the pleading-waiver rule stated in Village of Trempealeau v. Mikrut, 2004 WI 79, ¶ 23 , 273 Wis. 2d 76 , 681 N.W.2d 190 , and held that the Department of Transportation did not waive improper venue under § 227.53 by twice appearing in court before raising the objection.

12008–2008
Carl v. Spickler Enterprises, Ltd. green
wisctapp · 1991
2 sentences

2002We next address Channel 15's objection to the trial court's analysis of the operative facts in this case, which formed the basis for its conclusion that Channel 15 was not prejudiced. 13 The trial court relied on Carl v. Spickler Enterprises Ltd., 165 Wis. 2d 611, 623 , 478 N.W.2d 48 (Ct. App. 1991), for this formulation of prejudice: "whether the party opposing amendment has been given such notice of the operative facts which form the basis for the claim so as to enable him to prepare a defense or response." We agree with Channel 15 that when a trial court uses this formulation to determine i

2002We next address Channel 15's objection to the trial court's analysis of the operative facts in this case, which formed the basis for its conclusion that Channel 15 was not prejudiced. 13 The trial court relied on Carl v. Spickler Enterprises Ltd., 165 Wis. 2d 611, 623 , 478 N.W.2d 48 (Ct. App. 1991), for this formulation of prejudice: "whether the party opposing amendment has been given such notice of the operative facts which form the basis for the claim so as to enable him to prepare a defense or response." We agree with Channel 15 that when a trial court uses this formulation to determine i

12002–2002
Jones v. State green
wis · 1999
2 sentences

2001It is well-settled "that where two conflicting statutes apply to the same subject, the more specific controls." Jones v. State, 226 Wis. 2d 565, 576 , 594 N.W.2d 738 (1999).

2001It is well-settled "that where two conflicting statutes apply to the same subject, the more specific controls." Jones v. State, 226 Wis. 2d 565, 576 , 594 N.W.2d 738 (1999).

12001–2001
First National Bank of Wisconsin Rapids v. Dickinson green
wisctapp · 1981
11985–1985
Lister v. Board of Regents of the University of Wisconsin System green
wis · 1976
11980–1980
Sniadach v. Family Finance Corp. of Bay View green
scotus · 1969
11979–1979
Fuentes v. Shevin green
scotus · 1972
11979–1979

Statutes the citing opinions construe

WI § Wis. Stat. § 802.02 (11) WI § Wis. Stat. § 802.03 (11) WI § Wis. Stat. § 802.06 (11) WI § Wis. Stat. § 808.10 (9) WI § Wis. Stat. § 802.08 (8) USC § 42u.s.c.1983 (7) WI § Wis. Stat. § 802.09 (5) WI § Wis. Stat. § 100.18 (3) WI § Wis. Stat. § 893.80 (3) WI § Wis. Stat. § 971.08 (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 293 (1916–2026) NY 219 (1927–2026) CA 200 (1899–2026) IL 144 (1878–2026) DE 97 (1982–2026) FL 69 (1963–2025) OH 61 (1989–2026) GA 61 (1972–2025) MI 51 (1974–2025) CT 42 (1921–2023) MO 39 (1911–2022) ID 39 (1924–2025) NC 38 (1928–2026) PA 36 (1930–2025) TN 33 (1995–2022) WV 33 (1963–2025) OR 33 (1922–2026) MA 32 (1952–2021) AL 32 (1909–2025) WI 31 (1979–2026) DC 29 (1946–2024) VA 28 (1987–2025) IN 27 (1891–2025) ME 26 (1977–2024) MD 25 (1988–2022) NJ 25 (1951–2026) KS 23 (1931–2026) OK 23 (1927–2019) IA 23 (1909–2026) UT 22 (1991–2025) CO 20 (1907–2026) AZ 19 (1951–2022) NM 19 (2002–2025) WA 18 (1927–2019) NV 18 (2011–2025) NE 17 (1884–2025) VT 16 (2008–2026) MN 16 (1982–2025) RI 12 (1996–2011) HI 12 (1978–2023) VI 11 (2008–2025) LA 11 (1933–2022) AK 11 (1962–2018) KY 10 (1920–2026) WY 10 (1956–2016) MS 9 (1984–2017) MT 7 (1944–2010) AR 7 (1985–2023) SC 7 (2009–2025) ND 3 (1966–2022)

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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