sufficiency of the evidence claim (Illinois) · Go Syfert
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sufficiency of the evidence claim in Illinois

189 Illinois opinions name it 2 courts 1989–2026 67 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.

Followed or applied (48)

CaseFollowedCited
Jackson v. Virginiared
scotus · 1979 · cited in 23 Illinois opinions naming this issue, 1992–2025
2 sentences

2023See Jackson v. Virginia, 443 U.S. 307, 318-19 (1979) (discussing the standard of review for a sufficiency of the evidence claim).

2021When a reviewing court considers a sufficiency of the evidence challenge, “ ‘the relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential 6 elements of the crime beyond a reasonable doubt.’ ” (Emphasis in original.) Id. (quoting Jackson v. Virginia, 443 U.S. 307, 319 (1979)).

1123
People v. Cunninghamgreen
ill · 2004 · cited in 12 Illinois opinions naming this issue, 2007–2025
2 sentences

2018App. 3d 481, 489 (1998)); rather, the critical inquiry on review of a sufficiency of the evidence claim is whether, after reviewing all of the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt (People v. Cunningham, 212 Ill. 2d 274, 278 (2004)).

2017App. 3d 481 , 489, 234 Ill.Dec. 685 , 703 N.E.2d 546 (1998) ); rather, the critical inquiry on review of a sufficiency of the evidence claim is whether, after reviewing all of the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt ( People v. Cunningham , 212 Ill. 2d 274 , 278, 288 Ill.Dec. 616 , 818 N.E.2d 304 (2004) ).

1112
People v. Wheelergreen
ill · 2007 · cited in 19 Illinois opinions naming this issue, 2009–2025
2 sentences

2023A reviewing court “will not retry a defendant when considering a sufficiency of the evidence challenge. [Citation.] The trier of fact is best equipped to judge the credibility of witnesses, and due consideration must be given to the fact that it was the trial court *** that saw and heard the witnesses.” Wheeler, 226 Ill. 2d at 114-15 . ¶ 22 The testimony of a single witness, if positive and credible, is sufficient to uphold a conviction.

2020“This court will not retry a defendant when considering a sufficiency of the evidence challenge.” Id., at 114–15.

719
People v. Collinsgreen
ill · 1985 · cited in 10 Illinois opinions naming this issue, 1989–2024
2 sentences

2024In examining a sufficiency of the evidence claim, we view the evidence in the light most favorable to the State to determine whether “any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” People v. Collins, 106 Ill. 2d 237, 261 (1985).

2019See Collins, 106 Ill. 2d at 261 (when determining a sufficiency of the evidence challenge, a reviewing court questions whether, after viewing the evidence in the light most favorable to the 7 prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt).

610
People v. Collinsgreen
ill · 2005 · cited in 6 Illinois opinions naming this issue, 2012–2022
2 sentences

2022People v. Collins, 214 Ill. 2d 206, 217 (2005).

2012When a defendant raises a sufficiency of the evidence claim, the relevant inquiry is “whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” (Internal quotation marks omitted.) People v. Collins, 214 Ill. 2d 206, 217 (2005).

66
People v. Coxgreen
ill · 2001 · cited in 6 Illinois opinions naming this issue, 2004–2021
2 sentences

2011As we have already stated when reviewing a sufficiency of the evidence claim, our inquiry is limited to “whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” (Emphasis in original.) Jackson, 443 U.S. at 319 ; accord Cox, 195 Ill. 2d at 387 .

2011As we have already stated when reviewing a sufficiency of the evidence claim, our inquiry is limited to “whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” (Emphasis in original.) Jackson, 443 U.S. at 319 ; accord Cox, 195 Ill. 2d at 387 .

66
People v. Smithgreen
ill · 1999 · cited in 7 Illinois opinions naming this issue, 2007–2024
2 sentences

2024People v. Smith, 185 Ill. 2d 532, 541 (1999).

2009“This court will not retry a defendant when considering a sufficiency of the evidence challenge.” People v. Wheeler, 226 Ill. 2d 92, 114 (2007), citing People v. Smith, 185 Ill. 2d 532, 541 (1999).

47
People v. Piatkowskigreen
ill · 2007 · cited in 6 Illinois opinions naming this issue, 2010–2026
2 sentences

2023See Piatkowski, 225 Ill. 2d at 566 (whether the evidence is closely balanced is a separate question from a sufficiency of the evidence claim, where “[t]he relevant inquiry for reasonable doubt purposes is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt”).

2023See Piatkowski, 225 Ill. 2d at 566 (whether the evidence is closely balanced is a separate question from a sufficiency of the evidence claim).

46
People v. Colemangreen
ill · 1998 · cited in 4 Illinois opinions naming this issue, 2016–2025
2 sentences

2025People v. Coleman, 183 Ill. 2d 366, 393 (1998).

2021People v. Coleman, 183 Ill. 2d 366, 393 (1998).

44
People v. Jacksongreen
illappct · 2005 · cited in 4 Illinois opinions naming this issue, 2013–2014
2 sentences

2014People v. Jackson, 358 Ill.

2014People v. Jackson, 358 Ill.

44
People v. Siguenza-Britogreen
ill · 2009 · cited in 4 Illinois opinions naming this issue, 2011–2023
2 sentences

2023People v. Siguenza-Brito, 235 Ill. 2d 213, 228 (2009).

2021In his brief, defendant’s argument focuses on the expert testimony and fails to even discuss defendant’s admissions and Tammy’s excited utterances, confirming that it was defendant who “beat her.” On direct appeal, counsel must evaluate the merits of a sufficiency of the evidence claim, recognizing that “a criminal conviction will not be set aside unless the evidence is so improbable or unsatisfactory as to create a reasonable doubt of the defendant’s guilt.” People v. Siguenza-Brito, 235 Ill. 2d 213, 225 (2009). ¶ 46 The argument that appellate counsel was ineffective for conceding that defen

34
People v. Saxongreen
illappct · 2007 · cited in 3 Illinois opinions naming this issue, 2024–2024
2 sentences

2024See, e.g., Saxon, 374 Ill.

2024See, e.g., Saxon, 374 Ill.

33
People v. Davisongreen
ill · 2009 · cited in 3 Illinois opinions naming this issue, 2016–2019
2 sentences

2019People v. Davison, 233 Ill. 2d 30, 43 (2009).

2016People v. Davison, 233 Ill. 2d 30, 43 (2009).

33
People v. Smithgreen
ill · 1997 · cited in 3 Illinois opinions naming this issue, 1999–2004
2 sentences

2004People v. Smith , 177 Ill. 2d 53, 73 (1997).

1999People v. Smith, 177 Ill. 2d 53, 73 , 685 N.E.2d 880, 888 (1997).

33
People v. Ryan B.green
ill · 2004 · cited in 3 Illinois opinions naming this issue, 2022–2022
2 sentences

2022Cf. In re Ryan B., 212 Ill. 2d 226, 231 (2004) (applying de novo review to a sufficiency of the evidence challenge to determine if uncontested facts satisfied the statutory elements of the offense).

2022Cf. In re Ryan B., 212 Ill. 2d 226, 231 (2004) (applying de novo review to a sufficiency of the evidence challenge to determine if uncontested facts satisfied the statutory elements of the offense).

23
People v. Pollockgreen
ill · 2002 · cited in 3 Illinois opinions naming this issue, 2020–2021
2 sentences

2021In deciding a sufficiency of the evidence claim, “the reviewing court must allow all reasonable inferences in favor of the prosecution.” Id. at 280 .

2020People v. Pollock, 202 Ill. 2d 189, 217 (2002). ¶ 30 To sustain a conviction for unlawful possession with intent to deliver, the State must prove (1) defendant knew of the narcotics, (2) the narcotics were in his immediate possession or control, and (3) defendant intended to deliver the narcotics.

23
People v. Reedgreen
illappct · 2009 · cited in 2 Illinois opinions naming this issue, 2021–2024
2 sentences

2024Although that would be a legally inconsistent verdict, an “inconsistent answer to the special interrogatory is not part of the sufficiency-of-the-evidence analysis.” People v. Reed, 396 Ill.

2021See, e.g., id. at 649 (“the alleged inconsistent answer to the special interrogatory is not part of the sufficiency-of-the-evidence analysis”).

22
People v. Hernandezgreen
illappct · 2012 · cited in 2 Illinois opinions naming this issue, 2024–2024
2 sentences

2024People v. Hernandez, 2012 IL App (1st) 092841, ¶ 67 (“the harmless-error inquiry was, ‘Is it clear beyond a reasonable doubt that a rational jury would have found the defendant guilty absent the error?’ [Citation.] This inquiry is different than that regarding sufficiency of the evidence.”).

2024People v. Hernandez, 2012 IL App (1st) 092841, ¶ 67 (“[T]he harmless-error inquiry was, ‘Is it clear beyond a reasonable doubt that a rational jury would have found the defendant guilty absent the error?’ [Citation.] This inquiry is different than that regarding sufficiency of the evidence.”).

22
People v. De Filippogreen
ill · 2009 · cited in 2 Illinois opinions naming this issue, 2024–2024
2 sentences

2024Specifically, defendant asserts that the State failed to show that defendant possessed the requisite intent or that he shared a common criminal design with the shooter. ¶ 30 “In reviewing a sufficiency of the evidence claim, a reviewing court must determine whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” (Emphasis in original and internal quotation marks omitted.) People v. De Filippo, 11 No. 1-20-0095 235 Ill. 2d 377, 384-85 (2009).

2024Sufficiency of the Evidence ¶ 26 Respondent argues that even if the circuit court did not err by denying his motion for a directed finding, the evidence regarding whether he had been issued a FOID card was insufficient to support a conviction. ¶ 27 “In reviewing a sufficiency of the evidence claim, a reviewing court must determine whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” (emphasis in original) (internal quotation marks omitted.) People v. De Fil

22
Strickland v. Washingtongreen
scotus · 1984 · cited in 2 Illinois opinions naming this issue, 2020–2023
2 sentences

2023App. 3d 341, 372 (2010); see also People v. Coleman, 2011 IL App (1st) 091005, ¶ 43 (citing Strickland, 466 U.S. at 694 ). ¶ 51 In the present case, the petitioner did not make an arguable claim that the result of his direct appeal would have been different had appellate counsel raised a sufficiency of the evidence claim regarding his aggravated kidnapping conviction. ¶ 52 The petitioner’s aggravated kidnapping conviction was premised on allegations that he knowingly and secretly confined M.B.-F. against her will and committed the felony offense of criminal sexual abuse. 720 ILCS 5/10-2(a)(3)

2020Claims of ineffective assistance of counsel are evaluated under the two-prong test set forth in Strickland v. Washington, 466 U.S. 668, 688, 694 (1984), which requires a showing that counsel’s performance “fell below an objective standard of reasonableness” and that the deficient performance was prejudicial in that “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Not only did counsel fail to include a sufficiency-of- the-evidence claim supported by affidavits in the motion to withdraw, he raised the claim

22
People v. Mooregreen
illappct · 1996 · cited in 2 Illinois opinions naming this issue, 2017–2017
22
People v. Oliveragreen
ill · 1995 · cited in 2 Illinois opinions naming this issue, 2014–2014
22
People v. Thomasgreen
ill · 1997 · cited in 2 Illinois opinions naming this issue, 2014–2014
22
In Re Alfred HHgreen
ill · 2009 · cited in 2 Illinois opinions naming this issue, 2014–2014
22
In Re JBgreen
ill · 2003 · cited in 2 Illinois opinions naming this issue, 2014–2014
22
People v. Evansgreen
ill · 2004 · cited in 2 Illinois opinions naming this issue, 2005–2005
22
People v. Beszgreen
illappct · 2003 · cited in 2 Illinois opinions naming this issue, 2003–2004
22
People v. Smithgreen
ill · 1992 · cited in 2 Illinois opinions naming this issue, 2002–2002
22
People v. Batchelorgreen
ill · 1996 · cited in 2 Illinois opinions naming this issue, 1998–1998
22
People v. Graygreen
ill · 2017 · cited in 4 Illinois opinions naming this issue, 2018–2022
2 sentences

2019Castillo argues that his conviction for first degree murder should be reduced to involuntary manslaughter because the evidence demonstrated that he acted recklessly and not knowingly. ¶ 25 When reviewing a sufficiency of the evidence claim, the appropriate inquiry is whether, “after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” (Emphasis omitted.) Jackson v. Virginia, 443 U.S. 307, 319 (1979); People v. Gray, 2017 IL 120958, ¶ 35 .

2018Cooper, 194 Ill. 2d at 434 . ¶ 55 When reviewing a sufficiency of the evidence claim, the appropriate inquiry is whether, after viewing the evidence in the light most favorable to the State, “ ‘any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.’ ” (Emphasis added.) People v. Gray, 2017 IL 120958, ¶ 35 (quoting People v. Belknap, 2014 IL 117094 , ¶ 67, quoting People v. Collins, 106 Ill. 2d 237, 261 (1985), quoting Jackson v. Virginia, 443 U.S. 307, 319 (1979)).

14
People v. Cathy M.green
illappct · 2001 · cited in 2 Illinois opinions naming this issue, 2018–2019
2 sentences

2019In re Cathy M., 326 Ill.

2018In re Cathy M. , 326 Ill.

12
People v. Coopergreen
ill · 2000 · cited in 2 Illinois opinions naming this issue, 2007–2018
2 sentences

2018Cooper, 194 Ill. 2d at 434 . ¶ 55 When reviewing a sufficiency of the evidence claim, the appropriate inquiry is whether, after viewing the evidence in the light most favorable to the State, “ ‘any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.’ ” (Emphasis added.) People v. Gray, 2017 IL 120958, ¶ 35 (quoting People v. Belknap, 2014 IL 117094 , ¶ 67, quoting People v. Collins, 106 Ill. 2d 237, 261 (1985), quoting Jackson v. Virginia, 443 U.S. 307, 319 (1979)).

2007This standard of review applies, “regardless of whether the evidence is direct or circumstantial [citation], and regardless of whether the defendant receives a bench or jury trial [citation].” People v. Cooper, 194 Ill. 2d 419, 431 (2000). -16- This court will not retry a defendant when considering a sufficiency of the evidence challenge.

12
People v. Whitegreen
illappct · 2017 · cited in 2 Illinois opinions naming this issue, 2018–2018
12
People v. Wildergreen
illappct · 2005 · cited in 2 Illinois opinions naming this issue, 2011–2011
12
People v. McDonaldgreen
ill · 1995 · cited in 1 Illinois opinions naming this issue, 2025–2025
11
People v. Krinitskygreen
illappct · 2012 · cited in 1 Illinois opinions naming this issue, 2025–2025
11
People v. Cliftongreen
illappct · 2019 · cited in 1 Illinois opinions naming this issue, 2025–2025
11
People v. Clarkgreen
illappct · 2010 · cited in 1 Illinois opinions naming this issue, 2025–2025
11
People v. Morenogreen
illappct · 2015 · cited in 1 Illinois opinions naming this issue, 2025–2025
11
People v. Basilegreen
illappct · 2022 · cited in 1 Illinois opinions naming this issue, 2024–2024
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
People v. Ryan B.green
ill · 2004 · cited in 3 Illinois opinions naming this issue, 2022–2022
2 sentences

2022Cf. In re Ryan B., 212 Ill. 2d 226, 231 (2004) (applying de novo review to a sufficiency of the evidence challenge to determine if uncontested facts satisfied the statutory elements of the offense).

2022Cf. In re Ryan B., 212 Ill. 2d 226, 231 (2004) (applying de novo review to a sufficiency of the evidence challenge to determine if uncontested facts satisfied the statutory elements of the offense).

13

Also cited on this issue (32)

CaseCitedYears
People v. McCarter green
illappct · 2011
2 sentences

2015In McCarter, we held that "[b]ecause the defendant's challenge is directed at the quantum of evidence presented against him, the correct standard of review is that which applies to the sufficiency of the evidence challenge." McCarter, 2011 IL App (1st) 092864, ¶ 60 .

2015In McCarter, we held that "[b]ecause the defendant's challenge is directed at the quantum of evidence presented against him, the correct standard of review is that which applies to the sufficiency of the evidence challenge." McCarter, 2011 IL App (1st) 092864, ¶ 60 .

62015–2015
People v. Taylor green
illappct · 2012
2 sentences

2019The Taylor court stated that " Baskerville confirms that the relevant issue in weighing a sufficiency-of-the-evidence challenge to a conviction for obstruction of justice is whether the defendant's conduct actually posed a material impediment to the administration of justice." 2012 IL App (2d) 110222 , ¶ 17, 362 Ill.Dec. 38 , 972 N.E.2d 753 . ¶ 44 Here, the defendant urges us to follow Taylor and reverse his conviction because he alleges that the State did not prove that his furnishing the false name caused a material impediment to the administration of justice.

2019Relying on this principle, the court in Taylor broadened the holding in Baskerville by applying it to the issue of obstructing justice by furnishing false information, stating that “Baskerville confirms that the relevant issue in weighing a sufficiency-of-the-evidence challenge to a conviction for obstruct[ing] *** justice is whether the defendant’s conduct actually posed a material impediment to the administration of justice.” Taylor, 2012 IL App (2d) 110222, ¶ 17 . ¶ 23 As noted, the defendant in the instant case cites Taylor to support his argument that his conviction must be reversed becau

32019–2019
People v. Jones green
ill · 2004
2 sentences

2026People v. Jones, 211 Ill. 2d 140 , 143 (2004).

2021My colleagues should not have addressed the argument. “[A]ny issues to be reviewed - must - - be presented in the petition filed in the circuit court.” People v. Jones, 211 Ill. 2d 140 , 148 (2004).

22021–2026
People v. Wright green
ill · 2017
2 sentences

2025In his reply brief, defendant explicitly abandoned his third and fourth arguments, leaving only the first two for our consideration. ¶ 19 A. Sufficiency of the Evidence ¶ 20 When presented with a sufficiency of the evidence claim, this court “does not retry the defendant, and the trier of fact remains responsible for making determinations regarding the credibility of witnesses, the weight to be given to their testimony, and the reasonable inferences to be drawn from the evidence.” People v. Wright, 2017 IL 119561 , ¶ 70.

2025As the evidence below consisted almost entirely of Patricia and defendant’s respective accounts of the altercation, defendant’s conviction certainly relies on the court’s credibility findings. 8 No. 1-23-2356 ¶ 25 When presented with a sufficiency of the evidence claim, this court “does not retry the defendant, and the trier of fact remains responsible for making determinations regarding the credibility of witnesses, the weight to be given to their testimony, and the reasonable inferences to be drawn from the evidence.” People v. Wright, 2017 IL 119561, ¶ 70 .

22025–2025
People v. Hardman green
ill · 2017
2 sentences

2025People v. Hardman, 2017 IL 121453 , ¶ 37.

2021Hardman, 2017 IL 121453, ¶ 37 . ¶ 25 Under that standard, reviewing courts draw all reasonable inferences from the evidence in favor of the prosecution and will not retry the defendant.

22021–2025
People v. Newton green
ill · 2018
2 sentences

2024“All reasonable inferences from the evidence must be drawn in favor of the prosecution.” People v. Newton, 2018 IL 122958, ¶ 24 .

2024“All reasonable inferences from the evidence must be drawn in favor of the prosecution.” People v. Newton, 2018 IL 122958, ¶ 24 .

22024–2024
People v. McKown green
ill · 2010
2 sentences

2018McKown , 236 Ill. 2d at 311 , 338 Ill.Dec. 415 , 924 N.E.2d 941 ; White , 2017 IL App (1st) 142358 , ¶ 36, 412 Ill.Dec. 25 , 74 N.E.3d 492 (observing "the minimal standard for a sufficiency of the evidence challenge").

2018McKown , 236 Ill. 2d at 311 , 338 Ill.Dec. 415 , 924 N.E.2d 941 ; White , 2017 IL App (1st) 142358 , ¶ 36, 412 Ill.Dec. 25 , 74 N.E.3d 492 (observing "the minimal standard for a sufficiency of the evidence challenge").

22018–2018
People v. Jiles green
illappct · 2006
22014–2014
People v. Dennis green
ill · 1998
22012–2012
People v. Lundy green
illappct · 2002
22003–2003
People v. Minniweather green
illappct · 1998
21999–1999
People v. Williams green
ill · 1987
21999–1999
Cataldo v. Meskill green
scotus · 1985
21992–1993
Prudential-Bache Securities Inc. v. Angelastro red
scotus · 1985
21992–1993
Patrick v. English green
sc · 1917
21992–1993
People v. Daniels green
illappct · 2025
12026–2026
Neil v. Biggers green
scotus · 1972
12026–2026
People v. Lamborn green
ill · 1999
12025–2025
People v. Flores green
illappct · 2022
12025–2025
People v. Jones green
ill · 2023
12025–2025
People v. Martin green
ill · 2011
12025–2025
People v. West green
ill · 1999
12025–2025
People v. Span green
illappct · 2011
12024–2024
People v. Cooper green
illappct · 2024
12024–2024
People v. Sebby green
ill · 2017
12024–2024
People v. Winston green
illappct · 2020
12023–2023
People v. Campbell green
illappct · 2019
12023–2023
Southern Wine and Spirits of Illinois v. Steiner green
illappct · 2014
12022–2022
People v. Coleman green
illappct · 2015
12022–2022
Smith v. Cain green
scotus · 2012
12021–2021
People v. Mars green
illappct · 2012
12021–2021
People v. Spencer green
illappct · 2012
12021–2021

Statutes the citing opinions construe

IL § 725 ILCS 5/122-1 (19) IL § 720 ILCS 5/5-2 (18) IL § 720 ILCS 5/9-1 (17) IL § 720 ILCS 5/24-1.1 (14) IL § 720 ILCS 5/8-4 (14) IL § 720 ILCS 5/4-5 (12) IL § 720 ILCS 5/10-2 (11) IL § 720 ILCS 5/10-1 (10) IL § 720 ILCS 5/12-3.2 (10) IL § 625 ILCS 5/11-501 (9) IL § 730 ILCS 5/5-4.5-25 (9) IL § 725 ILCS 5/111-3 (8)

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

OH 1032 (1972–2026) LA 995 (1984–2026) PA 634 (1975–2026) TX 318 (1984–2026) IN 314 (1986–2025) WA 279 (1992–2026) CA 225 (1988–2026) CT 210 (1985–2026) NE 202 (1998–2025) TN 191 (1996–2026) IL 189 (1989–2026) IA 187 (1984–2026) MN 139 (1987–2026) NM 117 (1995–2025) MI 98 (1985–2026) MO 97 (1987–2025) VA 76 (1996–2026) WI 64 (1986–2026) CO 62 (1994–2026) UT 53 (1993–2026) WY 53 (1986–2026) FL 45 (1990–2025) KS 45 (1981–2026) AR 44 (2002–2026) ND 42 (1993–2026) NH 34 (1991–2025) MS 29 (1995–2024) GA 24 (1986–2024) NC 23 (1982–2026) ME 23 (1994–2025) NV 17 (1976–2022) OK 16 (1986–2013) MD 15 (1972–2026) AL 14 (1984–2025) DC 14 (1992–2025) WV 13 (1995–2024) MA 12 (1996–2024) NJ 12 (1996–2026) VT 10 (2013–2021) AZ 9 (2006–2026) GU 9 (2021–2024) MT 8 (1991–2024) ID 8 (2013–2021) HI 7 (2007–2023) DE 7 (2017–2025) VI 6 (2012–2017) OR 4 (2004–2025) SD 4 (2009–2022) KY 4 (2009–2025) SC 3 (2013–2020) AK 3 (2014–2021) RI 2 (2015–2015) NY 2 (2005–2025)

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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