Eighth Amendment violation (Massachusetts) · Go Syfert
← Massachusetts issues

Eighth Amendment violation in Massachusetts

30 Massachusetts opinions name it 3 courts 1976–2026 8 in the last five years

The cases below were cited by Massachusetts 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 (35)

CaseFollowedCited
Torres v. Commissioner of Correctiongreen
mass · 1998 · cited in 5 Massachusetts opinions naming this issue, 2021–2026
2 sentences

2026Wilson v. Seiter, 501 U.S. 294, 298 (1991). "[W]hether prison conditions are sufficiently harmful to establish an Eighth Amendment violation[] is a purely legal determination for the court to make." Torres, 427 Mass. at 614 .

2026Wilson v. Seiter, 501 U.S. 294, 298 (1991). "[W]hether prison conditions are sufficiently harmful to establish an Eighth Amendment violation[] is a purely legal determination for the court to make." Torres, 427 Mass. at 614 .

25
Farmer v. Brennangreen
scotus · 1994 · cited in 5 Massachusetts opinions naming this issue, 1997–2025
2 sentences

2021Such an occurrence can be the basis for an Eighth Amendment claim, if it is shown to be caused by an unconstitutional "condition of confinement," see Farmer v. Brennan, 511 U.S. 825 (1994).

2021Such an occurrence can be the basis for an Eighth Amendment claim, if it is shown to be caused by an unconstitutional "condition of confinement," see Farmer v. Brennan, 511 U.S. 825 (1994).

25
Wilson v. Seitergreen
scotus · 1991 · cited in 3 Massachusetts opinions naming this issue, 1992–2026
2 sentences

2026Wilson v. Seiter, 501 U.S. 294, 298 (1991). "[W]hether prison conditions are sufficiently harmful to establish an Eighth Amendment violation[] is a purely legal determination for the court to make." Torres, 427 Mass. at 614 .

2026Wilson v. Seiter, 501 U.S. 294, 298 (1991). "[W]hether prison conditions are sufficiently harmful to establish an Eighth Amendment violation[] is a purely legal determination for the court to make." Torres, 427 Mass. at 614 .

23
Rebel Oil Co. v. Atlantic Richfield Co.green
scotus · 1998 · cited in 3 Massachusetts opinions naming this issue, 2021–2024
2 sentences

2024See Torres v. Commissioner of Correction, 427 Mass. 611, 614 , cert. denied, 525 U.S. 1017 (1998) ("whether prison conditions are sufficiently harmful to establish an Eighth Amendment violation, is a purely legal determination for the court to make").

2024See Torres v. Commissioner of Correction, 427 Mass. 611, 614 , cert. denied, 525 U.S. 1017 (1998) ("whether prison conditions are sufficiently harmful to establish an Eighth Amendment violation, is a purely legal determination for the court to make").

23
Helling v. McKinneygreen
scotus · 1993 · cited in 3 Massachusetts opinions naming this issue, 1994–2024
2 sentences

2024Cf. Helling v. McKinney, 509 U.S. 25, 36 (1993) (regarding prison conditions, Eighth Amendment analysis requires both "scientific and statistical inquiry into the seriousness of the potential harm" and "assess[ment] whether society considers the risk . . . to be so 3 On remand, the judge heard expert testimony and oral argument and accepted an additional exhibit in evidence, before issuing findings of fact and conclusions of law on whether mandatory life without parole sentences for eighteen through twenty year old offenders violates art. 26.

1994Last, I would follow the test annunciated in Helling v. McKinney, 113 S. Ct. 2475 (1993). 3 In Helling, supra at 2481 , the United States Supreme Court held that “[a prisoner] could state a cause of action under the Eighth Amendment by alleging that [prison officials] have, with deliberate indifference, exposed him to levels of [environmental tobacco smoke] that pose an unreasonable risk of serious damage to his future health.” The Supreme Court then remanded the case “to the District Court to provide an opportunity for [the prisoner] to prove his allegations, which will require him to prove b

23
Rhodes v. Chapmangreen
scotus · 1981 · cited in 3 Massachusetts opinions naming this issue, 1993–2020
2 sentences

2020See also Rhodes, 452 U.S. at 347 (Eighth Amendment violation requires showing that living conditions amount to "serious deprivation of basic human needs," including denial of medical care for serious medical needs).

2018To prove a "conditions of confinement" claim under the Eighth Amendment, Butler must show (1) conditions "sufficiently serious" as to "result in the denial of the 'minimal civilized measure of life's necessities,' " *349 Farmer v. Brennan , 511 U.S. 825 , 832, 834, 114 S.Ct. 1970 , 128 L.Ed.2d 811 (1994), quoting from Rhodes v. Chapman , 452 U.S. 337 , 347, 101 S.Ct. 2392 , 69 L.Ed.2d 59 (1981), and (2) that the department acted with "deliberate indifference" to his health or safety. 14 Farmer v. Brennan , supra at 834 , 114 S.Ct. 1970 . *88 "No static 'test' can exist by which courts determin

23
United States v. Bajakajiangreen
scotus · 1998 · cited in 2 Massachusetts opinions naming this issue, 2006–2025
2 sentences

2025He does not raise an Eighth Amendment claim or make any reasoned argument that nonrenewal is "grossly disproportional to the gravity of [his] offense." United States v. Bajakajian, 524 U.S. 321, 334 (1998).

2025He does not raise an Eighth Amendment claim or make any reasoned argument that nonrenewal is "grossly disproportional to the gravity of [his] offense." United States v. Bajakajian, 524 U.S. 321, 334 (1998).

22
Estelle v. Gamblegreen
scotus · 1976 · cited in 2 Massachusetts opinions naming this issue, 1993–2002
2 sentences

2002In order to establish an Eighth Amendment claim arising out of inadequate medical care, a prisoner must prove “deliberate indifference to [his] serious medical needs.” Estelle v. Gamble, 97 S.Ct. 285, 291 (1976).

2002In order to establish an Eighth Amendment claim arising out of inadequate medical care, a prisoner must prove “deliberate indifference to [his] serious medical needs.” Estelle v. Gamble, 97 S.Ct. 285, 291 (1976).

22
Hudson v. McMilliangreen
scotus · 1992 · cited in 3 Massachusetts opinions naming this issue, 1997–2018
2 sentences

2018"Because routine discomfort is part of the penalty that criminal offenders pay for their offenses against society, only those deprivations denying the minimal civilized measure of life's necessities are sufficiently grave to form the basis of an Eighth Amendment violation." Hudson v. McMillian , 503 U.S. 1 , 9, 112 S.Ct. 995 , 117 L.Ed.2d 156 (1992) (citation and quotation omitted).

2018"Because routine discomfort is part of the penalty that criminal offenders pay for their offenses against society, only those deprivations denying the minimal civilized measure of life's necessities are sufficiently grave to form the basis of an Eighth Amendment violation." Hudson v. McMillian , 503 U.S. 1 , 9, 112 S.Ct. 995 , 117 L.Ed.2d 156 (1992) (citation and quotation omitted).

13
DuPont v. Commissioner of Correctiongreen
mass · 2007 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
2 sentences

2024See DuPont, 448 Mass. at 398 ("no reasonable expectation of proving an essential element of th[e] [plaintiff]'s case" [citation omitted]).

2024See DuPont, 448 Mass. at 398 ("no reasonable expectation of proving an essential element of th[e] [plaintiff]'s case" [citation omitted]).

11
Kosilek v. Spencergreen
ca1 · 2014 · cited in 1 Massachusetts opinions naming this issue, 2024–2024
1 sentence

2024Compare Torres v. Commissioner of Correction, 427 Mass. 611, 615-616 , cert. denied, 525 U.S. 1017 (1998) (stating art. 26 standard), with Kosilek v. Spencer, 774 F.3d 63, 82 (1st Cir. 2014), cert. denied sub nom., Kosilek v. O'Brien, 575 U.S. 998 (2015) (stating Eighth Amendment standard).

11
Joe Marsh, Leroy Owens v. Butler County, Alabama, the Butler County Commissiongreen
ca11 · 2001 · cited in 1 Massachusetts opinions naming this issue, 2021–2021
2 sentences

2021Although there had been no prior inmate-on-inmate attacks involving the large hot pots, "an Eighth Amendment violation can arise from unsafe conditions of confinement even if no assault or similar physical injury has yet occurred." Marsh v. Butler County, 268 F.3d 1014, 1034 (11th Cir. 2001) (en banc).

2021Although there had been no prior inmate-on-inmate attacks involving the large hot pots, "an Eighth Amendment violation can arise from unsafe conditions of confinement even if no assault or similar physical injury has yet occurred." Marsh v. Butler County, 268 F.3d 1014, 1034 (11th Cir. 2001) (en banc).

11
Pineda v. Toomeygreen
ca1 · 2008 · cited in 1 Massachusetts opinions naming this issue, 2020–2020
2 sentences

2020See Zingg v. Groblewski, 907 F.3d 630, 635 (1st Cir. 2018); Pineda v. Toomey, 533 F.3d 50, 54 (1st Cir. 2008).

2020See Zingg v. Groblewski, 907 F.3d 630, 635 (1st Cir. 2018); Pineda v. Toomey, 533 F.3d 50, 54 (1st Cir. 2008).

11
Trop v. Dullesgreen
scotus · 1958 · cited in 1 Massachusetts opinions naming this issue, 2020–2020
2 sentences

2020To prevail on an Eighth Amendment claim, an individual must establish that the punishment is inconsistent with "the evolving standards of decency that mark the progress of a maturing society." See Trop v. Dulles, 356 U.S. 86, 100-101 (1958).

2020To prevail on an Eighth Amendment claim, an individual must establish that the punishment is inconsistent with "the evolving standards of decency that mark the progress of a maturing society." See Trop v. Dulles, 356 U.S. 86, 100-101 (1958).

11
Zingg v. Groblewskigreen
ca1 · 2018 · cited in 1 Massachusetts opinions naming this issue, 2020–2020
2 sentences

2020See Zingg v. Groblewski, 907 F.3d 630, 635 (1st Cir. 2018); Pineda v. Toomey, 533 F.3d 50, 54 (1st Cir. 2008).

2020See Zingg v. Groblewski, 907 F.3d 630, 635 (1st Cir. 2018); Pineda v. Toomey, 533 F.3d 50, 54 (1st Cir. 2008).

11
MacLean v. State Board of Retirementgreen
mass · 2000 · cited in 1 Massachusetts opinions naming this issue, 2016–2016
1 sentence

2016This court has considered the claim’s second part, excessiveness, in two previous cases, MacLean v. State Bd. of Retirement, 432 Mass. 339, 347-350 (2000), and Maher v. Retirement Bd. of Quincy, 452 Mass. 517, 523-525 (2008), cert. denied, 556 U.S. 1166 (2009). 8 We have never addressed the threshold question whether the forfeiture of a public employee’s pension under § 15 (4) is a “fine” under the Eighth Amendment.

11
Doherty v. Retirement Board of Medfordgreen
mass · 1997 · cited in 1 Massachusetts opinions naming this issue, 2008–2008
2 sentences

2008General Laws c. 32, § 16 (3) (a) (2), expressly provides that “the decision of the [District] [C]curt [in reviewing the board’s decision] shall be final.” See note 3, supra. “[Certiorari is the only way of reviewing decisions declared final by statute.” Doherty v. Retirement Bd. of Medford, 425 Mass. 130, 134 (1997), quoting MacKenzie v. School Comm. of Ipswich, 342 Mass. 612, 614 (1961).

2008General Laws c. 32, § 16 (3) (a) (2), expressly provides that “the decision of the [District] [C]curt [in reviewing the board’s decision] shall be final.” See note 3, supra. “[Certiorari is the only way of reviewing decisions declared final by statute.” Doherty v. Retirement Bd. of Medford, 425 Mass. 130, 134 (1997), quoting MacKenzie v. School Comm. of Ipswich, 342 Mass. 612, 614 (1961).

11
MacKenzie v. School Committee of Ipswichgreen
mass · 1961 · cited in 1 Massachusetts opinions naming this issue, 2008–2008
2 sentences

2008General Laws c. 32, § 16 (3) (a) (2), expressly provides that “the decision of the [District] [C]curt [in reviewing the board’s decision] shall be final.” See note 3, supra. “[Certiorari is the only way of reviewing decisions declared final by statute.” Doherty v. Retirement Bd. of Medford, 425 Mass. 130, 134 (1997), quoting MacKenzie v. School Comm. of Ipswich, 342 Mass. 612, 614 (1961).

2008General Laws c. 32, § 16 (3) (a) (2), expressly provides that “the decision of the [District] [C]curt [in reviewing the board’s decision] shall be final.” See note 3, supra. “[Certiorari is the only way of reviewing decisions declared final by statute.” Doherty v. Retirement Bd. of Medford, 425 Mass. 130, 134 (1997), quoting MacKenzie v. School Comm. of Ipswich, 342 Mass. 612, 614 (1961).

11
Commonwealth v. Bairdgreen
mass · 1969 · cited in 1 Massachusetts opinions naming this issue, 2008–2008
2 sentences

2008Rptr. 593, n.9 (Super.Ct. 2005) (Agnes, J.) (noting that the defendant could not challenge the potential penalties for violating his parole unless such a violation occurred); Commonwealth v. Baird, 355 Mass. 746, 754-56 (1969) (declining to consider an Eighth Amendment challenge where the defendant had not yet been sentenced for a crime).

2008Rptr. 593, n.9 (Super.Ct. 2005) (Agnes, J.) (noting that the defendant could not challenge the potential penalties for violating his parole unless such a violation occurred); Commonwealth v. Baird, 355 Mass. 746, 754-56 (1969) (declining to consider an Eighth Amendment challenge where the defendant had not yet been sentenced for a crime).

11
Clancy v. McCabegreen
mass · 2004 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
2 sentences

2005Clancy v. McCabe, 441 Mass. at 318 .

2005Clancy v. McCabe, 441 Mass. at 318 .

11
Hathaway v. Coughlingreen
ca2 · 1994 · cited in 1 Massachusetts opinions naming this issue, 2002–2002
2 sentences

2002To determine what constitutes a serious medical need, a court contemplates, “a condition of urgency” that may result in “degeneration” or “extreme pain.” Chance, 143 F.3d at 702, citing Hathaway v. Coughlin, 37 F.3d 63, 66 (2d Cir. 1994).

2002To determine what constitutes a serious medical need, a court contemplates, “a condition of urgency” that may result in “degeneration” or “extreme pain.” Chance, 143 F.3d at 702, citing Hathaway v. Coughlin, 37 F.3d 63, 66 (2d Cir. 1994).

11
Chance v. Armstronggreen
ca2 · 1998 · cited in 1 Massachusetts opinions naming this issue, 2002–2002
11
Harrison v. Barkleygreen
ca2 · 2000 · cited in 1 Massachusetts opinions naming this issue, 2002–2002
2 sentences

2002Harrison, 219 F.3d at 137.

2002Harrison, 219 F.3d at 137.

11
United States v. Susan D. Bieri Leonard Bieri, IIIgreen
ca8 · 1995 · cited in 1 Massachusetts opinions naming this issue, 2000–2000
11
No. 98-1467 (Ca-96-1633-A)green
ca4 · 2000 · cited in 1 Massachusetts opinions naming this issue, 2000–2000
11
Hickey v. Reedergreen
ca8 · 1994 · cited in 1 Massachusetts opinions naming this issue, 1998–1998
11
Madrid v. Gomezgreen
cand · 1995 · cited in 1 Massachusetts opinions naming this issue, 1998–1998
11
McGuinness v. Duboisgreen
mad · 1995 · cited in 1 Massachusetts opinions naming this issue, 1997–1997
11
Steven M. Desrosiers v. John J. Morangreen
ca1 · 1991 · cited in 1 Massachusetts opinions naming this issue, 1993–1993
11
Meshkov v. Abington Townshipgreen
paed · 1981 · cited in 1 Massachusetts opinions naming this issue, 1986–1986
11
Madden v. City of Meridengreen
ctd · 1985 · cited in 1 Massachusetts opinions naming this issue, 1986–1986
11
Brewer v. Perringreen
michctapp · 1984 · cited in 1 Massachusetts opinions naming this issue, 1986–1986
11
cluster 308565green
ca2 · 1972 · cited in 1 Massachusetts opinions naming this issue, 1983–1983
11
Coker v. Georgiagreen
scotus · 1977 · cited in 1 Massachusetts opinions naming this issue, 1980–1980
11
United States v. Edward Wayne Beverleygreen
ca9 · 1969 · cited in 1 Massachusetts opinions naming this issue, 1976–1976
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
Miller v. Alabama green
scotus · 2012
2 sentences

2018First, children demonstrate a ' "lack of maturity and an underdeveloped sense of responsibility," leading to recklessness, impulsivity, and heedless risk-taking.' Second, children ' "are more vulnerable ... to negative influences and outside pressures," including from their family and peers; they have limited "contro[l] over their own environment"[;] and [they] lack the ability to extricate themselves from horrific, crime-producing settings.' Finally, 'a child's character is not as "well formed" as an adult's; his traits are "less fixed" and his actions less likely to be evidence of irretrieva

2018First, children demonstrate a ' "lack of maturity and an underdeveloped sense of responsibility," leading to recklessness, impulsivity, and heedless risk-taking.' Second, children ' "are more vulnerable ... to negative influences and outside pressures," including from their family and peers; they have limited "contro[l] over their own environment"[;] and [they] lack the ability to extricate themselves from horrific, crime-producing settings.' Finally, 'a child's character is not as "well formed" as an adult's; his traits are "less fixed" and his actions less likely to be evidence of irretrieva

22013–2018
Massachusetts School of Law at Andover, Inc. v. American Bar Ass'n green
ca1 · 1998
2 sentences

2024Once the Federal case was dismissed on the merits, Federal claim preclusion doctrine barred Smith from raising the art. 26 claim in Superior Court. 6 See Massachusetts Sch. of Law at Andover, Inc., 142 F.3d at 38 .

2024Once the Federal case was dismissed on the merits, Federal claim preclusion doctrine barred Smith from raising the art. 26 claim in Superior Court. 6 See Massachusetts Sch. of Law at Andover, Inc., 142 F.3d at 38 .

12024–2024
Lakin v. Barnhart green
ca1 · 2014
2 sentences

2021The First Circuit termed this a "small number of assaults"; in evaluating "when the risk of violence among inmates is sufficiently 'substantial' to satisfy the first prong of Farmer," the court deemed the padlock risk "well within the zone of those too insubstantial for an Eighth Amendment claim." Id. at 71 .

2021The First Circuit termed this a "small number of assaults"; in evaluating "when the risk of violence among inmates is sufficiently 'substantial' to satisfy the first prong of Farmer," the court deemed the padlock risk "well within the zone of those too insubstantial for an Eighth Amendment claim." Id. at 71 .

12021–2021
Commonwealth v. Villagran green
mass · 2017
2 sentences

2019Therefore, the sole question before us is whether this defendant's sentence crosses the line drawn by art. 26, which prohibits the imposition of "cruel or unusual punishments." "Where a defendant claims that a judge has made an error of constitutional dimension, 'we accept the judge's subsidiary findings of fact absent clear error and leave to the judge the responsibility of determining the weight and credibility to be given ... testimony presented at the motion hearing." Commonwealth v. Perez , 480 Mass. 562 , 567-568, 106 N.E.3d 620 (2018) ( Perez II ), quoting Commonwealth v. Villagran , 47

2019Therefore, the sole question before us is whether this defendant's sentence crosses the line drawn by art. 26, which prohibits the imposition of "cruel or unusual punishments." "Where a defendant claims that a judge has made an error of constitutional dimension, 'we accept the judge's subsidiary findings of fact absent clear error and leave to the judge the responsibility of determining the weight and credibility to be given ... testimony presented at the motion hearing." Commonwealth v. Perez , 480 Mass. 562 , 567-568, 106 N.E.3d 620 (2018) ( Perez II ), quoting Commonwealth v. Villagran , 47

12019–2019
Commonwealth v. Perez green
mass · 2018
2 sentences

2019Therefore, the sole question before us is whether this defendant's sentence crosses the line drawn by art. 26, which prohibits the imposition of "cruel or unusual punishments." "Where a defendant claims that a judge has made an error of constitutional dimension, 'we accept the judge's subsidiary findings of fact absent clear error and leave to the judge the responsibility of determining the weight and credibility to be given ... testimony presented at the motion hearing." Commonwealth v. Perez , 480 Mass. 562 , 567-568, 106 N.E.3d 620 (2018) ( Perez II ), quoting Commonwealth v. Villagran , 47

2019Therefore, the sole question before us is whether this defendant's sentence crosses the line drawn by art. 26, which prohibits the imposition of "cruel or unusual punishments." "Where a defendant claims that a judge has made an error of constitutional dimension, 'we accept the judge's subsidiary findings of fact absent clear error and leave to the judge the responsibility of determining the weight and credibility to be given ... testimony presented at the motion hearing." Commonwealth v. Perez , 480 Mass. 562 , 567-568, 106 N.E.3d 620 (2018) ( Perez II ), quoting Commonwealth v. Villagran , 47

12019–2019
Diatchenko v. District Attorney for the Suffolk District green
mass · 2013
2 sentences

2018First, children demonstrate a ' "lack of maturity and an underdeveloped sense of responsibility," leading to recklessness, impulsivity, and heedless risk-taking.' Second, children ' "are more vulnerable ... to negative influences and outside pressures," including from their family and peers; they have limited "contro[l] over their own environment"[;] and [they] lack the ability to extricate themselves from horrific, crime-producing settings.' Finally, 'a child's character is not as "well formed" as an adult's; his traits are "less fixed" and his actions less likely to be evidence of irretrieva

2018First, children demonstrate a ' "lack of maturity and an underdeveloped sense of responsibility," leading to recklessness, impulsivity, and heedless risk-taking.' Second, children ' "are more vulnerable ... to negative influences and outside pressures," including from their family and peers; they have limited "contro[l] over their own environment"[;] and [they] lack the ability to extricate themselves from horrific, crime-producing settings.' Finally, 'a child's character is not as "well formed" as an adult's; his traits are "less fixed" and his actions less likely to be evidence of irretrieva

12018–2018
Maher v. Retirement Board of Quincy green
mass · 2008
1 sentence

2016This court has considered the claim’s second part, excessiveness, in two previous cases, MacLean v. State Bd. of Retirement, 432 Mass. 339, 347-350 (2000), and Maher v. Retirement Bd. of Quincy, 452 Mass. 517, 523-525 (2008), cert. denied, 556 U.S. 1166 (2009). 8 We have never addressed the threshold question whether the forfeiture of a public employee’s pension under § 15 (4) is a “fine” under the Eighth Amendment.

12016–2016
Roper v. Simmons green
scotus · 2005
1 sentence

2013Miller, supra. First, children demonstrate a “ ‘lack of maturity and an underdeveloped sense of responsibility,’ leading to recklessness, impulsivity, and heedless risk-taking.” Id., quoting Roper, 543 U.S. at 569 .

12013–2013
United States v. James Lippert green
ca8 · 1998
12000–2000
Albert Lopez Gallego v. United States green
ca9 · 1960
11976–1976

Statutes the citing opinions construe

USC § 42u.s.c.1983 (10) MA § Mass. Gen. Laws ch. 12, § 11H (4) MA § Mass. Gen. Laws ch. 211, § 3 (4) MA § Mass. Gen. Laws ch. 249, § 4 (4) MA § Mass. Gen. Laws ch. 32, § 15 (4) MA § Mass. Gen. Laws ch. 265, § 2 (3) MA § Mass. Gen. Laws ch. 268A, § 7 (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

CA 305 (1983–2026) TX 222 (1988–2026) IL 124 (1981–2026) FL 85 (1981–2026) PA 80 (1985–2026) VA 62 (1983–2026) OH 48 (1999–2025) KS 43 (2001–2026) MS 42 (1986–2025) WA 37 (1983–2023) OR 35 (1992–2025) AZ 33 (1978–2024) TN 30 (1994–2022) MA 30 (1976–2026) CO 29 (1990–2026) MI 28 (1984–2025) IA 28 (1999–2022) ID 27 (1983–2024) SD 24 (1980–2024) AL 24 (1984–2026) NY 23 (1974–2026) OK 22 (1987–2020) MO 21 (1993–2023) IN 20 (1979–2024) NC 20 (1991–2025) NJ 20 (1983–2022) GA 18 (1992–2026) KY 17 (2003–2024) MD 17 (1972–2026) CT 17 (1995–2022) WI 14 (1994–2026) AR 14 (1996–2026) LA 13 (1987–2025) DE 13 (1988–2022) DC 13 (1975–2019) UT 13 (1995–2025) SC 12 (1991–2025) WY 12 (1986–2023) NE 11 (1999–2024) NM 9 (1991–2019) MN 8 (1976–2024) MT 8 (1996–2022) WV 7 (1994–2023) VT 6 (1998–2018) NV 6 (1979–2020) ND 6 (1992–2022) ME 5 (1987–2015) AK 4 (2010–2022) VI 3 (2003–2012) NH 3 (1980–2013) RI 3 (2004–2020)

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.

← Caselaw search · G Cite Topics · Brief Check