remnant of abandoned doctrine (New Hampshire) · Go Syfert
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remnant of abandoned doctrine in New Hampshire

30 New Hampshire opinions name it 1 courts 2003–2023 2 in the last five years

The cases below were cited by New Hampshire 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 (9)

CaseFollowedCited
Jacobs v. Director, N.H. Division of Motor Vehiclesgreen
nh · 2003 · cited in 8 New Hampshire opinions naming this issue, 2007–2020
2 sentences

2008The defendant argues that Hamum’s rule should thus be seen as “no more than a remnant of abandoned doctrine.” See Jacobs, 149 N.H. at 505 ; Nieto v. State, 70 P.3d 747 , 748 n.7 (Nev. 2003) (listing the jurisdictions). “[T]he overwhelming majority of states allow for the granting of credit for time served in presentence confinement while awaiting extradition when the sole reason for the foreign incarceration is the offense for which the defendant is ultimately convicted and sentenced.” Nieto, 70 P.3d at 748 .

2007As the discussion below demonstrates, we believe that we must abandon the intermediate scrutiny test we developed in Carson because related principles of law have so far developed as to have left this test “no more than a remnant of abandoned doctrine.” Jacobs, 149 N.H. at 505 (quotation omitted).

48
State v. Holmesgreen
nh · 2007 · cited in 5 New Hampshire opinions naming this issue, 2008–2014
2 sentences

2014We conclude that the defendant has failed to demonstrate that our decision in King “is no more than a remnant of abandoned doctrine,” State v. Holmes, 154 N.H. 723, 729 (2007) (quotation omitted), and we therefore decline to overrule it.

2008To the extent that Gallagher argues that we should overrule Callahan because it is merely a remnant of abandoned doctrine, see State v. Holmes, 154 N.H. 723, 724-25 (2007), we disagree.

35
Maplevale Builders, LLC v. Town of Danvillegreen
nh · 2013 · cited in 3 New Hampshire opinions naming this issue, 2013–2023
2 sentences

2023Maplevale Builders v. Town of Danville, 165 N.H. 99, 105 (2013).

2014Maplevale Builders v. Town of Danville, 165 N.H. 99, 105 (2013) (quotation omitted).

33
Planned Parenthood of Southeastern Pa. v. Caseyred
scotus · 1992 · cited in 3 New Hampshire opinions naming this issue, 2003–2011
2 sentences

2003Several factors inform our judgment, including: (1) “whether the rule has proven to be intolerable simply in defying practical workability,” id. at 854 ; (2) “whether the rule is subject to a kind of reliance that would lend a special hardship to the consequences of overruling,” id.; (3) “whether related principles of law have so far developed as to have left the old rule no more than a remnant of abandoned doctrine,” id. at 855 ; and (4) “whether facts have so changed, or come to be seen so differently, as to have robbed the old rule of significant application or justification,” id.

2003Several factors inform our judgment, including: (1) “whether the rule has proven to be intolerable simply in defying practical workability,” id. at 854 ; (2) “whether the rule is subject to a kind of reliance that would lend a special hardship to the consequences of overruling,” id.; (3) “whether related principles of law have so far developed as to have left the old rule no more than a remnant of abandoned doctrine,” id. at 855 ; and (4) “whether facts have so changed, or come to be seen so differently, as to have robbed the old rule of significant application or justification,” id.

23
State v. Quinterogreen
nh · 2011 · cited in 5 New Hampshire opinions naming this issue, 2012–2020
2 sentences

2020Id. at 532-33 .

2015Quintero, 162 N.H. at 533 .

15
State v. Durangreen
nh · 2008 · cited in 3 New Hampshire opinions naming this issue, 2011–2020
2 sentences

2020“Thus, when asked to reconsider a holding, the question is not whether we would decide the issue differently de novo, but whether the ruling has come to be seen so clearly as error that its enforcement was for that very reason doomed.” Id. 5 We will overturn a decision only after considering: (1) whether the rule has proven to be intolerable simply by defying practical workability; (2) whether the rule is subject to a kind of reliance that would lend a special hardship to the consequence of overruling; (3) whether related principles of law have so far developed as to have left the old rule no

2011Although Duran cited the four-factor test and claimed to apply it, see Duran, 158 N.H. at 153-54 , the actual analysis used by the court in that ease makes it plain that we overruled Hamum not because it had become unworkable or a remnant of abandoned doctrine, as the defendant argued, see id. at 154 , but principally because we believed the case was badly reasoned.

13
Alonzi v. Northeast Generation Services Co.green
nh · 2008 · cited in 3 New Hampshire opinions naming this issue, 2008–2020
2 sentences

2010Viewed in this light, the doctrine of necessaries is “no more than a remnant of abandoned doctrine” that has been “robbed ... [of its] justification.” Alonzi, 156 N.H. at 660 (quotation omitted).

2010Viewed in this light, the doctrine of necessaries is "no more than a remnant of abandoned doctrine" that has been "robbed ... [of its] justification." Alonzi, 156 N.H. at 660 , 940 A.2d 1153 (quotation omitted).

13
State v. Matthewsgreen
nh · 2008 · cited in 1 New Hampshire opinions naming this issue, 2020–2020
1 sentence

2020See Matthews, 157 N.H. at 420 .

11
Appeal of Phillipsgreen
nh · 2013 · cited in 1 New Hampshire opinions naming this issue, 2014–2014
1 sentence

2014Id. at 231-32 (quotation omitted).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
Ford v. New Hampshire Department of Transportation green
nh · 2012
2 sentences

2021Therefore, we will overturn a decision only after considering whether: (1) “the rule has proven to be intolerable simply by defying practical workability”; (2) “the rule is subject to a kind of reliance that would lend a special hardship to the consequence of overruling”; (3) “related principles of law have so far developed as to have left the old rule no more than a remnant of abandoned doctrine”; and (4) “facts have so changed, or come to be seen so differently, as to have robbed the old rule of significant application or justification.” Id. (quotations omitted).

2021“Although these factors guide our judgment, no single factor is wholly determinative, because the doctrine of stare decisis is not one to be either rigidly applied or blindly followed.” Id.

22013–2021
State of New Hampshire v. John A. Smith green
nh · 2014
2 sentences

2017State v. Smith , 166 N.H. 40 , 44, 86 A.3d 114 (2014).

2017State v. Smith , 166 N.H. 40 , 44, 86 A.3d 114 (2014).

12017–2017
Kalil v. Town of Dummer Zoning Board of Adjustment green
nh · 2010
1 sentence

2011Kalil, 159 N.H. at 731 .

12011–2011
Community Resources for Justice, Inc. v. City of Manchester green
nh · 2007
2 sentences

2008Id.

2008We believe that the McKenney-Komisarek rule, regarding the retrospective application of an amendment affecting appellate rights, must be abandoned because “related principles of law have so far developed as to have left [this] old rule no more than a remnant of abandoned doctrine.” Id.

12008–2008
State v. Komisarek green
nh · 1976
1 sentence

2008We overrule McKenney and Komisarek to the extent that they expanded the interpretation of the Ex Post Facto Clause to hold that the State had the burden of demonstrating “a legitimate need to employ [a] new procedure in cases involving prior acts” where “reliance on an established procedure is reasonable.” Komisarek, 116 N.H. at 428 .

12008–2008
Nieto v. State green
nev · 2003
2 sentences

2008The defendant argues that Hamum’s rule should thus be seen as “no more than a remnant of abandoned doctrine.” See Jacobs, 149 N.H. at 505 ; Nieto v. State, 70 P.3d 747 , 748 n.7 (Nev. 2003) (listing the jurisdictions). “[T]he overwhelming majority of states allow for the granting of credit for time served in presentence confinement while awaiting extradition when the sole reason for the foreign incarceration is the offense for which the defendant is ultimately convicted and sentenced.” Nieto, 70 P.3d at 748 .

2008The defendant argues that Hamum’s rule should thus be seen as “no more than a remnant of abandoned doctrine.” See Jacobs, 149 N.H. at 505 ; Nieto v. State, 70 P.3d 747 , 748 n.7 (Nev. 2003) (listing the jurisdictions). “[T]he overwhelming majority of states allow for the granting of credit for time served in presentence confinement while awaiting extradition when the sole reason for the foreign incarceration is the offense for which the defendant is ultimately convicted and sentenced.” Nieto, 70 P.3d at 748 .

12008–2008

Statutes the citing opinions construe

NH § N.H. Rev. Stat. Ann. § 651:2 (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

NM 37 (1998–2026) NH 30 (2003–2023) AK 8 (1993–2024) KS 3 (1994–2009) OK 3 (2001–2018) IA 3 (2022–2022) TN 2 (2000–2000)

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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