first step analysis (Florida) · Go Syfert
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first step analysis in Florida

29 Florida opinions name it 2 courts 1984–2025 3 in the last five years

The cases below were cited by Florida 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 (24)

CaseFollowedCited
LoBello v. State Farm Florida Insurance Co.green
fladistctapp · 2014 · cited in 2 Florida opinions naming this issue, 2023–2025
2 sentences

2025Co., 152 So. 3d 595, 599 (Fla. 2d DCA 2014) and additional citation omitted); Perez v. Citizens Prop.

2023Co., 152 So. 3d 595, 599 (Fla. 2d DCA 2014).

22
Venetian Salami Co. v. Parthenaisgreen
fla · 1989 · cited in 2 Florida opinions naming this issue, 2012–2020
2 sentences

2020Id. at 502 .

2012See id.

12
Blythe v. Atlas Industrial Enterprises, Inc.green
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2024–2024
2 sentences

2024Even so, the Fourth District then certified conflict with France v. France, 90 So. 3d 860 (Fla. 5th DCA 2012), a case addressing only the first step of that test.

2024See id. at 864 (holding that an out-of-state resident can commit a tortious act in Florida simply by recording a Florida resident).

11
Wright v. Stategreen
fladistctapp · 2007 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018See Wright v. State, 983 So. 2d 6, 9 (Fla. 1st DCA 2007).

11
Marcus Jamal Graham v. State of Floridagreen
fla · 2016 · cited in 1 Florida opinions naming this issue, 2017–2017
2 sentences

2017See Graham, 207 So.3d at 141 (relying on the record to determine whether the defendant’s multiple convictions were based on distinct acts); McCarter v. State, 204 So.3d 529, 530 (Fla. 1st DCA 2016) (concluding that,, the record established two distinct acts of solicitation, a request for illicit pictures and a solicitation for a lewd or lascivious molestation, to support appellant’s dual convictions for solicitation and traveling).

2017See Graham, 207 So. 3d at 141 (relying on the record to determine whether the defendant’s multiple convictions were based on distinct acts); McCarter v. State, 204 So. 3d 529, 530 (Fla. 1st DCA 2016) (concluding that the record established two distinct acts of solicitation, a request for illicit pictures and a solicitation for a lewd or lascivious molestation, to support appellant’s dual convictions for solicitation and traveling).

11
Lawrence D. Brown McCarter v. State of Floridagreen
fladistctapp · 2016 · cited in 1 Florida opinions naming this issue, 2017–2017
2 sentences

2017See Graham, 207 So.3d at 141 (relying on the record to determine whether the defendant’s multiple convictions were based on distinct acts); McCarter v. State, 204 So.3d 529, 530 (Fla. 1st DCA 2016) (concluding that,, the record established two distinct acts of solicitation, a request for illicit pictures and a solicitation for a lewd or lascivious molestation, to support appellant’s dual convictions for solicitation and traveling).

2017See Graham, 207 So. 3d at 141 (relying on the record to determine whether the defendant’s multiple convictions were based on distinct acts); McCarter v. State, 204 So. 3d 529, 530 (Fla. 1st DCA 2016) (concluding that the record established two distinct acts of solicitation, a request for illicit pictures and a solicitation for a lewd or lascivious molestation, to support appellant’s dual convictions for solicitation and traveling).

11
R.J.R. v. Stategreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2017–2017
2 sentences

2017A similar analysis was applied in R.J.R. v. State, 88 So.3d 264, 268 (Fla. 1st DCA 2012), when’ this Court observed, “the State failed to establish that the acts occurred in different locations, that there was any temporal break between the two acts that would have enabled R.J.R. to reflect and form a new criminal intent for the second act, or that there were any intervening acts interrupting RJ.R.’s resisting arrest.” Just as was required in the first step of the test, step two requires the examination of the entire record before a court may conclude that multiple acts are distinct for double

2017A similar analysis was applied in R.J.R. v. State, 88 So. 3d 264, 268 (Fla. 1st DCA 2012), when this Court observed, “the State failed to establish that the acts occurred in different locations, that there was any temporal break between the two acts that would have enabled R.J.R. to reflect and form a new criminal intent for the second act, or that there were any intervening acts interrupting R.J.R.’s resisting arrest.” 10 Just as was required in the first step of the test, step two requires the examination of the entire record before a court may conclude that multiple acts are distinct for do

11
Turner v. Stategreen
fladistctapp · 2013 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014See 1500 Coral Towers, 112 So.3d at 543-44 ; Waldrep, 400 So.2d at 785-86 ; Clena Invs., 2012 WL 1004851 , at *4.

11
Maryland v. Shatzergreen
scotus · 2010 · cited in 1 Florida opinions naming this issue, 2013–2013
2 sentences

2013“Relevant factors include the location of the questioning,” “its duration,” “statements made during the interview,” “the presence or absence of physical restraints during the questioning,” and “the release of the interviewee at the end of the questioning.” Howes, 132 S.Ct. at 1189 ; see Maryland v. Shatzer, 559 U.S. 98 , 130 S.Ct. 1213, 1224-26 , 175 L.Ed.2d 1045 (2010); Stansbury, 511 U.S. at 325 , 114 S.Ct. 1526 ; Berkemer v. McCarty, 468 U.S. 420, 437-38 , 104 S.Ct. 3138 , 82 L.Ed.2d 317 (1984); New York v. Quarles, 467 U.S. 649, 655 , 104 S.Ct. 2626 , 81 L.Ed.2d 550 (1984); Oregon v. Mathi

2013“Relevant factors include the location of the questioning,” “its duration,” “statements made during the interview,” “the presence or absence of physical restraints during the questioning,” and “the release of the interviewee at the end of the questioning.” Howes, 132 S.Ct. at 1189 ; see Maryland v. Shatzer, 559 U.S. 98 , 130 S.Ct. 1213, 1224-26 , 175 L.Ed.2d 1045 (2010); Stansbury, 511 U.S. at 325 , 114 S.Ct. 1526 ; Berkemer v. McCarty, 468 U.S. 420, 437-38 , 104 S.Ct. 3138 , 82 L.Ed.2d 317 (1984); New York v. Quarles, 467 U.S. 649, 655 , 104 S.Ct. 2626 , 81 L.Ed.2d 550 (1984); Oregon v. Mathi

11
Justice Administrative Commission v. Lenamongreen
fladistctapp · 2009 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013Comm’n v. Lenamon, 19 So.3d 1158, 1162 (Fla. 2d DCA 2009).

11
United States v. Leonard David Griffingreen
ca8 · 1990 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013“Relevant factors include the location of the questioning,” “its duration,” “statements made during the interview,” “the presence or absence of physical restraints during the questioning,” and “the release of the interviewee at the end of the questioning.” Howes, 132 S.Ct. at 1189 ; see Maryland v. Shatzer, 559 U.S. 98 , 130 S.Ct. 1213, 1224-26 , 175 L.Ed.2d 1045 (2010); Stansbury, 511 U.S. at 325 , 114 S.Ct. 1526 ; Berkemer v. McCarty, 468 U.S. 420, 437-38 , 104 S.Ct. 3138 , 82 L.Ed.2d 317 (1984); New York v. Quarles, 467 U.S. 649, 655 , 104 S.Ct. 2626 , 81 L.Ed.2d 550 (1984); Oregon v. Mathi

11
Gaber v. Stategreen
fla · 1996 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011The analysis of these two statutes reveals no clear statement of legislative intent one way or the other. *558 “[A]bsent an explicit statement of legislative intent to authorize separate punishments for two crimes, application of the Blockburger ‘same-elements’ test pursuant to section 775.021(4) ... is the sole method of determining whether multiple punishments are double-jeopardy violations.” Gaber v. State, 684 So.2d 189, 192 (Fla.1996) (footnote omitted); see also Valdes, 3 So.3d at 1070 (“ ‘Absent a clear statement of legislative intent to authorize separate punishments for two crimes, co

11
Gordon v. Stategreen
fla · 2001 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011The analysis of these two statutes reveals no clear statement of legislative intent one way or the other. *558 “[A]bsent an explicit statement of legislative intent to authorize separate punishments for two crimes, application of the Blockburger ‘same-elements’ test pursuant to section 775.021(4) ... is the sole method of determining whether multiple punishments are double-jeopardy violations.” Gaber v. State, 684 So.2d 189, 192 (Fla.1996) (footnote omitted); see also Valdes, 3 So.3d at 1070 (“ ‘Absent a clear statement of legislative intent to authorize separate punishments for two crimes, co

11
Valdes v. Stategreen
fla · 2009 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011The analysis of these two statutes reveals no clear statement of legislative intent one way or the other. *558 “[A]bsent an explicit statement of legislative intent to authorize separate punishments for two crimes, application of the Blockburger ‘same-elements’ test pursuant to section 775.021(4) ... is the sole method of determining whether multiple punishments are double-jeopardy violations.” Gaber v. State, 684 So.2d 189, 192 (Fla.1996) (footnote omitted); see also Valdes, 3 So.3d at 1070 (“ ‘Absent a clear statement of legislative intent to authorize separate punishments for two crimes, co

11
Small v. Stategreen
fla · 1994 · cited in 1 Florida opinions naming this issue, 2010–2010
1 sentence

2010Small v. State, 630 So.2d 1087, 1089 (Fla.1994). 1 This case is resolvable on the first step of the analysis.

11
Goad v. Florida Dept. of Correctionsgreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2008–2008
1 sentence

2008Under Hudson , the first step in the analysis is to ascertain the legislature's intent, and then to determine the effect of the statute under the following seven factors: (1) "[w]hether the sanction involves an affirmative disability or restraint"; (2) "whether it has historically been regarded as a punishment"; (3) "whether it comes into play only on a finding of scienter "; (4) "whether its operation will promote the traditional aims of punishment — retribution and deterrence"; (5) "whether the behavior to which it applies is already a crime"; (6) "whether an alternative purpose to which it

11
Tejeda v. Stategreen
fladistctapp · 2006 · cited in 1 Florida opinions naming this issue, 2007–2007
1 sentence

2007Wilson v. Salamon, 923 So.2d 363, 368 ("establish[ing] a bright-line test . . . [t]here is either activity on the record or there is not"); Diamond Drywall *846 Sys., Inc. v. Mashan Contractors, Inc., 943 So.2d 267, 269 (Fla. 3d DCA 2006)(" Wilson has uniformly been interpreted to mean that any document appearing in the record within one year prior to the filing of a motion to dismiss precludes the entry of dismissal for failure to prosecute.").

11
Wilson v. Salamongreen
fla · 2005 · cited in 1 Florida opinions naming this issue, 2007–2007
1 sentence

2007Wilson v. Salamon, 923 So.2d 363, 368 ("establish[ing] a bright-line test . . . [t]here is either activity on the record or there is not"); Diamond Drywall *846 Sys., Inc. v. Mashan Contractors, Inc., 943 So.2d 267, 269 (Fla. 3d DCA 2006)(" Wilson has uniformly been interpreted to mean that any document appearing in the record within one year prior to the filing of a motion to dismiss precludes the entry of dismissal for failure to prosecute.").

11
Bradley v. Stategreen
fla · 2001 · cited in 1 Florida opinions naming this issue, 2003–2003
11
BARNETT BK. OF E. POLK COUNTY v. Fleminggreen
fla · 1987 · cited in 1 Florida opinions naming this issue, 2002–2002
11
Lunding v. New York Tax Appeals Tribunalgreen
scotus · 1998 · cited in 1 Florida opinions naming this issue, 2000–2000
11
Kinney System, Inc. v. Continental Ins. Co.green
fla · 1996 · cited in 1 Florida opinions naming this issue, 1997–1997
11
State v. Browngreen
fla · 1988 · cited in 1 Florida opinions naming this issue, 1990–1990
11
Skaggs-Albertson's v. ABC Liquors, Inc.green
fla · 1978 · cited in 1 Florida opinions naming this issue, 1985–1985
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (21)

CaseCitedYears
United States v. Andrew Jackson Robertson green
ca5 · 1978
2 sentences

2003In the first step of the analysis, the trial court must determine "whether the accused exhibited an actual subjective expectation to negotiate a plea at the time of the discussion." Robertson, 582 F.2d at 1366 .

1998In the first step of the analysis, the trial court must determine "whether the accused exhibited an actual subjective expectation to negotiate a plea at the time of the discussion." Robertson, 582 F.2d at 1366 .

21998–2003
Internet Solutions Corp. v. Marshall green
fla · 2010
2 sentences

2018However, as the Florida Supreme Court has emphasized, whether Florida’s long-arm statute applies to confer personal jurisdiction is only “the first step of the inquiry.” Internet Sols., 39 So. 3d at 1216 .

2018“The second step is a more restrictive one, precluding suit in any situation where the exercise of jurisdiction over the nonresident defendant would violate due process.” Id.

12018–2018
Ideal Mut. Ins. Co. v. Waldrep green
fladistctapp · 1981
1 sentence

2014See 1500 Coral Towers, 112 So.3d at 543-44 ; Waldrep, 400 So.2d at 785-86 ; Clena Invs., 2012 WL 1004851 , at *4.

12014–2014
New York v. Quarles green
scotus · 1984
2 sentences

2013“Relevant factors include the location of the questioning,” “its duration,” “statements made during the interview,” “the presence or absence of physical restraints during the questioning,” and “the release of the interviewee at the end of the questioning.” Howes, 132 S.Ct. at 1189 ; see Maryland v. Shatzer, 559 U.S. 98 , 130 S.Ct. 1213, 1224-26 , 175 L.Ed.2d 1045 (2010); Stansbury, 511 U.S. at 325 , 114 S.Ct. 1526 ; Berkemer v. McCarty, 468 U.S. 420, 437-38 , 104 S.Ct. 3138 , 82 L.Ed.2d 317 (1984); New York v. Quarles, 467 U.S. 649, 655 , 104 S.Ct. 2626 , 81 L.Ed.2d 550 (1984); Oregon v. Mathi

2013“Relevant factors include the location of the questioning,” “its duration,” “statements made during the interview,” “the presence or absence of physical restraints during the questioning,” and “the release of the interviewee at the end of the questioning.” Howes, 132 S.Ct. at 1189 ; see Maryland v. Shatzer, 559 U.S. 98 , 130 S.Ct. 1213, 1224-26 , 175 L.Ed.2d 1045 (2010); Stansbury, 511 U.S. at 325 , 114 S.Ct. 1526 ; Berkemer v. McCarty, 468 U.S. 420, 437-38 , 104 S.Ct. 3138 , 82 L.Ed.2d 317 (1984); New York v. Quarles, 467 U.S. 649, 655 , 104 S.Ct. 2626 , 81 L.Ed.2d 550 (1984); Oregon v. Mathi

12013–2013
Howes v. Fields green
scotus · 2012
2 sentences

2013The Court stated that the first step in the analysis involves ascertaining whether, given “the objective circumstances of the interrogation,” a reasonable person would have believed that he or she was not free to end the interrogation and leave. 132 S.Ct. at 1189 (quoting Stansbury v. California, 511 U.S. 318, 323 , 114 S.Ct. 1526 , 128 L.Ed.2d 293 (1994)); Thompson v. Keohane, 516 U.S. 99, 112 , 116 S.Ct. 457 , 133 L.Ed.2d 383 (1995).

2013“Determining whether an individual’s freedom of movement was curtailed, however, is simply the first step in the analysis, not the last.” Howes, 132 S.Ct. at 1189 .

12013–2013
Thompson v. Keohane green
scotus · 1995
2 sentences

2013The Court stated that the first step in the analysis involves ascertaining whether, given “the objective circumstances of the interrogation,” a reasonable person would have believed that he or she was not free to end the interrogation and leave. 132 S.Ct. at 1189 (quoting Stansbury v. California, 511 U.S. 318, 323 , 114 S.Ct. 1526 , 128 L.Ed.2d 293 (1994)); Thompson v. Keohane, 516 U.S. 99, 112 , 116 S.Ct. 457 , 133 L.Ed.2d 383 (1995).

2013The Court stated that the first step in the analysis involves ascertaining whether, given “the objective circumstances of the interrogation,” a reasonable person would have believed that he or she was not free to end the interrogation and leave. 132 S.Ct. at 1189 (quoting Stansbury v. California, 511 U.S. 318, 323 , 114 S.Ct. 1526 , 128 L.Ed.2d 293 (1994)); Thompson v. Keohane, 516 U.S. 99, 112 , 116 S.Ct. 457 , 133 L.Ed.2d 383 (1995).

12013–2013
Stansbury v. California green
scotus · 1994
2 sentences

2013The Court stated that the first step in the analysis involves ascertaining whether, given “the objective circumstances of the interrogation,” a reasonable person would have believed that he or she was not free to end the interrogation and leave. 132 S.Ct. at 1189 (quoting Stansbury v. California, 511 U.S. 318, 323 , 114 S.Ct. 1526 , 128 L.Ed.2d 293 (1994)); Thompson v. Keohane, 516 U.S. 99, 112 , 116 S.Ct. 457 , 133 L.Ed.2d 383 (1995).

2013The Court stated that the first step in the analysis involves ascertaining whether, given “the objective circumstances of the interrogation,” a reasonable person would have believed that he or she was not free to end the interrogation and leave. 132 S.Ct. at 1189 (quoting Stansbury v. California, 511 U.S. 318, 323 , 114 S.Ct. 1526 , 128 L.Ed.2d 293 (1994)); Thompson v. Keohane, 516 U.S. 99, 112 , 116 S.Ct. 457 , 133 L.Ed.2d 383 (1995).

12013–2013
Oregon v. Mathiason green
scotus · 1977
2 sentences

2013“Relevant factors include the location of the questioning,” “its duration,” “statements made during the interview,” “the presence or absence of physical restraints during the questioning,” and “the release of the interviewee at the end of the questioning.” Howes, 132 S.Ct. at 1189 ; see Maryland v. Shatzer, 559 U.S. 98 , 130 S.Ct. 1213, 1224-26 , 175 L.Ed.2d 1045 (2010); Stansbury, 511 U.S. at 325 , 114 S.Ct. 1526 ; Berkemer v. McCarty, 468 U.S. 420, 437-38 , 104 S.Ct. 3138 , 82 L.Ed.2d 317 (1984); New York v. Quarles, 467 U.S. 649, 655 , 104 S.Ct. 2626 , 81 L.Ed.2d 550 (1984); Oregon v. Mathi

2013“Relevant factors include the location of the questioning,” “its duration,” “statements made during the interview,” “the presence or absence of physical restraints during the questioning,” and “the release of the interviewee at the end of the questioning.” Howes, 132 S.Ct. at 1189 ; see Maryland v. Shatzer, 559 U.S. 98 , 130 S.Ct. 1213, 1224-26 , 175 L.Ed.2d 1045 (2010); Stansbury, 511 U.S. at 325 , 114 S.Ct. 1526 ; Berkemer v. McCarty, 468 U.S. 420, 437-38 , 104 S.Ct. 3138 , 82 L.Ed.2d 317 (1984); New York v. Quarles, 467 U.S. 649, 655 , 104 S.Ct. 2626 , 81 L.Ed.2d 550 (1984); Oregon v. Mathi

12013–2013
Berkemer v. McCarty green
scotus · 1984
2 sentences

2013“Relevant factors include the location of the questioning,” “its duration,” “statements made during the interview,” “the presence or absence of physical restraints during the questioning,” and “the release of the interviewee at the end of the questioning.” Howes, 132 S.Ct. at 1189 ; see Maryland v. Shatzer, 559 U.S. 98 , 130 S.Ct. 1213, 1224-26 , 175 L.Ed.2d 1045 (2010); Stansbury, 511 U.S. at 325 , 114 S.Ct. 1526 ; Berkemer v. McCarty, 468 U.S. 420, 437-38 , 104 S.Ct. 3138 , 82 L.Ed.2d 317 (1984); New York v. Quarles, 467 U.S. 649, 655 , 104 S.Ct. 2626 , 81 L.Ed.2d 550 (1984); Oregon v. Mathi

2013“Relevant factors include the location of the questioning,” “its duration,” “statements made during the interview,” “the presence or absence of physical restraints during the questioning,” and “the release of the interviewee at the end of the questioning.” Howes, 132 S.Ct. at 1189 ; see Maryland v. Shatzer, 559 U.S. 98 , 130 S.Ct. 1213, 1224-26 , 175 L.Ed.2d 1045 (2010); Stansbury, 511 U.S. at 325 , 114 S.Ct. 1526 ; Berkemer v. McCarty, 468 U.S. 420, 437-38 , 104 S.Ct. 3138 , 82 L.Ed.2d 317 (1984); New York v. Quarles, 467 U.S. 649, 655 , 104 S.Ct. 2626 , 81 L.Ed.2d 550 (1984); Oregon v. Mathi

12013–2013
Taylor v. State green
fla · 1983
1 sentence

2009This split is based on opposing interpretations of the supreme court’s decision in Taylor v. State, 444 So.2d 931 (Fla.1983), which held that attempted manslaughter was a cognizable crime in this state.

12009–2009
Hudson v. United States green
scotus · 1997
2 sentences

2008Under Hudson , the first step in the analysis is to ascertain the legislature's intent, and then to determine the effect of the statute under the following seven factors: (1) "[w]hether the sanction involves an affirmative disability or restraint"; (2) "whether it has historically been regarded as a punishment"; (3) "whether it comes into play only on a finding of scienter "; (4) "whether its operation will promote the traditional aims of punishment — retribution and deterrence"; (5) "whether the behavior to which it applies is already a crime"; (6) "whether an alternative purpose to which it

2008Under Hudson , the first step in the analysis is to ascertain the legislature's intent, and then to determine the effect of the statute under the following seven factors: (1) "[w]hether the sanction involves an affirmative disability or restraint"; (2) "whether it has historically been regarded as a punishment"; (3) "whether it comes into play only on a finding of scienter "; (4) "whether its operation will promote the traditional aims of punishment — retribution and deterrence"; (5) "whether the behavior to which it applies is already a crime"; (6) "whether an alternative purpose to which it

12008–2008
Kennedy v. Mendoza-Martinez green
scotus · 1963
2 sentences

2008Under Hudson , the first step in the analysis is to ascertain the legislature's intent, and then to determine the effect of the statute under the following seven factors: (1) "[w]hether the sanction involves an affirmative disability or restraint"; (2) "whether it has historically been regarded as a punishment"; (3) "whether it comes into play only on a finding of scienter "; (4) "whether its operation will promote the traditional aims of punishment — retribution and deterrence"; (5) "whether the behavior to which it applies is already a crime"; (6) "whether an alternative purpose to which it

2008Under Hudson , the first step in the analysis is to ascertain the legislature's intent, and then to determine the effect of the statute under the following seven factors: (1) "[w]hether the sanction involves an affirmative disability or restraint"; (2) "whether it has historically been regarded as a punishment"; (3) "whether it comes into play only on a finding of scienter "; (4) "whether its operation will promote the traditional aims of punishment — retribution and deterrence"; (5) "whether the behavior to which it applies is already a crime"; (6) "whether an alternative purpose to which it

12008–2008
Terry v. Ohio green
scotus · 1968
12007–2007
Franklin v. State green
fla · 2004
12004–2004
Townsend v. State green
fladistctapp · 1982
12003–2003
Del Duca v. Anthony green
fla · 1991
12002–2002
Wakulla County v. Davis green
fla · 1981
11990–1990
Adams v. Culver green
fla · 1959
11990–1990
Carawan v. State red
fla · 1987
11988–1988
Barnett v. Lakeland Construction Co. green
fladistctapp · 1982
11986–1986
Red Diamond Supply, Inc. v. Liquid Carbonic Corporation green
ca5 · 1981
11984–1984

Statutes the citing opinions construe

FL § 48.193 (4) FL § 775.021 (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 204 (1986–2026) CA 193 (1983–2026) IL 156 (1981–2026) OH 111 (1986–2026) IA 53 (1983–2024) WI 46 (1981–2025) OR 33 (1985–2024) KS 33 (1998–2026) MD 29 (1912–2025) FL 29 (1984–2025) MO 28 (1984–2024) NJ 27 (1983–2025) MI 26 (2007–2026) MN 25 (1986–2026) NM 25 (1997–2024) PA 25 (1982–2025) UT 24 (1904–2026) IN 23 (1981–2025) WA 23 (1975–2026) TN 22 (1995–2026) CT 21 (1989–2025) NY 20 (1981–2022) ME 18 (2000–2026) NC 18 (1981–2026) LA 16 (1990–2024) GA 15 (1988–2025) VT 14 (1993–2017) CO 14 (1985–2026) DC 14 (1988–2026) VA 12 (1993–2025) MA 11 (1996–2025) ID 11 (1986–2025) RI 11 (1984–2025) NE 10 (1995–2025) KY 10 (1990–2025) MT 9 (1995–2015) WV 8 (1982–2019) DE 8 (1992–2024) NH 8 (1990–2024) SD 5 (2002–2018) AK 5 (1988–2019) AZ 5 (1979–2013) MS 5 (2001–2015) ND 5 (2004–2014) HI 4 (1994–2017) NV 3 (2000–2022) OK 3 (2018–2025) AL 2 (2001–2001) AR 2 (2011–2016) VI 2 (2014–2023)

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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