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29 Washington opinions name it 2 courts 1914–2025 1 in the last five years
The cases below were cited by Washington 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.
| Case | Followed | Cited |
|---|---|---|
Morsbach v. Thurston Countygreen2 sentences2006Throughout the 20th century, railroad deeds posed a recurring problem for courts, prompting our court to opine that “[t]he authorities are in hopeless conflict” and, in large part, “cannot be reconciled.” Swan v. O’Leary, 37 Wn.2d 533, 535 , 225 P.2d 199 (1950). 5 In response to these conflicting authorities, in 1950, the Swan court attempted to lay down a bright-line rule governing railroad rights of way by interpreting the then seminal case Morsbach v. Thurston County, 152 Wash. 562 , 278 P. 686 (1929) 6 as follows: We think when [Morsbach] is critically read and considered with the precise 2006Throughout the 20th century, railroad deeds posed a recurring problem for courts, prompting our court to opine that “[t]he authorities are in hopeless conflict” and, in large part, “cannot be reconciled.” Swan v. O’Leary, 37 Wn.2d 533, 535 , 225 P.2d 199 (1950). 5 In response to these conflicting authorities, in 1950, the Swan court attempted to lay down a bright-line rule governing railroad rights of way by interpreting the then seminal case Morsbach v. Thurston County, 152 Wash. 562 , 278 P. 686 (1929) 6 as follows: We think when [Morsbach] is critically read and considered with the precise | 3 | 9 |
Roeder Co. v. Burlington Northern, Inc.green2 sentences2006The granting clause specifically conveyed “ Tor all railroad and other right of way purposes, certain tracts and parcels of land ....’” Id. 2006Based on the deed language, the court concluded that “[s]inee the granting clause of the . . . deed declares the purpose of the grant to be a right of way for a railroad, the deed passes an easement, not a fee.” Id. at 571 . “[AJbsent persuasive evidence of intent to the contrary,” the court found Morsbach, Swan, and Veach compelled it to read the “right of way” purpose language to find only an easement was transferred. | 2 | 6 |
Harris v. Ski Park Farms, Inc.green2 sentences2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 , 278 P. 686 ; Swan, 37 Wash.2d at 534 , 225 P.2d 199 ; Veach, 92 Wash.2d at 573-74 , 599 P.2d 526 ; Zobrist v. Culp, 95 Wash.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Roeder, 105 Wash.2d 567 , 716 P.2d 855 ; Lawson, 107 Wash.2d 444 , 730 P.2d 1308 ; see also Harris, 120 Wash.2d 727 , 844 P.2d 1006 ; Squire Inv., 59 Wash.App. 888 , 801 P.2d 1022 . 2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 ; Swan, 37 Wn.2d at 534 ; Veach, 92 Wn.2d at 573-74 ; Zobrist v. Culp, 95 Wn.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Burlington N., 105 Wn.2d 567 ; Lawson, 107 Wn.2d 444 ; see also Harris, 120 Wn.2d 727 ; Squire Inv., 59 Wn. | 2 | 2 |
Swan v. O'LEARYgreen2 sentences2006Throughout the 20th century, railroad deeds posed a recurring problem for courts, prompting our court to opine that “[t]he authorities are in hopeless conflict” and, in large part, “cannot be reconciled.” Swan v. O’Leary, 37 Wn.2d 533, 535 , 225 P.2d 199 (1950). 5 In response to these conflicting authorities, in 1950, the Swan court attempted to lay down a bright-line rule governing railroad rights of way by interpreting the then seminal case Morsbach v. Thurston County, 152 Wash. 562 , 278 P. 686 (1929) 6 as follows: We think when [Morsbach] is critically read and considered with the precise 2006Throughout the 20th century, railroad deeds posed a recurring problem for courts, prompting our court to opine that “[t]he authorities are in hopeless conflict” and, in large part, “cannot be reconciled.” Swan v. O’Leary, 37 Wn.2d 533, 535 , 225 P.2d 199 (1950). 5 In response to these conflicting authorities, in 1950, the Swan court attempted to lay down a bright-line rule governing railroad rights of way by interpreting the then seminal case Morsbach v. Thurston County, 152 Wash. 562 , 278 P. 686 (1929) 6 as follows: We think when [Morsbach] is critically read and considered with the precise | 1 | 11 |
| Ross, Inc. v. Leglergreen | 1 | 1 |
| Bode v. Flobert Industries, Inc.green | 1 | 1 |
| El Dorado & Wesson Railway Co. v. Smithgreen | 1 | 1 |
| City of Glendora v. Fausgreen | 1 | 1 |
| Askew v. Spencegreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Brown v. State
green
2 sentences2006In short, the deed is in statutory warranty form, which carries a presumption of conveying fee, Brown, 130 Wn.2d at 438 , but contains the words “right of way” in both the granting clause and the habendum clause, which we have stated presumptively evinces the parties’ intent to convey only an easement. 2006However, “where a party conveys property via a statutory warranty deed and the granting clause conveys a definite strip of land, courts ‘must find that the grantor [ ] intended to convey fee simple [absolute] title unless additional language in the deed[] clearly and expressly limits or qualifies the interest conveyed.’ ” Kershaw Sunnyside Ranches, Inc. v. Yakima Interurban Lines Ass’n, 156 Wn.2d 253, 264 , 126 P.3d 16 (2006) (first and third alterations in original) (quoting Brown, 130 Wn.2d at 437 ). | 8 | 2002–2006 |
Veach v. Culp
green
2 sentences2006Id. at 572-74 . ¶15 Again, in 1986, this court considered the effect of a railroad right of way deed. 2006Id. at 572-74 , 599 P.2d 526 . ¶ 15 Again, in 1986, this court considered the effect of a railroad right of way deed. | 6 | 1986–2006 |
Brown v. State
green
2 sentences2006In short, the deed is in statutory warranty form, which carries a presumption of conveying fee, Brown, 130 Wash.2d at 438 , 924 P.2d 908 , but contains the words "right of way" in both the granting clause and the habendum clause, which we have stated presumptively evinces the parties' intent to convey only an easement. 2006However, "where a party conveys property via a statutory warranty deed and the granting clause conveys a definite strip of land, courts `must find that the grantor[ ] intended to convey fee simple [absolute] title unless additional language in the deed[ ] clearly and expressly limits or qualifies the interest conveyed.'" Kershaw Sunnyside Ranches Inc. v. Yakima Interurban Lines Ass'n, 156 Wash.2d 253, 264 , 126 P.3d 16 (2006) (quoting Brown, 130 Wash.2d at 437 , 924 P.2d 908 ). | 5 | 2002–2006 |
Roeder Co. v. K&E Moving & Storage Co.
green
2 sentences2006Brown, 130 Wash.2d at 438 , 924 P.2d 908 (emphasis added). [9] But see Roeder Co. v. K & E Moving & Storage Co., 102 Wash.App. 49, 56 , 4 P.3d 839 (2000) (noting the "nominal consideration" of $1 "does not reveal much"), review denied, 142 Wash.2d 1017 , 16 P.3d 1264 (2001). [10] See CP 654-55 (habendum clause recites that the conveyance is "forever" and the granting clause purports to convey a "right of way for a railway forever, together with the perpetual right to . . . operate a railway" (emphasis added)). [11] Level 3 asserts a recent Division One case, Ray v. King County, 120 Wash.App. 5 2002Brown v. State, 130 Wn.2d 430, 437 , 924 P.2d 908 (1996); K&E Moving & Storage Co., 102 Wn. | 3 | 2002–2006 |
Kershaw Sunnyside Ranches, Inc. v. Yakima Interurban Lines Ass'n
green
2 sentences2006However, "where a party conveys property via a statutory warranty deed and the granting clause conveys a definite strip of land, courts `must find that the grantor[ ] intended to convey fee simple [absolute] title unless additional language in the deed[ ] clearly and expressly limits or qualifies the interest conveyed.'" Kershaw Sunnyside Ranches Inc. v. Yakima Interurban Lines Ass'n, 156 Wash.2d 253, 264 , 126 P.3d 16 (2006) (quoting Brown, 130 Wash.2d at 437 , 924 P.2d 908 ). 2006However, “where a party conveys property via a statutory warranty deed and the granting clause conveys a definite strip of land, courts ‘must find that the grantor [ ] intended to convey fee simple [absolute] title unless additional language in the deed[] clearly and expressly limits or qualifies the interest conveyed.’ ” Kershaw Sunnyside Ranches, Inc. v. Yakima Interurban Lines Ass’n, 156 Wn.2d 253, 264 , 126 P.3d 16 (2006) (first and third alterations in original) (quoting Brown, 130 Wn.2d at 437 ). | 2 | 2006–2006 |
Roeder Co. v. K & E Moving & Storage Co.
green
2 sentences2006Brown, 130 Wash.2d at 438 , 924 P.2d 908 (emphasis added). [9] But see Roeder Co. v. K & E Moving & Storage Co., 102 Wash.App. 49, 56 , 4 P.3d 839 (2000) (noting the "nominal consideration" of $1 "does not reveal much"), review denied, 142 Wash.2d 1017 , 16 P.3d 1264 (2001). [10] See CP 654-55 (habendum clause recites that the conveyance is "forever" and the granting clause purports to convey a "right of way for a railway forever, together with the perpetual right to . . . operate a railway" (emphasis added)). [11] Level 3 asserts a recent Division One case, Ray v. King County, 120 Wash.App. 5 2002Brown v. State, 130 Wash.2d 430, 437 , 924 P.2d 908 (1996); Roeder, 102 Wash.App. at 54 nn. 8-9, 4 P.3d 839 . | 2 | 2002–2006 |
Ray v. King County
green
2 sentences2006Level 3 asserts a recent Division One case, Ray v. King County, 120 Wn. 2006Brown, 130 Wash.2d at 438 , 924 P.2d 908 (emphasis added). [9] But see Roeder Co. v. K & E Moving & Storage Co., 102 Wash.App. 49, 56 , 4 P.3d 839 (2000) (noting the "nominal consideration" of $1 "does not reveal much"), review denied, 142 Wash.2d 1017 , 16 P.3d 1264 (2001). [10] See CP 654-55 (habendum clause recites that the conveyance is "forever" and the granting clause purports to convey a "right of way for a railway forever, together with the perpetual right to . . . operate a railway" (emphasis added)). [11] Level 3 asserts a recent Division One case, Ray v. King County, 120 Wash.App. 5 | 2 | 2006–2006 |
Kershaw Sunnyside Ranches, Inc. v. Yakima Interurban Lines Assoc.
green
2 sentences2006However, "where a party conveys property via a statutory warranty deed and the granting clause conveys a definite strip of land, courts `must find that the grantor[ ] intended to convey fee simple [absolute] title unless additional language in the deed[ ] clearly and expressly limits or qualifies the interest conveyed.'" Kershaw Sunnyside Ranches Inc. v. Yakima Interurban Lines Ass'n, 156 Wash.2d 253, 264 , 126 P.3d 16 (2006) (quoting Brown, 130 Wash.2d at 437 , 924 P.2d 908 ). 2006However, “where a party conveys property via a statutory warranty deed and the granting clause conveys a definite strip of land, courts ‘must find that the grantor [ ] intended to convey fee simple [absolute] title unless additional language in the deed[] clearly and expressly limits or qualifies the interest conveyed.’ ” Kershaw Sunnyside Ranches, Inc. v. Yakima Interurban Lines Ass’n, 156 Wn.2d 253, 264 , 126 P.3d 16 (2006) (first and third alterations in original) (quoting Brown, 130 Wn.2d at 437 ). | 2 | 2006–2006 |
Tallman v. E.I. P.R.R. Co.
green
2 sentences2002Tallman, 41 N.E.2d at 539 . 2002Tallman, 41 N.E.2d at 539 . | 2 | 2002–2002 |
Reichenbach v. Washington Short Line Railway Co.
green
2 sentences2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 ; Swan, 37 Wn.2d at 534 ; Veach, 92 Wn.2d at 573-74 ; Zobrist v. Culp, 95 Wn.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Burlington N., 105 Wn.2d 567 ; Lawson, 107 Wn.2d 444 ; see also Harris, 120 Wn.2d 727 ; Squire Inv., 59 Wn. 2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 ; Swan, 37 Wn.2d at 534 ; Veach, 92 Wn.2d at 573-74 ; Zobrist v. Culp, 95 Wn.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Burlington N., 105 Wn.2d 567 ; Lawson, 107 Wn.2d 444 ; see also Harris, 120 Wn.2d 727 ; Squire Inv., 59 Wn. | 2 | 2002–2002 |
King County v. Squire Investment Co.
green
2 sentences2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 , 278 P. 686 ; Swan, 37 Wash.2d at 534 , 225 P.2d 199 ; Veach, 92 Wash.2d at 573-74 , 599 P.2d 526 ; Zobrist v. Culp, 95 Wash.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Roeder, 105 Wash.2d 567 , 716 P.2d 855 ; Lawson, 107 Wash.2d 444 , 730 P.2d 1308 ; see also Harris, 120 Wash.2d 727 , 844 P.2d 1006 ; Squire Inv., 59 Wash.App. 888 , 801 P.2d 1022 . 2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 ; Swan, 37 Wn.2d at 534 ; Veach, 92 Wn.2d at 573-74 ; Zobrist v. Culp, 95 Wn.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Burlington N., 105 Wn.2d 567 ; Lawson, 107 Wn.2d 444 ; see also Harris, 120 Wn.2d 727 ; Squire Inv., 59 Wn. | 2 | 2002–2002 |
Zobrist v. Culp
green
2 sentences2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 ; Swan, 37 Wn.2d at 534 ; Veach, 92 Wn.2d at 573-74 ; Zobrist v. Culp, 95 Wn.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Burlington N., 105 Wn.2d 567 ; Lawson, 107 Wn.2d 444 ; see also Harris, 120 Wn.2d 727 ; Squire Inv., 59 Wn. 2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 ; Swan, 37 Wn.2d at 534 ; Veach, 92 Wn.2d at 573-74 ; Zobrist v. Culp, 95 Wn.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Burlington N., 105 Wn.2d 567 ; Lawson, 107 Wn.2d 444 ; see also Harris, 120 Wn.2d 727 ; Squire Inv., 59 Wn. | 2 | 2002–2002 |
Lawson v. State
green
2 sentences2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 , 278 P. 686 ; Swan, 37 Wash.2d at 534 , 225 P.2d 199 ; Veach, 92 Wash.2d at 573-74 , 599 P.2d 526 ; Zobrist v. Culp, 95 Wash.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Roeder, 105 Wash.2d 567 , 716 P.2d 855 ; Lawson, 107 Wash.2d 444 , 730 P.2d 1308 ; see also Harris, 120 Wash.2d 727 , 844 P.2d 1006 ; Squire Inv., 59 Wash.App. 888 , 801 P.2d 1022 . 2002Reichenbach v. Wash. Short Line Ry., 10 Wash. 357, 358 , 38 P. 1126 (1894); Morsbach, 152 Wash. at 564-65 ; Swan, 37 Wn.2d at 534 ; Veach, 92 Wn.2d at 573-74 ; Zobrist v. Culp, 95 Wn.2d 556 , 627 P.2d 1308 (1981) (citing cases from other jurisdictions); Burlington N., 105 Wn.2d 567 ; Lawson, 107 Wn.2d 444 ; see also Harris, 120 Wn.2d 727 ; Squire Inv., 59 Wn. | 2 | 2002–2002 |
Zobrist v. Culp
green
2 sentences1979App. 622, 629-31 , 570 P.2d 147 (1977) wherein we held that the granting clause there used passed only an easement for a railroad right-of-way and not the fee. 3 The repurchase clause of the deed reads: The real estate herein conveyed is to be used for the purpose of right of way for a railroad, and it is expressly understood and agreed by and between the Grantor and Grantee herein, that if said right of way or any portion thereof shall ever be abandoned and cease to be used for purposes of right of way for a railroad, by the Grantee its successors or assigns, then and in that event the Granto 1978Zobrist v. Culp, 18 Wn. | 2 | 1978–1979 |
State v. Saunders
green
1 sentence2025State v. Saunders, 153 Wn. | 1 | 2025–2025 |
Ray v. King County
green
2 sentences2006Brown, 130 Wash.2d at 438 , 924 P.2d 908 (emphasis added). [9] But see Roeder Co. v. K & E Moving & Storage Co., 102 Wash.App. 49, 56 , 4 P.3d 839 (2000) (noting the "nominal consideration" of $1 "does not reveal much"), review denied, 142 Wash.2d 1017 , 16 P.3d 1264 (2001). [10] See CP 654-55 (habendum clause recites that the conveyance is "forever" and the granting clause purports to convey a "right of way for a railway forever, together with the perpetual right to . . . operate a railway" (emphasis added)). [11] Level 3 asserts a recent Division One case, Ray v. King County, 120 Wash.App. 5 2006However, while the Ray deed did include the phrase "right of way" it did so only to the extent that it stated it was conveying a "right of way strip." Id. at 572, 86 P.3d 183 . | 1 | 2006–2006 |
State v. Moats
green
1 sentence2006Brown, 130 Wash.2d at 438 , 924 P.2d 908 (emphasis added). [9] But see Roeder Co. v. K & E Moving & Storage Co., 102 Wash.App. 49, 56 , 4 P.3d 839 (2000) (noting the "nominal consideration" of $1 "does not reveal much"), review denied, 142 Wash.2d 1017 , 16 P.3d 1264 (2001). [10] See CP 654-55 (habendum clause recites that the conveyance is "forever" and the granting clause purports to convey a "right of way for a railway forever, together with the perpetual right to . . . operate a railway" (emphasis added)). [11] Level 3 asserts a recent Division One case, Ray v. King County, 120 Wash.App. 5 | 1 | 2006–2006 |
Cook v. Hensler
green
2 sentences2005Cook, 57 Wash. at 399 , 107 P. 178 . ¶ 56 Turning to this deed, the granting clause provides that ECC does "convey and quit claim to [VCC] all its interest in the following described real estate, situate in Pierce County, Washington," the church property. 2005Cook, 57 Wash. at 399 , 107 P. 178 . ¶ 56 Turning to this deed, the granting clause provides that ECC does "convey and quit claim to [VCC] all its interest in the following described real estate, situate in Pierce County, Washington," the church property. | 1 | 2005–2005 |
Urbaitis v. Commonwealth Edison
green
2 sentences2004Brown, 130 Wash.2d at 437-38 , 924 P.2d 908 . [12] Brown, 130 Wash.2d at 438 , 924 P.2d 908 (citing Veach, 92 Wash.2d at 570 , 599 P.2d 526 ). [13] Brown, 130 Wash.2d at 439-40 , 924 P.2d 908 (citing Swan, 37 Wash.2d at 536 , 225 P.2d 199 ; 65 Am.Jur.2d Railroads § 76 (1972); Urbaitis v. Commonwealth Edison, 143 Ill.2d 458 , 159 Ill. 2004Brown, 130 Wash.2d at 437-38 , 924 P.2d 908 . [12] Brown, 130 Wash.2d at 438 , 924 P.2d 908 (citing Veach, 92 Wash.2d at 570 , 599 P.2d 526 ). [13] Brown, 130 Wash.2d at 439-40 , 924 P.2d 908 (citing Swan, 37 Wash.2d at 536 , 225 P.2d 199 ; 65 Am.Jur.2d Railroads § 76 (1972); Urbaitis v. Commonwealth Edison, 143 Ill.2d 458 , 159 Ill. | 1 | 2004–2004 |
State v. Smyth
green
1 sentence1986In Smyth , Justice Hans Linde, writing for the majority, stated there was no difference in meaning between Oregon's "face-to-face" confrontation clause and its federal counterpart. 593 P.2d at 1168 n.3. 3 A defendant does not have a right to compel the granting of immunity to a witness. | 1 | 1986–1986 |
State v. Mannhalt
green
1 sentence1986State v. Mannhalt, 33 Wn. | 1 | 1986–1986 |
State v. Matson
green
2 sentences1983The granting of immunity is governed by CrR 6.14. 3 Under this rule, " [a] defendant does not have a right to a grant of immunity to a witness, or to compel such a grant." State v. Matson, 22 Wn. 1983App. 114, 120-21 , 587 P.2d 540 (1978). | 1 | 1983–1983 |
State v. Collins
green
1 sentence1982State v. Workman, 90 Wn.2d 443 , 584 P.2d 382 (1978); State v. Collins, 30 Wn. | 1 | 1982–1982 |
State v. Workman
green
2 sentences1982State v. Workman, 90 Wn.2d 443 , 584 P.2d 382 (1978); State v. Collins, 30 Wn. 1982State v. Workman, 90 Wn.2d 443 , 584 P.2d 382 (1978); State v. Collins, 30 Wn. | 1 | 1982–1982 |
State v. Roybal
green
2 sentences1982A defendant is entitled to an instruction on a lesser included offense where two conditions are met: (1) every element of the lesser offense must be a part of the greater offense, State v. Roybal, 82 Wn.2d 577 , 512 P.2d 718 (1973); and (2) there must be evidence in the record to support the granting of an instruction. 1982A defendant is entitled to an instruction on a lesser included offense where two conditions are met: (1) every element of the lesser offense must be a part of the greater offense, State v. Roybal, 82 Wn.2d 577 , 512 P.2d 718 (1973); and (2) there must be evidence in the record to support the granting of an instruction. | 1 | 1982–1982 |
Kelley v. Howard S. Wright Construction Co.
green
2 sentences1978Co., 90 Wn.2d 323 , 582 P.2d 500 (1978). 1978Co., 90 Wn.2d 323 , 582 P.2d 500 (1978). | 1 | 1978–1978 |
| Maryland & Pennsylvania Railroad v. Mercantile-Safe Deposit & Trust Co. green | 1 | 1977–1977 |
| Winterroth v. Meats, Inc. green | 1 | 1975–1975 |
| Martinson v. Cruikshank green | 1 | 1943–1943 |
| Summy v. Ramsey green | 1 | 1930–1930 |
| Lockwood v. Ohio River R. green | 1 | 1929–1929 |
| Jones v. Van Bochove green | 1 | 1929–1929 |
| Ranney v. Meisenheimer green | 1 | 1922–1922 |
| Pearson v. City of Seattle neutral | 1 | 1918–1918 |
| People v. Toro neutral | 1 | 1914–1914 |
| People v. Amieiro neutral | 1 | 1914–1914 |
| Rosa Félix v. Medina Calderón neutral | 1 | 1914–1914 |
| Eureka Sandstone Co. v. Long neutral | 1 | 1914–1914 |
| Tingley v. Bellingham Bay Boom Co. neutral | 1 | 1914–1914 |
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.
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.