hearsay rule (Kansas) · Go Syfert
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hearsay rule in Kansas

177 Kansas opinions name it 2 courts 1922–2026 21 in the last five years

The cases below were cited by Kansas 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 (20)

CaseFollowedCited
State v. Myersgreen
kan · 1981 · cited in 4 Kansas opinions naming this issue, 1985–2024
2 sentences

2024See State v. Myers, 229 Kan. 168, 171 , 625 P.2d 1111 (1981) ("In determining the admissibility of hearsay evidence under one of the exceptions to the hearsay rule, a trial 10 court must also consider the application of the confrontation clauses . . . ."); State v. Martinez-Diaz, 63 Kan.

2024See State v. Myers, 229 Kan. 168, 171 , 625 P.2d 1111 (1981) ("In determining the admissibility of hearsay evidence under one of the exceptions to the hearsay rule, a trial 10 court must also consider the application of the confrontation clauses . . . ."); State v. Martinez-Diaz, 63 Kan.

24
State v. Brattgreen
kan · 1992 · cited in 4 Kansas opinions naming this issue, 1993–2020
2 sentences

1994In State v. Bratt, 250 Kan. 264 , 824 P.2d 983 (1992), we reviewed the rules for determining when incriminating statements admissible under the hearsay rule met the requirements of the Confrontation Clause of the United States Constitution.

1994In State v. Bratt, 250 Kan. 264 , 824 P.2d 983 (1992), we reviewed the rules for determining when incriminating statements admissible under the hearsay rule met the requirements of the Confrontation Clause of the United States Constitution.

24
State v. Staffordgreen
kan · 1994 · cited in 3 Kansas opinions naming this issue, 1998–2001
2 sentences

2001State v. Stafford, 255 Kan. 807, 810 , 878 P.2d 820 (1994).

2001State v. Stafford, 255 Kan. 807, 810 , 878 P.2d 820 (1994).

23
State v. Davisgreen
kanctapp · 1978 · cited in 2 Kansas opinions naming this issue, 2007–2021
2 sentences

2021See 2 Kan.

2007K.S.A. 60-463 (multiple hearsay); see State v. Davis, 2 Kan.

22
United States v. Zuckergreen
scotus · 1896 · cited in 2 Kansas opinions naming this issue, 2007–2007
22
United States v. William M. Ruffingreen
ca2 · 1978 · cited in 2 Kansas opinions naming this issue, 1986–1991
22
Crawford v. Washingtongreen
scotus · 2004 · cited in 4 Kansas opinions naming this issue, 2007–2024
2 sentences

2022The trial court ruled that Mathews' statements "would be admissible in trial under the hearsay exception and would not violate the Court's decision in Crawford [v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 , 158 L.

2022The trial court ruled that Mathews' statements "would be admissible in trial under the hearsay exception and would not violate the Court's decision in Crawford [v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 , 158 L.

14
State v. Petersongreen
kan · 1985 · cited in 3 Kansas opinions naming this issue, 1992–1995
2 sentences

1995The adoption of 60-460(d) replaced a portion of the res gestae exception with the contemporaneous statement exception to the hearsay rule. 236 Kan. at 829-30 .

1995Two of these cases involved hearsay evidence which was admissible under a hearsay exception: Peterson, 236 Kan. at 830-31 (the declarant was dead and thus unavailable as a witness, K.S.A. 60-460[d][3]); and Gadelkarim, 256 Kan. at 688 (the declarant was dead and thus unavailable as a witness).

13
State v. Trottergreen
kan · 1969 · cited in 3 Kansas opinions naming this issue, 1971–1981
2 sentences

1971(State v. Borserine, 184 Kan. 405, 411 , 337 P. 2d 697 ; State v. Shaw, 195 Kan. 677, 680, 681 , 408 P. 2d 650 ; State v. Adamson, 197 Kan. 486, 488-490 , 419 P. 2d 860 ; State v. Trotter, 203 Kan. 31 , 453 P. 2d 93 ; Gard, Kansas Code of Civil Procedure Annotated, § 60-460 [i], p. 478.) In addition, the appellant suggests the testimony is admissible as an exception to the hearsay rule on the grounds the statements of the declarant were declarations against interest, pursuant to K.

1971(State v. Borserine, 184 Kan. 405, 411 , 337 P. 2d 697 ; State v. Shaw, 195 Kan. 677, 680, 681 , 408 P. 2d 650 ; State v. Adamson, 197 Kan. 486, 488-490 , 419 P. 2d 860 ; State v. Trotter, 203 Kan. 31 , 453 P. 2d 93 ; Gard, Kansas Code of Civil Procedure Annotated, § 60-460 [i], p. 478.) In addition, the appellant suggests the testimony is admissible as an exception to the hearsay rule on the grounds the statements of the declarant were declarations against interest, pursuant to K.

13
State v. Shawgreen
kan · 1965 · cited in 3 Kansas opinions naming this issue, 1971–1978
2 sentences

1971(State v. Borserine, 184 Kan. 405, 411 , 337 P. 2d 697 ; State v. Shaw, 195 Kan. 677, 680, 681 , 408 P. 2d 650 ; State v. Adamson, 197 Kan. 486, 488-490 , 419 P. 2d 860 ; State v. Trotter, 203 Kan. 31 , 453 P. 2d 93 ; Gard, Kansas Code of Civil Procedure Annotated, § 60-460 [i], p. 478.) In addition, the appellant suggests the testimony is admissible as an exception to the hearsay rule on the grounds the statements of the declarant were declarations against interest, pursuant to K.

1971(State v. Borserine, 184 Kan. 405, 411 , 337 P. 2d 697 ; State v. Shaw, 195 Kan. 677, 680, 681 , 408 P. 2d 650 ; State v. Adamson, 197 Kan. 486, 488-490 , 419 P. 2d 860 ; State v. Trotter, 203 Kan. 31 , 453 P. 2d 93 ; Gard, Kansas Code of Civil Procedure Annotated, § 60-460 [i], p. 478.) In addition, the appellant suggests the testimony is admissible as an exception to the hearsay rule on the grounds the statements of the declarant were declarations against interest, pursuant to K.

13
Mlb v. Sljgreen
scotus · 1996 · cited in 2 Kansas opinions naming this issue, 2007–2007
12
In Re Mary P.green
kan · 1985 · cited in 2 Kansas opinions naming this issue, 1988–1996
12
Darlene Thomas v. International Business MacHines a New York Corporation Doing Business in the State of Oklahomagreen
ca10 · 1995 · cited in 1 Kansas opinions naming this issue, 2026–2026
11
Milissa Garside v. Osco Drug, Inc.green
ca1 · 1990 · cited in 1 Kansas opinions naming this issue, 2026–2026
11
Drach v. Brucegreen
kan · 2006 · cited in 1 Kansas opinions naming this issue, 2024–2024
11
State v. Jeffersongreen
kan · 2008 · cited in 1 Kansas opinions naming this issue, 2022–2022
11
State v. Johnson-Howellgreen
kan · 1994 · cited in 1 Kansas opinions naming this issue, 2022–2022
11
United States v. Darwin Montanagreen
ca7 · 1999 · cited in 1 Kansas opinions naming this issue, 2021–2021
11
State v. Reedgreen
kan · 2015 · cited in 1 Kansas opinions naming this issue, 2021–2021
11
Bryant v. Farmers Insurance Exchangegreen
ca10 · 2005 · cited in 1 Kansas opinions naming this issue, 2015–2015
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (60)

CaseCitedYears
Ohio v. Roberts red
scotus · 1980
2 sentences

2007However, Ohio v. Roberts, 448 U.S. at 65-66 , makes it plain that in dealing with the admission of hearsay testimony and the defendant’s right of confrontation under the United States Constitution, it is not enough that state law regarding hearsay evidence has been satisfied, for the Sixth Amendment Confrontation Clause can operate to bar admission of evidence that would otherwise be admissible under an exception to the hearsay rule if its requirements are not met.

1986Ed. 2d 597 , 100 S. Ct. 2531 (1980), the United States Supreme Court considered the relationship between the confrontation clause and the hearsay rule with its many exceptions.

101981–2007
State v. Brickhouse green
kanctapp · 1995
2 sentences

2007The Court of Appeals reversed, finding the trial court’s selective admission of Cardello’s statements to the police to be an “uneven application of the hearsay rule” and therefore “an abuse of discretion.” 20 Kan.

2004This court determined that this application of the hearsay rule “offends our sense of justice and fair play and affects the jury process in an unacceptable manner.” 20 Kan.

61997–2007
State v. Hills green
kan · 1998
2 sentences

2011And we discussed our prior decision in State v. Hills, 264 Kan. 437, 443-48 , 957 P.2d 496 (1998), in which we held that "`[i]t is simply not permissible to admit an incriminating hearsay statement by the defendant while denying the admission of exculpatory portions of the same hearsay statement through the use of the hearsay rule.

2011And we discussed our prior decision in State v. Hills, 264 Kan. 437, 443-48 , 957 P.2d 496 (1998), in which we held that "`[i]t is simply not permissible to admit an incriminating hearsay statement by the defendant while denying the admission of exculpatory portions of the same hearsay statement through the use of the hearsay rule.

51999–2011
Chambers v. Mississippi green
scotus · 1973
2 sentences

2001Ed 2d 297, 93 S. Ct. 1038 (1973), in which that Court said that "where constitutional rights directly affecting the ascertainment of guilt are implicated, the hearsay rule may not be applied mechanistically to defeat the ends of justice." 410 U.S. at 302 .

2001Ed 2d 297, 93 S. Ct. 1038 (1973), in which that Court said that "where constitutional rights directly affecting the ascertainment of guilt are implicated, the hearsay rule may not be applied mechanistically to defeat the ends of justice." 410 U.S. at 302 .

51995–2001
State v. Sanders green
kan · 1995
2 sentences

1998“The hearsay exception found at K.S.A. 60-460(d)(3) requires several conditions to be satisfied: (1) The declarant is unavailable as a witness; (2) the statement was made at a time when the matter was recently perceived and while the declarant’s recollection was clear; and (3) the statement was made in good faith prior to the commencement of the action and with no incentive to falsify or distort.” State v. Sanders, 258 Kan. 409, 421 , 904 P.2d 951 (1995).

1998“The hearsay exception found at K.S.A. 60-460(d)(3) requires several conditions to be satisfied: (1) The declarant is unavailable as a witness; (2) the statement was made at a time when the matter was recently perceived and while the declarant’s recollection was clear; and (3) the statement was made in good faith prior to the commencement of the action and with no incentive to falsify or distort.” State v. Sanders, 258 Kan. 409, 421 , 904 P.2d 951 (1995).

41996–2007
State v. Oliphant green
kan · 1972
2 sentences

2007“In State v. Oliphant, 210 Kan. 451, 454 , 502 P.2d 626 (1972), we identified three types of statements exempted from the hearsay rule when offered, not for the truth of the matter asserted, but without reference to such a truth.

2007“In State v. Oliphant, 210 Kan. 451, 454 , 502 P.2d 626 (1972), we identified three types of statements exempted from the hearsay rule when offered, not for the truth of the matter asserted, but without reference to such a truth.

41981–2007
State v. Fisher green
kan · 1977
2 sentences

2007And these amendments grant no greater protection in this respect than does the Kansas Constitution Bill of Rights, § 10, which provides: "`In all prosecutions, the accused shall be allowed to . . . meet the witness face to face. . . .'" (Emphasis added.) Fisher, 222 Kan. at 80 , 563 P.2d 1012 ; see M.L.B. v. S.L.J., 519 U.S. 102, 139-40 , 117 S.Ct. 555 , 136 L.Ed.2d 473 (1996) (Thomas, J., dissenting); Dutton, 400 U.S. at 97 n. 4, 91 S.Ct. 210 (Harlan, J., concurring) (Confrontation Clause applies only to criminal prosecutions; Court has never equated the hearsay rule and the Confrontation Cla

2007And these amendments grant no greater protection in this respect than does the Kansas Constitution Bill of Rights, § 10, which provides: "`In all prosecutions, the accused shall be allowed to . . . meet the witness face to face. . . .'" (Emphasis added.) Fisher, 222 Kan. at 80 , 563 P.2d 1012 ; see M.L.B. v. S.L.J., 519 U.S. 102, 139-40 , 117 S.Ct. 555 , 136 L.Ed.2d 473 (1996) (Thomas, J., dissenting); Dutton, 400 U.S. at 97 n. 4, 91 S.Ct. 210 (Harlan, J., concurring) (Confrontation Clause applies only to criminal prosecutions; Court has never equated the hearsay rule and the Confrontation Cla

41980–2007
State v. Borserine green
kan · 1959
2 sentences

2006According to Flynn , "`K.S.A. 60-460(i) codifies in substance the exception to the hearsay rule as stated in [ State v. Borserine, 184 Kan. 405 , 337 P.2d 697 (1959)].

2006According to Flynn , "`K.S.A. 60-460(i) codifies in substance the exception to the hearsay rule as stated in [ State v. Borserine, 184 Kan. 405 , 337 P.2d 697 (1959)].

41971–2006
State v. Robinson green
kan · 2012
2 sentences

2024When a party "fails to identify the specific statements" in a hearsay challenge, "[w]e will not speculate as to the statements [the defendant] seeks to challenge." State v. Robinson, 293 Kan. 1002, 1027 , 270 P.3d 1183 (2012).

2024When a party "fails to identify the specific statements" in a hearsay challenge, "[w]e will not speculate as to the statements [the defendant] seeks to challenge." State v. Robinson, 293 Kan. 1002, 1027 , 270 P.3d 1183 (2012).

32016–2024
State v. Seacat green
kan · 2016
2 sentences

2021"The admissibility of evidence under an exception to the hearsay rule is reviewed for abuse of discretion." State v. Seacat, 303 Kan. 622, 634 , 366 P.3d 208 (2016).

2021"The admissibility of evidence under an exception to the hearsay rule is reviewed for abuse of discretion." State v. Seacat, 303 Kan. 622, 634 , 366 P.3d 208 (2016).

32017–2021
State v. Bailey green
kan · 1998
2 sentences

1999Moreover, we note that the hearsay exception provided for in K.S.A. 1998 Supp. 60-460(d)(3) is not a “firmly rooted hearsay exception.” See State v. Bailey, 263 Kan. 685, 695 , 952 P.2d 1289 (1998).

1999Moreover, we note that the hearsay exception provided for in K.S.A. 1998 Supp. 60-460(d)(3) is not a “firmly rooted hearsay exception.” See State v. Bailey, 263 Kan. 685, 695 , 952 P.2d 1289 (1998).

31999–2007
Dutton v. Evans green
scotus · 1970
2 sentences

2007Ed. 2d 473 , 117 S. Ct. 555 (1996) (Thomas, J., dissenting); Dutton, 400 U.S. at 97 n.4 (Harlan, J., concurring) (Confrontation Clause applies only to criminal prosecutions; Court has never equated the hearsay rule and the Confrontation Clause); Hannah v. Larche, 363 U.S. 420 , 440 n.16, 4 L.

2007And these amendments grant no greater protection in this respect than does the Kansas Constitution Bill of Rights, § 10, which provides: "`In all prosecutions, the accused shall be allowed to . . . meet the witness face to face. . . .'" (Emphasis added.) Fisher, 222 Kan. at 80 , 563 P.2d 1012 ; see M.L.B. v. S.L.J., 519 U.S. 102, 139-40 , 117 S.Ct. 555 , 136 L.Ed.2d 473 (1996) (Thomas, J., dissenting); Dutton, 400 U.S. at 97 n. 4, 91 S.Ct. 210 (Harlan, J., concurring) (Confrontation Clause applies only to criminal prosecutions; Court has never equated the hearsay rule and the Confrontation Cla

31994–2007
Zimmer v. State green
kan · 1970
2 sentences

1977K.S.A. 60-460 (cc) provides in substance that statements in published treatises, offered to prove the truth of a matter stated therein, are exceptions to the hearsay rule and may be received in evidence: “. . . [I]f the judge takes judicial notice, or a witness expert in the subject testifies, that the treatise ... is a reliable authority in the subject.” As we said in Zimmer v. State, 206 Kan. 304, 309 , 477 P. 2d 971 : “Mere publication does not ipso facto render a work admissible as independent substantive evidence.

1977K.S.A. 60-460 (cc) provides in substance that statements in published treatises, offered to prove the truth of a matter stated therein, are exceptions to the hearsay rule and may be received in evidence: “. . . [I]f the judge takes judicial notice, or a witness expert in the subject testifies, that the treatise ... is a reliable authority in the subject.” As we said in Zimmer v. State, 206 Kan. 304, 309 , 477 P. 2d 971 : “Mere publication does not ipso facto render a work admissible as independent substantive evidence.

31977–1999
Thompson v. Norman green
kan · 1967
2 sentences

1981As stated in Thompson v. Norman, 198 Kan. 436, 442-443 , 424 P.2d 593 (1967): “This [K.S.A. 60-460 (j)] broadens our former law in the realm of declarations against interest by those not parties to the action nor in privity with a party to the action, as exceptions to the hearsay rule.

1981As stated in Thompson v. Norman, 198 Kan. 436, 442-443 , 424 P.2d 593 (1967): “This [K.S.A. 60-460 (j)] broadens our former law in the realm of declarations against interest by those not parties to the action nor in privity with a party to the action, as exceptions to the hearsay rule.

31981–1994
Hurley v. Painter neutral
kan · 1958
2 sentences

1989Formerly there was a requirement of unavailability of the declarant as a prerequisite for reception of this character of testimony, and declarations were limited to those against the pecuniary or proprietary interest of the declarant (Hurley v. Painter, 182 Kan. 731 , 324 P.2d 142 ).

1989Formerly there was a requirement of unavailability of the declarant as a prerequisite for reception of this character of testimony, and declarations were limited to those against the pecuniary or proprietary interest of the declarant (Hurley v. Painter, 182 Kan. 731 , 324 P.2d 142 ).

31967–1989
State v. Lomax & Williams green
kan · 1980
2 sentences

2026The court noted that had the witness been available and subject to cross- examination, her out-of-court statements would have come within the hearsay exception in K.S.A. 60-460(a) and could have been presented to the jury if they were otherwise admissible. 227 Kan. at 658 .

1990In State v. Lomax & Williams, 227 Kan. 651, 658-62 , 608 P.2d 959 (1980), this court held that, where a witness (Bagby) testified *632 at a codefendant's preliminary hearing but could not remember what happened at the defendant's trial, the witness was not available for cross-examination under K.S.A. 60-460(a).

21990–2026
State v. Cosby green
kan · 2011
2 sentences

2024State v. Cosby, 293 Kan. 121, 127 , 262 P.3d 285 (2011).

2024State v. Cosby, 293 Kan. 121, 127 , 262 P.3d 285 (2011).

22016–2024
State v. Keys green
kan · 2022
2 sentences

2024To establish witness unavailability under the hearsay exception statute, K.S.A. 60-459(g)(4), the prosecution "must show it acted in good faith and made a diligent effort . . . [to] secure the witness' attendance at trial" as articulated in State v. Keys, 315 Kan. 690 , 709, 510 P.3d 706 (2022).

2024To establish witness unavailability under the hearsay exception statute, K.S.A. 60-459(g)(4), the prosecution "must show it acted in good faith and made a diligent effort . . . [to] secure the witness' attendance at trial" as articulated in State v. Keys, 315 Kan. 690 , 709, 510 P.3d 706 (2022).

22024–2024
State v. Carter green
kan · 2004
2 sentences

2024The rules regarding the admission or exclusion of evidence at trial may be applied as either a matter of law or discretion "depending on the contours of the rule in question." State v. Carter, 278 Kan. 74, 77 , 91 P.3d 1162 (2004).

2024The rules regarding the admission or exclusion of evidence at trial may be applied as either a matter of law or discretion "depending on the contours of the rule in question." State v. Carter, 278 Kan. 74, 77 , 91 P.3d 1162 (2004).

22005–2024
State v. Bird green
kan · 1985
2 sentences

2017The third person requirement for the application of the coconspirator exception to the hearsay rule, as declared in State v. 1 Bird, 238 Kan. 160, 176 , 708 P.2d 946 (1985), and its progeny, is hereby disapproved and overruled.

2017The third person requirement for the application of the coconspirator exception to the hearsay rule, as declared in State v. 1 Bird, 238 Kan. 160, 176 , 708 P.2d 946 (1985), and its progeny, is hereby disapproved and overruled.

21993–2017
Laterra Ex Rel. Commercial National Bank v. Treaster green
kanctapp · 1992
2 sentences

2017The court cited Laterra v. Treaster, 17 Kan.

2017The court cited Laterra v. Treaster, 17 Kan.

22011–2017
State v. Drach green
kan · 2000
2 sentences

2016This court held: “In prosecutions for homicide a deceased s declarations or threats indicating a suicidal disposition, if made within a reasonable time before his or her death, are not within the hearsay rule and are admissible unless the facts preclude the possibility of suicide.” (Emphasis added.) 268 Kan. 636 , Syl. ¶ 1.

2016This court held: "In prosecutions for homicide a deceased's declarations or threats indicating a suicidal disposition, if made within a reasonable time before his or her death, are not within the hearsay rule and are admissible unless the facts preclude the possibility of suicide." (Emphasis added.) 268 Kan. 636 , Syl. ¶ 1.

22001–2016
Mettee v. Urban Renewal Agency green
kan · 1974
22005–2012
City of Wichita v. Sealpak Co. green
kan · 2005
22007–2012
State v. Quick green
kan · 1979
21989–2010
State v. Roberts green
kan · 1977
21983–2009
State v. Rodriguez-Garcia green
kanctapp · 1999
22006–2007
Hannah v. Larche green
scotus · 1960
22007–2007
State v. Reed green
kan · 1973
21997–2007
Rollins v. State green
mdctspecapp · 2005
22005–2007
State v. Betts green
kan · 2001
22005–2007
West v. Martin green
kanctapp · 1986
21991–2006
State v. Armstead green
la · 1983
21988–2002
State v. Rhoten neutral
kan · 1953
21976–2001
White v. Illinois green
scotus · 1992
21998–1999
State v. Waugh green
kan · 1986
21996–1997
State v. Schultz green
kan · 1993
21995–1995
State v. Rider, Edens & Lemons green
kan · 1981
21983–1994
Schlatter v. Ibarra green
kan · 1975
21979–1984
Klein v. Wells green
kan · 1965
21982–1984

Statutes the citing opinions construe

KS § K.S.A. § 60-460 (134) KS § K.S.A. § 60-404 (29) KS § K.S.A. § 60-455 (27) KS § K.S.A. § 60-401 (24) KS § K.S.A. § 60-445 (20) KS § K.S.A. § 60-261 (19) KS § K.S.A. § 21-3401 (18) KS § K.S.A. § 60-456 (17) KS § K.S.A. § 60-459 (17) KS § K.S.A. § 60-407 (16) KS § K.S.A. § 22-3601 (14) KS § K.S.A. § 21-3427 (12)

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 2186 (1918–2026) NY 1697 (1905–2026) TX 1684 (1919–2026) IL 1581 (1922–2026) PA 1093 (1924–2026) OH 1027 (1925–2026) GA 665 (1916–2026) CT 631 (1925–2026) FL 612 (1936–2026) MO 548 (1915–2025) MI 523 (1919–2026) LA 516 (1938–2026) IN 507 (1917–2026) MA 462 (1936–2026) VA 448 (1919–2026) NJ 446 (1934–2026) TN 416 (1918–2026) WA 407 (1928–2026) MD 326 (1927–2026) NC 314 (1912–2026) DC 277 (1945–2026) AL 276 (1908–2026) MS 251 (1913–2026) IA 242 (1915–2025) OR 234 (1929–2026) KY 211 (1904–2026) NM 201 (1914–2026) AZ 187 (1955–2026) WI 181 (1939–2025) KS 177 (1922–2026) CO 174 (1926–2026) MN 167 (1913–2026) ID 138 (1916–2026) UT 132 (1924–2026) AR 132 (1953–2026) OK 132 (1925–2026) SC 124 (1929–2026) ME 121 (1916–2026) NE 116 (1941–2026) HI 114 (1927–2026) RI 110 (1961–2026) AK 103 (1964–2025) MT 102 (1929–2025) WV 101 (1913–2026) ND 77 (1905–2024) NV 77 (1969–2025) SD 76 (1909–2026) NH 76 (1905–2019) WY 70 (1965–2025) DE 61 (1925–2026) VT 48 (1921–2026) VI 12 (1977–2015) GU 5 (2022–2025) PR 2 (1962–2004)

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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