employee violation (Maryland) · Go Syfert
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employee violation in Maryland

26 Maryland opinions name it 2 courts 1986–2019 0 in the last five years

The cases below were cited by Maryland 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 (11)

CaseFollowedCited
Stoskin v. Bd. of Educ. Mont. Co.green
mdctspecapp · 1971 · cited in 2 Maryland opinions naming this issue, 2019–2019
2 sentences

2019See Stoskin v. Bd. of Educ. of Montgomery Cty. , 11 Md.

2019See Stoskin v. Bd. of Educ. of Montgomery Cty., 11 Md.

22
Shapiro v. Massengillgreen
mdctspecapp · 1995 · cited in 2 Maryland opinions naming this issue, 2002–2005
2 sentences

2002See Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-08 (D.Md.1996)(finding that the legal duty to report the misadministration of radiation belonged to the hospital as the licensee under the regulation, COMAR 26.12.01.01, § D. 409(b), and not the employee-physicist; therefore the employee could not claim protection from wrongful discharge under a public policy mandate); Bleich v. Florence Crittenton Serv., 98 Md.App. 123, 138-40 , 632 A.2d 463, 470-71 (1993)(recognizing a wrongful discharge claim for an educator terminated for filing a report for child abuse and neglect, as she was explicitly

2002See Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-08 (D.Md.1996)(finding that the legal duty to report the misadministration of radiation belonged to the hospital as the licensee under the regulation, COMAR 26.12.01.01, § D. 409(b), and not the employee-physicist; therefore the employee could not claim protection from wrongful discharge under a public policy mandate); Bleich v. Florence Crittenton Serv., 98 Md.App. 123, 138-40 , 632 A.2d 463, 470-71 (1993)(recognizing a wrongful discharge claim for an educator terminated for filing a report for child abuse and neglect, as she was explicitly

22
Thompson v. Memorial Hospital at Easton, Maryland, Inc.green
mdd · 1996 · cited in 2 Maryland opinions naming this issue, 2002–2005
2 sentences

2005For example, an employee may have a viable claim for wrongful discharge if the employee is terminated for reporting an activity that the employee is specifically required by law to report, see Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-8 (D.Md.1996) (finding that the duty to report illegal actions of the hospital was the duty of hospital and not the employee; therefore, the employee could not claim protection from wrongful discharge); Bleich, 98 Md.App. at 138-40, 632 A.2d 463 (recognizing wrongful discharge of teacher who was terminated for filing a legally required report of child abus

2002See Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-08 (D.Md.1996)(finding that the legal duty to report the misadministration of radiation belonged to the hospital as the licensee under the regulation, COMAR 26.12.01.01, § D. 409(b), and not the employee-physicist; therefore the employee could not claim protection from wrongful discharge under a public policy mandate); Bleich v. Florence Crittenton Serv., 98 Md.App. 123, 138-40 , 632 A.2d 463, 470-71 (1993)(recognizing a wrongful discharge claim for an educator terminated for filing a report for child abuse and neglect, as she was explicitly

22
Admiral Mortgage, Inc. v. Coopergreen
md · 2000 · cited in 5 Maryland opinions naming this issue, 2000–2018
2 sentences

2008Under LE section 3-507.1, a court may award an employee “an amount not exceeding 3 times the wage, and reasonable counsel fees and other costs” if it finds “that an employer withheld the wage of an employee in violation of the [the Wage Law] and not as a result of a bona fide dispute^]” “What constitutes a ‘bona fide dispute’ ... depends on the circumstances.” Admiral Mortg., Inc. v. Cooper, 357 Md. 533, 541 , 745 A.2d 1026 (2000).

2008Under LE section 3-507.1, a court may award an employee “an amount not exceeding 3 times the wage, and reasonable counsel fees and other costs” if it finds “that an employer withheld the wage of an employee in violation of the [the Wage Law] and not as a result of a bona fide dispute^]” “What constitutes a ‘bona fide dispute’ ... depends on the circumstances.” Admiral Mortg., Inc. v. Cooper, 357 Md. 533, 541 , 745 A.2d 1026 (2000).

15
Local 453 v. Otis Elevator Companygreen
ca2 · 1963 · cited in 3 Maryland opinions naming this issue, 1986–2014
2 sentences

2014For example, “[i]f the employer wanted the automatic right to discharge an employee for violation of certain company rules or for the commission of certain crimes, . . . it had the opportunity to seek such an explicit exclusion from the general arbitration clause when the collective agreement was negotiated, as it may do when the collective agreement expires.” Amalgamated Transit Union, 305 Md. at 388 (quoting Local 453, Int’l Union of Elec., Radio & Machine Workers v. Otis Elevator Co., 314 F.2d 25 , 28 (2d Cir. 1983)).

2014For example, “[i]f the employer wanted the automatic right to discharge an employee for violation of certain company rules or for the commission of certain crimes, ... it had the opportunity to seek such an explicit exclusion from the general arbitration clause when the collective agreement was negotiated, as it may do when the collective agreement expires.” Amalgamated Transit Union, 305 Md. at 388 , 504 A.2d 1132 (quoting Local 453, Int’l Union of Elec., Radio & Machine Workers v. Otis Elevator Co., 314 F.2d 25 , 28 (2d Cir.1963)).

13
Bleich v. Florence Crittenton Services of Baltimore, Inc.green
mdctspecapp · 1993 · cited in 2 Maryland opinions naming this issue, 2002–2005
2 sentences

2005For example, an employee may have a viable claim for wrongful discharge if the employee is terminated for reporting an activity that the employee is specifically required by law to report, see Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-8 (D.Md.1996) (finding that the duty to report illegal actions of the hospital was the duty of hospital and not the employee; therefore, the employee could not claim protection from wrongful discharge); Bleich, 98 Md.App. at 138-40, 632 A.2d 463 (recognizing wrongful discharge of teacher who was terminated for filing a legally required report of child abus

2002See Thompson v. Memorial Hosp., 925 F.Supp. 400, 407-08 (D.Md.1996)(finding that the legal duty to report the misadministration of radiation belonged to the hospital as the licensee under the regulation, COMAR 26.12.01.01, § D. 409(b), and not the employee-physicist; therefore the employee could not claim protection from wrongful discharge under a public policy mandate); Bleich v. Florence Crittenton Serv., 98 Md.App. 123, 138-40 , 632 A.2d 463, 470-71 (1993)(recognizing a wrongful discharge claim for an educator terminated for filing a report for child abuse and neglect, as she was explicitly

12
Indemnity Insurance Co. v. City of Garlandgreen
texapp · 2008 · cited in 1 Maryland opinions naming this issue, 2017–2017
1 sentence

2017See also Hedquist v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 272 Ga. 209, 210 , 528 S.E.2d 508 (2000) (holding that dismissal with prejudice of employee is not an adjudication upon the merits and therefore does not preclude respondeat superior liability finding against employer); Indemnity Ins. v. City of Garland, 258 S.W.3d 262, 272 (Tex. App. 2008) (under common law, dismissal with prejudice of employee, without settlement, was not a prior adjudication against the employee so as to bar claims against employer under collateral estoppel). 14 In a similar vein, some courts have held, consi

11
Hedquist v. Merrill Lynch, Pierce, Fenner & Smith, Inc.green
ga · 2000 · cited in 1 Maryland opinions naming this issue, 2017–2017
2 sentences

2017See also Hedquist v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 272 Ga. 209, 210 , 528 S.E.2d 508 (2000) (holding that dismissal with prejudice of employee is not an adjudication upon the merits and therefore does not preclude respondeat superior liability finding against employer); Indemnity Ins. v. City of Garland, 258 S.W.3d 262, 272 (Tex. App. 2008) (under common law, dismissal with prejudice of employee, without settlement, was not a prior adjudication against the employee so as to bar claims against employer under collateral estoppel). 14 In a similar vein, some courts have held, consi

2017See also Hedquist v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 272 Ga. 209, 210 , 528 S.E.2d 508 (2000) (holding that dismissal with prejudice of employee is not an adjudication upon the merits and therefore does not preclude respondeat superior liability finding against employer); Indemnity Ins. v. City of Garland, 258 S.W.3d 262, 272 (Tex. App. 2008) (under common law, dismissal with prejudice of employee, without settlement, was not a prior adjudication against the employee so as to bar claims against employer under collateral estoppel). 14 In a similar vein, some courts have held, consi

11
Blades v. Woodsgreen
md · 1995 · cited in 1 Maryland opinions naming this issue, 2013–2013
2 sentences

2013See Blades v. Woods, 338 Md. 475, 476-77, 479 , 659 A.2d 872, 872-73, 874 (1995) (The trial judge properly entered an order directing that two claims in a single case, a request for judicial review of a police department’s decision to fire an employee and a claim for damages for an alleged violation of 42 U.S.C. § 1983 , “proceed as separate actions.”).

2013See Blades v. Woods, 338 Md. 475, 476-77, 479 , 659 A.2d 872, 872-73, 874 (1995) (The trial judge properly entered an order directing that two claims in a single case, a request for judicial review of a police department’s decision to fire an employee and a claim for damages for an alleged violation of 42 U.S.C. § 1983 , “proceed as separate actions.”).

11
Peter J. Brennan, Secretary of Labor v. Occupational Safety and Health Review Commission and Raymond Hendrix, D/B/A Alsea Lumber Companygreen
ca9 · 1975 · cited in 1 Maryland opinions naming this issue, 1996–1996
2 sentences

1996Cf. Brennan v. OSHRC, 511 F.2d 1139, 1145 (9th Cir.1975) (holding that not requiring the Secretary to establish that an employer knew or should have known of the existence of an employee violation would in effect improperly make the employer strictly and absolutely liable for all violations).

1996Cf. Brennan v. OSHRC, 511 F.2d 1139, 1145 (9th Cir.1975) (holding that not requiring the Secretary to establish that an employer knew or should have known of the existence of an employee violation would in effect improperly make the employer strictly and absolutely liable for all violations).

11
R. H. Frazier & Son v. Leasgreen
md · 1916 · cited in 1 Maryland opinions naming this issue, 1991–1991
2 sentences

1991“If injury or death results to a workman from the deliberate intention of his employer to produce such injury or death, the employee, the widow, widower, child, children or dependents of the employee shall have the privilege either to take under this article or have cause of action against such employer, as if this article had not been passed.” Long ago this Court set forth the principles governing the interpretation of Maryland Workmen’s Compensation Act (Frazier v. Leas, 127 Md. 572, 575 , 96 A. 764, 765 (1916)): “First the intention of the Legislature as expressed in the words of the Act mu

1991“If injury or death results to a workman from the deliberate intention of his employer to produce such injury or death, the employee, the widow, widower, child, children or dependents of the employee shall have the privilege either to take under this article or have cause of action against such employer, as if this article had not been passed.” Long ago this Court set forth the principles governing the interpretation of Maryland Workmen’s Compensation Act (Frazier v. Leas, 127 Md. 572, 575 , 96 A. 764, 765 (1916)): “First the intention of the Legislature as expressed in the words of the Act mu

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (19)

CaseCitedYears
Amalgamated Transit Union, Division 1300 v. Mass Transit Administration green
md · 1986
2 sentences

2014For example, “[i]f the employer wanted the automatic right to discharge an employee for violation of certain company rules or for the commission of certain crimes, ... it had the opportunity to seek such an explicit exclusion from the general arbitration clause when the collective agreement was negotiated, as it may do when the collective agreement expires.” Amalgamated Transit Union, 305 Md. at 388 , 504 A.2d 1132 (quoting Local 453, Int’l Union of Elec., Radio & Machine Workers v. Otis Elevator Co., 314 F.2d 25 , 28 (2d Cir.1963)).

2014For example, “[i]f the employer wanted the automatic right to discharge an employee for violation of certain company rules or for the commission of certain crimes, ... it had the opportunity to seek such an explicit exclusion from the general arbitration clause when the collective agreement was negotiated, as it may do when the collective agreement expires.” Amalgamated Transit Union, 305 Md. at 388 , 504 A.2d 1132 (quoting Local 453, Int’l Union of Elec., Radio & Machine Workers v. Otis Elevator Co., 314 F.2d 25 , 28 (2d Cir.1963)).

22014–2014
Battaglia v. Clinical Perfusionists, Inc. green
md · 1995
2 sentences

2012The purpose of these provisions is “to provide a vehicle for employees to collect, and an incentive for employers to pay, back wages.” Battaglia v. Clinical Perfusionists, Inc., 338 Md. 352, 364 , 658 A.2d 680 (1995).

2012The purpose of these provisions is “to provide a vehicle for employees to collect, and an incentive for employers to pay, back wages.” Battaglia v. Clinical Perfusionists, Inc., 338 Md. 352, 364 , 658 A.2d 680 (1995).

22001–2012
Pinsky v. Pikesville Recreation Council green
mdctspecapp · 2013
2 sentences

2018LE § 3-507.2(b) states, "If ... a court finds that an employer withheld the wage of an employee in violation of this subtitle and not as the result of a bona fide dispute, the court may award the employee an amount not exceeding 3 times the wage, and reasonable counsel fees and other costs." The question of whether a defendant is an 'employer' under LE § 3-507.2(b) is, therefore, "a condition precedent to an action for treble damages, attorney's fees, and litigation costs under the statute, we must first consider whether the [defendant] could be subjected to such liability." *603 Pinsky v. Pik

2018App. 550 , 588, 78 A.3d 471 (2013).

12018–2018
Peters v. Early Healthcare Giver, Inc. green
md · 2014
2 sentences

2018The Court of Appeals in Peters reiterated its definition of a bona fide dispute: " 'a legitimate dispute over the validity of the claim or the amount that is owing [ ]' where the employer has a good faith basis for refusing an employee's claim for unpaid wages." 439 Md. 646 , 657, 97 A.3d 621 (2014) (citing Admiral Mort., Inc. v. Cooper , 357 Md. 533 , 543, 745 A.2d 1026 (2000) ).

2018The Court of Appeals in Peters reiterated its definition of a bona fide dispute: " 'a legitimate dispute over the validity of the claim or the amount that is owing [ ]' where the employer has a good faith basis for refusing an employee's claim for unpaid wages." 439 Md. 646 , 657, 97 A.3d 621 (2014) (citing Admiral Mort., Inc. v. Cooper , 357 Md. 533 , 543, 745 A.2d 1026 (2000) ).

12018–2018
Cohen v. Alliant Enterprises, Inc. green
ky · 2001
1 sentence

2017For example, in Cohen v. Alliant Enterprises, Inc., 60 S.W.3d 536 (Ky. 2001), the plaintiff sued a doctor and an emergency care center that employed him for medical negligence.

12017–2017
Newell v. Richards green
mdctspecapp · 1990
2 sentences

2013In Newell v. Richards, 83 Md.App. 371 , 574 A.2d 370 (1990), rev’d on other grounds, 323 Md. 717 , 594 A.2d 1152 (1991), involving a medical malpractice case filed in the Circuit Court for Baltimore County, the defendants, Dr. George J.

2013In Newell v. Richards, 83 Md.App. 371 , 574 A.2d 370 (1990), rev’d on other grounds, 323 Md. 717 , 594 A.2d 1152 (1991), involving a medical malpractice case filed in the Circuit Court for Baltimore County, the defendants, Dr. George J.

12013–2013
Newell v. Richards green
md · 1991
2 sentences

2013In Newell v. Richards, 83 Md.App. 371 , 574 A.2d 370 (1990), rev’d on other grounds, 323 Md. 717 , 594 A.2d 1152 (1991), involving a medical malpractice case filed in the Circuit Court for Baltimore County, the defendants, Dr. George J.

2013In Newell v. Richards, 83 Md.App. 371 , 574 A.2d 370 (1990), rev’d on other grounds, 323 Md. 717 , 594 A.2d 1152 (1991), involving a medical malpractice case filed in the Circuit Court for Baltimore County, the defendants, Dr. George J.

12013–2013
Friolo v. Frankel green
md · 2008
2 sentences

2008The court’s discretion is triggered ... under the Payment Law upon the court’s finding “that an employer withheld the wage of an employee in violation of this subtitle and not as a result of a bona fide dispute.” § 3-507.1(b). 403 Md. at 457 , 942 A.2d 1242 (emphasis supplied).

2008The court’s discretion is triggered ... under the Payment Law upon the court’s finding “that an employer withheld the wage of an employee in violation of this subtitle and not as a result of a bona fide dispute.” § 3-507.1(b). 403 Md. at 457 , 942 A.2d 1242 (emphasis supplied).

12008–2008
Medex v. McCabe green
md · 2002
2 sentences

2004(Emphasis added.) “The principal purpose of the Act ‘[isj to provide a vehicle for employees to collect, and an incentive for employers to pay, back wages.’ ” Medex v. McCabe, 372 Md. 28, 39 , 811 A.2d 297 (2002).

2004(Emphasis added.) “The principal purpose of the Act ‘[isj to provide a vehicle for employees to collect, and an incentive for employers to pay, back wages.’ ” Medex v. McCabe, 372 Md. 28, 39 , 811 A.2d 297 (2002).

12004–2004
Pennsylvania Threshermen & Farmers' Mutual Casualty Insurance v. Travelers Insurance green
md · 1963
2 sentences

1996Pennsylvania Threshermen and Farmers’ Mutual Casualty Insurance Co. v. Travelers Insurance Co., 233 Md. 205, 215 , 196 A.2d 76 (1963).

1996Pennsylvania Threshermen and Farmers’ Mutual Casualty Insurance Co. v. Travelers Insurance Co., 233 Md. 205, 215 , 196 A.2d 76 (1963).

11996–1996
Sheets v. Teddy's Frosted Foods, Inc. green
conn · 1980
1 sentence

1992In Sheets v. Teddy’s Frosted Foods, Inc., supra, the Supreme Court of Connecticut found that an employee stated a claim of abusive discharge against his employer, a producer of frozen food products, because: (a) the employee, a quality control director, identified specific deviations in the employer’s product from specifications contained in the employer’s standards and labels, which concerned the use of substandard raw materials and underweight components in the employer’s finished products; (b) false and misleading labels constituted a violation of a specific provision within the Connecticut

11992–1992
Silkworth v. Ryder Truck Rental, Inc. green
mdctspecapp · 1987
1 sentence

1991Id. at 270, 520 A.2d 1124 .

11991–1991
Washington Metropolitan Area Transit Authority v. Bullock green
mdctspecapp · 1986
2 sentences

1991First, absent the liberal rule, “the law seems to be ... [that] ‘where the employer has expressly forbidden his employee to use the employer’s automobile for his own personal purposes, such use of the automobile by the employee in violation of orders is not deemed to be one with the permission of the employer within the meaning of the omnibus clause of the liability insurance policy.’ ” Washington Transit Authority, 68 Md.App. at 35 , 509 A.2d 1217 (quoting Annotation, Automobile liability insurance: permission or consent to employee’s use of car within meaning of omnibus coverage clause, 5 A.

1991First, absent the liberal rule, “the law seems to be ... [that] ‘where the employer has expressly forbidden his employee to use the employer’s automobile for his own personal purposes, such use of the automobile by the employee in violation of orders is not deemed to be one with the permission of the employer within the meaning of the omnibus clause of the liability insurance policy.’ ” Washington Transit Authority, 68 Md.App. at 35 , 509 A.2d 1217 (quoting Annotation, Automobile liability insurance: permission or consent to employee’s use of car within meaning of omnibus coverage clause, 5 A.

11991–1991
Alexander v. Worthington green
md · 1853
1 sentence

1991“If injury or death results to a workman from the deliberate intention of his employer to produce such injury or death, the employee, the widow, widower, child, children or dependents of the employee shall have the privilege either to take under this article or have cause of action against such employer, as if this article had not been passed.” Long ago this Court set forth the principles governing the interpretation of Maryland Workmen’s Compensation Act (Frazier v. Leas, 127 Md. 572, 575 , 96 A. 764, 765 (1916)): “First the intention of the Legislature as expressed in the words of the Act mu

11991–1991
Harris v. Jones green
md · 1977
2 sentences

1987Count II—Intentional Infliction of Emotional Distress The elements of the tort of intentional infliction of emotional distress are set out in Harris v. Jones, 281 Md. 560 , 380 A.2d 611 (1977).

1987Count II—Intentional Infliction of Emotional Distress The elements of the tort of intentional infliction of emotional distress are set out in Harris v. Jones, 281 Md. 560 , 380 A.2d 611 (1977).

11987–1987
Joseph Boyd, an Infant by His Next Friend and Mother, Selena Boyd v. Liberty Mutual Insurance Company green
cadc · 1956
1 sentence

1986Unless clearly operating under the “liberal” rule, the law seems to be as stated in Annot., Automobile liability insurance: permission or consent to employee’s use of car within meaning of omnibus coverage clause, 5 A.L.R. 2d 600, 651 (1949): “Where the employer has expressly forbidden his employee to use the employer’s automobile for his own personal purposes, such use of the automobile by the employee in violation of orders is not deemed to be one with the permission of the employer within the meaning of the omnibus clause of the liability insurance policy.” See also Boyd v. Liberty Mutual I

11986–1986
McKee Ex Rel. Burton v. Travelers Insurance Co. green
moctapp · 1958
1 sentence

1986Unless clearly operating under the “liberal” rule, the law seems to be as stated in Annot., Automobile liability insurance: permission or consent to employee’s use of car within meaning of omnibus coverage clause, 5 A.L.R. 2d 600, 651 (1949): “Where the employer has expressly forbidden his employee to use the employer’s automobile for his own personal purposes, such use of the automobile by the employee in violation of orders is not deemed to be one with the permission of the employer within the meaning of the omnibus clause of the liability insurance policy.” See also Boyd v. Liberty Mutual I

11986–1986
Olgin v. Employers Mut. Casualty Co. neutral
texapp · 1950
1 sentence

1986Casu *36 alty Co., 228 S.W.2d 552 (Tex.Civ.App.1950); and 6C Appleman, supra, § 4370.

11986–1986
Ditmyer v. American Liberty Insurance green
gactapp · 1968
2 sentences

1986Unless clearly operating under the “liberal” rule, the law seems to be as stated in Annot., Automobile liability insurance: permission or consent to employee’s use of car within meaning of omnibus coverage clause, 5 A.L.R. 2d 600, 651 (1949): “Where the employer has expressly forbidden his employee to use the employer’s automobile for his own personal purposes, such use of the automobile by the employee in violation of orders is not deemed to be one with the permission of the employer within the meaning of the omnibus clause of the liability insurance policy.” See also Boyd v. Liberty Mutual I

1986Unless clearly operating under the “liberal” rule, the law seems to be as stated in Annot., Automobile liability insurance: permission or consent to employee’s use of car within meaning of omnibus coverage clause, 5 A.L.R. 2d 600, 651 (1949): “Where the employer has expressly forbidden his employee to use the employer’s automobile for his own personal purposes, such use of the automobile by the employee in violation of orders is not deemed to be one with the permission of the employer within the meaning of the omnibus clause of the liability insurance policy.” See also Boyd v. Liberty Mutual I

11986–1986

Statutes the citing opinions construe

USC § 42u.s.c.1988 (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 103 (1919–2026) OH 62 (1945–2025) MO 53 (1907–2024) TX 47 (1950–2025) IL 44 (1914–2024) NY 37 (1929–2025) CT 27 (1944–2020) MD 26 (1986–2019) TN 26 (1918–2025) WV 24 (1900–2022) PA 23 (1922–2026) IN 18 (1938–2018) NJ 18 (1974–2026) SC 15 (1945–2021) IA 15 (1948–2023) MN 14 (1969–2015) FL 13 (1968–2024) NM 13 (1945–2023) AZ 13 (1927–2026) LA 13 (1983–2026) VA 13 (1967–2024) AL 13 (1925–2017) GA 12 (1938–2010) WI 12 (1975–2024) NE 12 (1980–2025) MA 11 (1953–2013) MI 11 (1913–2024) OK 11 (1936–2016) NC 11 (1970–2018) ID 10 (1962–2021) ME 9 (1978–2022) OR 8 (1978–2020) AK 7 (1961–2010) DE 7 (1971–2024) RI 7 (1972–2014) WA 6 (1956–2021) MT 6 (1928–2017) CO 6 (1988–2005) KS 6 (1920–2026) AR 5 (1989–1997) UT 5 (1943–2021) HI 5 (1982–1998) KY 4 (1961–2024) SD 4 (1992–2008) WY 4 (1982–2019) DC 4 (2001–2015) ND 2 (1937–1963) MS 2 (1994–1998)

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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