164 Louisiana opinions name it 2 courts 1963–2026 14 in the last five years
The cases below were cited by Louisiana 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 |
|---|---|---|
State v. Ruizgreen2 sentences2024App. 4 Cir. 3/10/22), 336 So. 3d 513 , 529, stated: The Louisiana Supreme Court has held that the contemporaneous objection rule provides that “an irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.” State v. Ruiz, 06-1755, p. 8 (La. 4/11/07), 955 So.2d 81, 87 (citing La. 2022The Louisiana Supreme Court has held that the contemporaneous objection rule provides that “an irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.” State v. Ruiz, 06-1755, p. 8 (La. 4/11/07), 955 So.2d 81, 87 (citing La. | 4 | 6 |
State v. Lanclosgreen2 sentences2026State v. Santiago, 23-00501, p. 5 (La. 5/10/24), 384 So. 3d 879 , 882; State v. Lanclos, 07-0082, p. 6 (La. 4/8/08), 980 So. 2d 643, 648 . 2024State v. Lanclos, 2007-0082, p. 6 (La. 4/8/08), 980 So.2d 643, 648 . | 3 | 12 |
State v. Kaheygreen2 sentences2016C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of the occurrence.”); State v. Kahey, 436 So.2d 475, 489 (La. 1983) (“[A]n irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Lindsey, 404 So.2d 466, 478 (La. 1981) (“In the absence of a contemporaneous objection, an alleged error or irregularity in the proceedings cannot be availed of after the verdict is rendered.”); State v. Marcell, 320 So.2d 195, 197 (La. 1975) (“By failing to make a timely objection, 2016La.C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of the occurrence.”); State v. Kahey, 436 So.2d 475, 489 (La.1983) (“[A]n irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Lindsey, 404 So.2d 466, 478 (La.1981) ("In the absence of a contemporaneous objection, an alleged error or irregularity in the proceedings cannot be availed of after the verdict is rendered.”); State v. Marcell, 320 So.2d 195, 197 (La.1975) (“By failing to make a timely objection, | 2 | 5 |
State v. Marlowegreen2 sentences2020App. 4 Cir. 12/22/11), 81 So.3d 944, 966 (noting that the contemporaneous objection rule serves two purposes: “(1) to put the trial court on notice of the alleged irregularity or error, so that the court can cure the error; and (2) to prevent a party from gambling for a favorable outcome and then appealing on errors that could have been addressed by an objection if the outcome is not as hoped”). 2 While we find the trial court erred in its ultimate determination, as stated in our prior writ disposition, the trial court’s oral reasons reflect its adoption of the State’s singular basis for denyi 2013See State v. Marlowe, 10-1116, p. 85 (La.App. 4 Cir. 12/22/11), 81 So.3d 944, 965-966 , writ denied, 12-0231 (La.5/18/12), 89 So.3d 1191 (it is well-settled that an irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence, citing La.C.Cr.P. art. 841 A). | 2 | 4 |
| State v. Trahangreen | 2 | 2 |
State v. Knightgreen2 sentences2023See also State v. Knight, 323 So.2d 765, 769 (La. 1975); State v. Alexander, 430 So.2d 621 (La. 1983). 1978La.Code Crim.P. art 841; State v. Robertson, 358 So.2d 931 (La.1978); State v. Williams, 343 So.2d 1026 (La.), cert, denied, 434 U.S. 928 , 98 S.Ct. 412 , 54 L.Ed.2d 287 (1977); State v. Finley, 341 So.2d 381 (La.1976); State v. Knight, 323 So.2d 765 (La.1975). | 1 | 6 |
State v. Cartergreen2 sentences2019App. 5 Cir. 8/30/11), 75 So.3d 1 , writ denied, 11-2060 (La. 2/10/12), 80 So.3d 469 (holding defendant waived the argument that evidence should be suppressed because the search exceeded the scope of the search warrant when the defense counsel never asked the trial judge to rule on the “constitutionally overbroad” issue asserted for the first time on appeal); State v. Brown, 434 So.2d 399 (La. 1983) (rejecting defendant’s alternative argument regarding the denial of his motion to suppress because he had not raised the issue at trial); State v. Johnson, 07-1040 (La. 2013State v. Montejo, 06-1807, p. 22 (La.5/11/10), 40 So.3d 952, 967 , cert. denied, Montejo v. Louisiana, — U.S. -, 131 S.Ct. 656 , 178 L.Ed.2d 513 (2010); See: LSA-C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Simmons, 422 So.2d 138 (La.1982); State v. Harris, 414 So.2d 325 (La.1982); State v. Davis, 357 So.2d 1125 (La.1978); See also: State v. Carter, 10-973, p. 7-8 (La.App. 5 Cir. 8/30/11), 75 So.3d 1 , writ denied, 2011-2060 (La.2/10/12), 80 So.3d 469 (holding defendant waived the argument tha | 1 | 5 |
State v. Thomasgreen2 sentences2024Barring appellate review of an irregularity or error that was not objected to at the time of the occurrence “prevent[s] a defendant from gambling for a favorable verdict and then resorting to appeal on errors that might easily have been corrected by objection.” Id. 2011State v. Landos, 2007^0082,36 p. 6 (La.4/8/08), 980 So.2d 643, 648 , citing State v. Knott, 2005-2252 (La.5/5/06), 928 So.2d 534 , and State v. Thomas, 427 So.2d 428 (La.1982). | 1 | 4 |
State v. Dobsongreen2 sentences1991In Dobson, supra, this court stated: “C.Cr.P. art. 841 sets out the general contemporaneous objection rule in Louisiana: ‘An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.’ Art. 801 contains the following provision dealing specifically with a jury charge: A party may not assign as error the giving or failure to give a jury charge or any portion thereof unless an objection thereto is made before the jury retires or within such time as the court may reasonably cure the alleged error. 1991In Dobson, supra, this court stated: "C.Cr.P. art. 841 sets out the general contemporaneous objection rule in Louisiana: `An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.' Art. 801 contains the following provision dealing specifically with a jury charge: A party may not assign as error the giving or failure to give a jury charge or any portion thereof unless an objection thereto is made before the jury retires or within such time as the court may reasonably cure the alleged error. | 1 | 4 |
State v. Marlowegreen2 sentences2014La.C.Cr.P. art. 841(A); State v. Marlowe, 10-1116, p. 35 (La.App. 4 Cir. 12/22/11), 81 So.3d 944, 965-66 , writ denied, 12-0231 (La.5/18/12), 89 So.3d 1191 . 2013See State v. Marlowe, 10-1116, p. 85 (La.App. 4 Cir. 12/22/11), 81 So.3d 944, 965-966 , writ denied, 12-0231 (La.5/18/12), 89 So.3d 1191 (it is well-settled that an irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence, citing La.C.Cr.P. art. 841 A). | 1 | 3 |
| State v. Marcellgreen | 1 | 2 |
| State v. Sepcichgreen | 1 | 2 |
| State v. Kleingreen | 1 | 2 |
| State v. Baylisgreen | 1 | 2 |
| State v. Keysgreen | 1 | 1 |
| State v. Martgreen | 1 | 1 |
| State v. Hattongreen | 1 | 1 |
| State v. Griffingreen | 1 | 1 |
| State v. Draughngreen | 1 | 1 |
| State v. Lindseygreen | 1 | 1 |
| State v. Browngreen | 1 | 1 |
| State v. Robinsongreen | 1 | 1 |
| State v. Thorntongreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Louisiana. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Hamilton
green
2 sentences2006LSA-C.Cr.P. art. 841; State v. Bosley, 29,253 (La.App. 2d Cir.4/2/97), 691 So.2d 347 , writ denied, XXXX-XXXX (La.10/17/97), 701 So.2d 1333 ; State v. Hamilton, 594 So.2d 1376 (La. 2003La.C.Cr.P. art. 841; State v. Bosley, supra ; State v. Hamilton, 594 So.2d 1376 (La.App. 2d Cir.1992); State v. Brown, 552 So.2d 612 (La.App. 2d Cir.1989), writ denied, 558 So.2d 581 (La. 1990). | 9 | 1996–2006 |
State v. Finley
green
2 sentences1979See State v. Matthews, 354 So.2d 552 (La.1978); State v. Ford, 349 So.2d 300 (La.1977); State v. Finley, 341 So.2d 381 (La.1976). 1978La.Code Crim.P. art 841; State v. Robertson, 358 So.2d 931 (La.1978); State v. Williams, 343 So.2d 1026 (La.), cert, denied, 434 U.S. 928 , 98 S.Ct. 412 , 54 L.Ed.2d 287 (1977); State v. Finley, 341 So.2d 381 (La.1976); State v. Knight, 323 So.2d 765 (La.1975). | 8 | 1977–1979 |
State v. Knott
green
2 sentences2011Louisiana's contemporaneous objection rule provides, "An irregularity or error cannot be availed of after a verdict unless it was objected to at the time of occurrence." La.C.Cr.P. art. 841(A); State v. Ruiz, 06-1755 (La.4/11/07), 955 So.2d 81 ; State v. Knott, 05-2252 (La.5/5/06), 928 So.2d 534 . 2011Louisiana’s contemporaneous objection rule provides, “An irregularity or error cannot be availed of after a verdict unless it was objected to at the time of occurrence.” La.C.Cr.P. art. 841(A); State v. Ruiz, 06-1755 (La.4/11/07), 955 So.2d 81 ; State v. Knott, 05-2252 (La.5/5/06), 928 So.2d 534 . | 7 | 2008–2024 |
State v. Brown
green
2 sentences2003La.C.Cr.P. art. 841; State v. Bosley, supra ; State v. Hamilton, 594 So.2d 1376 (La.App. 2d Cir.1992); State v. Brown, 552 So.2d 612 (La.App. 2d Cir.1989), writ denied, 558 So.2d 581 (La. 1990). 2002LSA-C.Cr.P. art. 814; State v. Bosley, supra ; State v. Hamilton, 594 So.2d 1376 (La.App.2d Cir.1992); State v. Brown, 552 So.2d 612 (La.App. 2d Cir.1989), writ denied, 558 So.2d 581 (La.1990). | 7 | 1993–2003 |
State v. Brown
green
2 sentences2003La.C.Cr.P. art. 841; State v. Bosley, supra ; State v. Hamilton, 594 So.2d 1376 (La.App. 2d Cir.1992); State v. Brown, 552 So.2d 612 (La.App. 2d Cir.1989), writ denied, 558 So.2d 581 (La. 1990). 2002LSA-C.Cr.P. art. 814; State v. Bosley, supra ; State v. Hamilton, 594 So.2d 1376 (La.App.2d Cir.1992); State v. Brown, 552 So.2d 612 (La.App. 2d Cir.1989), writ denied, 558 So.2d 581 (La.1990). | 7 | 1993–2003 |
State v. Williams
green
2 sentences1979State v. Williams, 343 So.2d 1026 (La.1977). *765 We also find that the state's challenges for cause of the other ten prospective jurors were properly allowed by the trial judge. 1978La.Code Crim.P. art 841; State v. Robertson, 358 So.2d 931 (La.1978); State v. Williams, 343 So.2d 1026 (La.), cert, denied, 434 U.S. 928 , 98 S.Ct. 412 , 54 L.Ed.2d 287 (1977); State v. Finley, 341 So.2d 381 (La.1976); State v. Knight, 323 So.2d 765 (La.1975). | 7 | 1978–1979 |
State v. Carter
green
2 sentences2019App. 5 Cir. 8/30/11), 75 So.3d 1 , writ denied, 11-2060 (La. 2/10/12), 80 So.3d 469 (holding defendant waived the argument that evidence should be suppressed because the search exceeded the scope of the search warrant when the defense counsel never asked the trial judge to rule on the “constitutionally overbroad” issue asserted for the first time on appeal); State v. Brown, 434 So.2d 399 (La. 1983) (rejecting defendant’s alternative argument regarding the denial of his motion to suppress because he had not raised the issue at trial); State v. Johnson, 07-1040 (La. 2013State v. Montejo, 06-1807, p. 22 (La.5/11/10), 40 So.3d 952, 967 , cert. denied, Montejo v. Louisiana, — U.S. -, 131 S.Ct. 656 , 178 L.Ed.2d 513 (2010); See: LSA-C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Simmons, 422 So.2d 138 (La.1982); State v. Harris, 414 So.2d 325 (La.1982); State v. Davis, 357 So.2d 1125 (La.1978); See also: State v. Carter, 10-973, p. 7-8 (La.App. 5 Cir. 8/30/11), 75 So.3d 1 , writ denied, 2011-2060 (La.2/10/12), 80 So.3d 469 (holding defendant waived the argument tha | 5 | 2013–2019 |
State v. West
green
2 sentences2012As stated above, “materiality of false testimony is a matter of law to be determined by the court; it is not a factual question to be determined by the jury.” State v. West, supra. Additionally, LSA-C.Cr.P. art. 841(A) provides: An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence. 1987Art. 841 provides that "An irregularity of error cannot be availed *1141 of after verdict unless it was objected to at the time of the occurrence." In State v. West, 419 So.2d 868 (La.1982), the Court held that a ground for objection on appeal which was not raised in the trial court was untimely: We have held that the grounds of counsel's objections must be sufficiently brought to the attention of the trial judge to allow him the opportunity to make the proper ruling and correct any claimed prejudice to the defendant. | 5 | 1986–2012 |
State v. Taylor
green
2 sentences2016See LSA-C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Taylor, 93-2201 at pp. 4-7, 669 So.2d at 367-69 . 2016See LSA-C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Taylor, 93-2201 at pp. 4-7, 669 So.2d at 367-69 . | 4 | 2005–2018 |
State v. Stewart
green
2 sentences1998La.C.Cr.P. art. 841; State v. Stewart, 486 So.2d 906 (La.App. 1st Cir.1986). 1987LSA-C.Cr.P. art. 841; State v. Stewart, 486 So.2d 906 (La.App. 1st Cir.1986). | 4 | 1986–1998 |
State v. Jackson
green
2 sentences1993La.C.Cr.P. art. 841; State v. Jackson, 523 So.2d 251 (La.App. 2d Cir.), writ denied 530 So.2d 565 (1988). 1993State v. Jackson, 523 So.2d 251 (La.App. 2d Cir.), writ denied, 530 So.2d 565 (1988); LSA-C.Cr.P. | 4 | 1992–1993 |
State v. Jackson
green
2 sentences1993La.C.Cr.P. art. 841; State v. Jackson, 523 So.2d 251 (La.App. 2d Cir.), writ denied 530 So.2d 565 (1988). 1993State v. Jackson, 523 So.2d 251 (La.App. 2d Cir.), writ denied, 530 So.2d 565 (1988); LSA-C.Cr.P. | 4 | 1992–1993 |
State v. Phanor
green
2 sentences1978La.Code Crim.P. art. 841; State v. Williams, 343 So.2d 1026 (La.1977); State v. Finley, 341 So.2d 381 (La.1976); State v. Phanor, 325 So.2d 579 (La.1976). 1978State v. O'Blanc, 346 So.2d 686 (La.1977); State v. Williams, 343 So.2d 1026 (La.1977); State v. Finley, 341 So.2d 381 (La.1976); State v. Phanor, 325 So.2d 579 (La.1976); *560 State v. Knight, 323 So.2d 765 (La.1975); State v. Burgy, 320 So.2d 175 (La.1975). | 4 | 1976–1978 |
State v. Simmons
green
2 sentences2019C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Simmons, 422 So.2d 138 (La. 1982); Harris, supra; State v. Davis, 357 So.2d 1125 (La. 1978); State v. Carter, 10-973 (La. 2013State v. Montejo, 06-1807, p. 22 (La.5/11/10), 40 So.3d 952, 967 , cert. denied, Montejo v. Louisiana, — U.S. -, 131 S.Ct. 656 , 178 L.Ed.2d 513 (2010); See: LSA-C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Simmons, 422 So.2d 138 (La.1982); State v. Harris, 414 So.2d 325 (La.1982); State v. Davis, 357 So.2d 1125 (La.1978); See also: State v. Carter, 10-973, p. 7-8 (La.App. 5 Cir. 8/30/11), 75 So.3d 1 , writ denied, 2011-2060 (La.2/10/12), 80 So.3d 469 (holding defendant waived the argument tha | 3 | 1987–2019 |
State v. Bosley
green
2 sentences2006LSA-C.Cr.P. art. 841; State v. Bosley, 29,253 (La.App. 2d Cir.4/2/97), 691 So.2d 347 , writ denied, XXXX-XXXX (La.10/17/97), 701 So.2d 1333 ; State v. Hamilton, 594 So.2d 1376 (La. 1999State v. Bosley, 29,253 (La.App.2d Cir.4/2/97), 691 So.2d 347 , writ denied, 97-1203 (La.10/17/97), 701 So.2d 1333 ; State v. Hamilton, 594 So.2d 1376 (La.App. 2d Cir.1992); State v. Brown, 552 So.2d 612 (La.App.2d Cir.1989), writ denied, 558 So.2d 581 (1990); La.C.Cr.P. art. 841. | 3 | 1997–2006 |
State v. Ratcliff
green
2 sentences1997La.Code Crim.P. art. 841; State v. Ratcliff, 416 So.2d 528 (La.1982). 1996La.Code Crim.P. art. 841; State v. Ratcliff, 416 So.2d 528 (La.1982). | 3 | 1989–1997 |
State v. Morris
green
2 sentences1993C.Cr.P. 841; State v. Morris, 429 So.2d 111 (La.1983). 1987LSA-C.Cr.P. art. 841; State v. Morris, 429 So.2d 111 (La.1983). | 3 | 1983–1993 |
State v. Bazile
green
2 sentences1991C.Cr.P. art. 841 provides in pertinent part: "An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence." In State v. Bazile, 386 So.2d 349 (La. 1980), the defense objected to the voir dire procedure employed by the trial court after the jurors had been selected and sworn, but before opening arguments. 1988LSA-C.Cr.P. art. 841 states that: “An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.” The Louisiana Supreme Court has applied the rule of contemporaneous objection to irregularities occurring during the selection of a jury in State v. Bazile, 386 So.2d 349 (La.1980) and State v. Spencer, 446 So.2d 1197 (La.1984). | 3 | 1984–1991 |
Miranda v. Arizona
green
2 sentences1989Whoever commits the crime of first degree murder shall be punished by death or life imprisonment at hard labor without benefit of parole, probation, or suspension of sentence in accordance with the determination of the jury. [2] LSA-Const.1974, Art. 5, § 5(D) provides: (D) In addition to other appeals provided by this constitution, a case shall be appealable to the supreme court if (1) a law or ordinance has been declared unconstitutional or (2) the defendant has been convicted of a capital offense and a penalty of death actually has been imposed. [3] Miranda v. Arizona, 384 U.S. 436 , 86 S.Ct 1989Whoever commits the crime of first degree murder shall be punished by death or life imprisonment at hard labor without benefit of parole, probation, or suspension of sentence in accordance with the determination of the jury. [2] LSA-Const.1974, Art. 5, § 5(D) provides: (D) In addition to other appeals provided by this constitution, a case shall be appealable to the supreme court if (1) a law or ordinance has been declared unconstitutional or (2) the defendant has been convicted of a capital offense and a penalty of death actually has been imposed. [3] Miranda v. Arizona, 384 U.S. 436 , 86 S.Ct | 2 | 1989–2024 |
| State v. Davis green | 2 | 2013–2019 |
State v. Brown
green
2 sentences2019App. 5 Cir. 8/30/11), 75 So.3d 1 , writ denied, 11-2060 (La. 2/10/12), 80 So.3d 469 (holding defendant waived the argument that evidence should be suppressed because the search exceeded the scope of the search warrant when the defense counsel never asked the trial judge to rule on the “constitutionally overbroad” issue asserted for the first time on appeal); State v. Brown, 434 So.2d 399 (La. 1983) (rejecting defendant’s alternative argument regarding the denial of his motion to suppress because he had not raised the issue at trial); State v. Johnson, 07-1040 (La. 2013State v. Montejo, 06-1807, p. 22 (La.5/11/10), 40 So.3d 952, 967 , cert. denied, Montejo v. Louisiana, — U.S. -, 131 S.Ct. 656 , 178 L.Ed.2d 513 (2010); See: LSA-C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Simmons, 422 So.2d 138 (La.1982); State v. Harris, 414 So.2d 325 (La.1982); State v. Davis, 357 So.2d 1125 (La.1978); See also: State v. Carter, 10-973, p. 7-8 (La.App. 5 Cir. 8/30/11), 75 So.3d 1 , writ denied, 2011-2060 (La.2/10/12), 80 So.3d 469 (holding defendant waived the argument tha | 2 | 2013–2019 |
State v. Harris
green
2 sentences2019C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Simmons, 422 So.2d 138 (La. 1982); Harris, supra; State v. Davis, 357 So.2d 1125 (La. 1978); State v. Carter, 10-973 (La. 2013State v. Montejo, 06-1807, p. 22 (La.5/11/10), 40 So.3d 952, 967 , cert. denied, Montejo v. Louisiana, — U.S. -, 131 S.Ct. 656 , 178 L.Ed.2d 513 (2010); See: LSA-C.Cr.P. art. 841(A) (“An irregularity or error cannot be availed of after verdict unless it was objected to at the time of occurrence.”); State v. Simmons, 422 So.2d 138 (La.1982); State v. Harris, 414 So.2d 325 (La.1982); State v. Davis, 357 So.2d 1125 (La.1978); See also: State v. Carter, 10-973, p. 7-8 (La.App. 5 Cir. 8/30/11), 75 So.3d 1 , writ denied, 2011-2060 (La.2/10/12), 80 So.3d 469 (holding defendant waived the argument tha | 2 | 2013–2019 |
| State v. Thomas green | 2 | 2016–2016 |
| State v. Carter green | 2 | 2016–2016 |
| State v. Simpkins green | 2 | 2016–2016 |
| State v. Enclard green | 2 | 2012–2012 |
| State v. Cunningham green | 2 | 2008–2011 |
| State v. Noil green | 2 | 2008–2009 |
| State v. Noil green | 2 | 2008–2009 |
| State v. Smith green | 2 | 2007–2008 |
| State v. Bennett green | 2 | 1995–2006 |
| State v. Bosley green | 2 | 1999–2006 |
| State v. Bennett green | 2 | 1995–2006 |
| State v. Woodfox green | 2 | 1997–2000 |
| State v. Arnold green | 2 | 1981–1999 |
| State v. Williams green | 2 | 1992–1993 |
| State v. Gordy green | 2 | 1987–1993 |
| State v. Segura green | 2 | 1988–1988 |
| State v. Munzy green | 2 | 1988–1988 |
| State v. Ford green | 2 | 1979–1986 |
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.