view doctrine (Oregon) · Go Syfert
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view doctrine in Oregon

25 Oregon opinions name it 3 courts 1884–2025 5 in the last five years

The cases below were cited by Oregon 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 (9)

CaseFollowedCited
Brewer v. Erwinred
or · 1979 · cited in 1 Oregon opinions naming this issue, 2020–2020
2 sentences

2020See Brewer v. Erwin, 287 Or 435 , 455 n 12, 600 P2d 398 (1979) (noting that, although sections of the Restatements of the American Law Institute are not necessarily authoritative, we some- times quote them as “shorthand expressions of the court’s view that the analysis summarized in the Restatement cor- responds to Oregon law applicable to the facts of the case before the court”).13 13 As a more general matter, although we do not regard the restatements as binding statements of Oregon law, we do find them relevant and helpful “descrip- tive restatements of the law.” McPherson v. Oregon Dept. o

2020See Brewer v. Erwin, 287 Or 435 , 455 n 12, 600 P2d 398 (1979) (noting that, although sections of the Restatements of the American Law Institute are not necessarily authoritative, we some- times quote them as “shorthand expressions of the court’s view that the analysis summarized in the Restatement cor- responds to Oregon law applicable to the facts of the case before the court”).13 13 As a more general matter, although we do not regard the restatements as binding statements of Oregon law, we do find them relevant and helpful “descrip- tive restatements of the law.” McPherson v. Oregon Dept. o

11
McPherson v. State Ex Rel. Department of Correctionsgreen
orctapp · 2007 · cited in 1 Oregon opinions naming this issue, 2020–2020
2 sentences

2020See Brewer v. Erwin, 287 Or 435 , 455 n 12, 600 P2d 398 (1979) (noting that, although sections of the Restatements of the American Law Institute are not necessarily authoritative, we some- times quote them as “shorthand expressions of the court’s view that the analysis summarized in the Restatement cor- responds to Oregon law applicable to the facts of the case before the court”).13 13 As a more general matter, although we do not regard the restatements as binding statements of Oregon law, we do find them relevant and helpful “descrip- tive restatements of the law.” McPherson v. Oregon Dept. o

2020See Brewer v. Erwin, 287 Or 435 , 455 n 12, 600 P2d 398 (1979) (noting that, although sections of the Restatements of the American Law Institute are not necessarily authoritative, we some- times quote them as “shorthand expressions of the court’s view that the analysis summarized in the Restatement cor- responds to Oregon law applicable to the facts of the case before the court”).13 13 As a more general matter, although we do not regard the restatements as binding statements of Oregon law, we do find them relevant and helpful “descrip- tive restatements of the law.” McPherson v. Oregon Dept. o

11
State v. Fostergreen
ohio · 2006 · cited in 1 Oregon opinions naming this issue, 2006–2006
2 sentences

2006In State v. Lett, 161 Ohio App 3d 274, 829 NE 2d 1281 [2005], an en banc decision, the Eighth Appellate District found Blakely is inapplicable to consecutive sentencing because ‘the facts found by the court do not increase the maximum penalty for an individual offense.’ This is true; nevertheless, because the total punishment increases through consecutive sentences only after judicial findings beyond those determined by a jury or stipulated by a defendant, R.C. 2929.14(E)(4) violates principles announced in Blakely” 109 Oh St 3d at 21-22, 845 NE2d at 490-91 (citations, footnotes, and emphasis

2006St. 3d at 21-22, 845 N.E.2d at 490-91 (citations, footnotes, and emphasis omitted). [6] By contrast, the Washington Supreme Court took a narrower view of the rule of law announced in Apprendi : " Apprendi does not have any application to consecutive sentences; to conclude otherwise would extend Apprendi 's holding beyond the narrow grounds upon which it rested." State v. Cubias, 155 Wash.2d 549, 553 , 120 P.3d 929, 931 (2005).

11
State v. Cubiasgreen
wash · 2005 · cited in 1 Oregon opinions naming this issue, 2006–2006
2 sentences

2006In State v. Lett, 161 Ohio App 3d 274, 829 NE 2d 1281 [2005], an en banc decision, the Eighth Appellate District found Blakely is inapplicable to consecutive sentencing because ‘the facts found by the court do not increase the maximum penalty for an individual offense.’ This is true; nevertheless, because the total punishment increases through consecutive sentences only after judicial findings beyond those determined by a jury or stipulated by a defendant, R.C. 2929.14(E)(4) violates principles announced in Blakely” 109 Oh St 3d at 21-22, 845 NE2d at 490-91 (citations, footnotes, and emphasis

2006St. 3d at 21-22, 845 N.E.2d at 490-91 (citations, footnotes, and emphasis omitted). [6] By contrast, the Washington Supreme Court took a narrower view of the rule of law announced in Apprendi : " Apprendi does not have any application to consecutive sentences; to conclude otherwise would extend Apprendi 's holding beyond the narrow grounds upon which it rested." State v. Cubias, 155 Wash.2d 549, 553 , 120 P.3d 929, 931 (2005).

11
Rooney v. Kulongoskigreen
or · 1995 · cited in 1 Oregon opinions naming this issue, 1998–1998
2 sentences

1998See Rooney, 322 Or. at 55 , 902 P.2d 1143 (Unis, J., dissenting) (expressing the view that the requirement in ORS 250.085(5), that the court must draft and certify a ballot title that complies with statutory standards, violates the principle of separation of powers embodied in Article III, section 1, of the Oregon Constitution). [6] *43 When the court construes statutes in context and selects between alternative constructions of an uncertain text, it is compelled to choose the interpretation that avoids serious constitutional difficulty.

1998See Rooney, 322 Or at 55 (Unis, J., dissenting) (expressing the view that the requirement in ORS 250.085(5), that the court must draft and certify a ballot title that complies with statutory standards, violates the principle of separation of powers embodied in Article III, section 1, of the Oregon Constitution). 6 When the court construes statutes in context and selects between alternative constructions of an uncertain text, it is compelled to choose the interpretation that avoids serious constitutional difficulty.

11
United States v. Dionisiogreen
scotus · 1973 · cited in 1 Oregon opinions naming this issue, 1995–1995
2 sentences

1995The Court then cited instances in which it had applied that analysis to allow the admission of blood samples, Schmerber, 384 U.S. at 765 , 86 S.Ct. at 1832-33 , testimony derived from a compelled "lineup" and a compelled vocalization of a phrase provided by the police, United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed.2d 1149 (1967), a compelled handwriting exemplar, Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed.2d 1178 (1967), and a compelled reading of a transcript in order to provide a voice exemplar, States v. Dionisio, 410 U.S. 1, 7 , 93 S.Ct. 764 , *1035 768,

1995The Court then cited instances in which it had applied that analysis to allow the admission of blood samples, Schmerber, 384 U.S. at 765 , 86 S.Ct. at 1832-33 , testimony derived from a compelled "lineup" and a compelled vocalization of a phrase provided by the police, United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed.2d 1149 (1967), a compelled handwriting exemplar, Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed.2d 1178 (1967), and a compelled reading of a transcript in order to provide a voice exemplar, States v. Dionisio, 410 U.S. 1, 7 , 93 S.Ct. 764 , *1035 768,

11
Elsasser v. Wilcoxgreen
or · 1979 · cited in 1 Oregon opinions naming this issue, 1981–1981
1 sentence

1981The author of the majority opinion in Elsasser , speaking for himself only ( 286 Or at 775, n 3 ), questioned whether a forfeiture provision should ever be given effect, even where the purchaser has notice and an opportunity to cure the breach. 6 At the other extreme, Justice Holman, in his dissent, 7 expressed the view that the rule enunciated by the majority, although supported by prior decisions, made no sense.

11
Schenck v. . State Line Telephone Co.green
ny · 1924 · cited in 1 Oregon opinions naming this issue, 1970–1970
2 sentences

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

11
McConnell v. Herrongreen
or · 1965 · cited in 1 Oregon opinions naming this issue, 1967–1967
2 sentences

1967In my dissent in McConnell v. Herron, 240 Or 486, 494 , 402 P2d 726, 730 (1965), I expressed the view that the doctrine which treats the violation of a statute as negligence per se is indefensible and should be abolished.

1967In my dissent in McConnell v. Herron, 240 Or 486, 494 , 402 P2d 726, 730 (1965), I expressed the view that the doctrine which treats the violation of a statute as negligence per se is indefensible and should be abolished.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (34)

CaseCitedYears
East Valley Water v. Water Resources Commission green
or · 2025
2 sentences

2025Id.

2025Id. (slip op at 6).

22025–2025
Valenti v. Hopkins green
or · 1996
1 sentence

2022Id. at 327 . 1 The CC&Rs authorize the HOA board of directors to promulgate a set of committee policies and guidelines that further outline the policies and proce- dures for projects within the committee’s scope of approval authority. 2 In 2016, plaintiffs paid a $500 “pavement damage refundable deposit” rather than an assessment.

12022–2022
SAIF v. Chavez-Cordova green
orctapp · 2021
1 sentence

2021Cite as 314 Or App 5 (2021) 9 exploding and the cap injuring claimant’s eye was not a risk personal to claimant.

12021–2021
Shearer v. Lambert green
or · 1976
2 sentences

2021As to the plaintiff’s argument that the officer held insufficient rank, we observed that in Shearer the Supreme Court adopted the view that the privilege applies to “inferior state officers no matter how low their rank or standing.” Chamberlain, 184 Or App at 491 (quoting Shearer, 274 Or at 454 ).

2021As to the nature of the sergeant’s duties, we concluded that the priv- ilege applies “regardless of whether the alleged defamation occurred in the performance of a discretionary or ministe- rial function.” Id. at 492 .

12021–2021
Chamberlain v. City of Portland green
orctapp · 2002
1 sentence

2021As to the plaintiff’s argument that the officer held insufficient rank, we observed that in Shearer the Supreme Court adopted the view that the privilege applies to “inferior state officers no matter how low their rank or standing.” Chamberlain, 184 Or App at 491 (quoting Shearer, 274 Or at 454 ).

12021–2021
Routledge v. Dept. of Rev. green
ortc · 2020
1 sentence

2020Cite as 24 OTR 103 (2020) 109 The fact that the IRS chose to accept Plaintiff’s claim at face value, at least as of late 2017, tells the court nothing about the IRS’s view of the claim’s validity.

12020–2020
State v. McKinzie green
orctapp · 2003
1 sentence

2015We concluded, in reliance on McKinzie and Iverson, that because “the sanction for lack of notice is that ‘no statement may be admitted’ * * *, the question is not whether the delay caused harm but whether the admitted evidence did.” Id.

12015–2015
State v. Cubias green
wash · 2005
1 sentence

2006St. 3d at 21-22, 845 N.E.2d at 490-91 (citations, footnotes, and emphasis omitted). [6] By contrast, the Washington Supreme Court took a narrower view of the rule of law announced in Apprendi : " Apprendi does not have any application to consecutive sentences; to conclude otherwise would extend Apprendi 's holding beyond the narrow grounds upon which it rested." State v. Cubias, 155 Wash.2d 549, 553 , 120 P.3d 929, 931 (2005).

12006–2006
State v. Lett green
ohioctapp · 2005
1 sentence

2006In State v. Lett, 161 Ohio App 3d 274, 829 NE 2d 1281 [2005], an en banc decision, the Eighth Appellate District found Blakely is inapplicable to consecutive sentencing because ‘the facts found by the court do not increase the maximum penalty for an individual offense.’ This is true; nevertheless, because the total punishment increases through consecutive sentences only after judicial findings beyond those determined by a jury or stipulated by a defendant, R.C. 2929.14(E)(4) violates principles announced in Blakely” 109 Oh St 3d at 21-22, 845 NE2d at 490-91 (citations, footnotes, and emphasis

12006–2006
Krummacher v. Gierloff green
or · 1981
2 sentences

2003As the Supreme Court pointed out in Krummacher , "[t]he constitution gives no defendant the right to a perfect defense[.]" 290 Or. at 875 , 627 P.2d 458 .

2003As the Supreme Court pointed out in Krummacher , "[t]he constitution gives no defendant the right to a perfect defense[.]" 290 Or. at 875 , 627 P.2d 458 .

12003–2003
Tharalson v. State Department of Revenue green
or · 1978
2 sentences

1998Tharalson v. State Dept. of Rev., 281 Or 9, 13 , 573 P2d 298 (1978).

1998Tharalson v. State Dept. of Rev., 281 Or 9, 13 , 573 P2d 298 (1978).

11998–1998
Pennsylvania v. Muniz green
scotus · 1990
1 sentence

1995Embracing this view of the privilege's contours, we held that `the privilege is a bar against compelling "communications" or "testimony," but that compulsion which makes a suspect or accused the source of "real or physical evidence" does not violate it.' Ibid." Id. at 590-91, 110 S.Ct. at 2644-45 .

11995–1995
United States v. Wade green
scotus · 1967
2 sentences

1995The Court then cited instances in which it had applied that analysis to allow the admission of blood samples, Schmerber, 384 U.S. at 765 , 86 S.Ct. at 1832-33 , testimony derived from a compelled "lineup" and a compelled vocalization of a phrase provided by the police, United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed.2d 1149 (1967), a compelled handwriting exemplar, Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed.2d 1178 (1967), and a compelled reading of a transcript in order to provide a voice exemplar, States v. Dionisio, 410 U.S. 1, 7 , 93 S.Ct. 764 , *1035 768,

1995The Court then cited instances in which it had applied that analysis to allow the admission of blood samples, Schmerber, 384 U.S. at 765 , 86 S.Ct. at 1832-33 , testimony derived from a compelled "lineup" and a compelled vocalization of a phrase provided by the police, United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed.2d 1149 (1967), a compelled handwriting exemplar, Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed.2d 1178 (1967), and a compelled reading of a transcript in order to provide a voice exemplar, States v. Dionisio, 410 U.S. 1, 7 , 93 S.Ct. 764 , *1035 768,

11995–1995
Gilbert v. California green
scotus · 1967
2 sentences

1995The Court then cited instances in which it had applied that analysis to allow the admission of blood samples, Schmerber, 384 U.S. at 765 , 86 S.Ct. at 1832-33 , testimony derived from a compelled "lineup" and a compelled vocalization of a phrase provided by the police, United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed.2d 1149 (1967), a compelled handwriting exemplar, Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed.2d 1178 (1967), and a compelled reading of a transcript in order to provide a voice exemplar, States v. Dionisio, 410 U.S. 1, 7 , 93 S.Ct. 764 , *1035 768,

1995The Court then cited instances in which it had applied that analysis to allow the admission of blood samples, Schmerber, 384 U.S. at 765 , 86 S.Ct. at 1832-33 , testimony derived from a compelled "lineup" and a compelled vocalization of a phrase provided by the police, United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed.2d 1149 (1967), a compelled handwriting exemplar, Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed.2d 1178 (1967), and a compelled reading of a transcript in order to provide a voice exemplar, States v. Dionisio, 410 U.S. 1, 7 , 93 S.Ct. 764 , *1035 768,

11995–1995
Schmerber v. California green
scotus · 1966
2 sentences

1995The Court then cited instances in which it had applied that analysis to allow the admission of blood samples, Schmerber, 384 U.S. at 765 , 86 S.Ct. at 1832-33 , testimony derived from a compelled "lineup" and a compelled vocalization of a phrase provided by the police, United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed.2d 1149 (1967), a compelled handwriting exemplar, Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed.2d 1178 (1967), and a compelled reading of a transcript in order to provide a voice exemplar, States v. Dionisio, 410 U.S. 1, 7 , 93 S.Ct. 764 , *1035 768,

1995The Court then cited instances in which it had applied that analysis to allow the admission of blood samples, Schmerber, 384 U.S. at 765 , 86 S.Ct. at 1832-33 , testimony derived from a compelled "lineup" and a compelled vocalization of a phrase provided by the police, United States v. Wade, 388 U.S. 218 , 87 S.Ct. 1926 , 18 L.Ed.2d 1149 (1967), a compelled handwriting exemplar, Gilbert v. California, 388 U.S. 263 , 87 S.Ct. 1951 , 18 L.Ed.2d 1178 (1967), and a compelled reading of a transcript in order to provide a voice exemplar, States v. Dionisio, 410 U.S. 1, 7 , 93 S.Ct. 764 , *1035 768,

11995–1995
DeYoung v. Fallon green
orctapp · 1990
2 sentences

1993However, in Winn , the Supreme Court held that the view of immunity expressed in Chaffin "has been suspended," and replaced by the court's adoption of section 895G of the Restatement. [1] Where plaintiffs' liability is for negligence and defendants' for gross negligence, our decision in DeYoung v. Fallon, 104 Or.App. 66 , 798 P.2d 1114 (1990), indicates that the different levels of fault may be compared.

1993However, in Winn , the Supreme Court held that the view of immunity expressed in Chaffin "has been suspended," and replaced by the court's adoption of section 895G of the Restatement. [1] Where plaintiffs' liability is for negligence and defendants' for gross negligence, our decision in DeYoung v. Fallon, 104 Or.App. 66 , 798 P.2d 1114 (1990), indicates that the different levels of fault may be compared.

11993–1993
State v. Fish green
or · 1978
2 sentences

1989State v. Fish, 282 Or 53, 58-59 , 577 P2d 500 (1978) (Linde and Lent, JJ., concurring). 7 ORS 19.033 applies in criminal cases.

1989State v. Fish, 282 Or 53, 58-59 , 577 P2d 500 (1978) (Linde and Lent, JJ., concurring). 7 ORS 19.033 applies in criminal cases.

11989–1989
Brown v. State green
fla · 1968
1 sentence

1974This consideration was deemed important in Brown v. State, 206 So.2d 377, 382-383 , where the Florida Supreme Court expressed the view that its rule "comports with logic, within the confines of our adversary system, because it enables the state to have adjudicated in one trial all aspects of a criminal charge arising out of one transaction," and that it also "protects a defendant against a `splitting of accusations' with resultant multitudinous prosecutions and trials." In my opinion, the possible disadvantages of the Florida rule do not justify the retention of the majority rule.

11974–1974
Ladd v. General Insurance Co. green
or · 1963
2 sentences

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

11970–1970
Payne v. Griffin neutral
or · 1964
2 sentences

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

1970Indeed, there is considerable support for the view that the doctrine of election of remedies had "no independent viability" and that "estoppel and res judicata can be employed without resort to the election doctrine." [4] In any event, it is well established in Oregon that the "selection of a remedy that is not available does not bar later resort to an available remedy." Payne v. Griffin, 239 Or. 91, 95 , 396 P.2d 573 (1964), and cases cited therein. [5] Thus, as held in Ladd v. General Insurance Co., 236 Or. 260, 265 , 387 P.2d 572 (1964), quoting Mr. Justice Cardozo in Schenck v. State Line

11970–1970
Elliott v. Mosgrove green
or · 1939
2 sentences

1970Elliott v. Mosgrove, 162 Or. 507, 553 , 93 P.2d 1070 (1939).

1970Elliott v. Mosgrove, 162 Or. 507, 553 , 93 P.2d 1070 (1939).

11970–1970
Henthorne v. Hopwood green
or · 1959
11965–1965
Hatch v. Smail green
wis · 1946
11963–1963
Temple Enterprises, Inc. v. Combs green
or · 1940
11959–1959
Peri v. L.A. Junction Ry. green
cal · 1943
11950–1950
Russell v. Oregon R. & N. Co. green
or · 1909
11950–1950
Sather v. Giaconi green
or · 1923
11944–1944
Peabody v. O. R. & N. Co. green
or · 1891
11944–1944
Bunnell v. Parelius green
or · 1941
11944–1944
Clark v. Shea green
or · 1929
11944–1944
Giervolini v. Succession of Rodríguez green
prsupreme · 1916
11921–1921
Curtis v. La Grande Hydraulic Water Co. green
or · 1890
11921–1921
Parker v. . Conner green
ny · 1883
11884–1884
Stearns v. . Gage green
ny · 1879
11884–1884

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 174.010 (4)

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 105 (1894–2025) NY 73 (1886–2014) NJ 54 (1918–2026) PA 51 (1898–2024) TX 43 (1909–2023) IL 35 (1897–2026) FL 33 (1939–2018) MO 26 (1876–2001) OR 25 (1884–2025) WA 25 (1910–2018) MD 22 (1932–2020) IA 21 (1874–2024) SC 21 (1884–2013) MA 20 (1929–2025) OH 19 (1898–2021) NC 18 (1891–2024) AL 17 (1905–2012) MI 16 (1915–2024) OK 14 (1895–2021) WY 14 (1907–2022) CO 13 (1887–2016) IN 13 (1888–2013) KY 13 (1913–2025) LA 13 (1880–2017) MN 12 (1919–2008) UT 12 (1903–2025) AZ 12 (1952–2005) SD 11 (1914–2010) DC 11 (1991–2025) VA 10 (1906–2010) CT 10 (1989–2021) HI 10 (1901–2015) MS 10 (1893–2001) AK 9 (1969–2014) KS 9 (1907–2022) WI 9 (1930–2026) TN 9 (1917–2024) AR 8 (1915–2020) GA 7 (1854–1992) NM 6 (1939–2013) ID 6 (1911–2015) WV 5 (1912–1994) RI 5 (1961–1995) ME 4 (1905–2017) NV 4 (1967–1995) NE 4 (1896–1979) MT 4 (1905–2017) VT 3 (1896–1998) NH 3 (1965–2007) DE 3 (1924–1996) VI 2 (2017–2026) ND 2 (1966–1972)

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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