sovereign immunity (Wyoming) · Go Syfert
← Wyoming issues

sovereign immunity in Wyoming

25 Wyoming opinions name it 1 courts 1959–2025 4 in the last five years

The cases below were cited by Wyoming 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 (23)

CaseFollowedCited
Worthington v. Stategreen
wyo · 1979 · cited in 7 Wyoming opinions naming this issue, 1980–2024
2 sentences

2024Mem’l Hosp. v. Pfeifle, 2014 WY 3 , ¶ 17, 317 P.3d 573, 578 (Wyo. 2014). “[T]he doctrine of sovereign immunity has its ‘roots in the ancient common law of England which held “The King can do no wrong” and hence could not be sued in any court of law.’” Id. (quoting Worthington v. State, 598 P.2d 796, 803 (Wyo. 1979)).

2015That appeal, however, is appropriately addressed to the legislature or, perhaps, to the School District. [120] We have previously explained that the doctrine of sovereign immunity "has its roots in the ancient common law of England which held 'The King can do no wrong and henee could not be sued in any court of law." Worthington v. State, 598 P.2d 796, 803 (Wyo.1979) (footnote omitted).

47
Ruppenthal v. State Ex Rel. Economic Development & Stabilization Boardgreen
wyo · 1993 · cited in 3 Wyoming opinions naming this issue, 1996–2021
2 sentences

2021Dev. & Stabilization Bd., 849 P.2d 1316, 1320 (Wyo. 1993) (under the common law doctrine of sovereign immunity, a state is not subject to suit without its express consent) (citation omitted). [¶15] This interpretation of the Claims Act as retaining the State’s immunity from suit except in certain limited situations is consistent with our Constitution.

2020BOOMGAARDEN, Justice. [¶1] We granted Lantz-Boggio Architects, P.C.’s petition for writ of review to answer whether: a claim which would otherwise be barred by the doctrine of sovereign immunity for failure to comply with the claims procedure of the Wyoming Governmental Claims Act [may] nonetheless be asserted as a counterclaim in a government- initiated lawsuit if it arises out of the same transaction or occurrence that is the subject matter of the government’s claim and is asserted to reduce or defeat the government’s claim[.] [¶2] We conclude, and the parties agree, 1 that Ruppenthal v. Sta

33
Perkins v. Stategreen
ind · 1969 · cited in 2 Wyoming opinions naming this issue, 2014–2014
2 sentences

2014We acknowledged in Worthington that the doctrine of sovereign immunity has its "roots in the ancient common law of England which held 'The King can do no wrong' and hence could not be sued in any court of law." Id. at 803 (quoting Perkins v. State, 252 Ind. 549 , 251 N.E.2d 80 , 82 (1969)). [T 18] In reality, of course, the King does "do wrong," but the right to seek redress for such wrong is determined by the policy and will of the legislative body.

2014We acknowledged in Worthington that the doctrine of sovereign immunity has its "roots in the ancient common law of England which held 'The King can do no wrong' and hence could not be sued in any court of law." Id. at 803 (quoting Perkins v. State, 252 Ind. 549 , 251 N.E.2d 80 , 82 (1969)). [T 18] In reality, of course, the King does "do wrong," but the right to seek redress for such wrong is determined by the policy and will of the legislative body.

12
cluster 2097green
· · cited in 1 Wyoming opinions naming this issue, 2025–2025
2 sentences

2025“The denial of relief under Rule 41(g) is not with prejudice against the movant’s filing a civil suit for the value of property taken from him and then lost.” United States v. Norwood, 602 F.3d 830, 837 (7th Cir. 2010).

2025“The denial of relief under Rule 41(g) is not with prejudice against the movant’s filing a civil suit for the value of property taken from him and then lost.” United States v. Norwood, 602 F.3d 830, 837 (7th Cir. 2010).

11
Clymore v. United Statesgreen
ca10 · 2005 · cited in 1 Wyoming opinions naming this issue, 2025–2025
1 sentence

2025After reviewing the available federal cases, we agreed with the majority view that sovereign immunity bars monetary relief under Rule 41 when the government no longer possesses the property.2 Id. at ¶¶ 22, 26, 2 Those courts include: Clymore v. United States, 415 F.3d 1113, 1120 (10th Cir. 2005) (“We agree with the majority of the circuits and conclude sovereign immunity bars monetary relief in a Rule 41 ([g]) proceeding when the government no longer possesses the property”); Adeleke v. United States, 355 F.3d 144, 151 (2d Cir. 2004) (“Rule 41(g), which simply provides for the return of seized

11
United States v. Esther Bein and William Beingreen
ca3 · 2000 · cited in 1 Wyoming opinions naming this issue, 2025–2025
1 sentence

2025After reviewing the available federal cases, we agreed with the majority view that sovereign immunity bars monetary relief under Rule 41 when the government no longer possesses the property.2 Id. at ¶¶ 22, 26, 2 Those courts include: Clymore v. United States, 415 F.3d 1113, 1120 (10th Cir. 2005) (“We agree with the majority of the circuits and conclude sovereign immunity bars monetary relief in a Rule 41 ([g]) proceeding when the government no longer possesses the property”); Adeleke v. United States, 355 F.3d 144, 151 (2d Cir. 2004) (“Rule 41(g), which simply provides for the return of seized

11
Ralphael Okoro v. William Callaghangreen
ca7 · 2003 · cited in 1 Wyoming opinions naming this issue, 2025–2025
1 sentence

2025After reviewing the available federal cases, we agreed with the majority view that sovereign immunity bars monetary relief under Rule 41 when the government no longer possesses the property.2 Id. at ¶¶ 22, 26, 2 Those courts include: Clymore v. United States, 415 F.3d 1113, 1120 (10th Cir. 2005) (“We agree with the majority of the circuits and conclude sovereign immunity bars monetary relief in a Rule 41 ([g]) proceeding when the government no longer possesses the property”); Adeleke v. United States, 355 F.3d 144, 151 (2d Cir. 2004) (“Rule 41(g), which simply provides for the return of seized

11
Hammed Adeleke v. United Statesgreen
ca2 · 2004 · cited in 1 Wyoming opinions naming this issue, 2025–2025
1 sentence

2025After reviewing the available federal cases, we agreed with the majority view that sovereign immunity bars monetary relief under Rule 41 when the government no longer possesses the property.2 Id. at ¶¶ 22, 26, 2 Those courts include: Clymore v. United States, 415 F.3d 1113, 1120 (10th Cir. 2005) (“We agree with the majority of the circuits and conclude sovereign immunity bars monetary relief in a Rule 41 ([g]) proceeding when the government no longer possesses the property”); Adeleke v. United States, 355 F.3d 144, 151 (2d Cir. 2004) (“Rule 41(g), which simply provides for the return of seized

11
Campbell County Memorial Hospital v. Jaime A. Williams Pfeifle and Josh Pfeiflegreen
wyo · 2014 · cited in 1 Wyoming opinions naming this issue, 2024–2024
2 sentences

2024Mem’l Hosp. v. Pfeifle, 2014 WY 3 , ¶ 17, 317 P.3d 573, 578 (Wyo. 2014). “[T]he doctrine of sovereign immunity has its ‘roots in the ancient common law of England which held “The King can do no wrong” and hence could not be sued in any court of law.’” Id. (quoting Worthington v. State, 598 P.2d 796, 803 (Wyo. 1979)).

2024Mem’l Hosp. v. Pfeifle, 2014 WY 3 , ¶ 17, 317 P.3d 573, 578 (Wyo. 2014). “[T]he doctrine of sovereign immunity has its ‘roots in the ancient common law of England which held “The King can do no wrong” and hence could not be sued in any court of law.’” Id. (quoting Worthington v. State, 598 P.2d 796, 803 (Wyo. 1979)).

11
State Department of Corrections v. Wattsgreen
wyo · 2008 · cited in 1 Wyoming opinions naming this issue, 2022–2022
1 sentence

2022State Hosp. v. Romine, 2021 WY 47, ¶ 15 , 483 P.3d 840 , 845 (Wyo. 2021) (the Wyoming Governmental Claims Act retains the State’s sovereign immunity); Watts, ¶ 20, 177 P.3d at 798-99 (“We will use our standard rules of statutory construction to determine whether the legislature intended that immunity be waived for a particular claim [under the Wyoming Governmental Claims Act] 8 [¶22] Section 23-1-901 states in relevant part: (a) Any landowner . . . whose property is being damaged by any of the . . . trophy game animals . . . of this state shall, not later than fifteen (15) days after the damag

11
Parker Land & Cattle Co. v. Wyoming Game & Fish Commissiongreen
wyo · 1993 · cited in 1 Wyoming opinions naming this issue, 2022–2022
2 sentences

2022Game & Fish Comm’n, 845 P.2d 1040, 1044, 1050 (Wyo. 1993), the Department maintains § 23-1-901 is a waiver of the State’s sovereign immunity and must be “strictly construed against ‘derogation of the [S]tate’s sovereignty.’” However, Parker’s suggestion that § 23-1-901 constituted a waiver of the State’s sovereign immunity garnered the agreement of only two justices.

2022Parker, 845 P.2d at 1079-1080 (Thomas, J., and Cardine, J., concurring).

11
Weber v. Stategreen
wyo · 2011 · cited in 1 Wyoming opinions naming this issue, 2021–2021
2 sentences

2021As we explained in Weber v. State, 2011 WY 127, ¶ 25 , 261 P.3d 225, 232 (Wyo. 2011), immunity and liability are distinct concepts.

2021As we explained in Weber v. State, 2011 WY 127, ¶ 25 , 261 P.3d 225, 232 (Wyo. 2011), immunity and liability are distinct concepts.

11
Vigil v. Ruettgersgreen
wyo · 1994 · cited in 1 Wyoming opinions naming this issue, 2021–2021
1 sentence

2021Article 1, § 8 of the Wyoming Constitution provides in relevant part: “Suits may be brought against the state in such manner and in such courts as the legislature may by law direct.” We have repeatedly held this provision “requires explicit legislative authorization before a suit can be maintained against the state.” Vigil, 887 P.2d at 524 (emphasis added) (citations omitted).

11
Heimer v. Antelope Valley Improvementgreen
wyo · 2010 · cited in 1 Wyoming opinions naming this issue, 2021–2021
2 sentences

2021See also, Heimer v. Antelope Valley Improvement, 2010 WY 29, ¶ 15 , 226 P.3d 860, 863 (Wyo. 2010) (“Although governmental entities are traditionally immune from suit under the doctrine of sovereign immunity, the Wyoming legislature recognized ‘the inherently unfair and inequitable results which occur in the strict application of governmental immunity’ and enacted the Wyoming Governmental Claims Act . . . .” (emphasis added)); Bd. of Cnty.

2021See also, Heimer v. Antelope Valley Improvement, 2010 WY 29, ¶ 15 , 226 P.3d 860, 863 (Wyo. 2010) (“Although governmental entities are traditionally immune from suit under the doctrine of sovereign immunity, the Wyoming legislature recognized ‘the inherently unfair and inequitable results which occur in the strict application of governmental immunity’ and enacted the Wyoming Governmental Claims Act . . . .” (emphasis added)); Bd. of Cnty.

11
State v. Stovallgreen
wyo · 1982 · cited in 1 Wyoming opinions naming this issue, 2003–2003
2 sentences

2003See State v. Stovall, *960 648 P.2d 543, 548 (Wyo.1982).

2003See State v. Stovall, *960 648 P.2d 543, 548 (Wyo.1982).

11
Cranston v. Weston County Weed & Pest Boardgreen
wyo · 1992 · cited in 1 Wyoming opinions naming this issue, 1993–1993
11
Wallace G. Frederick v. United Statesgreen
ca5 · 1967 · cited in 1 Wyoming opinions naming this issue, 1993–1993
2 sentences

1993In the leading federal case of Frederick v. United States, 386 F.2d 481 (5th Cir.1967), the United States sued the guarantor of a government loan to recover an amount allegedly due after the sale of collateral.

1993The Frederick court concluded: [W]hen the sovereign sues it waives immunity as to claims of the defendant which assert matters in recoupment— arising out of the same transaction or occurrence which is the subject matter of the government’s suit, and to the extent of defeating the government's claim but not to the extent of a judgment against the government which is affirmative in the sense of involving relief different in kind or nature to that sought by the government or in the sense of exceeding the amount of the government’s claims; but the sovereign does not waive immunity as to claims whi

11
Washakie County School District Number One v. Herschlergreen
wyo · 1980 · cited in 1 Wyoming opinions naming this issue, 1987–1987
11
Rocky Mountain Oil and Gas Ass'n v. Stategreen
wyo · 1982 · cited in 1 Wyoming opinions naming this issue, 1987–1987
11
City of Evanston v. Griffithgreen
wyo · 1986 · cited in 1 Wyoming opinions naming this issue, 1987–1987
11
Mayle v. Pennsylvania Department of Highwaysgreen
pa · 1978 · cited in 1 Wyoming opinions naming this issue, 1986–1986
11
Ayala v. Philadelphia Board of Public Educationred
pa · 1973 · cited in 1 Wyoming opinions naming this issue, 1976–1976
11
Spanel v. Mounds View School District No. 621green
minn · 1962 · cited in 1 Wyoming opinions naming this issue, 1976–1976
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (32)

CaseCitedYears
DeLOGE v. State green
wyo · 2010
2 sentences

2025After reviewing the available federal cases, we agreed with the majority view that sovereign immunity bars monetary relief under Rule 41 when the government no longer possesses the property.2 Id. at ¶¶ 22, 26, 2 Those courts include: Clymore v. United States, 415 F.3d 1113, 1120 (10th Cir. 2005) (“We agree with the majority of the circuits and conclude sovereign immunity bars monetary relief in a Rule 41 ([g]) proceeding when the government no longer possesses the property”); Adeleke v. United States, 355 F.3d 144, 151 (2d Cir. 2004) (“Rule 41(g), which simply provides for the return of seized

2025Accordingly, we concluded “the district court correctly denied Mr. DeLoge’s request for damages because his claim is barred by the doctrine of sovereign immunity.” Id. at ¶ 26, 231 P.3d at 867–68. [¶22] The same result is required here.

22013–2025
Hafer v. Melo green
scotus · 1991
2 sentences

2016Kentucky v. Graham, 473 U.S. 159, 166 , 105 S.Ct. 3099, 3105 , 87 L.Ed.2d 114 (1985); Hafer v. Melo, 502 U.S. 21, 25 , 112 S.Ct. 358, 361 , 116 L.Ed.2d 301 (1991).

2016Kentucky v. Graham, 473 U.S. 159, 166 , 105 S.Ct. 3099, 3105 , 87 L.Ed.2d 114 (1985); Hafer v. Melo, 502 U.S. 21, 25 , 112 S.Ct. 358, 361 , 116 L.Ed.2d 301 (1991).

22016–2016
Kentucky v. Graham green
scotus · 1985
2 sentences

2016Kentucky v. Graham, 473 U.S. 159, 166 , 105 S.Ct. 3099, 3105 , 87 L.Ed.2d 114 (1985); Hafer v. Melo, 502 U.S. 21, 25 , 112 S.Ct. 358, 361 , 116 L.Ed.2d 301 (1991).

2016Kentucky v. Graham, 473 U.S. 159, 166 , 105 S.Ct. 3099, 3105 , 87 L.Ed.2d 114 (1985); Hafer v. Melo, 502 U.S. 21, 25 , 112 S.Ct. 358, 361 , 116 L.Ed.2d 301 (1991).

22016–2016
Hjorth Royalty Company v. Trustees of University green
wyo · 1924
2 sentences

2014As this Court noted in Worthington v. State, 598 P.2d 796, 801 (Wyo.1979): There are few, if any, precedents or rules that have been recognized longer or followed with greater fidelity than the rule that was set out in the case of Hjorth Royalty Company v. Trustees of University, 80 Wyo. 309 , 222 P. 9 (1924), which held that Art. 1, § 8, Wyoming Constitution, is not self-executing; that no suit can be maintained against the State until the legislature makes provision for such filing; and, that absent such consent, no suit or claim could be made against the State.

2014As this Court noted in Worthington v. State, 598 P.2d 796, 801 (Wyo.1979): There are few, if any, precedents or rules that have been recognized longer or followed with greater fidelity than the rule that was set out in the case of Hjorth Royalty Company v. Trustees of University, 80 Wyo. 309 , 222 P. 9 (1924), which held that Art. 1, § 8, Wyoming Constitution, is not self-executing; that no suit can be maintained against the State until the legislature makes provision for such filing; and, that absent such consent, no suit or claim could be made against the State.

22014–2014
Collins v. Memorial Hospital of Sheridan County green
wyo · 1974
2 sentences

1989Conversely in Collins v. Memorial Hospital of Sheridan County, 521 P.2d 1339 (Wyo. 1974), we determined that the purpose of insurance constituted a waiver of immunity, at least to the amount of the insurance coverage, and recognized that in response to Maffei, a statute had been enacted.

1989Conversely in Collins v. Memorial Hospital of Sheridan County, 521 P.2d 1339 (Wyo.1974), we determined that the purpose of insurance constituted a waiver of immunity, at least to the amount of the insurance coverage, and recognized that in response to Maffei, a statute had been enacted.

21976–1989
Jivelekas v. City of Worland green
wyo · 1976
2 sentences

1989Even Justice Raper, in his dissent in Jivelekas, 546 P.2d at 434 , recognized the appropriateness of change: It is not the duty nor the function of this or any court to tell a legislature how to perform its legislative function.

1989My views on this subject are sufficiently set forth in Jivelekas v. City of Worland, Wyo., 546 P.2d 419 , and need not be reiterated here.

21978–1989
Nieting v. Blondell green
minn · 1975
2 sentences

1986In one of the cases cited, Nieting v. Blonde!!, 306 Minn. 122 , 235 N.W.2d 597 , 603 n. 14 (1975), the Minnesota Supreme Court expressly noted: "We have been urged to declare the doctrine of sovereign immunity to be unconstitutional as a violation of due process or equal protection.

1986In one of the cases cited, Nieting v. Blonde!!, 306 Minn. 122 , 235 N.W.2d 597 , 603 n. 14 (1975), the Minnesota Supreme Court expressly noted: "We have been urged to declare the doctrine of sovereign immunity to be unconstitutional as a violation of due process or equal protection.

21976–1986
United States v. Carlos Miguel Potes Ramirez green
ca11 · 2001
1 sentence

2025After reviewing the available federal cases, we agreed with the majority view that sovereign immunity bars monetary relief under Rule 41 when the government no longer possesses the property.2 Id. at ¶¶ 22, 26, 2 Those courts include: Clymore v. United States, 415 F.3d 1113, 1120 (10th Cir. 2005) (“We agree with the majority of the circuits and conclude sovereign immunity bars monetary relief in a Rule 41 ([g]) proceeding when the government no longer possesses the property”); Adeleke v. United States, 355 F.3d 144, 151 (2d Cir. 2004) (“Rule 41(g), which simply provides for the return of seized

12025–2025
United States v. Byron Jones, A/K/A Carl Lee, A/K/A \B\"" green
ca4 · 2000
1 sentence

2025After reviewing the available federal cases, we agreed with the majority view that sovereign immunity bars monetary relief under Rule 41 when the government no longer possesses the property.2 Id. at ¶¶ 22, 26, 2 Those courts include: Clymore v. United States, 415 F.3d 1113, 1120 (10th Cir. 2005) (“We agree with the majority of the circuits and conclude sovereign immunity bars monetary relief in a Rule 41 ([g]) proceeding when the government no longer possesses the property”); Adeleke v. United States, 355 F.3d 144, 151 (2d Cir. 2004) (“Rule 41(g), which simply provides for the return of seized

12025–2025
United States of America v. Roy Lee Hall green
ca8 · 2001
1 sentence

2025After reviewing the available federal cases, we agreed with the majority view that sovereign immunity bars monetary relief under Rule 41 when the government no longer possesses the property.2 Id. at ¶¶ 22, 26, 2 Those courts include: Clymore v. United States, 415 F.3d 1113, 1120 (10th Cir. 2005) (“We agree with the majority of the circuits and conclude sovereign immunity bars monetary relief in a Rule 41 ([g]) proceeding when the government no longer possesses the property”); Adeleke v. United States, 355 F.3d 144, 151 (2d Cir. 2004) (“Rule 41(g), which simply provides for the return of seized

12025–2025
Wyoming State Hospital and State of Wyoming v. Mary Romine and Donald Romine, as Guardians and Conservators for and On Behalf of Justina Case, Their Ward green
wyo · 2021
1 sentence

2022State Hosp. v. Romine, 2021 WY 47, ¶ 15 , 483 P.3d 840 , 845 (Wyo. 2021) (the Wyoming Governmental Claims Act retains the State’s sovereign immunity); Watts, ¶ 20, 177 P.3d at 798-99 (“We will use our standard rules of statutory construction to determine whether the legislature intended that immunity be waived for a particular claim [under the Wyoming Governmental Claims Act] 8 [¶22] Section 23-1-901 states in relevant part: (a) Any landowner . . . whose property is being damaged by any of the . . . trophy game animals . . . of this state shall, not later than fifteen (15) days after the damag

12022–2022
Longacre v. State green
wyo · 1968
1 sentence

1998The Commission relies upon Longacre v. State, 448 P.2d 832 (Wyo.1968), for this assertion.

11998–1998
Hawkeye-Security Insurance Co. v. Apodaca green
wyo · 1974
1 sentence

1993We find, however, that Hawkeye-Security Insurance Co. v. Apodaca, 524 P.2d 874 (Wyo.1974), is instructive.

11993–1993
Duran v. Board of County Commissioners green
wyo · 1990
2 sentences

1993Cranston v. Weston County Weed and Pest Board, 826 P.2d 251, 255 (Wyo.1992); Duran v. Board of County Commissioners of Sweetwater County, 787 P.2d 971 (Wyo.1990).

1993Cranston v. Weston County Weed and Pest Board, 826 P.2d 251, 255 (Wyo.1992); Duran v. Board of County Commissioners of Sweetwater County, 787 P.2d 971 (Wyo.1990).

11993–1993
Marbury v. Madison green
· 1803
11989–1989
Sousa v. State green
nh · 1975
11989–1989
Willis v. Dept. of Cons. & Ec. Dev. green
nj · 1970
11986–1986
State v. Brosseau green
nh · 1983
11986–1986
McCall v. Batson red
sc · 1985
11986–1986
Pruett v. City of Rosedale red
miss · 1982
11986–1986
Krause v. State green
ohio · 1972
11986–1986
Muskopf v. Corning Hospital District red
cal · 1961
11986–1986
Bearden v. Metropolitan Dade County green
scotus · 1972
11986–1986
Holland-America Line v. Foreign Study League neutral
scotus · 1972
11986–1986
Retail Clerks Local 187 AFL-CIO v. University of Wyoming green
wyo · 1975
11982–1982
Oroz v. Board of County Com'rs of Carbon County green
wyo · 1978
11979–1979
O'Dell Ex Rel. O'Dell v. School District of Independence green
mo · 1975
11976–1976
Hicks v. State red
nm · 1976
11976–1976
Lovings v. Norfolk & W. Ry. Co. green
wva · 1900
11976–1976
Lore v. Town of Douglas green
wyo · 1960
11976–1976
Long v. City of Weirton green
wva · 1975
11976–1976
Vigil v. State neutral
nm · 1952
11959–1959

Statutes the citing opinions construe

WY § Wyo. Stat. § 1-39-101 (11) WY § Wyo. Stat. § 1-39-105 (10) WY § Wyo. Stat. § 1-39-104 (8) WY § Wyo. Stat. § 1-39-113 (7) WY § Wyo. Stat. § 1-39-102 (6) WY § Wyo. Stat. § 1-39-109 (6) WY § Wyo. Stat. § 1-39-112 (6) USC § 42u.s.c.1983 (5) WY § Wyo. Stat. § 1-39-106 (5) WY § Wyo. Stat. § 1-39-110 (5) WY § Wyo. Stat. § 1-39-103 (4) WY § Wyo. Stat. § 1-39-118 (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

TX 1934 (1892–2026) CT 461 (1963–2026) GA 420 (1945–2026) PA 363 (1951–2026) FL 299 (1962–2026) IL 290 (1953–2025) NC 248 (1960–2026) VA 221 (1973–2026) MO 200 (1914–2025) OH 186 (1960–2025) AL 172 (1968–2025) CA 152 (1935–2026) KY 136 (1935–2026) MD 133 (1967–2026) NY 129 (1922–2026) AR 120 (1975–2026) TN 114 (1973–2026) CO 93 (1954–2026) OK 91 (1936–2025) WA 90 (1914–2026) MA 88 (1967–2025) MS 88 (1974–2025) NM 84 (1964–2024) WI 81 (1962–2026) NJ 80 (1960–2026) MI 79 (1939–2026) NE 75 (1967–2025) VT 74 (1964–2025) SD 57 (1975–2026) HI 54 (1958–2025) LA 53 (1955–2022) ME 53 (1971–2025) MN 51 (1941–2025) IN 51 (1958–2025) IA 49 (1969–2025) OR 43 (1873–2026) SC 42 (1955–2025) DE 40 (1960–2025) AZ 38 (1963–2023) ID 38 (1970–2025) ND 37 (1982–2021) RI 36 (1962–2018) UT 36 (1950–2019) NH 32 (1971–2023) WV 29 (1958–2024) MT 27 (1973–2023) DC 26 (1966–2024) WY 25 (1959–2025) AK 23 (1972–2024) KS 22 (1969–2019) NV 13 (1960–2018) VI 3 (1991–2024) MP 2 (1986–2024) GU 2 (2023–2023)

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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