saving clause (Alabama) · Go Syfert
← Alabama issues

saving clause in Alabama

24 Alabama opinions name it 3 courts 1845–1998 0 in the last five years

The cases below were cited by Alabama 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 (10)

CaseFollowedCited
Pilot Life Insurance v. Dedeauxgreen
scotus · 1987 · cited in 2 Alabama opinions naming this issue, 1989–1989
2 sentences

1989In regard to this, Justice O'Connor wrote that the Court first took "what guidance was available from a 'common-sense view' of the language of the saving clause itself." 481 U.S. at 48 , 107 S.Ct. 1553 ( "any law of any State which regulates insurance" ).

1989"Second," she wrote, "we made use of the case law interpreting the phrase 'business of insurance' under the McCarran-Ferguson Act, 15 U.S.C. § 1011 et seq. , in interpreting the saving clause"; and, she noted that in doing so the Court used these criteria: " ' [F]irst , whether the practice has the effect of transferring or spreading a policyholder's risk; second , whether the practice is an integral part of the policy relationship between the insurer and the insured; and third , whether the practice is limited to entities within the insurance industry.' " 481 U.S. at 48 -49 , 107 S.Ct. at 155

12
cluster 382199green
ca3 · 1980 · cited in 1 Alabama opinions naming this issue, 1989–1989
1 sentence

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

11
cluster 392847green
ca5 · 1981 · cited in 1 Alabama opinions naming this issue, 1989–1989
1 sentence

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

11
Dennis C. Sours v. General Motors Corporationgreen
ca6 · 1983 · cited in 1 Alabama opinions naming this issue, 1989–1989
1 sentence

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

11
Holly Shipp v. General Motors Corporationgreen
ca5 · 1985 · cited in 1 Alabama opinions naming this issue, 1989–1989
2 sentences

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

1989Such compliance with "minimum safety standards does not exempt or immunize a manufacturer from common law strict liability." Shipp, 750 F.2d at 418 .

11
Hughes v. Ford Motor Co.green
ctd · 1987 · cited in 1 Alabama opinions naming this issue, 1989–1989
1 sentence

1989As Professor Miller summarizes, "The savings clause, it is argued, represents Congress'[s] intent that compliance with Federal safety standards does not protect automobile manufacturers from liability for defects relating to matters not covered by the federal standards." Airbag Preemption Controversy, supra, at 915 (citing Hughes v. Ford Motor Co., 677 F.Supp. 76, 78 (D.Conn. 1987); Cox v. Baltimore County, supra ; and Wickstrom v. Maplewood Toyota, Inc., 416 N.W.2d 838, 840 (Minn.App.1987), cert. denied, ___ U.S. ___, 108 S.Ct. 2905 , 101 L.Ed.2d 937 (1988)).

11
Wickstrom Ex Rel. Wickstrom v. Maplewood Toyota, Inc.green
minnctapp · 1987 · cited in 1 Alabama opinions naming this issue, 1989–1989
1 sentence

1989As Professor Miller summarizes, "The savings clause, it is argued, represents Congress'[s] intent that compliance with Federal safety standards does not protect automobile manufacturers from liability for defects relating to matters not covered by the federal standards." Airbag Preemption Controversy, supra, at 915 (citing Hughes v. Ford Motor Co., 677 F.Supp. 76, 78 (D.Conn. 1987); Cox v. Baltimore County, supra ; and Wickstrom v. Maplewood Toyota, Inc., 416 N.W.2d 838, 840 (Minn.App.1987), cert. denied, ___ U.S. ___, 108 S.Ct. 2905 , 101 L.Ed.2d 937 (1988)).

11
Lindsey v. State Department of Pensions & Securitygreen
alacivapp · 1986 · cited in 1 Alabama opinions naming this issue, 1986–1986
1 sentence

1986See, Brady v. State Pilotage Commission , 485 So.2d 1179 (Ala.Civ.App. 1985).

11
Hardman v. Personnel Appeal Boardgreen
ri · 1965 · cited in 1 Alabama opinions naming this issue, 1985–1985
2 sentences

1985"In the absence of any saving clause, a new law changing a rule of practice is generally regarded as applicable to all cases then pending." 73 Am.Jur.2d, Statutes § 354 (1974) (footnote omitted); see Hardman v. Personnel Board , 100 R.I. 145 , 211 A.2d 660 (1965).

1985"In the absence of any saving clause, a new law changing a rule of practice is generally regarded as applicable to all cases then pending." 73 Am.Jur.2d, Statutes § 354 (1974) (footnote omitted); see Hardman v. Personnel Board , 100 R.I. 145 , 211 A.2d 660 (1965).

11
Hewlett-Packard Co. v. Barnesgreen
cand · 1977 · cited in 1 Alabama opinions naming this issue, 1984–1984
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (66)

CaseCitedYears
Alessi v. Raybestos-Manhattan, Inc. green
scotus · 1981
2 sentences

1989We have observed in the past that the express pre-emption provisions of ERISA are deliberately expansive, and designed to 'establish pension plan regulation as exclusively a federal concern.' Alessi v. Raybestos-Manhattan, Inc. , 451 U.S. 504 , 523 , 101 S.Ct. 1895 , 1906 , 68 L.Ed.2d 402 (1981).

1989We have observed in the past that the express pre-emption provisions of ERISA are deliberately expansive, and designed to 'establish pension plan regulation as exclusively a federal concern.' Alessi v. Raybestos-Manhattan, Inc. , 451 U.S. 504 , 523 , 101 S.Ct. 1895 , 1906 , 68 L.Ed.2d 402 (1981).

21984–1989
Howell v. Hair green
ala · 1849
2 sentences

1853Again; it is insisted that the cases of Howell v. Hair, 15 Ala. 194 , and Newcombe v. Leavitt, 22 Ala. 631 , are decisive of the question under consideration in favor of the ruling of the court below.

1850Neither will the court imply a saving or an exception restrictive of its operation and which is not found in the statute. — Howell v. Hair, 15 Ala. 194 .

21850–1853
CSX Transportation, Inc. v. Easterwood green
scotus · 1993
2 sentences

1998Easterwood, 507 U.S. at 662 , 113 S.Ct. 1732 .

1998Easterwood, 507 U.S. at 662 , 113 S.Ct. 1732 .

11998–1998
Tucker v. Nichols green
ala · 1983
1 sentence

1989Moreover, our decision in Tucker v. Nichols , 431 So.2d 1263 (Ala. 1983), interpreted this saving clause broadly in order to avoid finding it unconstitutional.

11989–1989
Retail Clerks International Ass'n, Local 1625 v. Schermerhorn green
scotus · 1963
2 sentences

1989"Congress capped off the massive undertaking of ERISA with three provisions relating to the pre-emptive effect of the federal legislation: " 'Except as provided in subsection (b) of this section [the saving clause], the provisions of this subchapter and subchapter III of this chapter shall supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan . . . .' § 514(a), as set-forth in 29 U.S.C. § 1144 (a) (pre-emption clause). " '. . . .' ". . . . " '[T]he question whether a certain state action is pre-empted by federal law is one of congressional in

1989"Congress capped off the massive undertaking of ERISA with three provisions relating to the pre-emptive effect of the federal legislation: " 'Except as provided in subsection (b) of this section [the saving clause], the provisions of this subchapter and subchapter III of this chapter shall supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan . . . .' § 514(a), as set-forth in 29 U.S.C. § 1144 (a) (pre-emption clause). " '. . . .' ". . . . " '[T]he question whether a certain state action is pre-empted by federal law is one of congressional in

11989–1989
Cox v. Baltimore County green
mdd · 1986
1 sentence

1989As Professor Miller summarizes, "The savings clause, it is argued, represents Congress'[s] intent that compliance with Federal safety standards does not protect automobile manufacturers from liability for defects relating to matters not covered by the federal standards." Airbag Preemption Controversy, supra, at 915 (citing Hughes v. Ford Motor Co., 677 F.Supp. 76, 78 (D.Conn. 1987); Cox v. Baltimore County, supra ; and Wickstrom v. Maplewood Toyota, Inc., 416 N.W.2d 838, 840 (Minn.App.1987), cert. denied, ___ U.S. ___, 108 S.Ct. 2905 , 101 L.Ed.2d 937 (1988)).

11989–1989
Greenman v. Yuba Power Products, Inc. green
cal · 1963
2 sentences

1989Karagheusian, Inc., 44 N.J. 52 , 207 A.2d 305 (1965); Greenman v. Yuba Power Products, Inc., 59 Cal.2d 57 , 27 Cal.Rptr. 697 , 377 P.2d 897 (1963). [6] *943 Nor is the Wood court's assertion that the saving clause was meant to preserve common law warranty claims persuasive.

1989Karagheusian, Inc., 44 N.J. 52 , 207 A.2d 305 (1965); Greenman v. Yuba Power Products, Inc., 59 Cal.2d 57 , 27 Cal.Rptr. 697 , 377 P.2d 897 (1963). [6] *943 Nor is the Wood court's assertion that the saving clause was meant to preserve common law warranty claims persuasive.

11989–1989
cluster 497073 green
ca11 · 1987
2 sentences

1989However, the Alabama law of bad faith appears to us to have the same roots 'in the general principles of . . . tort and contract law' as was the case in Dedeaux . " 833 F.2d at 281 . 3 In Farlow v. Union Cent.

1989However, the Alabama law of bad faith appears to us to have the same roots `in the general principles of ... tort and contract law' as was the case in Dedeaux." 833 F.2d at 281 . [3] In Farlow v. Union Cent.

11989–1989
Patricia M. Wood v. General Motors Corporation green
ca1 · 1988
2 sentences

1989In Wood v. General Motors Corp., 865 F.2d 395 (1st Cir.1988), the First Circuit Court of Appeals discusses the state of the common law in 1966 concerning products liability and actions similar to the one now before this Court.

1989Thus when Congress inserted the savings clause, it did not contemplate that lawsuits would be brought with the potential to give rise to the current dilemma." 865 F.2d at 406 .

11989–1989
Santor v. a & M KARAGHEUSIAN, INC. red
nj · 1965
2 sentences

1989Karagheusian, Inc., 44 N.J. 52 , 207 A.2d 305 (1965); Greenman v. Yuba Power Products, Inc., 59 Cal.2d 57 , 27 Cal.Rptr. 697 , 377 P.2d 897 (1963). [6] *943 Nor is the Wood court's assertion that the saving clause was meant to preserve common law warranty claims persuasive.

1989Karagheusian, Inc., 44 N.J. 52 , 207 A.2d 305 (1965); Greenman v. Yuba Power Products, Inc., 59 Cal.2d 57 , 27 Cal.Rptr. 697 , 377 P.2d 897 (1963). [6] *943 Nor is the Wood court's assertion that the saving clause was meant to preserve common law warranty claims persuasive.

11989–1989
Malone v. White Motor Corp. green
scotus · 1978
2 sentences

1989"Congress capped off the massive undertaking of ERISA with three provisions relating to the pre-emptive effect of the federal legislation: " 'Except as provided in subsection (b) of this section [the saving clause], the provisions of this subchapter and subchapter III of this chapter shall supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan . . . .' § 514(a), as set-forth in 29 U.S.C. § 1144 (a) (pre-emption clause). " '. . . .' ". . . . " '[T]he question whether a certain state action is pre-empted by federal law is one of congressional in

1989"Congress capped off the massive undertaking of ERISA with three provisions relating to the pre-emptive effect of the federal legislation: " 'Except as provided in subsection (b) of this section [the saving clause], the provisions of this subchapter and subchapter III of this chapter shall supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan . . . .' § 514(a), as set-forth in 29 U.S.C. § 1144 (a) (pre-emption clause). " '. . . .' ". . . . " '[T]he question whether a certain state action is pre-empted by federal law is one of congressional in

11989–1989
General Motors Corp. v. Edwards green
ala · 1985
1 sentence

1989On appeal, the Schwartzes argue that, in light of this Court's decision in General Motors Corp. v. Edwards, 482 So.2d 1176 (Ala.1985), and the saving clause, the trial *930 court erred in precluding air bag/passive restraint claims because Congress neither expressly nor impliedly preempted such claims.

11989–1989
Union Labor Life Insurance v. Pireno green
scotus · 1982
2 sentences

1989Co. v. Pireno , 458 U.S. 119 , 129 , 102 S.Ct. 3002 , 3008 , 73 L.Ed.2d 647 (1982) (emphasis in original).

1989Co. v. Pireno , 458 U.S. 119 , 129 , 102 S.Ct. 3002 , 3008 , 73 L.Ed.2d 647 (1982) (emphasis in original).

11989–1989
Mescalero Apache Tribe v. O'Cheskey green
scotus · 1981
1 sentence

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

11989–1989
Marschak v. Kirkland green
scotus · 1981
1 sentence

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

11989–1989
LeClair v. Saunders green
scotus · 1981
1 sentence

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

11989–1989
H. L. Moore Drug Exchange v. Lilly green
scotus · 1982
1 sentence

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

11989–1989
Turoso v. Cleveland Municipal Court green
scotus · 1982
1 sentence

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

11989–1989
Shelley v. City of Los Angeles neutral
scotus · 1988
1 sentence

1989As Professor Miller summarizes, "The savings clause, it is argued, represents Congress'[s] intent that compliance with Federal safety standards does not protect automobile manufacturers from liability for defects relating to matters not covered by the federal standards." Airbag Preemption Controversy, supra, at 915 (citing Hughes v. Ford Motor Co., 677 F.Supp. 76, 78 (D.Conn. 1987); Cox v. Baltimore County, supra ; and Wickstrom v. Maplewood Toyota, Inc., 416 N.W.2d 838, 840 (Minn.App.1987), cert. denied, ___ U.S. ___, 108 S.Ct. 2905 , 101 L.Ed.2d 937 (1988)).

11989–1989
Allis-Chalmers Corp. v. Lueck green
scotus · 1985
2 sentences

1989"Congress capped off the massive undertaking of ERISA with three provisions relating to the pre-emptive effect of the federal legislation: " 'Except as provided in subsection (b) of this section [the saving clause], the provisions of this subchapter and subchapter III of this chapter shall supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan . . . .' § 514(a), as set-forth in 29 U.S.C. § 1144 (a) (pre-emption clause). " '. . . .' ". . . . " '[T]he question whether a certain state action is pre-empted by federal law is one of congressional in

1989"Congress capped off the massive undertaking of ERISA with three provisions relating to the pre-emptive effect of the federal legislation: " 'Except as provided in subsection (b) of this section [the saving clause], the provisions of this subchapter and subchapter III of this chapter shall supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan . . . .' § 514(a), as set-forth in 29 U.S.C. § 1144 (a) (pre-emption clause). " '. . . .' ". . . . " '[T]he question whether a certain state action is pre-empted by federal law is one of congressional in

11989–1989
The J.W. Copeland Co. v. Brown green
· 1916
1 sentence

1989See, e.g., Shipp v. General Motors Corp., 750 F.2d 418, 421 (5th Cir.1985) (where injury was caused by collapse of automobile's roof, fact that manufacturer complied with the only safety standard pertinent did not preclude plaintiff's recovery); Sours v. General Motors Corp., 717 F.2d 1511, 1516-17 (6th Cir.1983) (alleged compliance with FMVSS 216, promulgated after subject automobile was manufactured, not a defense); Dorsey v. Honda Motor Co., 655 F.2d 650, 656-57 (5th Cir.1981), cert. denied, 459 U.S. 880 , 103 S.Ct. 177 , 74 L.Ed.2d 145 (1982) (although manufacturer complied with FMVSS 209

11989–1989
cluster 349214 green
ca1 · 1977
11984–1984
Finney v. Speed neutral
· 1893
11981–1981
Monroe v. Simmons green
ga · 1890
11981–1981
Funk v. Wingert green
md · 1919
11981–1981
Seybold v. Magnolia Land Co. green
ala · 1979
11980–1980
Carlson v. Erickson neutral
ala · 1909
11956–1956
Jones v. Dimmick green
ala · 1912
11956–1956
Blake v. State ex rel. Going green
ala · 1912
11956–1956
Timmerman v. Stout neutral
ala · 1927
11956–1956
State ex rel. Clarke v. Carter neutral
ala · 1911
11932–1932
State ex rel. Crumpton v. Montgomery green
· 1912
11932–1932
State Ex Rel. Harmon v. Murphy neutral
ala · 1924
11932–1932
Ex Parte Elmore neutral
ala · 1918
11932–1932
King v. State neutral
alactapp · 1924
11932–1932
Clemmons v. State neutral
· 1924
11932–1932
Lee v. Hester neutral
ga · 1856
11925–1925
Carling v. Wilson green
ala · 1912
11925–1925
Manning v. Carter neutral
ala · 1915
11925–1925
Terry v. Rich neutral
· 1916
11925–1925

Statutes the citing opinions construe

USC § 29u.s.c.1144 (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 241 (1854–2025) IL 120 (1876–2023) NY 79 (1867–2024) TX 64 (1910–2025) WA 35 (1874–2025) MI 35 (1848–2022) PA 34 (1837–2021) IN 33 (1845–2017) LA 33 (1913–2001) OH 31 (1840–2025) CT 30 (1925–2026) MA 29 (1872–2015) FL 28 (1917–2021) MO 24 (1875–2020) AL 24 (1845–1998) KS 24 (1885–2010) MD 23 (1904–2026) OR 21 (1908–2021) MS 19 (1879–2018) NM 19 (1918–2021) OK 19 (1910–2003) MN 18 (1891–2001) NJ 18 (1942–2024) GA 17 (1908–2024) AZ 14 (1927–2020) NE 13 (1880–2015) TN 13 (1939–2017) IA 13 (1850–2021) NC 13 (1894–2014) AR 12 (1886–2006) KY 12 (1910–2014) CO 12 (1881–2010) WV 11 (1895–2016) ND 10 (1893–2011) SC 8 (1925–2015) MT 8 (1898–2002) RI 7 (1892–1999) PR 7 (1926–1987) NH 7 (1939–2021) HI 6 (1913–2014) SD 6 (1938–2011) ME 6 (1833–1979) VA 6 (1928–2023) VT 5 (1905–2011) DE 5 (1928–1963) WI 5 (1886–2018) WY 4 (1895–1991) DC 3 (1949–1996) UT 3 (1937–2026) VI 2 (2015–2026)

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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