wilful violation (Connecticut) · Go Syfert
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wilful violation in Connecticut

24 Connecticut opinions name it 3 courts 1992–2022 1 in the last five years

The cases below were cited by Connecticut 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 (12)

CaseFollowedCited
Lownds v. Lowndsgreen
connsuperct · 1988 · cited in 2 Connecticut opinions naming this issue, 1992–1999
2 sentences

1999See generally, Lownds v. Lownds , 41 Conn. Sup. 100 (1988) (a wilful violation of a child support order is absent when the payor has a bona fide belief that the order has been modified.) Alternatively, the court finds that the evidence establishes the elements of both waiver and estoppel under Massachusetts law and that the plaintiffs claim for past child support is precluded on these grounds.

1999See generally, Lownds v. Lownds , 41 Conn. Sup. 100 (1988) (a wilful violation of a child support order is absent when the payor has a bona fide belief that the order has been modified.) Alternatively, the court finds that the evidence establishes the elements of both waiver and estoppel under Massachusetts law and that the plaintiffs claim for past child support is precluded on these grounds.

22
Doe v. Marsellegreen
conn · 1996 · cited in 2 Connecticut opinions naming this issue, 1997–2001
2 sentences

2001See, e.g., Doe v. Marselle, 236 Conn. 845, 847, 859-60 , 675 A.2d 835 (1996) (“conclud[ing] that a wilful violation of [General Statutes] § 19a-583 requires only a knowing disclosure of confidential human immunodeficiency virus [HIV] related information,” not evil intent); State v. Dennis, 150 Conn. 245, 246, 250-51 , 188 A.2d 65 (1963) (holding that where defendant charged with “wilfully or unlawfully” committing “certain acts likely to impair the morals of a minor child, contrary to [General Statutes] § 53-21 . . . [s]pecific intent is not an element of the crime defined”); see also United S

2001See, e.g., Doe v. Marselle, 236 Conn. 845, 847, 859-60 , 675 A.2d 835 (1996) (“conclud[ing] that a wilful violation of [General Statutes] § 19a-583 requires only a knowing disclosure of confidential human immunodeficiency virus [HIV] related information,” not evil intent); State v. Dennis, 150 Conn. 245, 246, 250-51 , 188 A.2d 65 (1963) (holding that where defendant charged with “wilfully or unlawfully” committing “certain acts likely to impair the morals of a minor child, contrary to [General Statutes] § 53-21 . . . [s]pecific intent is not an element of the crime defined”); see also United S

12
United States v. Philip Peltzgreen
ca2 · 1970 · cited in 1 Connecticut opinions naming this issue, 2001–2001
1 sentence

2001Ed. 2d 302 (1972) (wilful violation of federal securities law requires only wilfulness to commit act, rather than specific intent to knowingly violate law); United States v. Peltz, 433 F.2d 48, 54-55 (2d Cir. 1970), cert. denied, 401 U.S. 955 , 91 S. Ct. 974 , 28 L.

11
UNITED STATES of America, Appellee, v. Robert SCHWARTZ, Appellantgreen
ca2 · 1972 · cited in 1 Connecticut opinions naming this issue, 2001–2001
1 sentence

2001See, e.g., Doe v. Marselle, 236 Conn. 845, 847, 859-60 , 675 A.2d 835 (1996) (“conclud[ing] that a wilful violation of [General Statutes] § 19a-583 requires only a knowing disclosure of confidential human immunodeficiency virus [HIV] related information,” not evil intent); State v. Dennis, 150 Conn. 245, 246, 250-51 , 188 A.2d 65 (1963) (holding that where defendant charged with “wilfully or unlawfully” committing “certain acts likely to impair the morals of a minor child, contrary to [General Statutes] § 53-21 . . . [s]pecific intent is not an element of the crime defined”); see also United S

11
State v. Dennisgreen
conn · 1963 · cited in 1 Connecticut opinions naming this issue, 2001–2001
2 sentences

2001See, e.g., Doe v. Marselle, 236 Conn. 845, 847, 859-60 , 675 A.2d 835 (1996) (“conclud[ing] that a wilful violation of [General Statutes] § 19a-583 requires only a knowing disclosure of confidential human immunodeficiency virus [HIV] related information,” not evil intent); State v. Dennis, 150 Conn. 245, 246, 250-51 , 188 A.2d 65 (1963) (holding that where defendant charged with “wilfully or unlawfully” committing “certain acts likely to impair the morals of a minor child, contrary to [General Statutes] § 53-21 . . . [s]pecific intent is not an element of the crime defined”); see also United S

2001See, e.g., Doe v. Marselle, 236 Conn. 845, 847, 859-60 , 675 A.2d 835 (1996) (“conclud[ing] that a wilful violation of [General Statutes] § 19a-583 requires only a knowing disclosure of confidential human immunodeficiency virus [HIV] related information,” not evil intent); State v. Dennis, 150 Conn. 245, 246, 250-51 , 188 A.2d 65 (1963) (holding that where defendant charged with “wilfully or unlawfully” committing “certain acts likely to impair the morals of a minor child, contrary to [General Statutes] § 53-21 . . . [s]pecific intent is not an element of the crime defined”); see also United S

11
Kansai Iron Works, Ltd. v. Marubeni-Iida, Inc.green
scotus · 1972 · cited in 1 Connecticut opinions naming this issue, 2001–2001
1 sentence

2001See, e.g., Doe v. Marselle, 236 Conn. 845, 847, 859-60 , 675 A.2d 835 (1996) (“conclud[ing] that a wilful violation of [General Statutes] § 19a-583 requires only a knowing disclosure of confidential human immunodeficiency virus [HIV] related information,” not evil intent); State v. Dennis, 150 Conn. 245, 246, 250-51 , 188 A.2d 65 (1963) (holding that where defendant charged with “wilfully or unlawfully” committing “certain acts likely to impair the morals of a minor child, contrary to [General Statutes] § 53-21 . . . [s]pecific intent is not an element of the crime defined”); see also United S

11
Nuveen v. Sandersgreen
scotus · 1972 · cited in 1 Connecticut opinions naming this issue, 2001–2001
1 sentence

2001See, e.g., Doe v. Marselle, 236 Conn. 845, 847, 859-60 , 675 A.2d 835 (1996) (“conclud[ing] that a wilful violation of [General Statutes] § 19a-583 requires only a knowing disclosure of confidential human immunodeficiency virus [HIV] related information,” not evil intent); State v. Dennis, 150 Conn. 245, 246, 250-51 , 188 A.2d 65 (1963) (holding that where defendant charged with “wilfully or unlawfully” committing “certain acts likely to impair the morals of a minor child, contrary to [General Statutes] § 53-21 . . . [s]pecific intent is not an element of the crime defined”); see also United S

11
In Re Robert T. Gustafson, Esquiregreen
ca9 · 1981 · cited in 1 Connecticut opinions naming this issue, 1997–1997
1 sentence

1997Under the circumstances, therefore, the trial court reasonably concluded that the plaintiffs conduct constituted a wilful violation under Practice Book § 986 (4) of the prohibition against disobeying a judicial authority during a criminal pro ceeding; see footnote 1 of this opinion; as well as an affront to the court’s dignity and its authority to control its proceedings. 24 See In re Dodson, supra, 214 Conn. 359 -60; Naunchek v. Naunchek, 191 Conn. 110, 114 , 463 A.2d 603 (1983); see also United States v. Allocco, 994 F.2d 82, 85 (2d Cir. 1993); United States v. Lumumba, 794 F.2d 806, 810 (2d

11
United States v. Chokwe Lumumbagreen
ca2 · 1986 · cited in 1 Connecticut opinions naming this issue, 1997–1997
11
United States v. Nicholas Allocco, Ronald Rubinstein, Esq.green
ca2 · 1993 · cited in 1 Connecticut opinions naming this issue, 1997–1997
1 sentence

1997Under the circumstances, therefore, the trial court reasonably concluded that the plaintiffs conduct constituted a wilful violation under Practice Book § 986 (4) of the prohibition against disobeying a judicial authority during a criminal pro ceeding; see footnote 1 of this opinion; as well as an affront to the court’s dignity and its authority to control its proceedings. 24 See In re Dodson, supra, 214 Conn. 359 -60; Naunchek v. Naunchek, 191 Conn. 110, 114 , 463 A.2d 603 (1983); see also United States v. Allocco, 994 F.2d 82, 85 (2d Cir. 1993); United States v. Lumumba, 794 F.2d 806, 810 (2d

11
United States v. Bobby G. Sealegreen
ca7 · 1972 · cited in 1 Connecticut opinions naming this issue, 1997–1997
1 sentence

1997Ed. 2d 79 (1977); United States v. Seale, 461 F.2d 345, 371 (7th Cir. 1972).

11
Commonwealth of Pennsylvania v. Local Union 542, International Union of Operating Engineers Appeal of Abraham E. Freedman, Esquiregreen
ca3 · 1977 · cited in 1 Connecticut opinions naming this issue, 1997–1997
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (28)

CaseCitedYears
In re Flanagan green
conn · 1997
2 sentences

2001"A judge may be sanctioned for a wilful violation of one of the canons of judicial conduct if he intended to engage in the conduct for which [he] is sanctioned whether or not he knows that he violates the rule." (Brackets omitted; citations omitted; internal quotation marks omitted.) In re Flanagan, 240 Conn. 157 , 183 (1997), cert. denied, 522 U.S. 865 , 118 S.Ct. 172 , 139 L.Ed.2d 114 (1998).

1997Recently our Supreme Court reaffirmed this principle, In re Flanagan , 240 Conn. 157 , 183 : "A judge may be sanctioned for a wilful violation of one of the canons of judicial conduct for which he is sanctioned whether or not he knows that he violates the rule." (Internal quotation marks and citations omitted.) The Plaintiff's claim that his violation is merely technical, fails under a similar analysis.

41997–2014
Wright v. Slater green
scotus · 1997
2 sentences

2014In re Flanagan, 240 Conn. 157, 183 , 690 A.2d 865 , cert. denied, 522 U.S. 865 , 118 S. Ct. 172 , 139 L.

2001"A judge may be sanctioned for a wilful violation of one of the canons of judicial conduct if he intended to engage in the conduct for which [he] is sanctioned whether or not he knows that he violates the rule." (Brackets omitted; citations omitted; internal quotation marks omitted.) In re Flanagan, 240 Conn. 157 , 183 (1997), cert. denied, 522 U.S. 865 , 118 S.Ct. 172 , 139 L.Ed.2d 114 (1998).

32001–2014
Spranger v. Runyon green
scotus · 1997
2 sentences

2014In re Flanagan, 240 Conn. 157, 183 , 690 A.2d 865 , cert. denied, 522 U.S. 865 , 118 S. Ct. 172 , 139 L.

2001"A judge may be sanctioned for a wilful violation of one of the canons of judicial conduct if he intended to engage in the conduct for which [he] is sanctioned whether or not he knows that he violates the rule." (Brackets omitted; citations omitted; internal quotation marks omitted.) In re Flanagan, 240 Conn. 157 , 183 (1997), cert. denied, 522 U.S. 865 , 118 S.Ct. 172 , 139 L.Ed.2d 114 (1998).

32001–2014
United States ex rel. Findley v. FPC-Boron Employees' Club green
scotus · 1997
2 sentences

2014In re Flanagan, 240 Conn. 157, 183 , 690 A.2d 865 , cert. denied, 522 U.S. 865 , 118 S. Ct. 172 , 139 L.

2001"A judge may be sanctioned for a wilful violation of one of the canons of judicial conduct if he intended to engage in the conduct for which [he] is sanctioned whether or not he knows that he violates the rule." (Brackets omitted; citations omitted; internal quotation marks omitted.) In re Flanagan, 240 Conn. 157 , 183 (1997), cert. denied, 522 U.S. 865 , 118 S.Ct. 172 , 139 L.Ed.2d 114 (1998).

32001–2014
Marcil v. Marcil green
connappct · 1985
2 sentences

2010Marcil v. Marcil, 4 Conn. App. 403, 405 , 494 A.2d 620 (1985).

1993Disobedience of a Court order does not constitute a wilful violation where there is a legitimate dispute, see Bucy v. Bucy, 23 Conn. App. 98 , 579 A.2d 117 , 119 (1990), or a mistaken perception, see Marcil, supra at 405 , 494 A.2d at 622 , regarding the decree.

21993–2010
Wilson v. Wilson green
connappct · 1995
2 sentences

2001Wilson v. Wilson, 38 Conn. App. 263, 275-76 , 661 A.2d 621 (1995).

2001Wilson v. Wilson, 38 Conn. App. 263, 275-76 , 661 A.2d 621 (1995).

22001–2001
Gelinas v. Town of West Hartford green
conn · 1993
2 sentences

2022The Appellate Court observed that there was no evidence ‘‘that the defendant had been convicted of any offense in a criminal proceeding’’; id., 115; as required by this court’s decision in Gelinas v. West Hartford, 225 Conn. 575, 593 , 626 A.2d 259 (1993), and its decision in Gelinas v. West Hartford, 65 Conn. App. 265, 280 , 782 A.2d 679 , cert. denied, 258 Conn. 926 , 783 A.2d 1028 (2001), which held that a criminal conviction was a predicate to the finding of wilfulness necessary to allow the imposition of fines of more than $100 per day pursuant to § 8-12.

2022The Appellate Court observed that there was no evidence ‘‘that the defendant had been convicted of any offense in a criminal proceeding’’; id., 115; as required by this court’s decision in Gelinas v. West Hartford, 225 Conn. 575, 593 , 626 A.2d 259 (1993), and its decision in Gelinas v. West Hartford, 65 Conn. App. 265, 280 , 782 A.2d 679 , cert. denied, 258 Conn. 926 , 783 A.2d 1028 (2001), which held that a criminal conviction was a predicate to the finding of wilfulness necessary to allow the imposition of fines of more than $100 per day pursuant to § 8-12.

12022–2022
Johnson v. Town of North Branford green
conn · 2001
2 sentences

2022The Appellate Court observed that there was no evidence ‘‘that the defendant had been convicted of any offense in a criminal proceeding’’; id., 115; as required by this court’s decision in Gelinas v. West Hartford, 225 Conn. 575, 593 , 626 A.2d 259 (1993), and its decision in Gelinas v. West Hartford, 65 Conn. App. 265, 280 , 782 A.2d 679 , cert. denied, 258 Conn. 926 , 783 A.2d 1028 (2001), which held that a criminal conviction was a predicate to the finding of wilfulness necessary to allow the imposition of fines of more than $100 per day pursuant to § 8-12.

2022The Appellate Court observed that there was no evidence ‘‘that the defendant had been convicted of any offense in a criminal proceeding’’; id., 115; as required by this court’s decision in Gelinas v. West Hartford, 225 Conn. 575, 593 , 626 A.2d 259 (1993), and its decision in Gelinas v. West Hartford, 65 Conn. App. 265, 280 , 782 A.2d 679 , cert. denied, 258 Conn. 926 , 783 A.2d 1028 (2001), which held that a criminal conviction was a predicate to the finding of wilfulness necessary to allow the imposition of fines of more than $100 per day pursuant to § 8-12.

12022–2022
Gelinas v. Town of West Hartford green
connappct · 2001
2 sentences

2022The Appellate Court observed that there was no evidence ‘‘that the defendant had been convicted of any offense in a criminal proceeding’’; id., 115; as required by this court’s decision in Gelinas v. West Hartford, 225 Conn. 575, 593 , 626 A.2d 259 (1993), and its decision in Gelinas v. West Hartford, 65 Conn. App. 265, 280 , 782 A.2d 679 , cert. denied, 258 Conn. 926 , 783 A.2d 1028 (2001), which held that a criminal conviction was a predicate to the finding of wilfulness necessary to allow the imposition of fines of more than $100 per day pursuant to § 8-12.

2022The Appellate Court observed that there was no evidence ‘‘that the defendant had been convicted of any offense in a criminal proceeding’’; id., 115; as required by this court’s decision in Gelinas v. West Hartford, 225 Conn. 575, 593 , 626 A.2d 259 (1993), and its decision in Gelinas v. West Hartford, 65 Conn. App. 265, 280 , 782 A.2d 679 , cert. denied, 258 Conn. 926 , 783 A.2d 1028 (2001), which held that a criminal conviction was a predicate to the finding of wilfulness necessary to allow the imposition of fines of more than $100 per day pursuant to § 8-12.

12022–2022
Hall v. Hall green
conn · 2018
2 sentences

2020Although Justice Mullins was not present when the case was argued before the court, he has read the briefs and appendices, and listened to a recording of the oral argument prior to partici- pating in this decision. ** April 13, 2020, the date that this decision was released as a slip opinion, is the operative date for all substantive and procedural purposes. 1 This court granted the plaintiff’s petition for certification to appeal, limited to the following issues: ‘‘(1) Did the Appellate Court properly con- clude that the trial court did not abuse its discretion in finding the plaintiff in con

2020Although Justice Mullins was not present when the case was argued before the court, he has read the briefs and appendices, and listened to a recording of the oral argument prior to partici- pating in this decision. ** April 13, 2020, the date that this decision was released as a slip opinion, is the operative date for all substantive and procedural purposes. 1 This court granted the plaintiff’s petition for certification to appeal, limited to the following issues: ‘‘(1) Did the Appellate Court properly con- clude that the trial court did not abuse its discretion in finding the plaintiff in con

12020–2020
Daniels v. Statewide Grievance Committee green
connappct · 2002
1 sentence

2005That reasoning equally is applicable to lawyers and, therefore, we conclude that the court properly held that rule 8.4 (4) does not have a scienter requirement.” (Citation omitted; internal quotation marks omitted.) Id.

12005–2005
Prial v. Prial green
connappct · 2001
2 sentences

2003In determining whether a trial court has abused its broad discretion in domestic relations matters, we allow every reasonable presumption in favor of the correctness of its action.” (Internal quotation marks omitted.) Prial v. Prial, 67 Conn. App. 7, 9-10 , 787 A.2d 50 (2001).

2003In determining whether a trial court has abused its broad discretion in domestic relations matters, we allow every reasonable presumption in favor of the correctness of its action.” (Internal quotation marks omitted.) Prial v. Prial, 67 Conn. App. 7, 9-10 , 787 A.2d 50 (2001).

12003–2003
Pacific Indemnity Co. v. Acel Delivery Service, Inc. green
scotus · 1971
1 sentence

2001Ed. 2d 302 (1972) (wilful violation of federal securities law requires only wilfulness to commit act, rather than specific intent to knowingly violate law); United States v. Peltz, 433 F.2d 48, 54-55 (2d Cir. 1970), cert. denied, 401 U.S. 955 , 91 S. Ct. 974 , 28 L.

12001–2001
O'Hair v. Paine green
scotus · 1971
1 sentence

2001Ed. 2d 302 (1972) (wilful violation of federal securities law requires only wilfulness to commit act, rather than specific intent to knowingly violate law); United States v. Peltz, 433 F.2d 48, 54-55 (2d Cir. 1970), cert. denied, 401 U.S. 955 , 91 S. Ct. 974 , 28 L.

12001–2001
Connolly v. Connolly green
conn · 1983
1 sentence

1999Connolly v. Connolly, 191 Conn. 468 , 483 (1983).

11999–1999
State v. Pieger green
conn · 1997
2 sentences

1998For purposes of this subsection, a wilful violation occurs when the party committing the violation knew or should have known that his conduct was a violation of section 42-110b.” These sections vest the trial court with discretion to award relief and impose penalties as it deems appropriate under the circumstances of each case. “[A] defendant who seeks to reverse the exercise of judicial discretion assumes a heavy burden.” (Internal quotation marks omitted.) State v. Pieger, 240 Conn. 639, 648 , 692 A.2d 1273 (1997).

1998For purposes of this subsection, a wilful violation occurs when the party committing the violation knew or should have known that his conduct was a violation of section 42-110b.” These sections vest the trial court with discretion to award relief and impose penalties as it deems appropriate under the circumstances of each case. “[A] defendant who seeks to reverse the exercise of judicial discretion assumes a heavy burden.” (Internal quotation marks omitted.) State v. Pieger, 240 Conn. 639, 648 , 692 A.2d 1273 (1997).

11998–1998
Levinson v. Connecticut Board of Chiropractic Examiners green
conn · 1989
2 sentences

1997Flanagan claims that our previous decisions in In re Zoarski, supra, 227 Conn. 793 -94, and Levinson v. Board of Chiropractic Examiners, 211 Conn. 508, 525 , 560 A.2d 403 (1989), require expert testimony in judicial review proceedings if a majority of the decisionmaking body is not composed of “experts,” i.e., either judges or lawyers.

1997Flanagan claims that our previous decisions in In re Zoarski, supra, 227 Conn. 793 -94, and Levinson v. Board of Chiropractic Examiners, 211 Conn. 508, 525 , 560 A.2d 403 (1989), require expert testimony in judicial review proceedings if a majority of the decisionmaking body is not composed of “experts,” i.e., either judges or lawyers.

11997–1997
In Re Complaint as to the Conduct of Gustafson green
or · 1988
1 sentence

1997A judge may be sanctioned for a wilful violation of one of the canons of judicial conduct if he intended to engage in the conduct for which he is sanctioned “whether or not [he] knows that he violates the rule.” Id.

11997–1997
Naunchek v. Naunchek green
conn · 1983
2 sentences

1997Under the circumstances, therefore, the trial court reasonably concluded that the plaintiffs conduct constituted a wilful violation under Practice Book § 986 (4) of the prohibition against disobeying a judicial authority during a criminal pro ceeding; see footnote 1 of this opinion; as well as an affront to the court’s dignity and its authority to control its proceedings. 24 See In re Dodson, supra, 214 Conn. 359 -60; Naunchek v. Naunchek, 191 Conn. 110, 114 , 463 A.2d 603 (1983); see also United States v. Allocco, 994 F.2d 82, 85 (2d Cir. 1993); United States v. Lumumba, 794 F.2d 806, 810 (2d

1997Under the circumstances, therefore, the trial court reasonably concluded that the plaintiffs conduct constituted a wilful violation under Practice Book § 986 (4) of the prohibition against disobeying a judicial authority during a criminal pro ceeding; see footnote 1 of this opinion; as well as an affront to the court’s dignity and its authority to control its proceedings. 24 See In re Dodson, supra, 214 Conn. 359 -60; Naunchek v. Naunchek, 191 Conn. 110, 114 , 463 A.2d 603 (1983); see also United States v. Allocco, 994 F.2d 82, 85 (2d Cir. 1993); United States v. Lumumba, 794 F.2d 806, 810 (2d

11997–1997
Henson v. Alphin green
scotus · 1977
11997–1997
Robinson v. Union Carbide Corp. green
scotus · 1977
1 sentence

1997Under the circumstances, therefore, the trial court reasonably concluded that the plaintiffs conduct constituted a wilful violation under Practice Book § 986 (4) of the prohibition against disobeying a judicial authority during a criminal pro ceeding; see footnote 1 of this opinion; as well as an affront to the court’s dignity and its authority to control its proceedings. 24 See In re Dodson, supra, 214 Conn. 359 -60; Naunchek v. Naunchek, 191 Conn. 110, 114 , 463 A.2d 603 (1983); see also United States v. Allocco, 994 F.2d 82, 85 (2d Cir. 1993); United States v. Lumumba, 794 F.2d 806, 810 (2d

11997–1997
New Milford Savings Bank v. Roina green
conn · 1995
11996–1996
Doe v. Marselle green
conn · 1995
11996–1996
Planning & Zoning Commission of Lisbon v. Desrosier green
connappct · 1988
11995–1995
cluster 389482 green
ca2 · 1981
11995–1995
Sportsmen's Boating Corp. v. Hensley green
conn · 1984
11994–1994
A-G Foods, Inc. v. Pepperidge Farm, Inc. green
conn · 1990
11994–1994
Bucy v. Bucy green
connappct · 1990
11993–1993

Where else courts name it

IL 113 (1904–2004) CT 24 (1992–2022) MA 16 (1963–2024) CA 12 (1943–1990) OR 11 (1979–1997) GA 11 (1909–2005) NY 8 (1926–2014) OH 8 (1935–2010) NC 7 (1894–1998) WI 6 (1939–2001) PA 5 (1927–1984) OK 5 (1992–2023) FL 5 (1924–2004) MO 4 (1891–1978) LA 4 (1972–2001) TX 4 (1912–1999) MI 4 (1914–2017) HI 3 (1998–2006) MN 3 (1965–1986) WV 3 (1932–1949) NM 3 (1985–2009) MS 3 (1999–2019) AL 3 (1938–2008) AZ 2 (1974–1998) MD 2 (1972–1986) VA 2 (1943–2015)

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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