abandonment doctrine (Pennsylvania) · Go Syfert
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abandonment doctrine in Pennsylvania

24 Pennsylvania opinions name it 5 courts 1905–2025 6 in the last five years

The cases below were cited by Pennsylvania 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 (11)

CaseFollowedCited
In re Adoption of S.P.green
pa · 2012 · cited in 4 Pennsylvania opinions naming this issue, 2015–2025
2 sentences

2025The Supreme Court explained that this was erroneous, - 23 - J-E04005-24 as the purpose of the passage “was to impose on the incarcerated parent, pursuant to an abandonment analysis, a duty to utilize available resources to continue a relationship with his or her child.” Id.

2023See In re Adoption of S.P., 47 A.3d at 827-28 (noting the improper conflation with a subsection(a)(1) abandonment analysis and, as to a duty to utilize available resources to maintain a relationship, stating, “Instead, the emphasis of this passage was to impose on the incarcerated parent, pursuant to an abandonment analysis, a duty to utilize available resources to continue a relationship with his or her child.”).

34
Commonwealth v. Shoatzgreen
pa · 1976 · cited in 2 Pennsylvania opinions naming this issue, 2023–2025
2 sentences

2025He ____________________________________________ 2 See also Commonwealth v. Shoatz, 366 A.2d 1216, 1220 (Pa. 1976) (emphasis added) (explaining that the definition of abandonment for Fourth Amendment purposes differs from the strict property-right sense; the abandonment analysis turns not on a property interest in the item but an appellant’s possession of a reasonable expectation of privacy in the property in question at the time of the search). -7- J-A08031-25 asserts he later gave the officers the keys and they used them to conduct a warrantless search of the car in violation of Alexander, su

2023Because he retained a reasonable expectation of privacy in the Alcatel phone, Mitchell ____________________________________________ 8 See also Commonwealth v. Shoatz, 366 A.2d 1216, 1220 (Pa. 1976) (emphasis added) (explaining the definition of abandonment for Fourth Amendment purposes differs from the strict property-right sense; the abandonment analysis turns not on a property interest in the item but an appellant’s possession of a reasonable expectation of privacy in the property in question at the time of the search). - 11 - J-S22041-22 asserts, the court should have suppressed the data an

22
Maritrans GP Inc. v. Pepper, Hamilton & Scheetzgreen
pa · 1992 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Instead, the trial court entertained Appellees’ claim of abandonment without giving effect to those express terms. [J-92-2020] - 9 Analysis of the trial court and the Superior Court opinions in this case reveals an essential initial step was skipped to determine whether the case properly sounded in equity as to be resolvable employing the equitable doctrine of abandonment.8 “Injunctive relief will lie where there is no adequate remedy at law.” Maritrans GP Inc. v. Pepper, Hamilton & Scheetz, 602 A.2d 1277, 1286 (Pa. 1992).

11
Sprague v. Caseygreen
pa · 1988 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
2 sentences

2010Scharlach, 809 A.2d at 383 (citing Sprague v. Casey, 520 Pa. 38, 45 , 550 A.2d 184, 187-88 (1988)); see Potter Title & Trust Co. v. Frank, 298 Pa. 137, 141 , 148 A. 50, 52 (1929) (holding that a plaintiffs eight-year delay in bringing suit constituted an abandonment of his claim); McGrann v. Allen, 291 Pa. 574, 580 , 140 A. 552, 554 (1928) (finding that laches barred the plaintiffs claim where he could have demanded an accounting twelve years earlier); Taylor v. Coggins, 244 Pa. 228, 231 , 90 A. 633, 635 (1914) (per curiam) (agreeing with trial court’s statement that “Suits brought after the p

2010Scharlach, 809 A.2d at 383 (citing Sprague v. Casey, 520 Pa. 38, 45 , 550 A.2d 184, 187-88 (1988)); see Potter Title & Trust Co. v. Frank, 298 Pa. 137, 141 , 148 A. 50, 52 (1929) (holding that a plaintiffs eight-year delay in bringing suit constituted an abandonment of his claim); McGrann v. Allen, 291 Pa. 574, 580 , 140 A. 552, 554 (1928) (finding that laches barred the plaintiffs claim where he could have demanded an accounting twelve years earlier); Taylor v. Coggins, 244 Pa. 228, 231 , 90 A. 633, 635 (1914) (per curiam) (agreeing with trial court’s statement that “Suits brought after the p

11
Taylor v. Cogginsgreen
pa · 1914 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
2 sentences

2010Scharlach, 809 A.2d at 383 (citing Sprague v. Casey, 520 Pa. 38, 45 , 550 A.2d 184, 187-88 (1988)); see Potter Title & Trust Co. v. Frank, 298 Pa. 137, 141 , 148 A. 50, 52 (1929) (holding that a plaintiffs eight-year delay in bringing suit constituted an abandonment of his claim); McGrann v. Allen, 291 Pa. 574, 580 , 140 A. 552, 554 (1928) (finding that laches barred the plaintiffs claim where he could have demanded an accounting twelve years earlier); Taylor v. Coggins, 244 Pa. 228, 231 , 90 A. 633, 635 (1914) (per curiam) (agreeing with trial court’s statement that “Suits brought after the p

2010Scharlach, 809 A.2d at 383 (citing Sprague v. Casey, 520 Pa. 38, 45 , 550 A.2d 184, 187-88 (1988)); see Potter Title & Trust Co. v. Frank, 298 Pa. 137, 141 , 148 A. 50, 52 (1929) (holding that a plaintiffs eight-year delay in bringing suit constituted an abandonment of his claim); McGrann v. Allen, 291 Pa. 574, 580 , 140 A. 552, 554 (1928) (finding that laches barred the plaintiffs claim where he could have demanded an accounting twelve years earlier); Taylor v. Coggins, 244 Pa. 228, 231 , 90 A. 633, 635 (1914) (per curiam) (agreeing with trial court’s statement that “Suits brought after the p

11
McGrann v. Allengreen
pa · 1927 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
2 sentences

2010Scharlach, 809 A.2d at 383 (citing Sprague v. Casey, 520 Pa. 38, 45 , 550 A.2d 184, 187-88 (1988)); see Potter Title & Trust Co. v. Frank, 298 Pa. 137, 141 , 148 A. 50, 52 (1929) (holding that a plaintiffs eight-year delay in bringing suit constituted an abandonment of his claim); McGrann v. Allen, 291 Pa. 574, 580 , 140 A. 552, 554 (1928) (finding that laches barred the plaintiffs claim where he could have demanded an accounting twelve years earlier); Taylor v. Coggins, 244 Pa. 228, 231 , 90 A. 633, 635 (1914) (per curiam) (agreeing with trial court’s statement that “Suits brought after the p

2010Scharlach, 809 A.2d at 383 (citing Sprague v. Casey, 520 Pa. 38, 45 , 550 A.2d 184, 187-88 (1988)); see Potter Title & Trust Co. v. Frank, 298 Pa. 137, 141 , 148 A. 50, 52 (1929) (holding that a plaintiffs eight-year delay in bringing suit constituted an abandonment of his claim); McGrann v. Allen, 291 Pa. 574, 580 , 140 A. 552, 554 (1928) (finding that laches barred the plaintiffs claim where he could have demanded an accounting twelve years earlier); Taylor v. Coggins, 244 Pa. 228, 231 , 90 A. 633, 635 (1914) (per curiam) (agreeing with trial court’s statement that “Suits brought after the p

11
Potter Title & Trust Co. v. Frankgreen
pa · 1929 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
2 sentences

2010Scharlach, 809 A.2d at 383 (citing Sprague v. Casey, 520 Pa. 38, 45 , 550 A.2d 184, 187-88 (1988)); see Potter Title & Trust Co. v. Frank, 298 Pa. 137, 141 , 148 A. 50, 52 (1929) (holding that a plaintiffs eight-year delay in bringing suit constituted an abandonment of his claim); McGrann v. Allen, 291 Pa. 574, 580 , 140 A. 552, 554 (1928) (finding that laches barred the plaintiffs claim where he could have demanded an accounting twelve years earlier); Taylor v. Coggins, 244 Pa. 228, 231 , 90 A. 633, 635 (1914) (per curiam) (agreeing with trial court’s statement that “Suits brought after the p

2010Scharlach, 809 A.2d at 383 (citing Sprague v. Casey, 520 Pa. 38, 45 , 550 A.2d 184, 187-88 (1988)); see Potter Title & Trust Co. v. Frank, 298 Pa. 137, 141 , 148 A. 50, 52 (1929) (holding that a plaintiffs eight-year delay in bringing suit constituted an abandonment of his claim); McGrann v. Allen, 291 Pa. 574, 580 , 140 A. 552, 554 (1928) (finding that laches barred the plaintiffs claim where he could have demanded an accounting twelve years earlier); Taylor v. Coggins, 244 Pa. 228, 231 , 90 A. 633, 635 (1914) (per curiam) (agreeing with trial court’s statement that “Suits brought after the p

11
J. C. Bonnot, D/B/A Bonnot Construction Company v. Congress of Independent Unions Local 14green
ca8 · 1964 · cited in 1 Pennsylvania opinions naming this issue, 2003–2003
1 sentence

2003Bonnot v. Local # 14, 331 F.2d 355, 359 (8th Cir.1964) (Blackmun, J.) (stating “The obvious purpose of the ‘may’ language is to give an aggrieved party the choice between arbitration or the abandonment of its claim.

11
Commonwealth v. Bensongreen
pasuperct · 1980 · cited in 1 Pennsylvania opinions naming this issue, 1982–1982
2 sentences

1982See Commonwealth v. Benson, 280 Pa.Super. 20, 30 , 421 A.2d 383, 388 (1980).

1982See Commonwealth v. Benson, 280 Pa.Super. 20, 30 , 421 A.2d 383, 388 (1980).

11
Commonwealth ex rel. Leider v. Leidergreen
pasuperct · 1967 · cited in 1 Pennsylvania opinions naming this issue, 1975–1975
2 sentences

1975Leider v. Leider, 210 Pa. Superior Ct. 433 , 233 A.2d 917 (1967), a dissenting opinion argued for the abandonment of the rule: “I can find no justification or morality in a rule which tends to absolve the rightful father of his duty of support, while imposing such an obligation upon an innocent husband merely because of his marital relationship. ...

1975Leider v. Leider, 210 Pa. Superior Ct. 433 , 233 A.2d 917 (1967), a dissenting opinion argued for the abandonment of the rule: “I can find no justification or morality in a rule which tends to absolve the rightful father of his duty of support, while imposing such an obligation upon an innocent husband merely because of his marital relationship. ...

11
A. D. Graham & Co. v. Pennsylvania Turnpike Commissiongreen
pa · 1943 · cited in 1 Pennsylvania opinions naming this issue, 1959–1959
1 sentence

1959Turnpike Commission, 347 Pa. 622, 635, 636 , supra. 9 Mr. Justice Dean in Huss v. Jacobs, 210 Pa. 145, 161 , 59 A. 991 , aptly said: “To preserve such a title [a title in fee simple to coal] the law does not require physical possession by the owner, that he should live in a coal mine”: Muzzio et al. v. Steele, 279 Pa. 226 , 123 A. 776 .

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Clark v. Mobile County Hospital Boardyellow
ala · 1963 · cited in 1 Pennsylvania opinions naming this issue, 1970–1970
2 sentences

1970But see Clark v. Mobile County Hospital Board, 275 Ala. 26 , 151 So. 2d 750 (1963); and Boyer v. Iowa High School Athletic Assn., 256 Ia. 337 , 127 N.W. 2d 606 (1964). [4] It should be noted that the abandonment of the rule of immunity as it is presently applied would not be an end to all immunities. "[N]o one today urges that a judicial remedy be given for all the injuries that may result from mistaken governmental action, or that the courts should decide when governmental action of a political nature is mistaken.

1970But see Clark v. Mobile County Hospital Board, 275 Ala. 26 , 151 So. 2d 750 (1963); and Boyer v. Iowa High School Athletic Assn., 256 Ia. 337 , 127 N.W. 2d 606 (1964). [4] It should be noted that the abandonment of the rule of immunity as it is presently applied would not be an end to all immunities. "[N]o one today urges that a judicial remedy be given for all the injuries that may result from mistaken governmental action, or that the courts should decide when governmental action of a political nature is mistaken.

11

Also cited on this issue (27)

CaseCitedYears
Kreamer v. Yoneida green
pa · 1905
2 sentences

1959Co., 301 Pa. 475, 481 , 152 A. 682 it was said: “ ‘A perfect title passing by the Commonwealth’s patent ... is in no danger from the doctrine of abandonment, unless, in consequence of [the] abandonment, adverse possession is taken by another and held for the period of the statute of limitations.’ ” See also: *557 Kreamer v. Voneida, 213 Pa. 74 , 62 A. 518 ; Graham & Co. v. Penna.

1959Co., 301 Pa. 475, 481 , 152 A. 682 it was said: “ ‘A perfect title passing by the Commonwealth’s patent ... is in no danger from the doctrine of abandonment, unless, in consequence of [the] abandonment, adverse possession is taken by another and held for the period of the statute of limitations.’ ” See also: *557 Kreamer v. Voneida, 213 Pa. 74 , 62 A. 518 ; Graham & Co. v. Penna.

31930–1959
Bear Valley Coal Co. v. Dewart green
· 1880
2 sentences

1943Such a title is in no danger from the doctrine of abandonment, for “. . . the doctrine of abandonment does not apply to a perfect title, but only to imperfect titles,” 2 *636 Bear Valley Coal Co. v. Dewart, 95 Pa. 72, 78 .

1930The doctrine of abandonment does not apply to a perfect title, but only to imperfect titles”: Bear Valley Coal Co. v. Dewart, 95 Pa. 72, 78 .

31905–1943
Commonwealth v. Finley green
pa · 1988
1 sentence

2025Appellant’s Brief at 3-4 (footnote added; issues reordered and modified; formatting, capitalization, punctuation and spelling modified for clarity; explanatory comments omitted).4 In reviewing an order dismissing a PCRA petition, our standard of review “is limited to examining whether the PCRA court’s determination is supported by the evidence of record and whether it is free of legal error.” ____________________________________________ 3 See Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988) (setting forth the requirements for withdrawal from representation during collateral review); Commonwealt

12025–2025
Commonwealth v. Turner green
pa · 1988
1 sentence

2025Appellant’s Brief at 3-4 (footnote added; issues reordered and modified; formatting, capitalization, punctuation and spelling modified for clarity; explanatory comments omitted).4 In reviewing an order dismissing a PCRA petition, our standard of review “is limited to examining whether the PCRA court’s determination is supported by the evidence of record and whether it is free of legal error.” ____________________________________________ 3 See Commonwealth v. Turner, 544 A.2d 927 (Pa. 1988) (setting forth the requirements for withdrawal from representation during collateral review); Commonwealt

12025–2025
Com. v. Lyn, R. green
pasuperct · 2024
1 sentence

2025He ____________________________________________ 2 See also Commonwealth v. Shoatz, 366 A.2d 1216, 1220 (Pa. 1976) (emphasis added) (explaining that the definition of abandonment for Fourth Amendment purposes differs from the strict property-right sense; the abandonment analysis turns not on a property interest in the item but an appellant’s possession of a reasonable expectation of privacy in the property in question at the time of the search). -7- J-A08031-25 asserts he later gave the officers the keys and they used them to conduct a warrantless search of the car in violation of Alexander, su

12025–2025
Com. v. Hall, J. green
pasuperct · 2023
1 sentence

2025He ____________________________________________ 2 See also Commonwealth v. Shoatz, 366 A.2d 1216, 1220 (Pa. 1976) (emphasis added) (explaining that the definition of abandonment for Fourth Amendment purposes differs from the strict property-right sense; the abandonment analysis turns not on a property interest in the item but an appellant’s possession of a reasonable expectation of privacy in the property in question at the time of the search). -7- J-A08031-25 asserts he later gave the officers the keys and they used them to conduct a warrantless search of the car in violation of Alexander, su

12025–2025
Aye v. Philadelphia Co. green
pa · 1899
2 sentences

2021Pa. 2004), Aye v. Philadelphia Co., 193 Pa. 451 (Pa. 1899), and the doctrine of abandonment.” Id.

2021Pa. 2004), Aye v. Philadelphia Co., 193 Pa. 451 (Pa. 1899), and the doctrine of abandonment.” Id.

12021–2021
Wyeth v. Levine green
scotus · 2009
1 sentence

2013Plaintiff urges, “To the extent that lower courts have erred by interpreting Napier in its broadest sense, that error can be cured by the abandonment of the doctrine of federal field preemption...” in favor of what plaintiff refers to as the “express preemption” analysis adopted in Wyeth, 555 U.S. 555 .

12013–2013
In Re Estate of Scharlach green
pasuperct · 2002
1 sentence

2010Scharlach, 809 A.2d at 383 (citing Sprague v. Casey, 520 Pa. 38, 45 , 550 A.2d 184, 187-88 (1988)); see Potter Title & Trust Co. v. Frank, 298 Pa. 137, 141 , 148 A. 50, 52 (1929) (holding that a plaintiffs eight-year delay in bringing suit constituted an abandonment of his claim); McGrann v. Allen, 291 Pa. 574, 580 , 140 A. 552, 554 (1928) (finding that laches barred the plaintiffs claim where he could have demanded an accounting twelve years earlier); Taylor v. Coggins, 244 Pa. 228, 231 , 90 A. 633, 635 (1914) (per curiam) (agreeing with trial court’s statement that “Suits brought after the p

12010–2010
Kirk v. Brentwood Manor Homes, Inc. green
pasuperct · 1960
1 sentence

2000Kirk, 191 Pa. Super. at 493 , 159 A.2d at 51 .

12000–2000
Commonwealth v. Basovsky green
pasuperct · 1960
1 sentence

2000Kirk, 191 Pa. Super. at 493 , 159 A.2d at 51 .

12000–2000
Niederman v. Brodsky green
pa · 1970
2 sentences

1973With the abandonment of the requirement of physical impact as a precondition to recovery for damages for emotional suffering by Niederman v. Brodsky, 436 Pa. 401 , 261 A. 2d 84 (1970), the concept of an award for such cause in human relations proceedings standing alone would not be unique.

1973With the abandonment of the requirement of physical impact as a precondition to recovery for damages for emotional suffering by Niederman v. Brodsky, 436 Pa. 401 , 261 A. 2d 84 (1970), the concept of an award for such cause in human relations proceedings standing alone would not be unique.

11973–1973
Boyer v. Iowa High School Athletic Association green
iowa · 1964
2 sentences

1970But see Clark v. Mobile County Hospital Board, 275 Ala. 26 , 151 So. 2d 750 (1963); and Boyer v. Iowa High School Athletic Assn., 256 Ia. 337 , 127 N.W. 2d 606 (1964). [4] It should be noted that the abandonment of the rule of immunity as it is presently applied would not be an end to all immunities. "[N]o one today urges that a judicial remedy be given for all the injuries that may result from mistaken governmental action, or that the courts should decide when governmental action of a political nature is mistaken.

1970But see Clark v. Mobile County Hospital Board, 275 Ala. 26 , 151 So. 2d 750 (1963); and Boyer v. Iowa High School Athletic Assn., 256 Ia. 337 , 127 N.W. 2d 606 (1964). [4] It should be noted that the abandonment of the rule of immunity as it is presently applied would not be an end to all immunities. "[N]o one today urges that a judicial remedy be given for all the injuries that may result from mistaken governmental action, or that the courts should decide when governmental action of a political nature is mistaken.

11970–1970
Flagiello v. Pennsylvania Hospital green
pa · 1965
1 sentence

1965Plaintiff suggests that Flagiello v. Pennsylvania Hospital, 417 Pa. 486 , amounts to an abandonment of the rule of immunity in Pennsylvania.

11965–1965
Summit Hosiery Co. v. Gottschall green
pa · 1928
2 sentences

1964The case of Summit Hosiery Co. v. Gottschall, 292 Pa. 464 , 141 A. 298 , relied upon by appellant, is readily distinguished.

1964The case of Summit Hosiery Co. v. Gottschall, 292 Pa. 464 , 141 A. 298 , relied upon by appellant, is readily distinguished.

11964–1964
Huss v. Jacobs neutral
pa · 1904
2 sentences

1959Turnpike Commission, 347 Pa. 622, 635, 636 , supra. 9 Mr. Justice Dean in Huss v. Jacobs, 210 Pa. 145, 161 , 59 A. 991 , aptly said: “To preserve such a title [a title in fee simple to coal] the law does not require physical possession by the owner, that he should live in a coal mine”: Muzzio et al. v. Steele, 279 Pa. 226 , 123 A. 776 .

1959Turnpike Commission, 347 Pa. 622, 635, 636 , supra. 9 Mr. Justice Dean in Huss v. Jacobs, 210 Pa. 145, 161 , 59 A. 991 , aptly said: “To preserve such a title [a title in fee simple to coal] the law does not require physical possession by the owner, that he should live in a coal mine”: Muzzio et al. v. Steele, 279 Pa. 226 , 123 A. 776 .

11959–1959
Muzzio v. Steele green
pa · 1924
11959–1959
Parks v. Pennsylvania R. R. Co. green
pa · 1930
2 sentences

1959Co., 301 Pa. 475, 481 , 152 A. 682 it was said: “ ‘A perfect title passing by the Commonwealth’s patent ... is in no danger from the doctrine of abandonment, unless, in consequence of [the] abandonment, adverse possession is taken by another and held for the period of the statute of limitations.’ ” See also: *557 Kreamer v. Voneida, 213 Pa. 74 , 62 A. 518 ; Graham & Co. v. Penna.

1959Co., 301 Pa. 475, 481 , 152 A. 682 it was said: “ ‘A perfect title passing by the Commonwealth’s patent ... is in no danger from the doctrine of abandonment, unless, in consequence of [the] abandonment, adverse possession is taken by another and held for the period of the statute of limitations.’ ” See also: *557 Kreamer v. Voneida, 213 Pa. 74 , 62 A. 518 ; Graham & Co. v. Penna.

11959–1959
Dougherty, Tr. v. Thomas, Exr. green
pa · 1933
2 sentences

1959Dougherty v. Thomas, 313 Pa. 287 , 169 A. 219 .

1959Dougherty v. Thomas, 313 Pa. 287 , 169 A. 219 .

11959–1959
Spigelmire v. North Braddock School District green
pa · 1945
11948–1948
Pittsburgh v. Allegheny County green
pa · 1945
11948–1948
Toffalori v. Donatelli Granite Co. green
pasuperct · 1945
11948–1948
Kreamer v. Voneida neutral
pasuperct · 1904
11930–1930
Wright v. Guier neutral
pa · 1840
11930–1930
Pierce v. Barney neutral
pa · 1904
11930–1930
Hoffman v. Bell green
pa · 1869
11905–1905
Putnam v. Tyler green
pa · 1888
11905–1905

Statutes the citing opinions construe

PA § 23 Pa. Cons. Stat. § 2511 (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

MO 149 (1885–2025) TX 84 (1909–2026) IL 66 (1898–2025) CA 41 (1863–2026) NY 39 (1873–2025) LA 32 (1931–2023) CT 28 (1967–2024) FL 26 (1931–2025) OH 25 (1960–2026) PA 24 (1905–2025) UT 24 (1987–2020) MI 23 (1886–2026) WA 20 (1963–2019) AZ 18 (1965–2025) IN 15 (1881–2019) CO 14 (1914–2026) TN 12 (1899–2024) NJ 11 (1957–2024) MS 11 (1924–2020) AL 11 (1912–2011) ID 10 (1873–2024) SC 10 (1926–2024) MD 8 (1976–2016) MA 7 (1938–2025) IA 7 (1940–2021) OK 7 (1947–1993) AR 7 (1898–2017) AK 7 (1983–1998) WI 6 (1938–2026) GA 6 (1976–2017) NC 6 (1948–2014) MN 6 (1914–2004) NM 6 (2012–2016) NE 6 (1906–2009) VT 5 (1881–2015) KY 5 (1932–2025) VA 5 (1902–2024) NH 4 (1859–2007) KS 4 (1976–2025) DC 4 (1978–2023) MT 3 (1910–2010) OR 3 (1978–2014) WV 3 (1957–1997) HI 3 (1940–2006) RI 3 (1987–2005) ME 2 (1992–2012) DE 2 (2019–2022) SD 2 (1915–1990) NV 2 (1983–2014)

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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