First Amendment challenge (Virginia) · Go Syfert
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First Amendment challenge in Virginia

24 Virginia opinions name it 6 courts 1988–2026 6 in the last five years

The cases below were cited by Virginia 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 (16)

CaseFollowedCited
Broadrick v. Oklahomagreen
scotus · 1973 · cited in 4 Virginia opinions naming this issue, 1991–2005
2 sentences

2005The First Amendment doctrine of overbreadth requires proof that a law "punishes a `substantial' amount of protected free speech, `judged in relation to the statute's plainly legitimate sweep.'" Virginia v. Hicks, 539 U.S. 113 , 118, 123 S.Ct. 2191 , 156 L.Ed.2d 148 (2003) (citing Broadrick v. Oklahoma, 413 U.S. 601 , 615, 93 S.Ct. 2908 , 37 L.Ed.2d 830 (1973)).

2005The First Amendment doctrine of overbreadth requires proof that a law "punishes a `substantial' amount of protected free speech, `judged in relation to the statute's plainly legitimate sweep.'" Virginia v. Hicks, 539 U.S. 113 , 118, 123 S.Ct. 2191 , 156 L.Ed.2d 148 (2003) (citing Broadrick v. Oklahoma, 413 U.S. 601 , 615, 93 S.Ct. 2908 , 37 L.Ed.2d 830 (1973)).

24
Herbert Liverman v. City of Petersburggreen
ca4 · 2016 · cited in 2 Virginia opinions naming this issue, 2024–2024
2 sentences

2024“Courts begin the First Amendment inquiry by assessing whether the speech at issue relates to a matter of public concern.” Liverman v. City of Petersburg, 844 F.3d 400, 406 (4th Cir. 2016).

2024“Courts begin the First Amendment inquiry by assessing whether the speech at issue relates to a matter of public concern.” Liverman v. City of Petersburg, 844 F.3d 400, 406 (4th Cir. 2016).

22
Shenandoah Publishing House, Inc. v. Fanninggreen
va · 1988 · cited in 2 Virginia opinions naming this issue, 2015–2022
2 sentences

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

22
Massachusetts v. Oakesgreen
scotus · 1989 · cited in 2 Virginia opinions naming this issue, 1991–1998
2 sentences

1998Overbreadth Under the First Amendment "'The First Amendment doctrine of . . . overbreadth is an exception to the general rule that a person to whom a statute may be constitutionally applied cannot challenge the statute on the ground that it may be unconstitutionally applied to others.'" Perkins v. Commonwealth, 12 Va. App. 7, 11-12 , 402 S.E.2d 229, 232 (1991) (quoting Massachusetts v. Oakes, 491 U.S. 576, 581 (1989)).

1998Overbreadth Under the First Amendment "'The First Amendment doctrine of . . . overbreadth is an exception to the general rule that a person to whom a statute may be constitutionally applied cannot challenge the statute on the ground that it may be unconstitutionally applied to others.'" Perkins v. Commonwealth, 12 Va. App. 7, 11-12 , 402 S.E.2d 229, 232 (1991) (quoting Massachusetts v. Oakes, 491 U.S. 576, 581 (1989)).

22
Richmond Newspapers, Inc. v. Commonwealthgreen
va · 1981 · cited in 2 Virginia opinions naming this issue, 1988–2022
2 sentences

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

12
Allison v. Browngreen
va · 2017 · cited in 1 Virginia opinions naming this issue, 2026–2026
1 sentence

2026He notes that the circuit court acknowledged he pled an “as-applied First Amendment challenge,” argues this challenge adequately described “what is commonly called a First Amendment Retaliation Claim,” and asserts that to distinguish between the two is to make “a distinction without a difference.” “[E]very litigant is entitled to be told by his adversary in plain and explicit language what is his ground of complaint or defense.” Lehmann v. WFV Holdings, LLC, 80 Va. App. 802 , 812 (2024) (quoting Grayson v. Westwood Bldgs., L.P., 300 Va. 25 , 69 (2021)); see also Allison v. Brown, 293 Va. 617,

11
Brian Jeffrey Turner v. Commonwealth of Virginiagreen
vactapp · 2015 · cited in 1 Virginia opinions naming this issue, 2024–2024
2 sentences

2024Id. at 463 . - 18 - can we say an abuse of discretion has occurred.” Turner v. Commonwealth, 65 Va. App. 312, 327 (2015) (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)). 1.

2024Id. at 463 . - 18 - can we say an abuse of discretion has occurred.” Turner v. Commonwealth, 65 Va. App. 312, 327 (2015) (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)). 1.

11
Grattan v. Com.green
va · 2009 · cited in 1 Virginia opinions naming this issue, 2024–2024
2 sentences

2024Id. at 463 . - 18 - can we say an abuse of discretion has occurred.” Turner v. Commonwealth, 65 Va. App. 312, 327 (2015) (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)). 1.

2024Id. at 463 . - 18 - can we say an abuse of discretion has occurred.” Turner v. Commonwealth, 65 Va. App. 312, 327 (2015) (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)). 1.

11
In Re the Knight Publishing Company D/B/A the Charlotte Observergreen
ca4 · 1984 · cited in 1 Virginia opinions naming this issue, 2022–2022
2 sentences

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

11
Greg Rushford, the Washington Post Company, Intervenor v. The New Yorker Magazine, Inc., and William Shawn Reneta Adlergreen
ca4 · 1988 · cited in 1 Virginia opinions naming this issue, 2022–2022
2 sentences

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

11
St. Amant v. Thompsongreen
scotus · 1968 · cited in 1 Virginia opinions naming this issue, 2011–2011
2 sentences

2011Amant v. Thompson, 390 U.S. 727, 732 , 88 S. Ct. 1323, 1326 (1968).

2011Amant v. Thompson, 390 U.S. 727, 732 , 88 S. Ct. 1323, 1326 (1968).

11
In Re Andrew Shain Sid Gaulden Cindi Ross Scoppe Schuyler Kropf, United States of America v. Jefferson Marion Long, Jr., A/K/A \Bud\" Long"green
ca4 · 1992 · cited in 1 Virginia opinions naming this issue, 2004–2004
2 sentences

2004Therefore, “the absence of confidentiality or vindictiveness in the facts of this case fatally undermines the reporters’ claim to a First Amendment privilege.” Id.

2004Therefore, “the absence of confidentiality or vindictiveness in the facts of this case fatally undermines the reporters’ claim to a First Amendment privilege.” Id.

11
Los Angeles Police Department v. United Reporting Publishing Corp.green
scotus · 2000 · cited in 1 Virginia opinions naming this issue, 2002–2002
2 sentences

2002For example, the Supreme Court stated in Los Angeles Police Department v. United Reporting Publishing Corp., 528 U.S. 32, 38 (1999): “The traditional rule is that ‘a person to whom a statute may constitutionally be applied may not challenge that statute on the ground that it may conceivably be applied unconstitutionally to others in situations not before the Court.’ New York v. Ferber, 458 U.S. 747, 767 (1982) (citing Broadrick v. Oklahoma, 413 U.S. 601, 610 (1973)).

2002For example, the Supreme Court stated in Los Angeles Police Department v. United Reporting Publishing Corp., 528 U.S. 32, 38 (1999): “The traditional rule is that ‘a person to whom a statute may constitutionally be applied may not challenge that statute on the ground that it may conceivably be applied unconstitutionally to others in situations not before the Court.’ New York v. Ferber, 458 U.S. 747, 767 (1982) (citing Broadrick v. Oklahoma, 413 U.S. 601, 610 (1973)).

11
New York v. Ferbergreen
scotus · 1982 · cited in 1 Virginia opinions naming this issue, 2002–2002
2 sentences

2002For example, the Supreme Court stated in Los Angeles Police Department v. United Reporting Publishing Corp., 528 U.S. 32, 38 (1999): “The traditional rule is that ‘a person to whom a statute may constitutionally be applied may not challenge that statute on the ground that it may conceivably be applied unconstitutionally to others in situations not before the Court.’ New York v. Ferber, 458 U.S. 747, 767 (1982) (citing Broadrick v. Oklahoma, 413 U.S. 601, 610 (1973)).

2002For example, the Supreme Court stated in Los Angeles Police Department v. United Reporting Publishing Corp., 528 U.S. 32, 38 (1999): “The traditional rule is that ‘a person to whom a statute may constitutionally be applied may not challenge that statute on the ground that it may conceivably be applied unconstitutionally to others in situations not before the Court.’ New York v. Ferber, 458 U.S. 747, 767 (1982) (citing Broadrick v. Oklahoma, 413 U.S. 601, 610 (1973)).

11
Perkins v. Commonwealthgreen
vactapp · 1991 · cited in 1 Virginia opinions naming this issue, 1998–1998
11
Seattle Times Co. v. Rhinehartgreen
scotus · 1984 · cited in 1 Virginia opinions naming this issue, 1988–1988
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (21)

CaseCitedYears
Virginia v. Hicks green
scotus · 2003
2 sentences

2006As the Supreme Court recently said, “The First Amendment doctrine of overbreadth is an exception to our normal rule regarding the standards for facial challenges.” Virginia v. Hicks, 539 U.S. 113, 118 , 123 S.Ct. 2191, 2196 , 156 L.Ed.2d 148 (2003).

2006As the Supreme Court recently said, “The First Amendment doctrine of overbreadth is an exception to our normal rule regarding the standards for facial challenges.” Virginia v. Hicks, 539 U.S. 113, 118 , 123 S.Ct. 2191, 2196 , 156 L.Ed.2d 148 (2003).

32005–2006
Connick Ex Rel. Parish of Orleans v. Myers green
scotus · 1983
2 sentences

2024“The inquiry into the protected status of speech is one of law, not fact.” Connick, 461 U.S. at 148 n.7.

2024“The inquiry into the protected status of speech is one of law, not fact.” Connick, 461 U.S. at 148 n.7.

22024–2024
Grandbouche v. Clancy green
ca1 · 1987
2 sentences

2026The trial court must also determine the validity of the claimed First Amendment privilege.” Id. (citation omitted).

2026Id. at 1467 .

12026–2026
Coleman v. City of Richmond green
vactapp · 1988
2 sentences

2024“Only when reasonable jurists could not differ 10 Shaw thus misplaces his reliance on Coleman v. City of Richmond, 5 Va. App. 459 (1988), where we applied the overbreadth exception to consider the defendant’s First Amendment challenge to the loitering ordinance under which he was convicted.

2024“Only when reasonable jurists could not differ 10 Shaw thus misplaces his reliance on Coleman v. City of Richmond, 5 Va. App. 459 (1988), where we applied the overbreadth exception to consider the defendant’s First Amendment challenge to the loitering ordinance under which he was convicted.

12024–2024
cluster 769389 green
ca4 · 2000
2 sentences

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

2022Seeking to open up this proceeding to the public, the newspaper publisher has not only asked us to unseal our “sealing order” but has also asked us to provide “constitutionally- 1 See Richmond Newspapers, Inc. v. Commonwealth, 222 Va. 574, 589-90 (1981) (Richmond II) (holding that “interested members of the public should have the right to be heard”); Shenandoah Publ’g House v. Fanning, 235 Va. 253, 259 (1988) (applying the procedural guidelines announced in Richmond II to judicial records in civil proceedings); cf. Ashcroft v. Conoco, Inc., 218 F.3d 288 , 302 (4th Cir. 2000) (requiring courts

12022–2022
Packingham v. North Carolina green
scotus · 2017
1 sentence

2019Effect on Speech and Association Given that the challenged statutory requirements advance a significant governmental interest, appellant can prevail in his First Amendment challenge only if he can show that those requirements are not "narrowly tailored," id. (quoting McCullen v. Coakley , 573 U.S. 464 , 486, 134 S.Ct. 2518 , 2534-35, 189 L.Ed.2d 502 (2014) ), and "burden substantially more speech than necessary" to advance that interest, Humanitarian Law Project , 561 U.S. at 27 , 130 S.Ct. at 2723 -24 (quoting Turner Broad.

12019–2019
Holder v. Humanitarian Law Project green
scotus · 2010
2 sentences

2019Effect on Speech and Association Given that the challenged statutory requirements advance a significant governmental interest, appellant can prevail in his First Amendment challenge only if he can show that those requirements are not "narrowly tailored," id. (quoting McCullen v. Coakley , 573 U.S. 464 , 486, 134 S.Ct. 2518 , 2534-35, 189 L.Ed.2d 502 (2014) ), and "burden substantially more speech than necessary" to advance that interest, Humanitarian Law Project , 561 U.S. at 27 , 130 S.Ct. at 2723 -24 (quoting Turner Broad.

2019Effect on Speech and Association Given that the challenged statutory requirements advance a significant governmental interest, appellant can prevail in his First Amendment challenge only if he can show that those requirements are not "narrowly tailored," id. (quoting McCullen v. Coakley , 573 U.S. 464 , 486, 134 S.Ct. 2518 , 2534-35, 189 L.Ed.2d 502 (2014) ), and "burden substantially more speech than necessary" to advance that interest, Humanitarian Law Project , 561 U.S. at 27 , 130 S.Ct. at 2723 -24 (quoting Turner Broad.

12019–2019
Turner Broadcasting System, Inc. v. Federal Communications Commission green
scotus · 1997
2 sentences

2019Sys., Inc. , 520 U.S. at 189 , 117 S.Ct. at 1186 ).

2019Sys., Inc. , 520 U.S. at 189 , 117 S.Ct. at 1186 ).

12019–2019
McCullen v. Coakley green
scotus · 2014
2 sentences

2019Effect on Speech and Association Given that the challenged statutory requirements advance a significant governmental interest, appellant can prevail in his First Amendment challenge only if he can show that those requirements are not "narrowly tailored," id. (quoting McCullen v. Coakley , 573 U.S. 464 , 486, 134 S.Ct. 2518 , 2534-35, 189 L.Ed.2d 502 (2014) ), and "burden substantially more speech than necessary" to advance that interest, Humanitarian Law Project , 561 U.S. at 27 , 130 S.Ct. at 2723 -24 (quoting Turner Broad.

2019Effect on Speech and Association Given that the challenged statutory requirements advance a significant governmental interest, appellant can prevail in his First Amendment challenge only if he can show that those requirements are not "narrowly tailored," id. (quoting McCullen v. Coakley , 573 U.S. 464 , 486, 134 S.Ct. 2518 , 2534-35, 189 L.Ed.2d 502 (2014) ), and "burden substantially more speech than necessary" to advance that interest, Humanitarian Law Project , 561 U.S. at 27 , 130 S.Ct. at 2723 -24 (quoting Turner Broad.

12019–2019
Police Dept. of Chicago v. Mosley green
scotus · 1972
2 sentences

2014Id. (citing Consol.

2014Id. (citing Consol.

12014–2014
Stanley v. City of Norfolk green
va · 1977
2 sentences

2008Stanley concerned a charge of disorderly conduct during an assault and raised a due process overbreadth challenge and not a First Amendment claim. 218 Va. at 505 -06 , 237 S.E.2d at 800 .

2008Stanley concerned a charge of disorderly conduct during an assault and raised a due process overbreadth challenge and not a First Amendment claim. 218 Va. at 505 -06 , 237 S.E.2d at 800 .

12008–2008
Commonwealth v. Hicks green
va · 2002
2 sentences

2008In that case the majority applied the United States Supreme Court's exception to the standing rule reciting that "in the context of a First Amendment challenge, a litigant may challenge government action granting government officials standardless discretion even if that government action as applied to the litigant is constitutionally permissible." Id. at 55 , 563 S.E.2d at 678 .

2008In that case the majority applied the United States Supreme Court's exception to the standing rule reciting that "in the context of a First Amendment challenge, a litigant may challenge government action granting government officials standardless discretion even if that government action as applied to the litigant is constitutionally permissible." Id. at 55 , 563 S.E.2d at 678 .

12008–2008
Esper Bonding Co. v. Commonwealth green
va · 1981
2 sentences

2008Esper Bonding Co. involved the Commonwealth's attempt to assert third party rights regarding the forfeiture of a bail bond, which we denied. 222 Va. at 597 -98 , 283 S.E.2d at 186 .

2008Esper Bonding Co. involved the Commonwealth's attempt to assert third party rights regarding the forfeiture of a bail bond, which we denied. 222 Va. at 597 -98 , 283 S.E.2d at 186 .

12008–2008
County Court of Ulster Cty. v. Allen green
scotus · 1979
2 sentences

2005County Court of Ulster County v. Allen, 442 U.S. 140, 154-55 , 99 S.Ct. 2213, 2223-24 , 60 L.Ed.2d 777 (1979).

2005County Court of Ulster County v. Allen, 442 U.S. 140, 154-55 , 99 S.Ct. 2213, 2223-24 , 60 L.Ed.2d 777 (1979).

12005–2005
McIntyre v. Ohio Elections Commission green
scotus · 1995
2 sentences

2004The Supreme Court has noted the grave importance of protecting the freedom to publish anonymously, McIntyre v. Ohio Elections Commission, 514 U.S. 334 (1995).

2004The Supreme Court has noted the grave importance of protecting the freedom to publish anonymously, McIntyre v. Ohio Elections Commission, 514 U.S. 334 (1995).

12004–2004
Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah green
scotus · 1993
1 sentence

2001This test has, to date, only been applied by the Supreme Court in cases involving criminal statutes or ordinances, see, e.g., Smith', Church of Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (1993), and may not be applicable if the free exercise claim is invoked with another First Amendment claim.

12001–2001
Employment Div., Dept. of Human Resources of Ore. v. Smith red
scotus · 1990
12001–2001
Hernandez v. Superintendent, Fredericksburg-Rappahannock Joint Security Center green
vaed · 1992
11998–1998
Leathers v. Medlock green
scotus · 1991
11991–1991
Valentine v. Chrestensen red
scotus · 1942
11988–1988
Virginia State Board of Pharmacy v. Virginia Citizens Consumer Council, Inc. green
scotus · 1976
11988–1988

Statutes the citing opinions construe

USC § 15u.s.c.7701 (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 279 (1966–2026) TX 181 (1984–2026) WA 129 (1975–2026) PA 108 (1966–2026) IL 91 (1979–2026) NY 88 (1959–2026) FL 74 (1976–2025) NJ 67 (1976–2026) MA 57 (1969–2025) CO 54 (1982–2026) OH 53 (1980–2026) CT 46 (1990–2025) MN 45 (1981–2024) WI 45 (1982–2026) MI 45 (1980–2026) DC 44 (1975–2025) AZ 33 (1976–2026) MD 33 (1983–2025) OR 33 (1974–2024) IA 33 (1976–2026) IN 31 (1974–2024) GA 29 (1982–2024) WV 25 (1981–2021) VA 24 (1988–2026) ME 24 (1970–2026) VT 23 (1980–2025) KS 23 (1973–2025) NM 22 (1982–2026) NC 19 (1991–2025) UT 19 (1982–2025) TN 18 (1979–2026) MO 17 (1982–2015) KY 17 (1992–2024) RI 16 (1982–2000) AK 16 (1979–2025) AR 16 (1985–2024) NE 15 (1990–2019) SC 15 (1979–2021) NH 13 (1967–2023) LA 13 (1972–2021) NV 12 (1981–2025) MT 12 (1990–2025) ID 11 (1977–2016) DE 10 (1984–2025) ND 10 (1982–2023) OK 10 (1976–2025) SD 9 (1969–2020) MS 8 (1970–2025) AL 8 (1987–2015) HI 8 (1999–2014) WY 7 (2003–2019) VI 4 (1996–2017)

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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