custody requirement (New Mexico) · Go Syfert
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custody requirement in New Mexico

23 New Mexico opinions name it 2 courts 1981–2025 6 in the last five years

The cases below were cited by New Mexico 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 (18)

CaseFollowedCited
State v. SMILEgreen
nmctapp · 2009 · cited in 3 New Mexico opinions naming this issue, 2011–2014
2 sentences

2014See, e.g., Smile, 2009-NMCA-064, ¶ 27 .

2014See, e.g., Smile, 2009-NMCA-064, ¶ 27 .

33
State v. Olivasgreen
nmctapp · 2011 · cited in 4 New Mexico opinions naming this issue, 2013–2021
2 sentences

2021Rather, we consider how “a reasonable man in the suspect’s position would have understood his situation.” Id. (internal quotation marks and citation omitted). {20} In the event that there is no formal arrest prior to questioning, “our appellate courts engage in a fact-specific analysis of the totality of the circumstances under which the questioning took place in order to decide whether the custody requirement is met.” State v. Olivas, 2011-NMCA-030, ¶ 10 , 149 N.M. 498 , 252 P.3d 722 .

2021Rather, we consider how “a reasonable man in the suspect’s position would have understood his situation.” Id. (internal quotation marks and citation omitted). {20} In the event that there is no formal arrest prior to questioning, “our appellate courts engage in a fact-specific analysis of the totality of the circumstances under which the questioning took place in order to decide whether the custody requirement is met.” State v. Olivas, 2011-NMCA-030, ¶ 10 , 149 N.M. 498 , 252 P.3d 722 .

24
State v. Hermosillogreen
nmctapp · 2014 · cited in 2 New Mexico opinions naming this issue, 2023–2025
2 sentences

2025See State v. Hermosillo, 2014-NMCA-102, ¶ 11 , 336 P.3d 446 (“If no formal arrest occurred prior to questioning, our appellate courts engage in a fact-specific analysis of the totality of the circumstances under which the questioning took place in order to decide whether the custody requirement is met.”). {6} Before the investigating officer arrived, civilian bystanders1 prevented Defendant from fleeing the scene of the accident.

2023See State v. Hermosillo, 2014-NMCA-102, ¶ 30 , 336 P.3d 446 (“[T]he fact that [the d]efendant was handcuffed is one of many factors that must be considered under the totality of the circumstances.”). {12} The State also cites to Armijo v. State ex rel.

22
International Ass'n of Firefighters v. City of Carlsbadgreen
nmctapp · 2009 · cited in 2 New Mexico opinions naming this issue, 2010–2011
2 sentences

2011See Int'l Ass'n of Firefighters v. City of Carlsbad, 2009-NMCA-097, ¶ 11 , 147 N.M. 6 , 216 P.3d 256 ("We seek to give meaning to all parts of the statute, such that no portion is rendered surplusage or meaningless."), cert. denied, 2009-NMCERT-007 , 147 N.M. 363 , 223 P.3d 360 . {15} Indeed, if we were to read Subsection (L) as Petitioner requests, granting a nonadoptive or non-natural parent standing to bring a custody claim, we would be rendering meaningless the Legislature's limitation of standing to adoptive and natural parents.

2011See Int'l Ass'n of Firefighters v. City of Carlsbad, 2009-NMCA-097, ¶ 11 , 147 N.M. 6 , 216 P.3d 256 ("We seek to give meaning to all parts of the statute, such that no portion is rendered surplusage or meaningless."), cert. denied, 2009-NMCERT-007 , 147 N.M. 363 , 223 P.3d 360 . {15} Indeed, if we were to read Subsection (L) as Petitioner requests, granting a nonadoptive or non-natural parent standing to bring a custody claim, we would be rendering meaningless the Legislature's limitation of standing to adoptive and natural parents.

22
State Ex Rel. Children, Youth & Families Department v. Marlene C.green
nmctapp · 2009 · cited in 2 New Mexico opinions naming this issue, 2011–2011
2 sentences

2011See Marlene C., 2009-NMCA-058, ¶¶ 15-18 , 146 N.M. 588 , 212 P.3d 1142 .

2011See Marlene C., 2009-NMCA-058, ¶¶ 15-18 , 146 N.M. 588 , 212 P.3d 1142 .

22
State v. Gardnergreen
nm · 2009 · cited in 2 New Mexico opinions naming this issue, 2010–2011
2 sentences

2011See Int'l Ass'n of Firefighters v. City of Carlsbad, 2009-NMCA-097, ¶ 11 , 147 N.M. 6 , 216 P.3d 256 ("We seek to give meaning to all parts of the statute, such that no portion is rendered surplusage or meaningless."), cert. denied, 2009-NMCERT-007 , 147 N.M. 363 , 223 P.3d 360 . {15} Indeed, if we were to read Subsection (L) as Petitioner requests, granting a nonadoptive or non-natural parent standing to bring a custody claim, we would be rendering meaningless the Legislature's limitation of standing to adoptive and natural parents.

2010See Int’l Ass’n of Firefighters v. City of Carlsbad, 2009-NMCA-097, ¶ 11 , 147 N.M. 6 , 216 P.3d 256 (“We seek to give meaning to all parts of the statute, such that no portion is rendered surplusage or meaningless.”), cert. denied, 2009-NMCERT-007 , 147 N.M. 363 , 223 P.3d 360 . {15} Indeed, if we were to read Subsection (L) as Petitioner requests, granting a non-adoptive or non-natural parent standing to bring a custody claim, we would be rendering meaningless the Legislature’s limitation of standing to adoptive and natural parents.

22
State of Nm Ex Rel. Cyfd v. Marlene C.green
nmctapp · 2009 · cited in 2 New Mexico opinions naming this issue, 2011–2011
2 sentences

2011See Marlene C., 2009-NMCA-058, ¶¶ 15-18 , 146 N.M. 588 , 212 P.3d 1142 .

2011See Marlene C., 2009-NMCA-058, ¶¶ 15-18 , 146 N.M. 588 , 212 P.3d 1142 .

22
Albq. Commons v. City of Albqgreen
nm · 2009 · cited in 2 New Mexico opinions naming this issue, 2010–2011
2 sentences

2011See Int'l Ass'n of Firefighters v. City of Carlsbad, 2009-NMCA-097, ¶ 11 , 147 N.M. 6 , 216 P.3d 256 ("We seek to give meaning to all parts of the statute, such that no portion is rendered surplusage or meaningless."), cert. denied, 2009-NMCERT-007 , 147 N.M. 363 , 223 P.3d 360 . {15} Indeed, if we were to read Subsection (L) as Petitioner requests, granting a nonadoptive or non-natural parent standing to bring a custody claim, we would be rendering meaningless the Legislature's limitation of standing to adoptive and natural parents.

2010See Int’l Ass’n of Firefighters v. City of Carlsbad, 2009-NMCA-097, ¶ 11 , 147 N.M. 6 , 216 P.3d 256 (“We seek to give meaning to all parts of the statute, such that no portion is rendered surplusage or meaningless.”), cert. denied, 2009-NMCERT-007 , 147 N.M. 363 , 223 P.3d 360 . {15} Indeed, if we were to read Subsection (L) as Petitioner requests, granting a non-adoptive or non-natural parent standing to bring a custody claim, we would be rendering meaningless the Legislature’s limitation of standing to adoptive and natural parents.

22
Ezell v. Rochagreen
nm · 2009 · cited in 2 New Mexico opinions naming this issue, 2010–2011
2 sentences

2011See Int'l Ass'n of Firefighters v. City of Carlsbad, 2009-NMCA-097, ¶ 11 , 147 N.M. 6 , 216 P.3d 256 ("We seek to give meaning to all parts of the statute, such that no portion is rendered surplusage or meaningless."), cert. denied, 2009-NMCERT-007 , 147 N.M. 363 , 223 P.3d 360 . {15} Indeed, if we were to read Subsection (L) as Petitioner requests, granting a nonadoptive or non-natural parent standing to bring a custody claim, we would be rendering meaningless the Legislature's limitation of standing to adoptive and natural parents.

2010See Int’l Ass’n of Firefighters v. City of Carlsbad, 2009-NMCA-097, ¶ 11 , 147 N.M. 6 , 216 P.3d 256 (“We seek to give meaning to all parts of the statute, such that no portion is rendered surplusage or meaningless.”), cert. denied, 2009-NMCERT-007 , 147 N.M. 363 , 223 P.3d 360 . {15} Indeed, if we were to read Subsection (L) as Petitioner requests, granting a non-adoptive or non-natural parent standing to bring a custody claim, we would be rendering meaningless the Legislature’s limitation of standing to adoptive and natural parents.

22
State v. Munozgreen
nm · 1998 · cited in 2 New Mexico opinions naming this issue, 2021–2024
2 sentences

2024See Munoz, 1998-NMSC-048, ¶¶ 8, 43-44 (citing Oregon v. Mathiason, 429 U.S. 492, 495 (1977)) (noting in the factual background section the defendant’s allegation that the agent raised his voice but not factoring it into the custody analysis, and holding that where the defendant voluntarily went to the police station, was informed that he could leave at any time, was not handcuffed, and left without hindrance, the defendant’s freedom of movement was not restrained in any way associated with a formal arrest, and “[a]ny interview of one suspected of a crime by a police officer will have coercive

2021The following factors guide our inquiry: “the purpose, place, and length of interrogation[,] . . . the extent to which the defendant is confronted with evidence of guilt, the physical surroundings of the interrogation, the duration of the detention, and the degree of pressure applied to the defendant.” State v. Munoz, 1998-NMSC-048, ¶ 40 , 126 N.M. 535 , 972 P.2d 847 (internal quotation marks and citation omitted). {21} Defendant drove to the sheriff’s department on his own accord for the purpose of discussing the burglary of his trailer with Detective Babadi.

12
State v. Wilsongreen
nmctapp · 2007 · cited in 2 New Mexico opinions naming this issue, 2009–2021
2 sentences

2021Rather, we consider how “a reasonable man in the suspect’s position would have understood his situation.” Id. (internal quotation marks and citation omitted). {20} In the event that there is no formal arrest prior to questioning, “our appellate courts engage in a fact-specific analysis of the totality of the circumstances under which the questioning took place in order to decide whether the custody requirement is met.” State v. Olivas, 2011-NMCA-030, ¶ 10 , 149 N.M. 498 , 252 P.3d 722 .

2009See generally State v. Wilson, 2007-NMCA-111, ¶ 23 , 142 N.M. 737 , 169 P.3d 1184 (explaining that, in assessing whether an individual was in custody for Miranda purposes, “the court must apply an objective test to resolve the ultimate inquiry: was there a formal arrest or restraint of freedom of movement of the degree associated with a formal arrest” (internal quotation marks and citation omitted)), cert. denied, 2007-NMCERT-008 , 142 N.M. 435 , 166 P.3d 1089 .

12
Oregon v. Mathiasongreen
scotus · 1977 · cited in 1 New Mexico opinions naming this issue, 2024–2024
1 sentence

2024See Munoz, 1998-NMSC-048, ¶¶ 8, 43-44 (citing Oregon v. Mathiason, 429 U.S. 492, 495 (1977)) (noting in the factual background section the defendant’s allegation that the agent raised his voice but not factoring it into the custody analysis, and holding that where the defendant voluntarily went to the police station, was informed that he could leave at any time, was not handcuffed, and left without hindrance, the defendant’s freedom of movement was not restrained in any way associated with a formal arrest, and “[a]ny interview of one suspected of a crime by a police officer will have coercive

11
Misquez v. Bacagreen
nmctapp · 2002 · cited in 1 New Mexico opinions naming this issue, 2022–2022
1 sentence

2022In In re Byrnes, 2002-NMCA-102, ¶¶ 1, 3-7 , 132 N.M. 718 , 54 P.3d 996 , this Court affirmed a $1,000 contempt fine imposed on an attorney who continually interrupted and argued with the district court judge during a custody hearing, despite several admonitions to stop. {30} In another illustrative case, In re Cherryhomes, an attorney was summarily held in contempt after he became combative and belligerent. 1985-NMCA-108 , ¶ 3, 103 N.M. 771 , 714 P.2d 188 .

11
State v. Bravogreen
nmctapp · 2005 · cited in 1 New Mexico opinions naming this issue, 2013–2013
1 sentence

2013Therefore, we must “engage in a fact-specific 20 analysis of the totality of the circumstances under which the questioning took place 3 1 in order to decide whether the custody requirement is met.” State v. Olivas, 2011- 2 NMCA-030, ¶ 10, 149 N.M. 498 , 252 P.3d 722 . 3 {7} We have previously identified several factors to consider when determining 4 whether a reasonable person would believe he is free to leave, including “the purpose, 5 place, and length of interrogation[,] . . . the extent to which the defendant is 6 confronted with evidence of guilt, the physical surroundings of the interrog

11
State v. Figueroagreen
nm · 2010 · cited in 1 New Mexico opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., State v. Smile, 2009-NMCA-064, ¶ 27 , 146 N.M. 525 , 212 P.3d 413 , cert. quashed, 2010-NMCERT-006 , 148 N.M. 584 , 241 P.3d 182 .

11
State v. SMILEgreen
nm · 2010 · cited in 1 New Mexico opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., State v. Smile, 2009-NMCA-064, ¶ 27 , 146 N.M. 525 , 212 P.3d 413 , cert. quashed, 2010-NMCERT-006 , 148 N.M. 584 , 241 P.3d 182 .

11
State v. Montoyagreen
nm · 2010 · cited in 1 New Mexico opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., State v. Smile, 2009-NMCA-064, ¶ 27 , 146 N.M. 525 , 212 P.3d 413 , cert. quashed, 2010-NMCERT-006 , 148 N.M. 584 , 241 P.3d 182 .

11
Heilman v. Heilmangreen
kan · 1957 · cited in 1 New Mexico opinions naming this issue, 1981–1981
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (13)

CaseCitedYears
State Ex Rel. Children, Youth & Families Department v. Marlene C. green
nm · 2011
2 sentences

2015In re Esther V., 11 2011-NMSC-005, ¶ 27 ; § 32A-4-18(A), (D).

2015In re Esther V., 2011-NMSC-005, ¶ 27 ; § 32A-4-18(A), (D).

22015–2015
Coppler & Mannick, P.C. v. Wakeland green
nm · 2005
2 sentences

2011Coppler & Mannick, P.C., 2005-NMSC-022, ¶ 8 , 138 N.M. 108 , 117 P.3d 914 .

2011Coppler & Mannick, P.C., 2005-NMSC-022, ¶ 8 , 138 N.M. 108 , 117 P.3d 914 .

22010–2011
In Re Summary Contempt Proceedings Against Cherryhomes green
nmctapp · 1985
2 sentences

2022In In re Byrnes, 2002-NMCA-102, ¶¶ 1, 3-7 , 132 N.M. 718 , 54 P.3d 996 , this Court affirmed a $1,000 contempt fine imposed on an attorney who continually interrupted and argued with the district court judge during a custody hearing, despite several admonitions to stop. {30} In another illustrative case, In re Cherryhomes, an attorney was summarily held in contempt after he became combative and belligerent. 1985-NMCA-108 , ¶ 3, 103 N.M. 771 , 714 P.2d 188 .

2022In In re Byrnes, 2002-NMCA-102, ¶¶ 1, 3-7 , 132 N.M. 718 , 54 P.3d 996 , this Court affirmed a $1,000 contempt fine imposed on an attorney who continually interrupted and argued with the district court judge during a custody hearing, despite several admonitions to stop. {30} In another illustrative case, In re Cherryhomes, an attorney was summarily held in contempt after he became combative and belligerent. 1985-NMCA-108 , ¶ 3, 103 N.M. 771 , 714 P.2d 188 .

12022–2022
State v. Hoeffel green
nmctapp · 1991
2 sentences

2022Cf. State v. Hoeffel, 1991-NMCA-070 , ¶ 5, 112 N.M. 358 , 815 P.2d 654 (“As a general rule, collateral estoppel, in either a criminal or a civil context, does not bind one who was not a party in the prior action.”).

2022Cf. State v. Hoeffel, 1991-NMCA-070 , ¶ 5, 112 N.M. 358 , 815 P.2d 654 (“As a general rule, collateral estoppel, in either a criminal or a civil context, does not bind one who was not a party in the prior action.”).

12022–2022
In Re Byrnes green
nmctapp · 2002
2 sentences

2022In In re Byrnes, 2002-NMCA-102, ¶¶ 1, 3-7 , 132 N.M. 718 , 54 P.3d 996 , this Court affirmed a $1,000 contempt fine imposed on an attorney who continually interrupted and argued with the district court judge during a custody hearing, despite several admonitions to stop. {30} In another illustrative case, In re Cherryhomes, an attorney was summarily held in contempt after he became combative and belligerent. 1985-NMCA-108 , ¶ 3, 103 N.M. 771 , 714 P.2d 188 .

2022In In re Byrnes, 2002-NMCA-102, ¶¶ 1, 3-7 , 132 N.M. 718 , 54 P.3d 996 , this Court affirmed a $1,000 contempt fine imposed on an attorney who continually interrupted and argued with the district court judge during a custody hearing, despite several admonitions to stop. {30} In another illustrative case, In re Cherryhomes, an attorney was summarily held in contempt after he became combative and belligerent. 1985-NMCA-108 , ¶ 3, 103 N.M. 771 , 714 P.2d 188 .

12022–2022
Alfieri v. Alfieri green
nmctapp · 1987
2 sentences

2018Cf. Alfieri v. Alfieri, 1987-NMCA-003 , ¶ 27, 105 N.M. 373 , 733 P.2d 4 (explaining that it has been “recognized that a custodial parent’s demonstrated lack of cooperation [with the other parent] and refusal to follow prior court orders concerning visitation may constitute grounds for a change of custody in an extreme case” (emphasis added)). 16 1 decided by . . . allocating ultimate responsibility for a particular major decision 2 area to one legal custodian”). 3 {23} Moreover, we note that other aspects of Lombardo’s recommendations 4 further support the interpretation that what Lombardo was

2018Cf. Alfieri v. Alfieri, 1987-NMCA-003 , ¶ 27, 105 N.M. 373 , 733 P.2d 4 (explaining that it has been “recognized that a custodial parent’s demonstrated lack of cooperation [with the other parent] and refusal to follow prior court orders concerning visitation may constitute grounds for a change of custody in an extreme case” (emphasis added)). 16 1 decided by . . . allocating ultimate responsibility for a particular major decision 2 area to one legal custodian”). 3 {23} Moreover, we note that other aspects of Lombardo’s recommendations 4 further support the interpretation that what Lombardo was

12018–2018
Schuermann v. Schuermann green
nm · 1980
2 sentences

2017Accordingly, we hold that any modification or 7 change from the stipulated interim order required a showing of a “substantial and 8 material change in circumstances.” See Schuermann v. Schuermann, 1980-NMSC- 9 027, ¶¶ 4, 7, 94 N.M. 81 , 607 P.2d 619 (stating that there is a strong presumption in 10 favor of the original custody arrangement, and the party seeking to alter the status quo 11 bears the burden of proving a change in circumstances). 12 {26} The district court in this case did not consider whether there was a substantial 13 and material change in circumstances affecting the best inte

2017Accordingly, we hold that any modification or 7 change from the stipulated interim order required a showing of a “substantial and 8 material change in circumstances.” See Schuermann v. Schuermann, 1980-NMSC- 9 027, ¶¶ 4, 7, 94 N.M. 81 , 607 P.2d 619 (stating that there is a strong presumption in 10 favor of the original custody arrangement, and the party seeking to alter the status quo 11 bears the burden of proving a change in circumstances). 12 {26} The district court in this case did not consider whether there was a substantial 13 and material change in circumstances affecting the best inte

12017–2017
State v. Tran green
nmctapp · 2008
1 sentence

2013Cal. Dec. 30, 2010) (recognizing a shared view, among courts that have considered the issue, that “the collateral immigration consequences 1 We note that in Tran, 2009-NMCA-010, ¶ 17 , this Court concluded that a Rule 1- 060(B)(4) motion was the correct procedural mechanism for the defendant to request relief.

12013–2013
Wachter v. Wachter green
lactapp · 1983
1 sentence

2011Id. at 8 1264.

12011–2011
State v. Wilson neutral
nm · 2007
1 sentence

2009See generally State v. Wilson, 2007-NMCA-111, ¶ 23 , 142 N.M. 737 , 169 P.3d 1184 (explaining that, in assessing whether an individual was in custody for Miranda purposes, “the court must apply an objective test to resolve the ultimate inquiry: was there a formal arrest or restraint of freedom of movement of the degree associated with a formal arrest” (internal quotation marks and citation omitted)), cert. denied, 2007-NMCERT-008 , 142 N.M. 435 , 166 P.3d 1089 .

12009–2009
State v. Marquez neutral
nm · 2007
1 sentence

2009See generally State v. Wilson, 2007-NMCA-111, ¶ 23 , 142 N.M. 737 , 169 P.3d 1184 (explaining that, in assessing whether an individual was in custody for Miranda purposes, “the court must apply an objective test to resolve the ultimate inquiry: was there a formal arrest or restraint of freedom of movement of the degree associated with a formal arrest” (internal quotation marks and citation omitted)), cert. denied, 2007-NMCERT-008 , 142 N.M. 435 , 166 P.3d 1089 .

12009–2009
State ex rel. Children, Youth & Families Department green
nmctapp · 2001
1 sentence

2008Children, Youth & Families Department v. Michelle B., 2001-NMCA-071 , 130 N.M. 781 , 32 P.3d 790 , in order to make her first point.

12008–2008
In Re State Ex Rel. Cyfd green
nmctapp · 2001
2 sentences

2008Children, Youth & Families Department v. Michelle B., 2001-NMCA-071 , 130 N.M. 781 , 32 P.3d 790 , in order to make her first point.

2008Children, Youth & Families Department v. Michelle B., 2001-NMCA-071 , 130 N.M. 781 , 32 P.3d 790 , in order to make her first point.

12008–2008

Statutes the citing opinions construe

NM § N.M. Stat. § 32A-4-1 (5) NM § N.M. Stat. § 32A-4-2 (5) NM § N.M. Stat. § 32A-4-22 (5) NM § N.M. Stat. § 32A-4-15 (4) NM § N.M. Stat. § 32A-4-16 (4) NM § N.M. Stat. § 32A-4-18 (4) NM § N.M. Stat. § 32A-4-19 (4) NM § N.M. Stat. § 32A-4-20 (4) NM § N.M. Stat. § 40-4-7 (4) NM § N.M. Stat. § 40-4-9 (4) NM § N.M. Stat. § 40-4-9.1 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 324 (1961–2026) NY 102 (1977–2026) AL 91 (1996–2026) IL 69 (1968–2025) CA 61 (1948–2024) OH 60 (1997–2026) MI 53 (1958–2026) TX 42 (1990–2026) NC 40 (1978–2024) MD 35 (1970–2025) LA 34 (1972–2020) CT 34 (1982–2026) IN 31 (1990–2026) NJ 30 (1953–2026) UT 23 (1980–2026) CO 23 (1970–2026) NM 23 (1981–2025) FL 20 (1975–2017) MS 20 (1995–2026) DC 17 (1978–2016) VA 17 (1993–2026) TN 16 (1990–2024) MT 15 (1977–2012) NV 15 (1972–2025) MA 15 (1990–2025) WA 14 (1951–2026) VT 14 (1990–2025) NE 14 (1979–2025) GA 13 (1962–2024) AK 13 (1981–2020) WI 13 (1962–2026) MN 12 (1985–2026) MO 11 (1980–2018) SC 10 (1993–2021) IA 10 (2004–2023) ME 9 (1998–2022) KS 9 (2007–2025) KY 8 (2006–2025) ND 8 (1991–2003) DE 8 (1995–2026) AR 7 (1981–2019) HI 7 (1996–2022) SD 7 (1982–2022) AZ 7 (1994–2026) ID 7 (1969–2022) NH 7 (1999–2023) RI 6 (1997–2022) WY 6 (1998–2022) OR 4 (1987–2005) WV 3 (1968–2019) OK 2 (1977–2004)

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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