part performance doctrine in Washington

23 Washington opinions name it 2 courts 1925–2022 1 in the last five years

The cases below were cited by Washington 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 (5)

Case	Followed	Cited
Berg v. Tinggreen wash · 1995 · cited in 10 Washington opinions naming this issue, 1996–2018 2 sentences 1996Those factors are: (1) delivery and assumption of actual and exclusive possession; (2) payment or tender of consideration; and (3) the making of permanent, substantial and valuable improvements Berg, 125 Wn.2d at 556 (quoting Kruse v. Hemp, 121 Wn.2d 715, 724-25 , 853 P.2d 1373 (1993)). 7 The court held that application of section 129 "would run counter to the eviden-tiary function underlying this state’s part performance doctrine.” Berg, 125 Wn.2d at 561 . 1996Those factors are: (1) delivery and assumption of actual and exclusive possession; (2) payment or tender of consideration; and (3) the making of permanent, substantial and valuable improvements Berg, 125 Wn.2d at 556 (quoting Kruse v. Hemp, 121 Wn.2d 715, 724-25 , 853 P.2d 1373 (1993)). 7 The court held that application of section 129 "would run counter to the eviden-tiary function underlying this state’s part performance doctrine.” Berg, 125 Wn.2d at 561 .	3	10
Miller v. McCamishgreen wash · 1971 · cited in 6 Washington opinions naming this issue, 1995–2022 2 sentences 2022The equitable doctrine of part performance “prevents a party from asserting the invalidity of a contract where the other party has acted in conformity with the contract and thus placed himself in a position where it would be intolerable in equity to deny its enforcement.” Id. at 643- 44 (citing Miller, 78 Wn.2d at 827 ). 2022To apply the doctrine of part performance, we look to three factors, “ ‘(1) delivery and assumption of actual and exclusive possession of the land, (2) payment or tender of the consideration, whether in money or property or services, and (3) the making of permanent, substantial and valuable improvements, referable to the contract.’ ” Id. at 644 (quoting Powers, 20 Wn.	1	6
Richardson v. Taylor Land & Livestock Co.green wash · 1946 · cited in 2 Washington opinions naming this issue, 1993–1995 2 sentences 1993Finally, we address the Tings' contention that the part performance doctrine is unavailable to the Bergs based on the proposition stated in Richardson that " '[i]n every case where the doctrine of part performance has been applied, the elements of a constructive fraud will be found to exist, and in the absence of these elements equity always refuses to interfere." 25 Wn.2d at 528 (quoting J. 1993Finally, we address the Tings' contention that the part performance doctrine is unavailable to the Bergs based on the proposition stated in Richardson that " '[i]n every case where the doctrine of part performance has been applied, the elements of a constructive fraud will be found to exist, and in the absence of these elements equity always refuses to interfere." 25 Wn.2d at 528 (quoting J.	1	2
Corson Corp. v. Frontier, Inc.green wash · 1960 · cited in 1 Washington opinions naming this issue, 1998–1998 2 sentences 1998See, e.g., Corson Corp. v. Frontier, Inc., 55 Wash.2d 652 , 830 654-55, 349 P.2d 424 (1960); Cal. Civ.Code § 1698. 1998See, e.g., Corson Corp. v. Frontier, Inc., 55 Wash.2d 652 , 830 654-55, 349 P.2d 424 (1960); Cal. Civ.Code § 1698.	1	1
Kirk v. Tomultygreen washctapp · 1992 · cited in 1 Washington opinions naming this issue, 1993–1993 1 sentence 1993See Kirk v. Tomulty, 66 Wn.	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (29)

Case	Cited	Years
Dewberry v. George neutral washctapp · 2003 2 sentences 2018App. 351, 361 , 62 P.3d 525 (2003). 3 No. 75965-5-1/4 To satisfy the doctrine of part performance, there must be clear and unequivocal evidence that leaves no doubt as to the terms, character, or existence of the contract. 2015App. 351, 361-62 , 62 P.3d 525 (2003) (quoting Granquist v. McKean, 29 Wn.2d 440, 445 , 187 P.2d 623 (1947)).	3	2015–2018
Granquist v. McKean green wash · 1947 2 sentences 2015App. 351, 361-62 , 62 P.3d 525 (2003) (quoting Granquist v. McKean, 29 Wn.2d 440, 445 , 187 P.2d 623 (1947)). 2015App. 351, 361-62 , 62 P.3d 525 (2003) (quoting Granquist v. McKean, 29 Wn.2d 440, 445 , 187 P.2d 623 (1947)).	2	2015–2015
In re the Marriage of DewBerry green washctapp · 2003 2 sentences 2015Unwritten or unsigned agreements are saved under the doctrine of part performance when ( 1) the contract is proven by clear, cogent, and convincing evidence; and ( 2) the acts constituting part performance " unmistakably point to the existence of the claimed agreement." In re Marriage ofDewBerry, 115 Wn. 2015Unwritten or unsigned agreements are saved under the doctrine of part performance when (1) the contract is proven by clear, cogent, and convincing evidence and (2) the acts constituting part performance ‘“unmistakably point to the existence of the claimed agreement.’ ” In re Marriage of DewBerry, 115 Wn.	2	2015–2015
Kruse v. Hemp green wash · 1993 2 sentences 1996Those factors are: (1) delivery and assumption of actual and exclusive possession; (2) payment or tender of consideration; and (3) the making of permanent, substantial and valuable improvements Berg, 125 Wn.2d at 556 (quoting Kruse v. Hemp, 121 Wn.2d 715, 724-25 , 853 P.2d 1373 (1993)). 7 The court held that application of section 129 "would run counter to the eviden-tiary function underlying this state’s part performance doctrine.” Berg, 125 Wn.2d at 561 . 1996Those factors are: (1) delivery and assumption of actual and exclusive possession; (2) payment or tender of consideration; and (3) the making of permanent, substantial and valuable improvements Berg, 125 Wn.2d at 556 (quoting Kruse v. Hemp, 121 Wn.2d 715, 724-25 , 853 P.2d 1373 (1993)). 7 The court held that application of section 129 "would run counter to the eviden-tiary function underlying this state’s part performance doctrine.” Berg, 125 Wn.2d at 561 .	2	1995–1996
Union Savings & Trust Co. v. Krumm neutral wash · 1915 2 sentences 1975We are persuaded that the better-reasoned cases followed the rule as stated in Union Sav. & Trust Co. v. Krumm, 88 Wash. 20, 33 , 152 P. 681 (1915): The doctrine of part performance, however, has no application to this clause [which declares void every oral contract not to be performed within 1 year] of the statute of frauds. 1975We are persuaded that the better-reasoned cases followed the rule as stated in Union Sav. & Trust Co. v. Krumm, 88 Wash. 20, 33 , 152 P. 681 (1915): The doctrine of part performance, however, has no application to this clause [which declares void every oral contract not to be performed within 1 year] of the statute of frauds.	2	1925–1975
Powers v. Hastings green washctapp · 1978 2 sentences 2022The equitable doctrine of part performance “prevents a party from asserting the invalidity of a contract where the other party has acted in conformity with the contract and thus placed himself in a position where it would be intolerable in equity to deny its enforcement.” Id. at 643- 44 (citing Miller, 78 Wn.2d at 827 ). 2022To apply the doctrine of part performance, we look to three factors, “ ‘(1) delivery and assumption of actual and exclusive possession of the land, (2) payment or tender of the consideration, whether in money or property or services, and (3) the making of permanent, substantial and valuable improvements, referable to the contract.’ ” Id. at 644 (quoting Powers, 20 Wn.	1	2022–2022
Losh Family, LLC v. Kertsman green washctapp · 2010 1 sentence 2018Miller v. McCamish, 78 Wn.2d 821, 829 , 479 P.2d 919 (1971); Losh Family, LLC v. Kertsman, 155 Wn.	1	2018–2018
Goulding v. Cook green mass · 1996 1 sentence 2008Order of Odd Fellows, 269 Or. 174, 185 , 523 P.2d 1018 (Or. 1974) (encroachment of nine inches, no mandatory injunction where no substantial damages); cf. Goulding v. Cook, 422 Mass. 276, 279-80 , 661 N.E.2d 1322 (Mass. 1996) (while Massachusetts courts will not enjoin "truly minimal encroachments," injunction to remove septic system taking up a "spatially significant portion of the plaintiffs' lot" was upheld). [8] Under the doctrine of part performance, a court may specifically enforce an oral agreement to convey an estate in real property if there is sufficient part performance of the agree	1	2008–2008
Zerr v. HECETA LODGE NO. 111, IND. ORDER OF ODD F. green or · 1974 2 sentences 2008Order of Odd Fellows, 269 Or. 174, 185 , 523 P.2d 1018 (Or. 1974) (encroachment of nine inches, no mandatory injunction where no substantial damages); cf. Goulding v. Cook, 422 Mass. 276, 279-80 , 661 N.E.2d 1322 (Mass. 1996) (while Massachusetts courts will not enjoin "truly minimal encroachments," injunction to remove septic system taking up a "spatially significant portion of the plaintiffs' lot" was upheld). [8] Under the doctrine of part performance, a court may specifically enforce an oral agreement to convey an estate in real property if there is sufficient part performance of the agree 2008Order of Odd Fellows, 269 Or. 174, 185 , 523 P.2d 1018 (Or. 1974) (encroachment of nine inches, no mandatory injunction where no substantial damages); cf. Goulding v. Cook, 422 Mass. 276, 279-80 , 661 N.E.2d 1322 (Mass. 1996) (while Massachusetts courts will not enjoin "truly minimal encroachments," injunction to remove septic system taking up a "spatially significant portion of the plaintiffs' lot" was upheld). [8] Under the doctrine of part performance, a court may specifically enforce an oral agreement to convey an estate in real property if there is sufficient part performance of the agree	1	2008–2008
Dunbabin v. ALLEN REALTY COMPANY neutral washctapp · 1980 2 sentences 1995Stephens v. Nelson, 37 Wn.2d 28, 35 , 221 P.2d 520 (1950) (later the conclusion in Stephens that a description is defective if it omits the county and state was reversed in Lofberg v. Viles, supra ); Dunbabin v. Allen Realty Co., 26 Wn. 1995Stephens v. Nelson, 37 Wn.2d 28, 35 , 221 P.2d 520 (1950) (later the conclusion in Stephens that a description is defective if it omits the county and state was reversed in Lofberg v. Viles, supra); Dunbabin v. Allen Realty Co., 26 Wn.	1	1995–1995
Herrmann v. Hodin green wash · 1961 2 sentences 1995Herrmann v. Hodin, 58 Wn.2d 441 , 364 P.2d 21 (1961), cited in Howell, at 496. 1995Herrmann v. Hodin, 58 Wn.2d 441 , 364 P.2d 21 (1961), cited in Howell, at 496.	1	1995–1995
Stephens v. Nelson neutral wash · 1950 2 sentences 1995Stephens v. Nelson, 37 Wn.2d 28, 35 , 221 P.2d 520 (1950) (later the conclusion in Stephens that a description is defective if it omits the county and state was reversed in Lofberg v. Viles, supra ); Dunbabin v. Allen Realty Co., 26 Wn. 1995Stephens v. Nelson, 37 Wn.2d 28, 35 , 221 P.2d 520 (1950) (later the conclusion in Stephens that a description is defective if it omits the county and state was reversed in Lofberg v. Viles, supra ); Dunbabin v. Allen Realty Co., 26 Wn.	1	1995–1995
Powers v. Hastings green wash · 1980 2 sentences 1995Kruse v. Hemp, 121 Wn.2d 715, 724-25 , 853 P.2d 1373 (1993); Powers v. Hastings, 93 Wn.2d 709, 717 , 612 P.2d 371 (1980). 1995Kruse v. Hemp, 121 Wn.2d 715, 724-25 , 853 P.2d 1373 (1993); Powers v. Hastings, 93 Wn.2d 709, 717 , 612 P.2d 371 (1980).	1	1995–1995
Garbrick v. Franz green wash · 1942 2 sentences 1995In Garbrick v. Franz, 13 Wn.2d 427, 431 , 125 P.2d 295 (1942), also cited by the Court of Appeals, the court said that the test for the part performance exception is: "Have the acts of one of the parties changed his situation to such an extent that he cannot be adequately compensated in damages or placed in his original position?" This language must not be read out of context, though. 1995In Garbrick v. Franz, 13 Wn.2d 427, 431 , 125 P.2d 295 (1942), also cited by the Court of Appeals, the court said that the test for the part performance exception is: "Have the acts of one of the parties changed his situation to such an extent that he cannot be adequately compensated in damages or placed in his original position?" This language must not be read out of context, though.	1	1995–1995
Labor Hall Ass'n, Inc. v. Danielsen green wash · 1945 2 sentences 1984In response, Milne cites Labor Hall Ass'n v. Danielsen, 24 Wn.2d 75 , 163 P.2d 167 , 161 A.L.R. 1079 (1945) for the argument that more than payment of rent is required to utilize the doctrine of part performance. 1984In response, Milne cites Labor Hall Ass'n v. Danielsen, 24 Wn.2d 75 , 163 P.2d 167 , 161 A.L.R. 1079 (1945) for the argument that more than payment of rent is required to utilize the doctrine of part performance.	1	1984–1984
McKay v. Calderwood neutral wash · 1905 2 sentences 1946In McKay v. Calderwood, 37 Wash. 194 , 79 Pac. 629 , this court recognized as true the statement made by Mr. Pomeroy in his work on Specific Performance of Contracts (3d ed.) 255, § 106, that “In every case where the doctrine of part performance has been applied, the elements of a constructive fraud will be found to exist, and in the absence of these elements equity always refuses to interfere. 1946In McKay v. Calderwood, 37 Wash. 194 , 79 Pac. 629 , this court recognized as true the statement made by Mr. Pomeroy in his work on Specific Performance of Contracts (3d ed.) 255, § 106, that “In every case where the doctrine of part performance has been applied, the elements of a constructive fraud will be found to exist, and in the absence of these elements equity always refuses to interfere.	1	1946–1946
Iturrino v. Iturrino green prsupreme · 1916 1 sentence 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am.	1	1945–1945
McGlauflin v. Holman green wash · 1890 1 sentence 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am.	1	1945–1945
Schulte v. Schering neutral wash · 1891 2 sentences 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am. 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am.	1	1945–1945
Dorman v. Plowman green wash · 1906 2 sentences 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am. 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am.	1	1945–1945
O'Connor v. Oliver neutral wash · 1907 2 sentences 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am. 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am.	1	1945–1945
Northcraft v. Blumauer neutral wash · 1909 2 sentences 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am. 1945We have recognized the equitable doctrine above mentioned, and we are entirely in accord with the following decisions of this court, cited by appellant, where that doctrine was invoked: McGlauflin v. Holman, 1 Wash. 239 , 24 Pac. 439 ; Schulte v. Schering, 2 Wash. 127 , 26 Pac. 78 ; Dorman v. Plowman, 41 Wash. 477 , 83 Pac. 322 ; O’Connor v. Oliver, 45 Wash. 549 , 88 Pac. 1025 ; Northcraft v. Blumauer, 53 Wash. 243 , 101 Pac. 871 , 132 Am.	1	1945–1945
Wolfe v. Wallingford Bank & Trust Co. green conn · 1937 2 sentences 1941The decisions in all the States which have had occasion to determine the question, with one exception (Georgia), hold in effect that the doctrine of part performance, being purely equitable, is not recognized in actions at, law and is not available in such actions to recover damages for breach of a contract within the statute of frauds.” Wolfe v. Wallingford Bank & Trust Co., 122 Conn. 507 , 191 Atl. 88 . 1941The decisions in all the States which have had occasion to determine the question, with one exception (Georgia), hold in effect that the doctrine of part performance, being purely equitable, is not recognized in actions at, law and is not available in such actions to recover damages for breach of a contract within the statute of frauds.” Wolfe v. Wallingford Bank & Trust Co., 122 Conn. 507 , 191 Atl. 88 .	1	1941–1941
Arrillaga v. Registrar of Property of Bayamón green prsupreme · 1956	1	1941–1941
Chamberlain v. Abrams green wash · 1905 1 sentence 1941R. 1305, which cites and discusses a great number of decisions to that effect: “It appears to be the general rule that the doctrine of part performance is purely an equitable doctrine, unrecognized at law, and accordingly will not sustain an action at law based on a contract within the Statute of Frauds.” This statement is followed by a citation of a long list of decisions, including two decisions of this court: Johnson v. Upper, 38 Wash. 693 , 80 Pac. 801 , and Chamberlain v. Abrams, 36 Wash. 587 , 79 Pac. 204 .	1	1941–1941
Johnson v. Upper neutral wash · 1905 2 sentences 1941R. 1305, which cites and discusses a great number of decisions to that effect: “It appears to be the general rule that the doctrine of part performance is purely an equitable doctrine, unrecognized at law, and accordingly will not sustain an action at law based on a contract within the Statute of Frauds.” This statement is followed by a citation of a long list of decisions, including two decisions of this court: Johnson v. Upper, 38 Wash. 693 , 80 Pac. 801 , and Chamberlain v. Abrams, 36 Wash. 587 , 79 Pac. 204 . 1941R. 1305, which cites and discusses a great number of decisions to that effect: “It appears to be the general rule that the doctrine of part performance is purely an equitable doctrine, unrecognized at law, and accordingly will not sustain an action at law based on a contract within the Statute of Frauds.” This statement is followed by a citation of a long list of decisions, including two decisions of this court: Johnson v. Upper, 38 Wash. 693 , 80 Pac. 801 , and Chamberlain v. Abrams, 36 Wash. 587 , 79 Pac. 204 .	1	1941–1941
Lamken v. Miller green wash · 1935	1	1935–1935
Keith v. Smith neutral wash · 1907	1	1925–1925
Thill v. Johnston neutral wash · 1910	1	1925–1925

Statutes the citing opinions construe

WA § Wash. Rev. Code § 64.04.010 (11) WA § Wash. Rev. Code § 64.04.020 (7) WA § Wash. Rev. Code § 19.36.010 (4) WA § Wash. Rev. Code § 2.06.040 (3) WA § Wash. Rev. Code § 59.04.010 (3) WA § Wash. Rev. Code § 59.18.210 (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

NY 55 (1951–2025) WA 23 (1925–2022) CT 20 (1981–2014) OH 19 (1981–2025) AL 18 (1942–2011) ID 17 (1982–2023) IN 16 (1892–2025) UT 13 (1977–2022) ME 12 (2004–2020) MO 11 (1891–2025) AZ 11 (1977–2025) FL 9 (1974–2024) MI 9 (1917–2023) MD 9 (1939–1998) IL 8 (1986–2025) CA 8 (1930–2024) ND 7 (1903–2021) CO 7 (1983–2005) MN 6 (1909–2016) SC 6 (1984–2022) PA 6 (1982–2026) TN 6 (1983–2011) OR 6 (1975–2008) WI 5 (1945–2024) RI 5 (1991–2011) TX 5 (1967–2015) IA 5 (1939–2014) NC 5 (1920–2010) WY 4 (1993–2012) VA 4 (1851–2005) MT 3 (1926–2017) SD 3 (1912–2018) NJ 3 (1986–2013) DC 3 (1984–1998) NH 3 (2008–2017) DE 3 (1975–2019) VT 3 (1986–2015) GA 2 (2019–2022) KS 2 (1930–2018) KY 2 (1935–1947) NV 2 (1985–2018) NM 2 (2010–2021) VI 2 (1977–2025)

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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