second prong test (Colorado) · Go Syfert
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second prong test in Colorado

22 Colorado opinions name it 2 courts 1971–2025 4 in the last five years

The cases below were cited by Colorado 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 (20)

CaseFollowedCited
Strickland v. Washingtongreen
scotus · 1984 · cited in 4 Colorado opinions naming this issue, 2020–2025
2 sentences

2025To satisfy the second prong of the test, the defendant must show that “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id. at 694 . ¶ 13 Defense counsel is not simply “the alter-ego or mouthpiece of the accused, but is a trained advocate charged with representing an accused.” People v. Schultheis, 638 P.2d 8, 12 (Colo. 1981).

2024See Strickland v. Washington, 466 U.S. 668, 687 (1984). ¶ 16 In assessing the first prong of the Strickland test, we must “indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance; that is, the defendant must overcome the presumption that, under the circumstances, the challenged action ‘might be considered sound 6 trial strategy.’” Id. at 689 (quoting Michel v. Louisiana, 350 U.S. 91, 101 (1955)); see also Le v. Mullin, 311 F.3d 1002, 1025 (10th Cir. 2002) (“For counsel’s performance to be constitutionally ineffective, it must have b

24
Hill v. Lockhartgreen
scotus · 1985 · cited in 2 Colorado opinions naming this issue, 2016–2016
2 sentences

2016See id. at 294 (quoting Hill, 474 U.S. at 59 , 106 S.Ct. 366 ).

2016See id. at 294 (quoting Hill, 474 U.S. at 59).

22
Ferrara v. United Statesgreen
ca1 · 2006 · cited in 2 Colorado opinions naming this issue, 2016–2016
2 sentences

2016Both sides in this case also draw our attention to Ferrara v. United States, 456 F.3d 278, 290 (ist Cir. 2006), which established that a defendant can show his plea was involuntary under Brady v. United States, 397 U.S. 742 , 90 S.Ct. 1463 , 25 L:Ed.2d 747 (1970), if he shows (1) "some egregiously impermissible conduct ... antedated the entry of his plea," and (2) "the misconduct influenced his decision to plead guilty or, put another way, that it was material to that choice." The Ferrara court made clear that the second prong of this test requires the same analysis as ineffective-assistance c

2016The difference now is that things that we did, things that were said, you know things that were between us became not between us and I understand the reasons for that but what’s to stop that from happening in the future[?]” Before hanging up, Corson said “I love you.” 5 Both sides in this case also draw our attention to Ferrara v. United States, 456 F.3d 278, 290 (1st Cir. 2006), which established that a defendant can show his plea was involuntary under Brady v. United States, 397 U.S. 742 (1970), if he shows (1) “some egregiously impermissible conduct . . . antedated the entry of his plea,” a

22
Brady v. United Statesgreen
scotus · 1970 · cited in 2 Colorado opinions naming this issue, 2016–2016
2 sentences

2016Both sides in this case also draw our attention to Ferrara v. United States, 456 F.3d 278, 290 (ist Cir. 2006), which established that a defendant can show his plea was involuntary under Brady v. United States, 397 U.S. 742 , 90 S.Ct. 1463 , 25 L:Ed.2d 747 (1970), if he shows (1) "some egregiously impermissible conduct ... antedated the entry of his plea," and (2) "the misconduct influenced his decision to plead guilty or, put another way, that it was material to that choice." The Ferrara court made clear that the second prong of this test requires the same analysis as ineffective-assistance c

2016The difference now is that things that we did, things that were said, you know things that were between us became not between us and I understand the reasons for that but what’s to stop that from happening in the future[?]” Before hanging up, Corson said “I love you.” 5 Both sides in this case also draw our attention to Ferrara v. United States, 456 F.3d 278, 290 (1st Cir. 2006), which established that a defendant can show his plea was involuntary under Brady v. United States, 397 U.S. 742 (1970), if he shows (1) “some egregiously impermissible conduct . . . antedated the entry of his plea,” a

22
Ainscough v. Owensgreen
colo · 2004 · cited in 2 Colorado opinions naming this issue, 2011–2013
2 sentences

2013Moreover, "{dleprivations of many legally created rights, although themselves intangible, are nevertheless injuries-in-fact." Ainscough, 90 P.3d at 856 , accord Cloverleaf Kennel Club, Inc. v. Colo. Racing Comm'n, 620 P.2d 1051, 1058 (Colo.1980) ("It is ... well settled that the injury in fact conferring standing may not only be intangible, but may exist solely by virtue of statutes creating legal rights the invasion of which creates standing." (internal citations and quotations omitted)). $84 The second prong of the test requires that the plaintiff have a legal interest protecting against the

2011The order of dismissal explicitly refers to and relies upon C.R.C.P. 12(b)(5), cites extensively to authorities construing that rule, and makes no mention of C.R.C.P. 12(b)(1) or the terms "jurisdiction" or "standing." Defendants stress, however, that the order concludes that "there has been no injury to a legally protected interest of Monica's." The district court's language parallels the second prong for the test of standing—whether the plaintiff suffered harm "to a legally protected interest." Ainscough v. Owens, 90 P.3d 851, 855 (Colo.2004).

12
People v. Schultheisgreen
colo · 1981 · cited in 1 Colorado opinions naming this issue, 2025–2025
1 sentence

2025To satisfy the second prong of the test, the defendant must show that “there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id. at 694 . ¶ 13 Defense counsel is not simply “the alter-ego or mouthpiece of the accused, but is a trained advocate charged with representing an accused.” People v. Schultheis, 638 P.2d 8, 12 (Colo. 1981).

11
Hung Thanh Le v. Mullingreen
ca10 · 2002 · cited in 1 Colorado opinions naming this issue, 2024–2024
1 sentence

2024See Strickland v. Washington, 466 U.S. 668, 687 (1984). ¶ 16 In assessing the first prong of the Strickland test, we must “indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance; that is, the defendant must overcome the presumption that, under the circumstances, the challenged action ‘might be considered sound 6 trial strategy.’” Id. at 689 (quoting Michel v. Louisiana, 350 U.S. 91, 101 (1955)); see also Le v. Mullin, 311 F.3d 1002, 1025 (10th Cir. 2002) (“For counsel’s performance to be constitutionally ineffective, it must have b

11
Michel v. Louisianagreen
scotus · 1956 · cited in 1 Colorado opinions naming this issue, 2024–2024
1 sentence

2024See Strickland v. Washington, 466 U.S. 668, 687 (1984). ¶ 16 In assessing the first prong of the Strickland test, we must “indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance; that is, the defendant must overcome the presumption that, under the circumstances, the challenged action ‘might be considered sound 6 trial strategy.’” Id. at 689 (quoting Michel v. Louisiana, 350 U.S. 91, 101 (1955)); see also Le v. Mullin, 311 F.3d 1002, 1025 (10th Cir. 2002) (“For counsel’s performance to be constitutionally ineffective, it must have b

11
People v. Karpierzgreen
coloctapp · 2006 · cited in 1 Colorado opinions naming this issue, 2024–2024
1 sentence

2024See Strickland v. Washington, 466 U.S. 668, 687 (1984). ¶ 16 In assessing the first prong of the Strickland test, we must “indulge a strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance; that is, the defendant must overcome the presumption that, under the circumstances, the challenged action ‘might be considered sound 6 trial strategy.’” Id. at 689 (quoting Michel v. Louisiana, 350 U.S. 91, 101 (1955)); see also Le v. Mullin, 311 F.3d 1002, 1025 (10th Cir. 2002) (“For counsel’s performance to be constitutionally ineffective, it must have b

11
Kashiya Nwanguma v. Donald Trumpgreen
ca6 · 2018 · cited in 1 Colorado opinions naming this issue, 2023–2023
1 sentence

2023Intent to Produce Violent or Lawless Action ¶245 The second prong of the test for incitement is that “the speaker intends that his speech will result in the use of violence or lawless action.” Nwanguma, 903 F.3d at 609.

11
Counterman v. Coloradogreen
scotus · 2023 · cited in 1 Colorado opinions naming this issue, 2023–2023
1 sentence

2023The Supreme Court has interpreted this second prong of the Brandenburg test to require specific intent.21 Counterman, 600 U.S. at 79, 81 (establishing that “when incitement is at issue, we have spoken in terms of specific intent, presumably equivalent to purpose or knowledge,” and defining acting purposely as “‘consciously desir[ing]’ a result”).

11
Thornton v. Peoplegreen
colo · 1986 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021Only the second prong of this analysis is at issue now. ¶27 A waiver is voluntary if it is "not extracted by threats or violence, promises, or undue influence." Davis , ¶ 18 , 352 P.3d at 955 ( quoting People v. Smith , 716 P.2d 1115, 1118 ( Colo. 1986 ) ) . ¶28 A waiver is knowing and intelligent if the record clearly shows that the defendant understood the nature of the charges, the statutory offenses included within them, the range of allowable punishments, the possible defenses to the charges and circumstances in their mitigation, and all other facts essential to a broad understanding of t

11
People v. Davisgreen
colo · 2015 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021Only the second prong of this analysis is at issue now. ¶27 A waiver is voluntary if it is "not extracted by threats or violence, promises, or undue influence." Davis , ¶ 18 , 352 P.3d at 955 ( quoting People v. Smith , 716 P.2d 1115, 1118 ( Colo. 1986 ) ) . ¶28 A waiver is knowing and intelligent if the record clearly shows that the defendant understood the nature of the charges, the statutory offenses included within them, the range of allowable punishments, the possible defenses to the charges and circumstances in their mitigation, and all other facts essential to a broad understanding of t

11
Quintano v. Peoplegreen
colo · 2005 · cited in 1 Colorado opinions naming this issue, 2014–2014
1 sentence

2014See id. at 219 . "[I]ncidents of sexual assault may be factually distinct if separate criminal acts have occurred at different times and were separated by intervening events." Quintano, 105 P.3d at 591 . ¶ 27 At the resentencing hearing, the postconviction court determined that defendant admitted "to violating [the] victim on at least two occasions in Douglas County, and those are the offenses for which he's being sentenced today." The court found "that there are separate offenses for which [defendant] is being sentenced in this case" because one incident "occurred ... in the living room of [d

11
Woellhaf v. Peoplegreen
colo · 2005 · cited in 1 Colorado opinions naming this issue, 2014–2014
1 sentence

2014See id. at 219 . "[I]ncidents of sexual assault may be factually distinct if separate criminal acts have occurred at different times and were separated by intervening events." Quintano, 105 P.3d at 591 . ¶ 27 At the resentencing hearing, the postconviction court determined that defendant admitted "to violating [the] victim on at least two occasions in Douglas County, and those are the offenses for which he's being sentenced today." The court found "that there are separate offenses for which [defendant] is being sentenced in this case" because one incident "occurred ... in the living room of [d

11
Cloverleaf Kennel Club, Inc. v. Colorado Racing Commissiongreen
colo · 1980 · cited in 1 Colorado opinions naming this issue, 2013–2013
1 sentence

2013Moreover, "{dleprivations of many legally created rights, although themselves intangible, are nevertheless injuries-in-fact." Ainscough, 90 P.3d at 856 , accord Cloverleaf Kennel Club, Inc. v. Colo. Racing Comm'n, 620 P.2d 1051, 1058 (Colo.1980) ("It is ... well settled that the injury in fact conferring standing may not only be intangible, but may exist solely by virtue of statutes creating legal rights the invasion of which creates standing." (internal citations and quotations omitted)). $84 The second prong of the test requires that the plaintiff have a legal interest protecting against the

11
People v. Maygreen
colo · 1993 · cited in 1 Colorado opinions naming this issue, 2006–2006
2 sentences

2006May, 859 P.2d at 883 . "[T]he waiver must have been made with a full awareness, both of the nature of the right being abandoned and the consequences of the decision to abandon it." Burbine, 475 U.S. at 421 , 106 S.Ct. 1135 ; see May, 859 P.2d at 882 ; Hopkins, 774 P.2d at 851 .

2006May, 859 P.2d at 883 . "[T]he waiver must have been made with a full awareness, both of the nature of the right being abandoned and the consequences of the decision to abandon it." Burbine, 475 U.S. at 421 , 106 S.Ct. 1135 ; see May, 859 P.2d at 882 ; Hopkins, 774 P.2d at 851 .

11
County Road Users Ass'n v. Board of County Commissionersgreen
coloctapp · 1999 · cited in 1 Colorado opinions naming this issue, 2000–2000
1 sentence

2000See County Road Users Ass'n, 987 P.2d at 864 .

11
Mass Transit Administration v. Granite Construction Co.green
mdctspecapp · 1984 · cited in 1 Colorado opinions naming this issue, 1998–1998
2 sentences

1998Co., 57 Md.App. 766 , 471 A.2d 1121, 1125 (Md.Ct.Spec.App.1984) (setting forth the second prong of the test as “appreciation or knowledge by the defendant of the benefit”); S & M Rotogravure Serv., Inc. v. Baer, 77 Wis.2d 454 , 252 N.W.2d 913, 915-16 (Wis.1977) (equating appreciation with knowledge and finding appreciation where defendant knew of the remodeling work).

1998Co., 57 Md.App. 766 , 471 A.2d 1121, 1125 (Md.Ct.Spec.App.1984) (setting forth the second prong of the test as “appreciation or knowledge by the defendant of the benefit”); S & M Rotogravure Serv., Inc. v. Baer, 77 Wis.2d 454 , 252 N.W.2d 913, 915-16 (Wis.1977) (equating appreciation with knowledge and finding appreciation where defendant knew of the remodeling work).

11
S & M Rotogravure Service, Inc. v. Baergreen
wis · 1977 · cited in 1 Colorado opinions naming this issue, 1998–1998
2 sentences

1998Co., 57 Md.App. 766 , 471 A.2d 1121, 1125 (Md.Ct.Spec.App.1984) (setting forth the second prong of the test as “appreciation or knowledge by the defendant of the benefit”); S & M Rotogravure Serv., Inc. v. Baer, 77 Wis.2d 454 , 252 N.W.2d 913, 915-16 (Wis.1977) (equating appreciation with knowledge and finding appreciation where defendant knew of the remodeling work).

1998Co., 57 Md.App. 766 , 471 A.2d 1121, 1125 (Md.Ct.Spec.App.1984) (setting forth the second prong of the test as “appreciation or knowledge by the defendant of the benefit”); S & M Rotogravure Serv., Inc. v. Baer, 77 Wis.2d 454 , 252 N.W.2d 913, 915-16 (Wis.1977) (equating appreciation with knowledge and finding appreciation where defendant knew of the remodeling work).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (13)

CaseCitedYears
Aguilar v. Texas red
scotus · 1964
2 sentences

1974The majority opinion holds that the second prong of the test set forth in Aguilar v. Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 (1964), and Spinelli v. United States, 394 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 (1969), is satisfied by the assertion contained in the affidavit that the affiant received information from “a previously reliable confidential informant whose information has resulted in narcotics arrest and seizures on at least two past occasions.” In my view, to approve this language as competent to demonstrate the reliability of the informer is to permit the Fourth Amendm

1974The majority opinion holds that the second prong of the test set forth in Aguilar v. Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 (1964), and Spinelli v. United States, 394 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 (1969), is satisfied by the assertion contained in the affidavit that the affiant received information from “a previously reliable confidential informant whose information has resulted in narcotics arrest and seizures on at least two past occasions.” In my view, to approve this language as competent to demonstrate the reliability of the informer is to permit the Fourth Amendm

31974–1975
Spinelli v. United States red
scotus · 1969
2 sentences

1974The majority opinion holds that the second prong of the test set forth in Aguilar v. Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 (1964), and Spinelli v. United States, 394 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 (1969), is satisfied by the assertion contained in the affidavit that the affiant received information from “a previously reliable confidential informant whose information has resulted in narcotics arrest and seizures on at least two past occasions.” In my view, to approve this language as competent to demonstrate the reliability of the informer is to permit the Fourth Amendm

1974The majority opinion holds that the second prong of the test set forth in Aguilar v. Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 (1964), and Spinelli v. United States, 394 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 (1969), is satisfied by the assertion contained in the affidavit that the affiant received information from “a previously reliable confidential informant whose information has resulted in narcotics arrest and seizures on at least two past occasions.” In my view, to approve this language as competent to demonstrate the reliability of the informer is to permit the Fourth Amendm

31974–1975
People v. Brethauer green
colo · 1971
2 sentences

1975Aguilar v. Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 ; Spinelli v. United States, 393 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 ; People v. Arnold, 186 Colo. 372 , 527 P.2d 806 ; People v. Brethauer, 174 Colo. 29 , 482 P.2d 369 .

1975Aguilar v. Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 ; Spinelli v. United States, 393 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 ; People v. Arnold, 186 Colo. 372 , 527 P.2d 806 ; People v. Brethauer, 174 Colo. 29 , 482 P.2d 369 .

21975–1975
People v. Arnold green
colo · 1974
2 sentences

1975Aguilar v. Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 ; Spinelli v. United States, 393 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 ; People v. Arnold, 186 Colo. 372 , 527 P.2d 806 ; People v. Brethauer, 174 Colo. 29 , 482 P.2d 369 .

1975Aguilar v. Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 ; Spinelli v. United States, 393 U.S. 410 , 89 S.Ct. 584 , 21 L.Ed.2d 637 ; People v. Arnold, 186 Colo. 372 , 527 P.2d 806 ; People v. Brethauer, 174 Colo. 29 , 482 P.2d 369 .

21975–1975
People v. Arguello green
colo · 1989
1 sentence

2021Arguello , 772 P.2d at 94 . ¶29 The court must indulge every reasonable presumption against finding a waiver of the right to counsel .

12021–2021
Concerning the Application for Water Rights v. Raftopoulos Bros. neutral
colo · 2013
2 sentences

2020P’ship v. Raftopoulos Bros., 2013 CO 41, ¶ 32 , 307 P.3d 1056, 1064 . ¶14 To obtain a conditional water right, an applicant must demonstrate that: “(1) it has taken a ‘first step,’ which includes an intent to appropriate the water and an overt act manifesting such intent; (2) its intent is not based on a speculative sale or transfer of the water to be appropriated; and (3) there is a substantial probability that the applicant ‘can and will’ complete the appropriation with diligence and within a reasonable time.” Id. at ¶ 33, 307 P.3d at 1064 . ¶15 At issue in this case is whether United’s appl

2020P’ship v. Raftopoulos Bros., 2013 CO 41, ¶ 32 , 307 P.3d 1056, 1064 . ¶14 To obtain a conditional water right, an applicant must demonstrate that: “(1) it has taken a ‘first step,’ which includes an intent to appropriate the water and an overt act manifesting such intent; (2) its intent is not based on a speculative sale or transfer of the water to be appropriated; and (3) there is a substantial probability that the applicant ‘can and will’ complete the appropriation with diligence and within a reasonable time.” Id. at ¶ 33, 307 P.3d at 1064 . ¶15 At issue in this case is whether United’s appl

12020–2020
Haralampopoulos ex rel. Haralampopoulos v. Kelly green
coloctapp · 2011
1 sentence

2014The second prong requires that "the content of the statement must be such as is reasonably relied on by a physician in treatment or diagnosis." Kelly, 2011 WL 4908743 at *7 , -- P.3d at --.

12014–2014
Moran v. Burbine green
scotus · 1986
2 sentences

2006May, 859 P.2d at 883 . "[T]he waiver must have been made with a full awareness, both of the nature of the right being abandoned and the consequences of the decision to abandon it." Burbine, 475 U.S. at 421 , 106 S.Ct. 1135 ; see May, 859 P.2d at 882 ; Hopkins, 774 P.2d at 851 .

2006May, 859 P.2d at 883 . "[T]he waiver must have been made with a full awareness, both of the nature of the right being abandoned and the consequences of the decision to abandon it." Burbine, 475 U.S. at 421 , 106 S.Ct. 1135 ; see May, 859 P.2d at 882 ; Hopkins, 774 P.2d at 851 .

12006–2006
People v. Hopkins green
colo · 1989
2 sentences

2006May, 859 P.2d at 883 . "[T]he waiver must have been made with a full awareness, both of the nature of the right being abandoned and the consequences of the decision to abandon it." Burbine, 475 U.S. at 421 , 106 S.Ct. 1135 ; see May, 859 P.2d at 882 ; Hopkins, 774 P.2d at 851 .

2006May, 859 P.2d at 883 . “[T]he waiver must have been made with a full awareness, both of the nature of the right being abandoned and the consequences of the decision to abandon it.” Burbine, 475 U.S. at 421 , 106 S.Ct. 1135 ; see May, 859 P.2d at 882 ; Hopkins, 774 P.2d at 851 .

12006–2006
United States v. One Assortment of 89 Firearms green
scotus · 1984
2 sentences

1987Id. at 365-66 , 104 S.Ct. at 1106-07 . 5 We adopt this same two-pronged test under the Colorado Double Jeopardy Clause.

1987Id. at 365-66 , 104 S.Ct. at 1106-07 . 5 We adopt this same two-pronged test under the Colorado Double Jeopardy Clause.

11987–1987
Wasalco, Inc. v. El Paso County green
coloctapp · 1984
11986–1986
Draper v. United States green
scotus · 1959
11971–1971
People v. Baird green
colo · 1970
11971–1971

Statutes the citing opinions construe

CO § Colo. Rev. Stat. § 24-51-1105 (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

TX 385 (1976–2026) CA 223 (1972–2026) IL 201 (1979–2026) OH 176 (1980–2026) PA 152 (1974–2026) GA 148 (1980–2026) NY 109 (1970–2026) CT 109 (1983–2026) FL 81 (1981–2024) NJ 80 (1979–2026) WA 72 (1982–2025) MS 58 (1984–2022) IN 50 (1989–2020) MO 48 (1984–2022) MI 41 (1982–2025) NC 40 (1975–2024) TN 39 (1980–2024) LA 37 (1981–2025) AR 36 (1979–2022) IA 34 (1979–2024) MN 34 (1977–2026) KS 33 (1989–2024) MD 32 (1980–2025) MT 31 (1978–2025) AL 31 (1989–2023) WI 29 (1991–2026) MA 29 (1996–2025) UT 26 (1982–2025) ID 26 (1991–2024) VA 25 (1974–2025) CO 22 (1971–2025) NM 22 (1980–2025) DC 19 (1972–2023) VT 19 (1988–2024) ME 18 (1978–2023) RI 17 (1984–2019) OR 17 (1984–2024) KY 16 (1991–2024) HI 15 (1994–2024) SD 15 (1985–2023) ND 14 (1986–2018) WV 12 (1991–2025) WY 12 (1991–2025) AZ 11 (1976–2026) SC 10 (1992–2023) DE 10 (1976–2023) NE 10 (1984–2025) NH 8 (1993–2020) OK 7 (2002–2025) NV 7 (1998–2023) AK 4 (1982–2009)

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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