good faith exception (Maine) · Go Syfert
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good faith exception in Maine

22 Maine opinions name it 2 courts 1981–2023 4 in the last five years

The cases below were cited by Maine 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 (30)

CaseFollowedCited
United States v. Leongreen
scotus · 1984 · cited in 9 Maine opinions naming this issue, 1993–2023
2 sentences

2023See United States v. Leon, 468 U.S. 897, 922-23 (1984) (establishing the good faith exception). 28 and the evidence obtained from the execution of the warrants was properly admitted because each warrant was supported by probable cause.

2021United States v. Leon, 468 U.S. 897,922 (1984)(recognizing the good faith exception under the Fourth Amendment to the United States Constitution).

49
State of Maine v. Oscar Nunezgreen
me · 2016 · cited in 2 Maine opinions naming this issue, 2020–2021
2 sentences

2021In fact, the Law Court has specifically observed in a previous instance "that a number of state supreme courts have rejected the good faith exception on state constitutional grounds." State v. Nunez, 2016 ME 185 , j 17, n. 8, 153 A.3d 84 .

2021In fact, the Law Court has specifically observed in a previous instance "that a number of state supreme courts have rejected the good faith exception on state constitutional grounds." State v. Nunez, 2016 ME 185 , j 17, n. 8, 153 A.3d 84 .

22
State of Maine v. Christopher J. Johndrogreen
me · 2013 · cited in 2 Maine opinions naming this issue, 2016–2019
2 sentences

2019See State v. Johndro, 2013 ME 106 , 82 A.3d 820 (unreasonable for officer to rely on affidavit that described the only link between defendant and the crime as him driving his car in the area at the time which is "entirely noncriminal and unsuspicious on its own"); State v. Diamond, 18 628 A.2d 1032 (Me. 1993) (affidavit was based on solely on 18 Johndro described Diamond clearly.

2019See State v. Johndro, 2013 ME 106 , 82 A.3d 820 (unreasonable for officer to rely on affidavit that described the only link between defendant and the crime as him driving his car in the area at the time which is "entirely noncriminal and unsuspicious on its own"); State v. Diamond, 18 628 A.2d 1032 (Me. 1993) (affidavit was based on solely on 18 Johndro described Diamond clearly.

22
Lyon v. United Statesgreen
mnd · 1994 · cited in 2 Maine opinions naming this issue, 2006–2008
2 sentences

2008The purpose of the good faith clause is to shield donees from liability in situations where “because of confusion, an organ is removed without genuine consent.” 9 Lyon v. United States, 843 F.Supp. 531, 536 (D.Minn.1994).

2006The good faith immunity "is designed for situations . . . where because of confusion, an organ is removed without genuine consent." Lyon v. United States, 843 F. Supp. 531,536 (D.

22
Government of the Virgin Islands v. Vidal Galdon Aquino, Government of the Virgin Islands v. Ishmael Guillerma Reyesgreen
ca3 · 1967 · cited in 2 Maine opinions naming this issue, 1981–1993
2 sentences

1993The good-faith effort must be “genuine and bona fide,” Government of the Virgin Islands v. Aquino, 378 F.2d 540, 552 (3d Cir.1967), and exercised with “reasonable diligence and care,” United States v. Lynch, 499 F.2d 1011, 1022-23 (D.C.Cir.1974).

1981The good-faith effort must be “genuine and bona fide,” Government of the Virgin Islands v. Aquino, 378 F.2d 540, 552 (3d Cir. 1967), and exercised with “reasonable diligence and care,” United States v. Lynch, 499 F.2d 1011, 1022-23 (D.C.Cir.1974).

22
United States v. Perry Lynchgreen
cadc · 1974 · cited in 2 Maine opinions naming this issue, 1981–1993
2 sentences

1993The good-faith effort must be “genuine and bona fide,” Government of the Virgin Islands v. Aquino, 378 F.2d 540, 552 (3d Cir.1967), and exercised with “reasonable diligence and care,” United States v. Lynch, 499 F.2d 1011, 1022-23 (D.C.Cir.1974).

1981The good-faith effort must be “genuine and bona fide,” Government of the Virgin Islands v. Aquino, 378 F.2d 540, 552 (3d Cir. 1967), and exercised with “reasonable diligence and care,” United States v. Lynch, 499 F.2d 1011, 1022-23 (D.C.Cir.1974).

22
State v. Diamondgreen
me · 1993 · cited in 3 Maine opinions naming this issue, 2013–2019
2 sentences

2019See State v. Johndro, 2013 ME 106 , 82 A.3d 820 (unreasonable for officer to rely on affidavit that described the only link between defendant and the crime as him driving his car in the area at the time which is "entirely noncriminal and unsuspicious on its own"); State v. Diamond, 18 628 A.2d 1032 (Me. 1993) (affidavit was based on solely on 18 Johndro described Diamond clearly.

2016See Johndro, 2013 ME 106, ¶¶ 19-20 , 82 A.3d 820 ; State v. Diamond, 628 A.2d 1032, 1034 (Me. 1993).

13
State of Maine v. Randall J. Weddlegreen
me · 2020 · cited in 2 Maine opinions naming this issue, 2021–2023
2 sentences

2023In light of this determination, the court need not address the other contentions raised by the State in support of the search, including: search incident to Defendant's probation conditions (U.S. v. Knights, 534 US. 112, 119-21 (2001)(Discussing the significantly diminished expectation of privacy of a probationer); search incident to Defendant’s probation, claiming reasonable grounds to believe contraband was present based on the allegations in the warrant request combined with the discovery of contraband on Defendant's spouse (Griffin v. Wisconsin, 483 U.S. 868, 880 (1987); or the good faith

2021Therefore, in order for this court to properly determine whether the good faith exception applies, the Court will "examine whether the [exclusionary] rule's deterrent effect will be achieved ... [by] weigh[ing] the likelihood of such deterrence against the costs of withholding reliable information from the truth-seeking process." Page 9 of 17 Weddle, 2020 ME 12 , ! 33, 224 A.3d 1035 .

12
State v. Estabrookgreen
me · 2007 · cited in 2 Maine opinions naming this issue, 2016–2020
2 sentences

2016See State v. Estabrook, 2007 ME 130, ¶¶ 1, 9 , 932 A.2d 549 (affirming trial court’s denial of a motion to suppress on the ground that the warrant affidavit was supported by probablé cause and declining to address the good faith exception); State v. Marquis, 525 A.2d 1041, 1042-43 (Me. 1987) (declining to address good faith—the only issue argued by the State on appeal— and instead first considering probable cause). 8 B.

2016See State v. Estabrook, 2007 ME 130, ¶¶ 1, 9 , 932 A.2d 549 (affirming trial court’s denial of a motion to suppress on the ground that the warrant affidavit was supported by probablé cause and declining to address the good faith exception); State v. Marquis, 525 A.2d 1041, 1042-43 (Me. 1987) (declining to address good faith—the only issue argued by the State on appeal— and instead first considering probable cause). 8 B.

12
Griffin v. Wisconsingreen
scotus · 1987 · cited in 1 Maine opinions naming this issue, 2023–2023
1 sentence

2023In light of this determination, the court need not address the other contentions raised by the State in support of the search, including: search incident to Defendant's probation conditions (U.S. v. Knights, 534 US. 112, 119-21 (2001)(Discussing the significantly diminished expectation of privacy of a probationer); search incident to Defendant’s probation, claiming reasonable grounds to believe contraband was present based on the allegations in the warrant request combined with the discovery of contraband on Defendant's spouse (Griffin v. Wisconsin, 483 U.S. 868, 880 (1987); or the good faith

11
State v. Izzogreen
me · 1993 · cited in 1 Maine opinions naming this issue, 2021–2021
1 sentence

2021Automobile Exception Maine has adopted the United States Supreme Court's automobile exception to the warrant requirement in that "the existence of probable cause justifies a warrantless seizure and reasonable search of a motor vehicle ... whether or not exigent circumstances prevailed at either the time of the seizure or the time of the search." State v. Lzzo, 623 A .2d 1277, 1181-82 (Me. 1993 )( citations and quotations omitted).

11
Morgan v. Kooistragreen
me · 2008 · cited in 1 Maine opinions naming this issue, 2021–2021
2 sentences

2021See Morgan v. Kooistra, 2008 ME 26, ¶¶ 31-38 , 941 A.2d 447 .

2021See Morgan v. Kooistra, 2008 ME 26, ¶¶ 31-38 , 941 A.2d 447 .

11
Davis v. United Statesgreen
scotus · 2011 · cited in 1 Maine opinions naming this issue, 2020–2020
2 sentences

2020See Davis v. United States, 564 U.S. 229 , 241 (2011) (“Evidence obtained during a search conducted in reasonable reliance on binding precedent is not subject to the exclusionary rule.”); State v. Ward, 604 N.W.2d 517, 525-31 (Wis. 2000) (applying the good faith exception when officers executed a search pursuant to a no-knock police entry policy that had been twice approved by the state’s highest court). [¶36] Although we have not previously relied on the good faith exception, we do so today because, in these unique circumstances, the suppression of the results of the warrantless blood draw wo

2020See Davis v. United States, 564 U.S. 229 , 241 (2011) (“Evidence obtained during a search conducted in reasonable reliance on binding precedent is not subject to the exclusionary rule.”); State v. Ward, 604 N.W.2d 517, 525-31 (Wis. 2000) (applying the good faith exception when officers executed a search pursuant to a no-knock police entry policy that had been twice approved by the state’s highest court). [¶36] Although we have not previously relied on the good faith exception, we do so today because, in these unique circumstances, the suppression of the results of the warrantless blood draw wo

11
State v. Rochegreen
me · 1996 · cited in 1 Maine opinions naming this issue, 2020–2020
1 sentence

2020The officer who ordered Weddle’s blood draw acted in good faith reliance on a statute blessed as constitutional as recently as 2007, Cormier, 2007 ME 112, ¶ 37 , 928 A.2d 753 , and whose predecessor statute we also upheld in State v. Roche, 681 A.2d 472, 475 (Me. 1996).

11
State v. Wardgreen
wis · 2000 · cited in 1 Maine opinions naming this issue, 2020–2020
2 sentences

2020See Davis v. United States, 564 U.S. 229 , 241 (2011) (“Evidence obtained during a search conducted in reasonable reliance on binding precedent is not subject to the exclusionary rule.”); State v. Ward, 604 N.W.2d 517, 525-31 (Wis. 2000) (applying the good faith exception when officers executed a search pursuant to a no-knock police entry policy that had been twice approved by the state’s highest court). [¶36] Although we have not previously relied on the good faith exception, we do so today because, in these unique circumstances, the suppression of the results of the warrantless blood draw wo

2020See Davis v. United States, 564 U.S. 229 , 241 (2011) (“Evidence obtained during a search conducted in reasonable reliance on binding precedent is not subject to the exclusionary rule.”); State v. Ward, 604 N.W.2d 517, 525-31 (Wis. 2000) (applying the good faith exception when officers executed a search pursuant to a no-knock police entry policy that had been twice approved by the state’s highest court). [¶36] Although we have not previously relied on the good faith exception, we do so today because, in these unique circumstances, the suppression of the results of the warrantless blood draw wo

11
Herring v. United Statesgreen
scotus · 2009 · cited in 1 Maine opinions naming this issue, 2019–2019
1 sentence

2019As laid out in our cases, the exclusionary rule serves to deter deliberate, reckless, or grossly negligent conduct, or in some circumstances recurring or systematic negligence. 14 555 U.S. 135, 144 (2009). 53.

11
Greenstreet v. Stategreen
md · 2006 · cited in 1 Maine opinions naming this issue, 2019–2019
2 sentences

2019It discussed relevant portions of Leon, [n]oting that one purpose of the exclusionary rule is to alter the behavior of individual law enforcement officers and their departments to deter them from willful or negligent conduct depriving a defendant of some right, the [Leon] Court observed that this deterrent policy 'cannot be expected, and should not be applied, to deter objectively reasonable law enforcement activity.' 898 A.2d 961, 976 (Md. 2006). 56.

2019Id. at 979 .

11
State v. Chapmangreen
me · 1985 · cited in 1 Maine opinions naming this issue, 2017–2017
1 sentence

2017See State v. Chapman, 495 A.2d at 317 . 5 The State has not argued that the good faith exception applies here.

11
State v. Canelogreen
nh · 1995 · cited in 1 Maine opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., State v. Canelo, 139 N.H. 376 , 653 A.2d 1097, 1105 (1995); State v. Gutierrez, 116 N.M. 431 , 863 P.2d 1052, 1068 (1993); State v. Oakes, 157 Vt. 171 , 598 A.2d 119, 121-22 (Vt. 1991); State v. Novembrino, 105 N.J. 95 , 519 A.2d 820, 857 (1987). 9 .

2016See, e.g., State v. Canelo, 139 N.H. 376 , 653 A.2d 1097, 1105 (1995); State v. Gutierrez, 116 N.M. 431 , 863 P.2d 1052, 1068 (1993); State v. Oakes, 157 Vt. 171 , 598 A.2d 119, 121-22 (Vt. 1991); State v. Novembrino, 105 N.J. 95 , 519 A.2d 820, 857 (1987). 9 .

11
State v. Novembrinogreen
nj · 1987 · cited in 1 Maine opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., State v. Canelo, 139 N.H. 376 , 653 A.2d 1097, 1105 (1995); State v. Gutierrez, 116 N.M. 431 , 863 P.2d 1052, 1068 (1993); State v. Oakes, 157 Vt. 171 , 598 A.2d 119, 121-22 (Vt. 1991); State v. Novembrino, 105 N.J. 95 , 519 A.2d 820, 857 (1987). 9 .

2016See, e.g., State v. Canelo, 139 N.H. 376 , 653 A.2d 1097, 1105 (1995); State v. Gutierrez, 116 N.M. 431 , 863 P.2d 1052, 1068 (1993); State v. Oakes, 157 Vt. 171 , 598 A.2d 119, 121-22 (Vt. 1991); State v. Novembrino, 105 N.J. 95 , 519 A.2d 820, 857 (1987). 9 .

11
State v. Gutierrezgreen
nm · 1993 · cited in 1 Maine opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., State v. Canelo, 139 N.H. 376 , 653 A.2d 1097, 1105 (1995); State v. Gutierrez, 116 N.M. 431 , 863 P.2d 1052, 1068 (1993); State v. Oakes, 157 Vt. 171 , 598 A.2d 119, 121-22 (Vt. 1991); State v. Novembrino, 105 N.J. 95 , 519 A.2d 820, 857 (1987). 9 .

2016See, e.g., State v. Canelo, 139 N.H. 376 , 653 A.2d 1097, 1105 (1995); State v. Gutierrez, 116 N.M. 431 , 863 P.2d 1052, 1068 (1993); State v. Oakes, 157 Vt. 171 , 598 A.2d 119, 121-22 (Vt. 1991); State v. Novembrino, 105 N.J. 95 , 519 A.2d 820, 857 (1987). 9 .

11
State v. Oakesgreen
vt · 1991 · cited in 1 Maine opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., State v. Canelo, 139 N.H. 376 , 653 A.2d 1097, 1105 (1995); State v. Gutierrez, 116 N.M. 431 , 863 P.2d 1052, 1068 (1993); State v. Oakes, 157 Vt. 171 , 598 A.2d 119, 121-22 (Vt. 1991); State v. Novembrino, 105 N.J. 95 , 519 A.2d 820, 857 (1987). 9 .

2016See, e.g., State v. Canelo, 139 N.H. 376 , 653 A.2d 1097, 1105 (1995); State v. Gutierrez, 116 N.M. 431 , 863 P.2d 1052, 1068 (1993); State v. Oakes, 157 Vt. 171 , 598 A.2d 119, 121-22 (Vt. 1991); State v. Novembrino, 105 N.J. 95 , 519 A.2d 820, 857 (1987). 9 .

11
State v. Marquisgreen
me · 1987 · cited in 1 Maine opinions naming this issue, 2016–2016
2 sentences

2016See State v. Estabrook, 2007 ME 130, ¶¶ 1, 9 , 932 A.2d 549 (affirming trial court’s denial of a motion to suppress on the ground that the warrant affidavit was supported by probablé cause and declining to address the good faith exception); State v. Marquis, 525 A.2d 1041, 1042-43 (Me. 1987) (declining to address good faith—the only issue argued by the State on appeal— and instead first considering probable cause). 8 B.

2016See, e.g., Arbour, 2016 ME 126 , ¶ 16 n.12, 146 A.3d 1106 (“Because we conclude that there was a substantial basis for the finding of probable cause to issue the search warrant, we do not consider the State’s alternative ‘good faith' argument,"); State v. Nadeau, 2010 ME 71 , ¶ 48 n.10, 1 A.3d 445 (“We do not discuss the Superior Court’s application of the good faith exception because the search warrant, which authorized the July forensic examination of the computer, never ‘expired.’ ’’); Estabrook, 2007 ME 130, ¶¶ 1, 9 , 932 A.2d 549 ; State v. Veglia, 620 A.2d 276 , 277-79 & n.3 (Me. 1993) (

11
State of Maine v. Franklin F. Arbour Jr.green
me · 2016 · cited in 1 Maine opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., Arbour, 2016 ME 126 , ¶ 16 n.12, 146 A.3d 1106 (“Because we conclude that there was a substantial basis for the finding of probable cause to issue the search warrant, we do not consider the State’s alternative ‘good faith' argument,"); State v. Nadeau, 2010 ME 71 , ¶ 48 n.10, 1 A.3d 445 (“We do not discuss the Superior Court’s application of the good faith exception because the search warrant, which authorized the July forensic examination of the computer, never ‘expired.’ ’’); Estabrook, 2007 ME 130, ¶¶ 1, 9 , 932 A.2d 549 ; State v. Veglia, 620 A.2d 276 , 277-79 & n.3 (Me. 1993) (

2016See, e.g., Arbour, 2016 ME 126 , ¶ 16 n.12, 146 A.3d 1106 (“Because we conclude that there was a substantial basis for the finding of probable cause to issue the search warrant, we do not consider the State’s alternative ‘good faith' argument,"); State v. Nadeau, 2010 ME 71 , ¶ 48 n.10, 1 A.3d 445 (“We do not discuss the Superior Court’s application of the good faith exception because the search warrant, which authorized the July forensic examination of the computer, never ‘expired.’ ’’); Estabrook, 2007 ME 130, ¶¶ 1, 9 , 932 A.2d 549 ; State v. Veglia, 620 A.2d 276 , 277-79 & n.3 (Me. 1993) (

11
State v. Tarantinogreen
me · 1991 · cited in 1 Maine opinions naming this issue, 2016–2016
1 sentence

2016See, e.g., Arbour, 2016 ME 126 , ¶ 16 n.12, 146 A.3d 1106 (“Because we conclude that there was a substantial basis for the finding of probable cause to issue the search warrant, we do not consider the State’s alternative ‘good faith' argument,"); State v. Nadeau, 2010 ME 71 , ¶ 48 n.10, 1 A.3d 445 (“We do not discuss the Superior Court’s application of the good faith exception because the search warrant, which authorized the July forensic examination of the computer, never ‘expired.’ ’’); Estabrook, 2007 ME 130, ¶¶ 1, 9 , 932 A.2d 549 ; State v. Veglia, 620 A.2d 276 , 277-79 & n.3 (Me. 1993) (

11
McCall Co. v. Wrightgreen
nyappdiv · 1909 · cited in 1 Maine opinions naming this issue, 2012–2012
11
John T. Demars v. General Dynamics Corporationgreen
ca1 · 1985 · cited in 1 Maine opinions naming this issue, 2012–2012
11
Perry v. Saint Francis Hospital & Medical Center, Inc.green
ksd · 1995 · cited in 1 Maine opinions naming this issue, 2006–2006
11
Purdy v. Community Telecommunications Corp.green
me · 1995 · cited in 1 Maine opinions naming this issue, 2003–2003
11
United States v. Michael Hawkinsgreen
ca1 · 1998 · cited in 1 Maine opinions naming this issue, 2003–2003
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (13)

CaseCitedYears
Department of Environmental Protection v. Woodman green
me · 1997
2 sentences

2021Id. [¶26] As to Thurlow’s burden, the focus is not on what the Nelsons considered to be a reasonable factual support for their letter or their interpretation of the facts;7 it is on whether the facts as presented by Thurlow, see also Dep’t of Env’t Prot. v. Woodman, 1997 ME 164 , ¶ 3 n.3, 697 A.2d 1295 (“It is well established that pro se litigants are held to the same standards as represented parties.”). 7 The Nelsons’ understanding of the facts could affect a good-faith analysis should they successfully assert a conditional privilege as to the underlying defamation claim.

2021Id. [¶26] As to Thurlow’s burden, the focus is not on what the Nelsons considered to be a reasonable factual support for their letter or their interpretation of the facts;7 it is on whether the facts as presented by Thurlow, see also Dep’t of Env’t Prot. v. Woodman, 1997 ME 164 , ¶ 3 n.3, 697 A.2d 1295 (“It is well established that pro se litigants are held to the same standards as represented parties.”). 7 The Nelsons’ understanding of the facts could affect a good-faith analysis should they successfully assert a conditional privilege as to the underlying defamation claim.

12021–2021
Ralph Nader v. Maine Democratic Party green
me · 2013
1 sentence

2021Id. [¶26] As to Thurlow’s burden, the focus is not on what the Nelsons considered to be a reasonable factual support for their letter or their interpretation of the facts;7 it is on whether the facts as presented by Thurlow, see also Dep’t of Env’t Prot. v. Woodman, 1997 ME 164 , ¶ 3 n.3, 697 A.2d 1295 (“It is well established that pro se litigants are held to the same standards as represented parties.”). 7 The Nelsons’ understanding of the facts could affect a good-faith analysis should they successfully assert a conditional privilege as to the underlying defamation claim.

12021–2021
Illinois v. Krull green
scotus · 1987
2 sentences

2020However, the Supreme Court has also applied the good faith exception to situations where an officer has obtained evidence by acting in “objectively reasonable reliance on a statute.” Krull, 480 U.S. at 349 .

2020Nor can a law enforcement officer be said to have acted in good-faith reliance upon a statute if its provisions are such that a reasonable officer should have known that the statute was unconstitutional.” Id. at 355 . [¶35] Accordingly, the good faith exception has been applied when a law enforcement officer reasonably relies, in good faith, on a statute or common law rule that the officer has no reason to believe was unconstitutional and which has previously been declared constitutional by an appellate court with binding authority.

12020–2020
State v. Cormier green
me · 2007
2 sentences

2020The officer who ordered Weddle’s blood draw acted in good faith reliance on a statute blessed as constitutional as recently as 2007, Cormier, 2007 ME 112, ¶ 37 , 928 A.2d 753 , and whose predecessor statute we also upheld in State v. Roche, 681 A.2d 472, 475 (Me. 1996).

2020The officer who ordered Weddle’s blood draw acted in good faith reliance on a statute blessed as constitutional as recently as 2007, Cormier, 2007 ME 112, ¶ 37 , 928 A.2d 753 , and whose predecessor statute we also upheld in State v. Roche, 681 A.2d 472, 475 (Me. 1996).

12020–2020
Stewart-Dore v. Webber Hospital Ass'n green
me · 2011
1 sentence

2017Ass'n, 2011 ME 26 , 1 11.

12017–2017
State v. Veglia green
me · 1993
12016–2016
State v. Nadeau green
me · 2010
12016–2016
Bodman v. Maine, Department of Health & Human Services green
med · 2010
12013–2013
Costain v. Sunbury Primary Care, P.A. green
me · 2008
12013–2013
Wyatt v. Cole green
scotus · 1992
12008–2008
Webb v. Haas green
me · 1999
12008–2008
Leibowitz v. Szoverffy neutral
nysupct · 1979
11988–1988
Union Building & Saving Ass'n v. Soderquist green
iowa · 1901
11988–1988

Where else courts name it

TX 511 (1917–2026) CA 374 (1925–2026) IL 307 (1899–2026) OH 285 (1909–2026) FL 175 (1962–2026) LA 155 (1947–2023) PA 149 (1897–2025) IN 146 (1929–2025) VA 138 (1916–2026) MI 121 (1965–2026) WI 115 (1927–2026) NY 110 (1919–2025) WA 108 (1960–2024) KS 100 (1980–2026) MD 90 (1968–2026) AR 87 (1981–2025) AZ 85 (1966–2025) IA 85 (1900–2025) MN 83 (1971–2026) NJ 82 (1957–2026) GA 75 (1883–2025) CO 69 (1936–2026) CT 63 (1935–2025) KY 50 (1927–2025) NC 49 (1983–2026) MA 49 (1975–2025) NE 46 (1988–2024) HI 46 (1965–2025) AL 45 (1916–2026) TN 45 (1989–2026) MO 43 (1901–2025) ND 41 (1984–2020) OR 40 (1956–2026) NM 39 (1930–2024) ID 36 (1985–2025) MS 33 (1950–2026) UT 33 (1985–2026) OK 32 (1938–2023) DE 32 (1952–2026) SD 32 (1982–2020) SC 28 (1987–2026) DC 26 (1951–2026) AK 25 (1976–2017) RI 23 (1973–2026) WY 23 (1984–2025) ME 22 (1981–2023) VT 21 (1986–2023) NV 19 (1991–2024) WV 16 (1982–2026) NH 12 (1985–2020) MT 11 (1996–2024) VI 3 (2009–2026)

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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