Anders brief in Connecticut

21 Connecticut opinions name it 3 courts 1986–2019 0 in the last five years

The cases below were cited by Connecticut 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 (8)

Case	Followed	Cited
Anders v. Californiagreen scotus · 1967 · cited in 14 Connecticut opinions naming this issue, 1986–2018 2 sentences 2017On April 29, 2016, the petitioner's appellate counsel filed an Anders brief and a motion for permission to withdraw as counsel, representing that "[u]pon thorough review and examination of the transcripts, information and record in this matter, the undersigned has determined that an appeal in this matter would be frivolous." See Anders v. California , 386 U.S. 738 , 744-45, 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967) ; see, e.g., Lorthe v. Commissioner of Correction , 103 Conn.App. 662 , 674, 931 A.2d 348 (discussing filing of briefs by appointed counsel, pursuant to Anders , to inform court that ha 2017On April 29, 2016, the petitioner's appellate counsel filed an Anders brief and a motion for permission to withdraw as counsel, representing that "[u]pon thorough review and examination of the transcripts, information and record in this matter, the undersigned has determined that an appeal in this matter would be frivolous." See Anders v. California , 386 U.S. 738 , 744-45, 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967) ; see, e.g., Lorthe v. Commissioner of Correction , 103 Conn.App. 662 , 674, 931 A.2d 348 (discussing filing of briefs by appointed counsel, pursuant to Anders , to inform court that ha	5	14
In Re VEgreen pasuperct · 1992 · cited in 1 Connecticut opinions naming this issue, 2019–2019 2 sentences 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t	1	1
Austin v. United Statesgreen scotus · 1994 · cited in 1 Connecticut opinions naming this issue, 2019–2019 2 sentences 2019See, e.g., Austin v. United States, 513 U.S. 5, 8 , 115 S. Ct. 380 , 130 L. 2019See, e.g., Austin v. United States, 513 U.S. 5, 8 , 115 S. Ct. 380 , 130 L.	1	1
Capp Industries, Inc. v. Schoenberggreen conn · 2007 · cited in 1 Connecticut opinions naming this issue, 2017–2017 1 sentence 2017On April 29, 2016, the petitioner's appellate counsel filed an Anders brief and a motion for permission to withdraw as counsel, representing that "[u]pon thorough review and examination of the transcripts, information and record in this matter, the undersigned has determined that an appeal in this matter would be frivolous." See Anders v. California , 386 U.S. 738 , 744-45, 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967) ; see, e.g., Lorthe v. Commissioner of Correction , 103 Conn.App. 662 , 674, 931 A.2d 348 (discussing filing of briefs by appointed counsel, pursuant to Anders , to inform court that ha	1	1
Alexander v. Commissioner of Correctiongreen conn · 2007 · cited in 1 Connecticut opinions naming this issue, 2017–2017 1 sentence 2017On April 29, 2016, the petitioner's appellate counsel filed an Anders brief and a motion for permission to withdraw as counsel, representing that "[u]pon thorough review and examination of the transcripts, information and record in this matter, the undersigned has determined that an appeal in this matter would be frivolous." See Anders v. California , 386 U.S. 738 , 744-45, 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967) ; see, e.g., Lorthe v. Commissioner of Correction , 103 Conn.App. 662 , 674, 931 A.2d 348 (discussing filing of briefs by appointed counsel, pursuant to Anders , to inform court that ha	1	1
Lorthe v. Commissioner of Correctiongreen connappct · 2007 · cited in 1 Connecticut opinions naming this issue, 2017–2017 2 sentences 2017On April 29, 2016, the petitioner's appellate counsel filed an Anders brief and a motion for permission to withdraw as counsel, representing that "[u]pon thorough review and examination of the transcripts, information and record in this matter, the undersigned has determined that an appeal in this matter would be frivolous." See Anders v. California , 386 U.S. 738 , 744-45, 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967) ; see, e.g., Lorthe v. Commissioner of Correction , 103 Conn.App. 662 , 674, 931 A.2d 348 (discussing filing of briefs by appointed counsel, pursuant to Anders , to inform court that ha 2017On April 29, 2016, the petitioner's appellate counsel filed an Anders brief and a motion for permission to withdraw as counsel, representing that "[u]pon thorough review and examination of the transcripts, information and record in this matter, the undersigned has determined that an appeal in this matter would be frivolous." See Anders v. California , 386 U.S. 738 , 744-45, 87 S.Ct. 1396 , 18 L.Ed.2d 493 (1967) ; see, e.g., Lorthe v. Commissioner of Correction , 103 Conn.App. 662 , 674, 931 A.2d 348 (discussing filing of briefs by appointed counsel, pursuant to Anders , to inform court that ha	1	1
In Re Maygreen nc · 2003 · cited in 1 Connecticut opinions naming this issue, 2013–2013 1 sentence 2013Id., 300.	1	1
Coleman v. Commissioner of Correctiongreen conn · 2005 · cited in 1 Connecticut opinions naming this issue, 2007–2007 2 sentences 2007If the record is inadequate for review, it is inadequate for plain error consideration. 5 In the context of the Anders motion, the third issue involved the alleged ineffective assistance of Gary A. Mastronardi, private counsel the petitioner retained subsequent to arraignment, as well as Pox’ assessment of the validity of the petitioner’s guilty plea. 6 The respondent also argues that we should be guided by its argument in Coleman v. Commissioner, 99 Conn. App. 310 , 913 A.2d 477 , cert. denied, 670 281 Conn. 924 , 918 A.2d 275 (2007); see also Coleman v. Commissioner of Correction, 274 Conn. 2007If the record is inadequate for review, it is inadequate for plain error consideration. 5 In the context of the Anders motion, the third issue involved the alleged ineffective assistance of Gary A. Mastronardi, private counsel the petitioner retained subsequent to arraignment, as well as Pox’ assessment of the validity of the petitioner’s guilty plea. 6 The respondent also argues that we should be guided by its argument in Coleman v. Commissioner, 99 Conn. App. 310 , 913 A.2d 477 , cert. denied, 670 281 Conn. 924 , 918 A.2d 275 (2007); see also Coleman v. Commissioner of Correction, 274 Conn.	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (24)

Case	Cited	Years
Franko v. Bronson green connappct · 1989 2 sentences 2007On the basis of his review of all of the records of the underlying crime, Fox concluded that the claims of ineffective assistance of counsel against Hankins and Mastronardi were frivolous and without merit, and sought the court’s permission to withdraw as counsel pursuant to Anders v. California, supra, 386 U.S. 738 , and Franko v. Bronson, 19 Conn. App. 686 , 563 A.2d 1036 (1989). 20 Fox also represented that the petitioner had received notice of the Anders motion and had thirty days within which to respond in writing. 2007On the basis of his review of all of the records of the underlying crime, Fox concluded that the claims of ineffective assistance of counsel against Hankins and Mastronardi were frivolous and without merit, and sought the court’s permission to withdraw as counsel pursuant to Anders v. California, supra, 386 U.S. 738 , and Franko v. Bronson, 19 Conn. App. 686 , 563 A.2d 1036 (1989). 20 Fox also represented that the petitioner had received notice of the Anders motion and had thirty days within which to respond in writing.	4	1995–2007
State v. Francis green conn · 2016 2 sentences 2017Accordingly, we can perceive no reason why appointed counsel, having carefully reviewed the record for possible sentencing errors in light of the governing legal principles and determined that none exist, must then be required to file an Anders brief identifying anything in the record that might arguably support a countervailing view, or why the trial court should then be required to undertake a full and independent review of the record to determine whether it agrees 595 with defense counsel's assessment of the defendant's claimed sentencing error." (Citations omitted.) Id., at 265-66 , 140 A 2017Accordingly, we can perceive no reason why appointed counsel, having carefully reviewed the record for possible sentencing errors in light of the governing legal principles and determined that none exist, must then be required to file an Anders brief identifying anything in the record that might arguably support a countervailing view, or why the trial court should then be required to undertake a full and independent review of the record to determine whether it agrees 595 with defense counsel's assessment of the defendant's claimed sentencing error." (Citations omitted.) Id., at 265-66 , 140 A	2	2016–2017
In re H.E. green mont · 2002 1 sentence 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t	1	2019–2019
In Re HE green mont · 2002 1 sentence 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t	1	2019–2019
Medical Review Panel for Claim of Brewer green la · 2006 1 sentence 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t	1	2019–2019
Gregory C. v. Los Angeles County Department of Children's Services neutral scotus · 1997 1 sentence 2019Gregory C. v. Los Angeles County Dept. of Children’s Services, 519 U.S. 1081 , 117 S. Ct. 747 , 136 L.	1	2019–2019
Williams v. Washington green scotus · 1997 1 sentence 2019Gregory C. v. Los Angeles County Dept. of Children’s Services, 519 U.S. 1081 , 117 S. Ct. 747 , 136 L.	1	2019–2019
Montez Garcia v. Johnson green scotus · 1997 1 sentence 2019Gregory C. v. Los Angeles County Dept. of Children’s Services, 519 U.S. 1081 , 117 S. Ct. 747 , 136 L.	1	2019–2019
In Re Sade C. green cal · 1996 2 sentences 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t	1	2019–2019
Denise H. v. Arizona Department of Economic Security green arizctapp · 1998 2 sentences 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t	1	2019–2019
Los Angeles County Department of Children's Services v. Gregory C. green cal · 1996 1 sentence 2019App.) (Anders applies under federal constitution, as well as rules of court), review denied, 936 So. 2d 1278 (La. 2006); In re V.E., 417 Pa. Super. 68, 81, 83 , 611 A.2d 1267 (1992) (Anders applies under federal constitution); In re H.E., 312 Mont. 182, 186 , 59 P.3d 29 (2002) (Anders applies, but constitutional basis was unspecified); L.C. v. State, supra, 963 P.2d 763–66 (Anders applies under both Utah and federal constitu- tions).23 But see Denise H. v. Arizona Dept. of Economic Security, 193 Ariz. 257 , 259–60, 972 P.2d 241 (App. 1998) (indigent parent has due process and statutory right t	1	2019–2019
Gaddie v. State green ind · 1991 1 sentence 2016Suffice it to say that we do not believe that the potential benefits of requiring the Anders procedure in the present context outweigh the costs, most notable among them being delays that inevitably would occur in the adjudication of a motion intended "to provide prompt, direct access to an uncomplicated legal process for correcting the occasional erroneous or illegal sentence." Gaddie v. State, 566 N.E.2d 535 , 537 (Ind.1991) ; see, e.g., United States ex rel.	1	2016–2016
Montejo v. Louisiana green scotus · 2009 2 sentences 2016Accordingly, we can perceive no reason why appointed counsel, having carefully reviewed the record for possible sentencing errors in light of governing legal principles and determined that none exist, must then be required to file an Anders brief identifying anything in the record that might arguably support a countervailing view, or why the trial court should then be required to undertake a full and independent review of the record to determine whether it agrees with defense counsel's assessment of the defendant's claimed sentencing error. 9 In reaching our conclusion, we are also mindful tha 2016Accordingly, we can perceive no reason why appointed counsel, having carefully reviewed the record for possible sentencing errors in light of governing legal principles and determined that none exist, must then be required to file an Anders brief identifying anything in the record that might arguably support a countervailing view, or why the trial court should then be required to undertake a full and independent review of the record to determine whether it agrees with defense counsel's assessment of the defendant's claimed sentencing error. 9 In reaching our conclusion, we are also mindful tha	1	2016–2016
In Re May green ncctapp · 2002 1 sentence 2013In support of his claim in this court, the petitioner relies on In re May, 153 N.C.	1	2013–2013
State v. Pascucci green conn · 1971 1 sentence 2009In State v. Pascucci, 161 *464 Conn. 382, 385-86, 288 A.2d 408 (1971), our Supreme Court stated: “[T]he United States Supreme Court in Anders v. California, [supra, 386 U.S. 738 ], outlined the procedure which it held was constitutionally required in such circumstances to assure to indigent defendants substantial equality and fair process on appeal. ...	1	2009–2009
North Carolina v. Alford green scotus · 1970 2 sentences 2009The appeal is dismissed. 1 See North Carolina v. Alford, 400 U.S. 25 , 91 S. Ct. 160 , 27 L. 2009The appeal is dismissed. 1 See North Carolina v. Alford, 400 U.S. 25 , 91 S. Ct. 160 , 27 L.	1	2009–2009
Mabry v. Johnson green scotus · 1984 2 sentences 2009Specifically, habeas counsel maintained that under Mabry v. Johnson, 467 U.S. 504 , 104 S. Ct. 2543 , 81 L. 2009Specifically, habeas counsel maintained that under Mabry v. Johnson, 467 U.S. 504 , 104 S. Ct. 2543 , 81 L.	1	2009–2009
Coleman v. Commissioner of Correction neutral connappct · 2007 2 sentences 2007If the record is inadequate for review, it is inadequate for plain error consideration. 5 In the context of the Anders motion, the third issue involved the alleged ineffective assistance of Gary A. Mastronardi, private counsel the petitioner retained subsequent to arraignment, as well as Pox’ assessment of the validity of the petitioner’s guilty plea. 6 The respondent also argues that we should be guided by its argument in Coleman v. Commissioner, 99 Conn. App. 310 , 913 A.2d 477 , cert. denied, 670 281 Conn. 924 , 918 A.2d 275 (2007); see also Coleman v. Commissioner of Correction, 274 Conn. 2007If the record is inadequate for review, it is inadequate for plain error consideration. 5 In the context of the Anders motion, the third issue involved the alleged ineffective assistance of Gary A. Mastronardi, private counsel the petitioner retained subsequent to arraignment, as well as Pox’ assessment of the validity of the petitioner’s guilty plea. 6 The respondent also argues that we should be guided by its argument in Coleman v. Commissioner, 99 Conn. App. 310 , 913 A.2d 477 , cert. denied, 670 281 Conn. 924 , 918 A.2d 275 (2007); see also Coleman v. Commissioner of Correction, 274 Conn.	1	2007–2007
Novak v. Levin neutral conn · 2007 1 sentence 2007If the record is inadequate for review, it is inadequate for plain error consideration. 5 In the context of the Anders motion, the third issue involved the alleged ineffective assistance of Gary A. Mastronardi, private counsel the petitioner retained subsequent to arraignment, as well as Pox’ assessment of the validity of the petitioner’s guilty plea. 6 The respondent also argues that we should be guided by its argument in Coleman v. Commissioner, 99 Conn. App. 310 , 913 A.2d 477 , cert. denied, *670 281 Conn. 924 , 918 A.2d 275 (2007); see also Coleman v. Commissioner of Correction, 274 Conn.	1	2007–2007
Sullivan v. Delisa green conn · 2007 1 sentence 2007If the record is inadequate for review, it is inadequate for plain error consideration. 5 In the context of the Anders motion, the third issue involved the alleged ineffective assistance of Gary A. Mastronardi, private counsel the petitioner retained subsequent to arraignment, as well as Pox’ assessment of the validity of the petitioner’s guilty plea. 6 The respondent also argues that we should be guided by its argument in Coleman v. Commissioner, 99 Conn. App. 310 , 913 A.2d 477 , cert. denied, *670 281 Conn. 924 , 918 A.2d 275 (2007); see also Coleman v. Commissioner of Correction, 274 Conn.	1	2007–2007
Collins v. York green conn · 1970 2 sentences 2007Those procedural changes do not affect this case. 21 Habeas corpus proceedings are civil in nature; Collins v. York, 159 Conn. 150, 153 , 267 A.2d 668 (1970); and the petitioner has no constitutional right to a jury trial. 22 Prior to the canvass, the prosecutor provided the trial court with the following factual basis for the murder charge against the petitioner. “[T]his incident, as the [court] clerk indicated, took place on the thirtieth of March of the year 2000 at approximately quarter to ten in the evening. 2007Those procedural changes do not affect this case. 21 Habeas corpus proceedings are civil in nature; Collins v. York, 159 Conn. 150, 153 , 267 A.2d 668 (1970); and the petitioner has no constitutional right to a jury trial. 22 Prior to the canvass, the prosecutor provided the trial court with the following factual basis for the murder charge against the petitioner. “[T]his incident, as the [court] clerk indicated, took place on the thirtieth of March of the year 2000 at approximately quarter to ten in the evening.	1	2007–2007
Vazquez v. Commissioner of Correction green connappct · 2005 2 sentences 2007I hope they can forgive me some day.” 20 Subsequent to the date Fox filed the Anders motion, this court modified some of the Franko procedures in Vazquez v. Commissioner of Correction, 88 Conn. App. 226 , 869 A.2d 234 (2005). 2007I hope they can forgive me some day.” 20 Subsequent to the date Fox filed the Anders motion, this court modified some of the Franko procedures in Vazquez v. Commissioner of Correction, 88 Conn. App. 226 , 869 A.2d 234 (2005).	1	2007–2007
Simms v. Warden green conn · 1994	1	2005–2005
Simms v. Warden, State Prison green conn · 1994	1	2005–2005

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 23-41 (4) CT § Conn. Gen. Stat. § 43-22 (4) CT § Conn. Gen. Stat. § 52-470 (4) CT § Conn. Gen. Stat. § 53a-134 (4) CT § Conn. Gen. Stat. § 23-42 (3) CT § Conn. Gen. Stat. § 51-296 (3) CT § Conn. Gen. Stat. § 53a-54a (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 5327 (1925–2026) PA 2839 (1970–2026) OH 509 (1994–2026) LA 346 (1995–2025) NY 157 (1989–2026) FL 125 (1972–2026) CA 65 (1992–2026) IL 64 (1973–2026) AZ 56 (1970–2022) AR 54 (2001–2026) KY 34 (2001–2026) WA 29 (1969–2024) NC 23 (1994–2025) UT 21 (1978–2023) CT 21 (1986–2019) GA 19 (1978–2022) MT 15 (1992–2025) WY 14 (1989–2023) AL 10 (1986–2015) SC 9 (2002–2024) OR 6 (1984–2025) IN 6 (1972–2026) VT 5 (2005–2014) MI 4 (1984–2022) CO 4 (2006–2010) WI 4 (1974–2001) AK 3 (1988–2023) DC 3 (1981–2026) TN 3 (1997–2000) SD 2 (2004–2015) HI 2 (1996–2001) IA 2 (2021–2021) ND 2 (2020–2020) VA 2 (2003–2022)

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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