knock and announce rule in Washington

21 Washington opinions name it 2 courts 1972–2020 0 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 (12)

Case	Followed	Cited
State v. Coylegreen wash · 1980 · cited in 8 Washington opinions naming this issue, 1982–2019 2 sentences 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule	2	8
State v. Carsongreen washctapp · 1978 · cited in 2 Washington opinions naming this issue, 2002–2002 2 sentences 2002See also State v. Carson, 21 Wash. App. 318 , 584 P.2d 990 (1978) (presence or absence of exigent circumstances sufficient to constitute an exception to the knock and wait rule is factual determination to be made by trial court); State v. Young, 76 Wash.2d 212, 217 , 455 P.2d 595 (1969); State v. Edwards, 20 Wash.App. 648 , 581 P.2d 154 (1978); State v. Woodall 32 Wash.App. 407 , 647 P.2d 1051 (1982), rev'd on other grounds, 100 Wash.2d 74 , 666 P.2d 364 (1983). 2002See also State v. Carson, 21 Wn.	2	2
State v. Richardsgreen wash · 1998 · cited in 5 Washington opinions naming this issue, 2002–2020 2 sentences 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule 2011Ed. 2d 56 (2006) (“the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression” (Kennedy, J., concurring)), with State v. Coyle, 95 Wn.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington’s knock-and-wait rule), and State v. Richards, 136 Wn.2d 361 , 962 P.2d 118 (1998)).	1	5
State v. Richardsgreen wash · 1998 · cited in 4 Washington opinions naming this issue, 2002–2020 2 sentences 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule 2011Ed. 2d 56 (2006) (“the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression” (Kennedy, J., concurring)), with State v. Coyle, 95 Wn.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington’s knock-and-wait rule), and State v. Richards, 136 Wn.2d 361 , 962 P.2d 118 (1998)).	1	4
United States v. Francisco Bustamante-Gamez, United States of America v. Abelardo Garcia-Ramirezgreen ca9 · 1973 · cited in 3 Washington opinions naming this issue, 1974–1994 2 sentences 1994We say this having in mind three interests that are advanced by the knock and announce requirement of § 3109 [the federal equivalent of RCW 10.31.040]: (1) reducing the potential for a violent confrontation between the police and an occupant startled by an unannounced intrusion, Miller v. United States, 357 U.S. 301 , 313 n. 12, 78 S.Ct. 1190 , 1198 n. 12, 2 L.Ed.2d 1332 (1958); (2) preventing needless destruction of private property, United States v. Bustamante-Gamez, 488 F.2d 4, 9 (9th Cir. 1973); and (3) showing respect for the individual’s privacy interest in his home. 1978United States v. Bustamante-Gamez, 488 F.2d 4 (9th Cir.1973); United States v. Mullin, 329 F.2d 295 (4th Cir.1964).	1	3
Hudson v. Michigangreen scotus · 2006 · cited in 1 Washington opinions naming this issue, 2011–2011 2 sentences 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule	1	1
State v. O'BREMSKIgreen wash · 1967 · cited in 1 Washington opinions naming this issue, 2011–2011 2 sentences 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule	1	1
United States v. Maurice Kempgreen cadc · 1994 · cited in 1 Washington opinions naming this issue, 1997–1997 1 sentence 1997United States v. Kemp, 12 F.3d 1140, 1142 (D.C.	1	1
State v. Nedergardgreen washctapp · 1988 · cited in 1 Washington opinions naming this issue, 1992–1992 1 sentence 1992See State v. Nedergard, 51 Wn.	1	1
State v. Batesgreen ariz · 1978 · cited in 1 Washington opinions naming this issue, 1987–1987 2 sentences 1987State v. Bates, 120 Ariz. 561 , 587 P.2d 747, 749 (1978) (forcible entry to execute a search warrant after 3 to 5 seconds from announcement of purpose and authority was not "lengthy inaction" sufficient to constitute constructive refusal of admittance, therefore was unreasonable in the absence of information the occupants were armed or dangerous). 1987State v. Bates, 120 Ariz. 561 , 587 P.2d 747, 749 (1978) (forcible entry to execute a search warrant after 3 to 5 seconds from announcement of purpose and authority was not "lengthy inaction" sufficient to constitute constructive refusal of admittance, therefore was unreasonable in the absence of information the occupants were armed or dangerous).	1	1
Sandland v. Stategreen alaskactapp · 1981 · cited in 1 Washington opinions naming this issue, 1987–1987 1 sentence 1987Sandland , at 1198.	1	1
State v. Millergreen washctapp · 1972 · cited in 1 Washington opinions naming this issue, 1984–1984	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
State v. Young green wash · 1969 2 sentences 1974We next consider whether compliance with the knock and announce rule in this case was excused because of “exigent and necessitous circumstances,” State v. Young, 76 Wn.2d 212, 217 , 455 P.2d 595 (1969). 1974We next consider whether compliance with the knock and announce rule in this case was excused because of “exigent and necessitous circumstances,” State v. Young, 76 Wn.2d 212, 217 , 455 P.2d 595 (1969).	4	1974–2016
State of Washington v. Jude Joseph Ortiz neutral washctapp · 2016 2 sentences 2020State v. Ortiz, 196 Wn. 2019We evaluate the reasonableness of the waiting period by looking to the underlying purposes of the knock and announce rule, including “‘(1) reduction of potential violence to both occupants and police arising from an unannounced entry, (2) prevention of unnecessary property damage, and (3) protection of an occupant’s right to privacy.’” Ortiz, 196 Wn.	2	2019–2020
State v. Garcia-Hernandez green washctapp · 1992 2 sentences 2016Id. at 496 . 1997Coyle, 95 Wn.2d at 5 ; State v. Garcia-Hernandez, 67 Wn.	2	1997–2016
Richards v. Wisconsin green scotus · 1997 2 sentences 2002Strict compliance with the knock and announce rule is required unless the State can demonstrate that the police had “a reasonable suspicion that knocking and announcing their presence, under the particular circumstances, would be dangerous or futile, or that it would inhibit the effective investigation of the crime by, for example, allowing the destruction of evidence.” Richards v. Wisconsin, 520 U.S. 385, 394 , 117 S. Ct. 1416 , 137 L. 2002Strict compliance with the knock and announce rule is required unless the State can demonstrate that the police had “a reasonable suspicion that knocking and announcing their presence, under the particular circumstances, would be dangerous or futile, or that it would inhibit the effective investigation of the crime by, for example, allowing the destruction of evidence.” Richards v. Wisconsin, 520 U.S. 385, 394 , 117 S. Ct. 1416 , 137 L.	2	2002–2002
State v. Woodall green washctapp · 1982 2 sentences 2002See also State v. Carson, 21 Wash. App. 318 , 584 P.2d 990 (1978) (presence or absence of exigent circumstances sufficient to constitute an exception to the knock and wait rule is factual determination to be made by trial court); State v. Young, 76 Wash.2d 212, 217 , 455 P.2d 595 (1969); State v. Edwards, 20 Wash.App. 648 , 581 P.2d 154 (1978); State v. Woodall 32 Wash.App. 407 , 647 P.2d 1051 (1982), rev'd on other grounds, 100 Wash.2d 74 , 666 P.2d 364 (1983). 2002See also State v. Carson, 21 Wash. App. 318 , 584 P.2d 990 (1978) (presence or absence of exigent circumstances sufficient to constitute an exception to the knock and wait rule is factual determination to be made by trial court); State v. Young, 76 Wash.2d 212, 217 , 455 P.2d 595 (1969); State v. Edwards, 20 Wash.App. 648 , 581 P.2d 154 (1978); State v. Woodall 32 Wash.App. 407 , 647 P.2d 1051 (1982), rev'd on other grounds, 100 Wash.2d 74 , 666 P.2d 364 (1983).	2	1987–2002
Miller v. United States green scotus · 1958 2 sentences 1994We say this having in mind three interests that are advanced by the knock and announce requirement of § 3109 [the federal equivalent of RCW 10.31.040]: (1) reducing the potential for a violent confrontation between the police and an occupant startled by an unannounced intrusion, Miller v. United States, 357 U.S. 301 , 313 n. 12, 78 S.Ct. 1190 , 1198 n. 12, 2 L.Ed.2d 1332 (1958); (2) preventing needless destruction of private property, United States v. Bustamante-Gamez, 488 F.2d 4, 9 (9th Cir. 1973); and (3) showing respect for the individual’s privacy interest in his home. 1994We say this having in mind three interests that are advanced by the knock and announce requirement of § 3109 [the federal equivalent of RCW 10.31.040]: (1) reducing the potential for a violent confrontation between the police and an occupant startled by an unannounced intrusion, Miller v. United States, 357 U.S. 301 , 313 n. 12, 78 S.Ct. 1190 , 1198 n. 12, 2 L.Ed.2d 1332 (1958); (2) preventing needless destruction of private property, United States v. Bustamante-Gamez, 488 F.2d 4, 9 (9th Cir. 1973); and (3) showing respect for the individual’s privacy interest in his home.	2	1974–1994
State v. Myers green wash · 1984 2 sentences 1990State v. Myers, 102 Wn.2d 548, 552 , 689 P.2d 38 (1984). 1990State v. Myers, 102 Wn.2d 548, 552 , 689 P.2d 38 (1984).	2	1987–1990
State v. Hatcher green washctapp · 1970 2 sentences 1974In State v. Hatcher, 3 Wn. 1972Hatcher, 3 Wn.	2	1972–1974
State v. Cardenas green wash · 2002 1 sentence 2020Id.	1	2020–2020
Strickland v. Washington green scotus · 1984 2 sentences 2016Strickland v. Washington, 466 U.S. 668, 686 , 104 S. Ct. 2052 , 80 L. 2016Strickland v. Washington, 466 U.S. 668, 686 , 104 S. Ct. 2052 , 80 L.	1	2016–2016
Richardson v. State green fladistctapp · 2001 1 sentence 2016Id. at 908 . ¶26 This case is nearly identical to these two cases. ¶27 Because the police violated the knock and announce rule, and there is no legitimate strategic or tactical reason for failing to challenge the search, counsel was deficient for not moving to suppress the evidence.	1	2016–2016
State v. Johnson green washctapp · 1999 1 sentence 2016Id. at 543-44 . ¶18 Likewise, in State v. Johnson, 94 Wn.	1	2016–2016
State v. Lomax neutral washctapp · 1979 2 sentences 2016Each case is distinguishable from the facts present here. ¶17 In State v. Lomax, 24 Wn. 2016Id. at 543-44 . ¶18 Likewise, in State v. Johnson, 94 Wn.	1	2016–2016
State v. Vangen green wash · 1967 2 sentences 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule	1	2011–2011
State v. Rothenberger green wash · 1968 2 sentences 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule 2011Compare Hudson v. Michigan, 547 U.S. 586, 603 , 126 S.Ct. 2159 , 165 L.Ed.2d 56 (2006) ("the causal link between a violation of the knock-and-announce requirement and a later search is too attenuated to allow suppression" (Kennedy, J., concurring)), with State v. Coyle, 95 Wash.2d 1, 14 , 621 P.2d 1256 (1980) (stating that suppression is the proper remedy for violations of Washington's knock-and-wait rule), and State v. Richards, 136 Wash.2d 361 , 962 P.2d 118 (1998). [8] E.g., State v. O'Bremski, 70 Wash.2d 425, 428 , 423 P.2d 530 (1967) ("We have consistently adhered to the exclusionary rule	1	2011–2011
State v. Woodall green wash · 1983 2 sentences 2002See also State v. Carson, 21 Wash. App. 318 , 584 P.2d 990 (1978) (presence or absence of exigent circumstances sufficient to constitute an exception to the knock and wait rule is factual determination to be made by trial court); State v. Young, 76 Wash.2d 212, 217 , 455 P.2d 595 (1969); State v. Edwards, 20 Wash.App. 648 , 581 P.2d 154 (1978); State v. Woodall 32 Wash.App. 407 , 647 P.2d 1051 (1982), rev'd on other grounds, 100 Wash.2d 74 , 666 P.2d 364 (1983). 2002See also State v. Carson, 21 Wash. App. 318 , 584 P.2d 990 (1978) (presence or absence of exigent circumstances sufficient to constitute an exception to the knock and wait rule is factual determination to be made by trial court); State v. Young, 76 Wash.2d 212, 217 , 455 P.2d 595 (1969); State v. Edwards, 20 Wash.App. 648 , 581 P.2d 154 (1978); State v. Woodall 32 Wash.App. 407 , 647 P.2d 1051 (1982), rev'd on other grounds, 100 Wash.2d 74 , 666 P.2d 364 (1983).	1	2002–2002
State v. Edwards neutral washctapp · 1978 2 sentences 2002See also State v. Carson, 21 Wash. App. 318 , 584 P.2d 990 (1978) (presence or absence of exigent circumstances sufficient to constitute an exception to the knock and wait rule is factual determination to be made by trial court); State v. Young, 76 Wash.2d 212, 217 , 455 P.2d 595 (1969); State v. Edwards, 20 Wash.App. 648 , 581 P.2d 154 (1978); State v. Woodall 32 Wash.App. 407 , 647 P.2d 1051 (1982), rev'd on other grounds, 100 Wash.2d 74 , 666 P.2d 364 (1983). 2002See also State v. Carson, 21 Wash. App. 318 , 584 P.2d 990 (1978) (presence or absence of exigent circumstances sufficient to constitute an exception to the knock and wait rule is factual determination to be made by trial court); State v. Young, 76 Wash.2d 212, 217 , 455 P.2d 595 (1969); State v. Edwards, 20 Wash.App. 648 , 581 P.2d 154 (1978); State v. Woodall 32 Wash.App. 407 , 647 P.2d 1051 (1982), rev'd on other grounds, 100 Wash.2d 74 , 666 P.2d 364 (1983).	1	2002–2002
State v. Ellis green washctapp · 1978 1 sentence 1997Because the uniformed officers were not immediately visible, and because the lead detectives were not readily identifiable by their clothing as legitimate law enforcement officers, Richards argues that this case is similar to State v. Ellis, 21 Wn.	1	1997–1997
State v. Lehman green washctapp · 1985 2 sentences 1990The Lehman court held that the officers sufficiently complied with the knock and announce rule because "[t]o wait for a grant or denial of admission . . . would serve no purpose." State v. Lehman, 40 Wn. 1990The Lehman court held that the officers sufficiently complied with the knock and announce rule because "[t]o wait for a grant or denial of admission ... would serve no purpose." State v. Lehman, 40 Wn.	1	1990–1990
State v. McIntyre green washctapp · 1984	1	1987–1987
State v. Berlin green washctapp · 1987	1	1987–1987
State v. Jeter green washctapp · 1981	1	1987–1987
Dalia v. United States green scotus · 1979	1	1982–1982
State v. Jones green washctapp · 1976	1	1982–1982
State v. Wilson green washctapp · 1973	1	1982–1982
State v. Hilliard green washctapp · 1978	1	1979–1979
State v. Campbell green washctapp · 1976	1	1979–1979
United States v. Grover Lee Mullin and Stephen Parker Perry green ca4 · 1964	1	1978–1978
People v. Gallmon green ny · 1967	1	1978–1978

Statutes the citing opinions construe

WA § Wash. Rev. Code § 10.31.040 (19) WA § Wash. Rev. Code § 2.06.040 (3) WA § Wash. Rev. Code § 69.50.401 (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

PA 54 (1982–2023) NM 34 (1993–2023) FL 32 (1979–2026) OH 30 (1983–2017) MA 30 (1980–2025) TX 29 (2002–2013) NJ 27 (1995–2026) IL 25 (1978–2010) WA 21 (1972–2020) WI 21 (1985–2022) OR 13 (1970–2014) MD 13 (1997–2009) HI 11 (1995–2022) DC 11 (1990–2002) ND 11 (1985–2014) MN 10 (1972–2015) LA 9 (1998–2015) MI 9 (1997–2003) IN 8 (1972–2010) VA 8 (1989–2007) AR 8 (1982–2017) RI 7 (1974–2014) CA 7 (2000–2016) MO 6 (1998–2011) UT 6 (1988–2015) AL 6 (1984–2004) NY 6 (1977–2024) DE 6 (1969–2015) TN 6 (1998–2010) MT 5 (2004–2019) KS 5 (1992–2014) CO 4 (1989–2011) IA 4 (1982–2017) NC 4 (1979–2002) KY 4 (1998–2024) NE 3 (1991–2016) AZ 3 (1981–2010) NH 3 (1985–2010) AK 2 (1979–1986) GA 2 (2005–2012) OK 2 (2007–2024) VT 2 (1993–2000)

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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