noscitur a sociis doctrine (California) · Go Syfert
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noscitur a sociis doctrine in California

19 California opinions name it 3 courts 1987–2025 7 in the last five years

The cases below were cited by California 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 (16)

CaseFollowedCited
Texas Commerce Bank v. Garamendigreen
calctapp · 1992 · cited in 3 California opinions naming this issue, 2006–2025
2 sentences

2025(See Yassin v. Solis (2010) 184 Cal.App.4th 524, 536 .) 50 Although the trial court does not reference it, the trial court appears to be applying the doctrine of noscitur a sociis (it is known by its associates), which is the principle that “ ‘ “the meaning of a word may be enlarged or restrained by reference to the object of the whole clause in which it is used.” ’ ” (Dyna-Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1391, fn. 14 .) However, that principle is “applicable to terms that are ‘associated’ by grouping or serial enumeration in the same phrase or clause, not to

2025(See Yassin v. Solis (2010) 184 Cal.App.4th 524, 536 .) 50 Although the trial court does not reference it, the trial court appears to be applying the doctrine of noscitur a sociis (it is known by its associates), which is the principle that “ ‘ “the meaning of a word may be enlarged or restrained by reference to the object of the whole clause in which it is used.” ’ ” (Dyna-Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1391, fn. 14 .) However, that principle is “applicable to terms that are ‘associated’ by grouping or serial enumeration in the same phrase or clause, not to

33
Dyna-Med, Inc. v. Fair Employment & Housing Commissionred
cal · 1987 · cited in 3 California opinions naming this issue, 2014–2025
2 sentences

2025(See Yassin v. Solis (2010) 184 Cal.App.4th 524, 536 .) 50 Although the trial court does not reference it, the trial court appears to be applying the doctrine of noscitur a sociis (it is known by its associates), which is the principle that “ ‘ “the meaning of a word may be enlarged or restrained by reference to the object of the whole clause in which it is used.” ’ ” (Dyna-Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1391, fn. 14 .) However, that principle is “applicable to terms that are ‘associated’ by grouping or serial enumeration in the same phrase or clause, not to

2014“Expressio unius est exclusio alterius means that ‘the expression of certain things in a [contract] necessarily involves exclusion of other things not expressed. . . .’ [Citation.]” (Dyna–Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1391, fn. 13 .) The same logic is reflected in the doctrine of noscitur a sociis, meaning “it is known by friends.” “Under the rule of noscitur a sociis, ‘ “the meaning of a word may be enlarged or restrained by reference to the object of the whole clause in which it is used.” ’ [Citations.]” (Id. at p. 1391, fn. 14.) “ ‘In accordance with thi

33
People v. Drennangreen
calctapp · 2000 · cited in 2 California opinions naming this issue, 2006–2008
2 sentences

2008Noscitur a sociis (it is *1371 known by its associates) is the principle that "a word takes meaning from the company it keeps." ( People v. Drennan (2000) 84 Cal.App.4th 1349, 1355 [ 101 Cal.Rptr.2d 584 ].) "`In accordance with this principle of construction, a court will adopt a restrictive meaning of a listed item if acceptance of a more expansive meaning would . . . make the item markedly dissimilar to the other items in the list.'" ( People ex rel.

2008Noscitur a sociis (it is *1371 known by its associates) is the principle that "a word takes meaning from the company it keeps." ( People v. Drennan (2000) 84 Cal.App.4th 1349, 1355 [ 101 Cal.Rptr.2d 584 ].) "`In accordance with this principle of construction, a court will adopt a restrictive meaning of a listed item if acceptance of a more expansive meaning would . . . make the item markedly dissimilar to the other items in the list.'" ( People ex rel.

22
Moore v. California State Board of Accountancygreen
cal · 1992 · cited in 2 California opinions naming this issue, 1994–2023
2 sentences

2023(See Moore v. California State Bd. of Accountancy (1992) 2 Cal.4th 999 , 1011–1012 [any maxim of jurisprudence, including ejusdem generis and noscitur a sociis, must yield to legislative intent if application of maxim would frustrate intent underlying statute]; Irwin v. City of Manhattan Beach (1966) 65 Cal.2d 13, 21 [“quest after legislative purpose remains paramount” to all maxims of jurisprudence which operate as interpretive aids]; Almond Alliance of California v. Fish & Game Com. (2022) 79 Cal.App.5th 337 , 354 [“Statutory interpretation cannons . . . must heed to legislative intent”].) 3

1994In accordance with this principle of construction, a court will adopt a restrictive meaning of a listed item if acceptance of a more expansive meaning ... would otherwise make the item markedly dissimilar to the other items in the list." ( Moore v. California State Bd. of Accountancy (1992) 2 Cal.4th 999, 1011-1012 [ 9 Cal. Rptr.2d 358 , 831 P.2d 798 ].) The majority opinion fails to follow this directive, instead choosing to interpret isolated phrases without reference to the whole.

12
Irwin v. City of Manhattan Beachgreen
cal · 1966 · cited in 1 California opinions naming this issue, 2023–2023
1 sentence

2023(See Moore v. California State Bd. of Accountancy (1992) 2 Cal.4th 999 , 1011–1012 [any maxim of jurisprudence, including ejusdem generis and noscitur a sociis, must yield to legislative intent if application of maxim would frustrate intent underlying statute]; Irwin v. City of Manhattan Beach (1966) 65 Cal.2d 13, 21 [“quest after legislative purpose remains paramount” to all maxims of jurisprudence which operate as interpretive aids]; Almond Alliance of California v. Fish & Game Com. (2022) 79 Cal.App.5th 337 , 354 [“Statutory interpretation cannons . . . must heed to legislative intent”].) 3

11
Colleen v. Ford v. Schering-Plough Corporation Schering Corporation Metropolitan Life Insurance Companygreen
ca3 · 1998 · cited in 1 California opinions naming this issue, 2023–2023
1 sentence

2023The principle of noscitur a sociis requires that the term, ‘place of public accommodation,’ be interpreted within the context of the accompanying words, and 20 this context suggests that some connection between the good or service complained of and an actual physical place is required.” (Weyer, supra, 198 F.3d at p. 1114, first italics added; see also Ford, supra, 145 F.3d at p. 614 [“the doctrine of noscitur a sociis” directs that terms “should be interpreted by reference to the accompanying words of the statute ‘to avoid the giving of unintended breadth to the Acts of Congress’ ”].) The Mart

11
Helen Weyer v. Twentieth Century Fox Film Corporationgreen
ca9 · 2000 · cited in 1 California opinions naming this issue, 2023–2023
2 sentences

2023The principle of noscitur a sociis requires that the term, ‘place of public accommodation,’ be interpreted within the context of the accompanying words, and 20 this context suggests that some connection between the good or service complained of and an actual physical place is required.” (Weyer, supra, 198 F.3d at p. 1114, first italics added; see also Ford, supra, 145 F.3d at p. 614 [“the doctrine of noscitur a sociis” directs that terms “should be interpreted by reference to the accompanying words of the statute ‘to avoid the giving of unintended breadth to the Acts of Congress’ ”].) The Mart

2023The principle of noscitur a sociis requires that the term, ‘place of public accommodation,’ be interpreted within the context of the accompanying words, and 20 this context suggests that some connection between the good or service complained of and an actual physical place is required.” (Weyer, supra, 198 F.3d at p. 1114, first italics added; see also Ford, supra, 145 F.3d at p. 614 [“the doctrine of noscitur a sociis” directs that terms “should be interpreted by reference to the accompanying words of the statute ‘to avoid the giving of unintended breadth to the Acts of Congress’ ”].) The Mart

11
People ex rel. Lungren v. Superior Courtgreen
cal · 1996 · cited in 1 California opinions naming this issue, 2023–2023
1 sentence

2023(See Lungren, supra, 14 Cal.4th at p. 308 [rejecting an invocation of the noscitur a sociis principle because when viewed in light of the relevant statute’s broader purpose, “the seeming dissimilarities between” 24 In re N.R.

11
Blue Shield of California Life & Health Insurance v. Superior Courtgreen
calctapp · 2011 · cited in 1 California opinions naming this issue, 2022–2022
1 sentence

2022Co. v. Superior Court (2011) 192 Cal.App.4th 727, 740 [same].) 16 Thus, pursuant to the doctrine of noscitur a sociis, the disputed term cannot be so narrowly construed so as to “ ‘ “make the item markedly dissimilar to the other items in the list, ” ’ ” but it also cannot be so broadly construed so as to “ ‘ “make other items in the list unnecessary or redundant.” ’ ” (Busker v. Wabtec Corp. (2021) 11 Cal.5th 1147 , 1160 & fn. 11 [construing a term so that it is not “markedly different” from other listed terms].) Here, NetEase’s narrow construction of the third listed term in the series would

11
Blue v. Bontagreen
calctapp · 2002 · cited in 1 California opinions naming this issue, 2014–2014
1 sentence

2014(Blue v. Bonta’, supra, 99 Cal.App.4th at p. 989.) These rules are aids to statutory construction, bearing in mind that “our first task ... is to ascertain the intent of the Legislature so as to effectuate the purpose of the law.” (Dyna-Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1386 [ 241 Cal.Rptr. 67 , 743 P.2d 1323 ].) 6 The statute reads: “A person or entity that takes, secretes, appropriates, obtains, or retains, or assists in taking, secreting, appropriating, obtaining, or retaining the real or personal property of an elder or dependent adult when the elder or dep

11
O'GRADY v. Superior Courtgreen
calctapp · 2006 · cited in 1 California opinions naming this issue, 2014–2014
2 sentences

2014Under this rule “ ‘ “where general words follow the enumeration of particular classes of person or things, the general words will be construed as applicable only to person or things of the same general nature or class as those enumerated.” ’ ” (O’Grady v. Superior Court (2006) 139 Cal.App.4th 1423, 1461 [ 44 Cal.Rptr.3d 72 ].) The second is the doctrine of noscitur a sociis which provides that a term may be defined by reference to the fellow members of its class.

2014Under this rule “ ‘ “where general words follow the enumeration of particular classes of person or things, the general words will be construed as applicable only to person or things of the same general nature or class as those enumerated.” ’ ” (O’Grady v. Superior Court (2006) 139 Cal.App.4th 1423, 1461 [ 44 Cal.Rptr.3d 72 ].) The second is the doctrine of noscitur a sociis which provides that a term may be defined by reference to the fellow members of its class.

11
Credit Suisse First Boston Mortgage Capital, LLC v. Danning, Gill, Diamond & Kollitzgreen
calctapp · 2009 · cited in 1 California opinions naming this issue, 2011–2011
2 sentences

2011(Credit Suisse First Boston Mortgage Capital, LLC v. Darning, Gill, Diamond & Kollitz (2009) 178 Cal.App.4th 1290, 1298, fn. 6 [ 101 Cal.Rptr.3d 192 ].) Under this principle, courts will adopt a restrictive meaning of a listed item if acceptance of a broader meaning would make other items in the list unnecessary or redundant, or would otherwise make the item markedly dissimilar to the other items in the list.

2011(Credit Suisse First Boston Mortgage Capital, LLC v. Darning, Gill, Diamond & Kollitz (2009) 178 Cal.App.4th 1290, 1298, fn. 6 [ 101 Cal.Rptr.3d 192 ].) Under this principle, courts will adopt a restrictive meaning of a listed item if acceptance of a broader meaning would make other items in the list unnecessary or redundant, or would otherwise make the item markedly dissimilar to the other items in the list.

11
Poway Unified School Dist. v. Superior Court of San Diego Countygreen
calctapp · 1998 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004(Poway Unified School Dist. v. Superior Court (1998) 62 Cal.App.4th 1496, 1503 [ 73 Cal.Rptr.2d 777 ].) Thus, the doctrine of noscitur a sociis (the meaning is derived from context) allows courts to find the meaning of a disputed phrase by reference to the entire enactment of which the phrase is a part.

2004(Poway Unified School Dist. v. Superior Court (1998) 62 Cal.App.4th 1496, 1503 [ 73 Cal.Rptr.2d 777 ].) Thus, the doctrine of noscitur a sociis (the meaning is derived from context) allows courts to find the meaning of a disputed phrase by reference to the entire enactment of which the phrase is a part.

11
Gifford v. J & a HOLDINGSgreen
calctapp · 1997 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004(Gifford v. J & A Holdings (1997) 54 Cal.App.4th 996, 1004 [ 63 Cal.Rptr.2d 253 ].) Where necessary, this involves drawing inferences as to meaning based on the context of the language under examination.

2004(Gifford v. J & A Holdings (1997) 54 Cal.App.4th 996, 1004 [ 63 Cal.Rptr.2d 253 ].) Where necessary, this involves drawing inferences as to meaning based on the context of the language under examination.

11
People v. Rogersred
cal · 1971 · cited in 1 California opinions naming this issue, 1994–1994
2 sentences

1994It is a principle of statutory construction that the meaning of a word may be determined by reference to other terms *50 that are associated with it in the same statute. ( People v. Rogers (1971) 5 Cal.3d 129, 142 [ 95 Cal. Rptr. 601 , 486 P.2d 129 ] (conc. and dis. opn. of Mosk, J.) [discussing doctrine of noscitur a sociis ].) "[W]hen a statute contains a list or catalogue of items, a court should determine the meaning of each by reference to the others, giving preference to an interpretation that uniformly treats items similar in nature and scope....

1994It is a principle of statutory construction that the meaning of a word may be determined by reference to other terms *50 that are associated with it in the same statute. ( People v. Rogers (1971) 5 Cal.3d 129, 142 [ 95 Cal. Rptr. 601 , 486 P.2d 129 ] (conc. and dis. opn. of Mosk, J.) [discussing doctrine of noscitur a sociis ].) "[W]hen a statute contains a list or catalogue of items, a court should determine the meaning of each by reference to the others, giving preference to an interpretation that uniformly treats items similar in nature and scope....

11
Vilardo v. County of Sacramentogreen
calctapp · 1942 · cited in 1 California opinions naming this issue, 1994–1994
2 sentences

1994A word of uncertain meaning may be known from its associates and its meaning “enlarged or restrained by reference to the object of the whole clause in which it is used.” (Vilardo v. County of Sacramento (1942) 54 Cal.App.2d 413, 420 [ 129 P.2d 165 ].) Section 20022, subdivision (b)(6), excludes from compensation “employers’ payments which are to be credited as employee contributions for benefits provided by [PERS], or employers’ payments which are to be credited to employee accounts in deferred compensation plans; provided, that amounts deducted from a member’s wages for participation in a def

1994A word of uncertain meaning may be known from its associates and its meaning “enlarged or restrained by reference to the object of the whole clause in which it is used.” (Vilardo v. County of Sacramento (1942) 54 Cal.App.2d 413, 420 [ 129 P.2d 165 ].) Section 20022, subdivision (b)(6), excludes from compensation “employers’ payments which are to be credited as employee contributions for benefits provided by [PERS], or employers’ payments which are to be credited to employee accounts in deferred compensation plans; provided, that amounts deducted from a member’s wages for participation in a def

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (13)

CaseCitedYears
Yassin v. Solis green
calctapp · 2010
1 sentence

2025(See Yassin v. Solis (2010) 184 Cal.App.4th 524, 536 .) 50 Although the trial court does not reference it, the trial court appears to be applying the doctrine of noscitur a sociis (it is known by its associates), which is the principle that “ ‘ “the meaning of a word may be enlarged or restrained by reference to the object of the whole clause in which it is used.” ’ ” (Dyna-Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1391, fn. 14 .) However, that principle is “applicable to terms that are ‘associated’ by grouping or serial enumeration in the same phrase or clause, not to

12025–2025
Oden v. BOARD OF ADMINISTRATION OF PUBLIC EMPLOYEES'RETIREMENT SYSTEM green
calctapp · 1994
1 sentence

2023Under the rule of noscitur a sociis, “[a] word of uncertain meaning may be known from its associates and its meaning ‘enlarged or restrained by reference to the object of the whole clause in which it is used. ’ ” (Oden v. Board of Administration (1994) 23 Cal.App.4th 194, 203 .) “ ‘In accordance with this principle of construction, a court will adopt a restrictive meaning of a listed item if acceptance of a more expansive meaning would make other items in the list unnecessary or redundant, or would otherwise make the item markedly dissimilar to the other items in the list.’ ” (People ex rel.

12023–2023
cluster 763727 green
cadc · 1999
1 sentence

2023(See Portland Cement Ass’n v. Ruckelshaus (D.D.C. 1973) 486 F.2d 375 , 392–393, superseded by statute on other grounds as stated in American Trucking Ass’ns, Inc. v. United States EPA (D.D.C. 1999) 175 F.3d 1027 [remanding to the agency for further review where the agency failed to make available to the public the test methodology used on existing cement plants which formed a partial basis for the emission control level adopted by the agency].) A reading of the term “empirical” in Government Code section 11346.2 as referring to a specific type of research study comports with the statutory cons

12023–2023
Portland Cement Association v. Ruckelshaus green
cadc · 1973
1 sentence

2023(See Portland Cement Ass’n v. Ruckelshaus (D.D.C. 1973) 486 F.2d 375 , 392–393, superseded by statute on other grounds as stated in American Trucking Ass’ns, Inc. v. United States EPA (D.D.C. 1999) 175 F.3d 1027 [remanding to the agency for further review where the agency failed to make available to the public the test methodology used on existing cement plants which formed a partial basis for the emission control level adopted by the agency].) A reading of the term “empirical” in Government Code section 11346.2 as referring to a specific type of research study comports with the statutory cons

12023–2023
People v. Garcia green
cal · 2016
1 sentence

2021(See People v. Garcia (2016) 62 Cal.4th 1116, 1124 .) While its application does not compel an interpretation of “project” that is limited to fixed works, it nevertheless supports giving the term that more restricted meaning. 12 BUSKER v. WABTEC CORPORATION Opinion of the Court by Corrigan, J. terms like “building” or “road” in the definition of “locality” could potentially suggest an intent to broaden the scope of “public works,” nothing else in the 1937 legislation would support such a conclusion.

12021–2021
People v. Fields green
calctapp · 1980
2 sentences

2015(Texas Commerce Bank v. Garamendi, supra, 11 Cal.App.4th at p. 471 .) The doctrine is merely an extrinsic aid to interpretation and is “to be used only when the clear meaning of the words used in the statute is doubtful . . . .” (People v. Fields (1980) 105 Cal.App.3d 341, 344 ; 2A Sutherland, Statutory Construction (7th ed. 2014) § 47.16, p. 353.) It “may not be used to create doubts or offset the plain meaning of the statutes [citation].” (People v. Fields, supra, at p. 344 .) We must first consider “the primary rule of statutory construction that courts must attempt to ascertain the legisla

2015(Texas Commerce Bank v. Garamendi, supra, 11 Cal.App.4th at p. 471 .) The doctrine is merely an extrinsic aid to interpretation and is “to be used only when the clear meaning of the words used in the statute is doubtful . . . .” (People v. Fields (1980) 105 Cal.App.3d 341, 344 ; 2A Sutherland, Statutory Construction (7th ed. 2014) § 47.16, p. 353.) It “may not be used to create doubts or offset the plain meaning of the statutes [citation].” (People v. Fields, supra, at p. 344 .) We must first consider “the primary rule of statutory construction that courts must attempt to ascertain the legisla

12015–2015
People v. Trevino green
cal · 2001
1 sentence

2015(Texas Commerce Bank v. Garamendi, supra, 11 Cal.App.4th at p. 471 .) The doctrine is merely an extrinsic aid to interpretation and is “to be used only when the clear meaning of the words used in the statute is doubtful . . . .” (People v. Fields (1980) 105 Cal.App.3d 341, 344 ; 2A Sutherland, Statutory Construction (7th ed. 2014) § 47.16, p. 353.) It “may not be used to create doubts or offset the plain meaning of the statutes [citation].” (People v. Fields, supra, at p. 344 .) We must first consider “the primary rule of statutory construction that courts must attempt to ascertain the legisla

12015–2015
Costa Serena Owners Coalition v. Costa Serena Architectural Committee green
calctapp · 2009
1 sentence

2014“Expressio unius est exclusio alterius means that ‘the expression of certain things in a [contract] necessarily involves exclusion of other things not expressed. . . .’ [Citation.]” (Dyna–Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1391, fn. 13 .) The same logic is reflected in the doctrine of noscitur a sociis, meaning “it is known by friends.” “Under the rule of noscitur a sociis, ‘ “the meaning of a word may be enlarged or restrained by reference to the object of the whole clause in which it is used.” ’ [Citations.]” (Id. at p. 1391, fn. 14.) “ ‘In accordance with thi

12014–2014
Sierra Club v. Superior Court green
cal · 2013
1 sentence

2014“Expressio unius est exclusio alterius means that ‘the expression of certain things in a [contract] necessarily involves exclusion of other things not expressed. . . .’ [Citation.]” (Dyna–Med, Inc. v. Fair Employment & Housing Com. (1987) 43 Cal.3d 1379, 1391, fn. 13 .) The same logic is reflected in the doctrine of noscitur a sociis, meaning “it is known by friends.” “Under the rule of noscitur a sociis, ‘ “the meaning of a word may be enlarged or restrained by reference to the object of the whole clause in which it is used.” ’ [Citations.]” (Id. at p. 1391, fn. 14.) “ ‘In accordance with thi

12014–2014
United States v. Robert Dale Belless green
ca9 · 2003
1 sentence

2013The defendant in Belless had been convicted of illegally possessing a firearm in violation of section 922(g)(9) based on his prior battery conviction, following a guilty plea, under a Wyoming statute which defines the crime of battery as ―‗unlawfully touch[ing] another in a rude, insolent or angry manner or intentionally, knowingly or recklessly cause[ing] bodily injury to another.‘‖ ( Belless, supra, 338 F.3d at pp. 1065, 1067.) In concluding the Wyoming battery statute did not amount to an MCDV, the Ninth Circuit held, ―[a]s a matter of law,‖ ―that the physical force to which the federal sta

12013–2013
Department of Fish & Game v. Anderson-Cottonwood Irrigation District green
calctapp · 1992
2 sentences

1995In Department of Fish & Game v. Anderson-Cottonwood Irrigation Dist., supra, 8 Cal.App.4th 1554 , it was held that the prohibition of section 2080 was applicable to the killing of salmon drawn into an irrigation district's pumping facility on the Sacramento River.

1995In Department of Fish & Game v. Anderson-Cottonwood Irrigation Dist., supra, 8 Cal.App.4th 1554 , it was held that the prohibition of section 2080 was applicable to the killing of salmon drawn into an irrigation district's pumping facility on the Sacramento River.

11995–1995
People v. Stout green
calctapp · 1971
1 sentence

1987Under the doctrine of noscitur a sociis, where the meaning of a particular word is doubtful when taken by itself, the doubt may be removed and the true meaning ascertained by reference to the meaning of its associated words. (58 Cal.Jur.3d, Statutes, § 136; cf. People v. Stout (1971) 18 Cal.App.3d 172, 177 ; People v. Buese (1963) 220 Cal.App.2d 802, 807 ; 64 Ops.Cal.Atty.Gen. 173 , 177 (1981).) Here the terms "associated with" the word "employer" are not only forms of business organization, but are terms which apply to the conduct of private, non-governmental activity (cf., 70 Ops.Cal.Atty.Ge

11987–1987
People v. Buese green
calctapp · 1963
1 sentence

1987Under the doctrine of noscitur a sociis, where the meaning of a particular word is doubtful when taken by itself, the doubt may be removed and the true meaning ascertained by reference to the meaning of its associated words. (58 Cal.Jur.3d, Statutes, § 136; cf. People v. Stout (1971) 18 Cal.App.3d 172, 177 ; People v. Buese (1963) 220 Cal.App.2d 802, 807 ; 64 Ops.Cal.Atty.Gen. 173 , 177 (1981).) Here the terms "associated with" the word "employer" are not only forms of business organization, but are terms which apply to the conduct of private, non-governmental activity (cf., 70 Ops.Cal.Atty.Ge

11987–1987

Where else courts name it

MI 49 (2000–2026) CA 19 (1987–2025) IL 16 (2005–2025) FL 15 (1992–2025) WA 13 (1998–2024) CO 6 (2010–2024) VA 5 (1971–2015) AR 4 (1995–2010) TN 4 (2005–2015) OR 4 (1982–2023) CT 4 (1994–1998) NV 3 (2023–2025) NJ 3 (1973–2023) MN 3 (1999–2013) IA 3 (1981–2012) NY 3 (1996–2002) RI 3 (2004–2011) WI 3 (1930–1932) MD 2 (1982–2014) WV 2 (1999–2021) HI 2 (1974–1996) UT 2 (1991–1993) TX 2 (2022–2022) AZ 2 (2023–2023) AL 2 (2003–2024)

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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