flexible standard (Texas) · Go Syfert
← Texas issues

flexible standard in Texas

127 Texas opinions name it 3 courts 1973–2025 17 in the last five years

The cases below were cited by Texas 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 (40)

CaseFollowedCited
University of Texas Medical School at Houston v. Thangreen
tex · 1995 · cited in 39 Texas opinions naming this issue, 1996–2025
2 sentences

2021But determining “[w]hat process is due is measured by a flexible standard that depends on the practical requirements of the circumstances.” Than, 901 S.W.2d at 930 (citing Mathews, 424 U.S. at 334 ).

2016This flexible standard includes: “(1) the private interest that will be affected by the official action; (2) the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and (3) the government’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.” Than, 901 S.W.2d at 930 , citing Mathews, 424 U.S. at 335 , 96 S.Ct. at 903 .

1539
Mathews v. Eldridgegreen
scotus · 1976 · cited in 56 Texas opinions naming this issue, 1995–2024
2 sentences

2022But “what process is due in any given situation is measured by a flexible standard that depends on the practical requirements of the circumstances.” R.M.T., 352 S.W.3d at 17 ; see Mathews, 424 U.S. at 349 , 96 S. Ct. at 909 .

2022But “what process is due in any given situation is measured by a flexible standard that depends on the practical requirements of the circumstances.” R.M.T., 352 S.W.3d at 17 ; see Mathews, 424 U.S. at 349 , 96 S. Ct. at 909 .

1356
Goss v. Lopezgreen
scotus · 1975 · cited in 10 Texas opinions naming this issue, 1995–2020
2 sentences

2020Mathews, 424 U.S. at 334 , 96 S.Ct. at 902 ; Goss [v. Lopez], 419 U.S. [565,] 578, 95 S.Ct. [729,] 738-39[, 42 L.Ed.2d 725 (1975)].

2004Mathews , 424 U.S. at 334 , 96 S. Ct. at 902 ; see also Goss v. Lopez , 419 U.S. 565, 575-77 , 95 S. Ct. 729, 738-39 (1975).

510
Rhodes v. Stategreen
texcrimapp · 2007 · cited in 5 Texas opinions naming this issue, 2013–2022
2 sentences

2015The State argues that since appellant insisted on going forward with the first revocation proceeding with full awareness that a second motion to revoke based on the purported drug and alcohol violations was likely to be filed, he acquiesced in how the two proceedings unfolded, and he is therefore es-topped from complaining (and/or has waived the right to complain) after the fact. ”[E]s-toppel is a flexible doctrine that manifests itself in various forms that are not limited to unilateral requests.” See Rhodes v. State, 240 S.W.3d 882, 891 (Tex.Crim.App.2007).

2015Written Notice of the Claimed Violations of Probation The record from the first revocation proceeding reflects that appellant had written notice of the State’s allegations that appellant had failed to report to his probation officer, that 15 The State argues that since appellant insisted on going forward with the first revocation proceeding with full awareness that a second motion to revoke based on the purported drug and alcohol violations was likely to be filed, he acquiesced in how the two proceedings unfolded, and he is therefore estopped from complaining (and/or has waived the right to co

45
Nenno v. Stategreen
texcrimapp · 1998 · cited in 3 Texas opinions naming this issue, 2018–2023
2 sentences

2019“Soft” sciences, such as psychology, are reviewed under a more flexible standard set out in Nenno v. State, 970 S.W.2d 549, 561 (Tex.Crim.App. 1998), overruled on other grounds by State v. Terrazas, 4 S.W.3d 720, 727 (Tex.Crim.App. 1999) (en banc); see Weatherred v. State, 15 S.W.3d 540, 542 (Tex.Crim.App. 2000); Holcombe, 2018 WL 6629700 , at *5 (applying the Nenno standard to expert testimony in the area of psychology).

2018Given that methods of proving reliability vary depending on the field of expertise, proffered testimony from experts in “soft” sciences such as psychology is reviewed under a more flexible standard set out in Nenno v. State, 970 S.W.2d 549, 561 (Tex. Crim.

33
State v. Crankgreen
tex · 1984 · cited in 3 Texas opinions naming this issue, 2015–2015
2 sentences

2015Sch. v. Than, 901 S.W.2d 926, 930 (Tex. 1995) (“What process is due is measured by a flexible standard that depends on the practical requirements of the circumstances.”); State v. Crank, 666 S.W.2d 91, 94 (Tex. 1984) (“[T]he ultimate test of due process of law in an administrative hearing is the presence of rudiments of fair play long known to our law.”).

2015“What process is due is measured by a flexible standard that depends on the practical requirements of the circumstances.” Than, 901 S.W.2d at 930 . “[T]he ultimate test of due process of law in an administrative hearing is the presence of rudiments of fair play long known to our law.” State v. Crank, 666 S.W.2d 91, 94 (Tex. 1984).

33
Rodarte v. Coxgreen
texapp · 1991 · cited in 3 Texas opinions naming this issue, 2006–2008
2 sentences

2008See Rodarte v. Cox , 828 S.W.2d 65 , 69–70 (Tex. App.—Tyler 1991, writ denied).

2006See Rodarte v. Cox, 828 S.W.2d 65, 69-70 (Tex.App.-Tyler 1991, writ denied).

33
Cooper Tire & Rubber Co. v. Mendezgreen
tex · 2006 · cited in 4 Texas opinions naming this issue, 2008–2019
2 sentences

2014The Supreme Court in Mendez listed the Robinson factors that trial courts may consider in determining whether expert testimony is reliable but made clear that “these factors are non-exclusive and that Rule 702 contemplates a flexible inquiry.” 204 S.W.3d at 801 (citing Robinson, 923 S.W.2d at 557 ).

2010“We emphasized in Robinson that these factors are non-exclusive and that [Texas] Rule [of Evidence] 702 contemplates a flexible inquiry.” Cooper Tire & Rubber Co. v. Mendez, 204 S.W.3d 797, 801 (Tex.2006). . ”[T]emporal proximity alone does not meet standards of scientific reliability and does not, by itself, support an inference of medical causation. ...

24
Gammill v. Jack Williams Chevrolet, Inc.green
tex · 1998 · cited in 3 Texas opinions naming this issue, 2006–2021
2 sentences

2006However, the role of the trial court "is not to determine whether an expert's conclusions are *131 correct, but only whether the analysis used to reach them is reliable." Gammill, 972 S.W.2d at 728 ; see also Robinson, 923 S.W.2d at 557 ("Rule 702 envisions a flexible inquiry focusing solely on the underlying principles and methodology, not on the conclusions that they generate.").

2006However, the role of the trial court “is not to determine whether an expert’s conclusions are correct, but only whether the analysis used to reach them is reliable.” Gammill, 972 S.W.2d at 728 ; see also Robinson, 928 S.W.2d at 557 (“Rule 702 envisions a flexible inquiry focusing solely on the underlying principles and methodology, not on the conclusions that they generate.”).

23
Burdick v. Takushigreen
scotus · 1992 · cited in 3 Texas opinions naming this issue, 2002–2020
2 sentences

2020Burdick v. Takushi, 504 U.S. 428, 434 (1992) (quoting Tashjian v. Republican Party of Conn., 479 U.S. 208, 213-14 (1986) and Anderson v. Celebrezze, 460 U.S. 780, 789 (1983)). b.

2020Burdick v. Takushi, 504 U.S. 428, 434 (1992) (quoting Tashjian v. Republican Party of Conn., 479 U.S. 208, 213-14 (1986) and Anderson v. Celebrezze, 460 U.S. 780, 789 (1983)). b.

23
Texas Department of Transportation v. Sefzikgreen
tex · 2011 · cited in 2 Texas opinions naming this issue, 2020–2020
2 sentences

2020Comm’n, 478 S.W.3d at 875 -76 (citing Tex. Dep’t of Transp. v. Sefzik, 355 S.W.3d 618, 622 (Tex. 2011) (per curiam); Tex. Nat.

2020Comm’n, 478 S.W.3d at 875 -76 (citing Tex. Dep’t of Transp. v. Sefzik, 355 S.W.3d 618, 622 (Tex. 2011) (per curiam); Tex. Nat.

22
Tashjian v. Republican Party of Connecticutgreen
scotus · 1986 · cited in 2 Texas opinions naming this issue, 2020–2020
2 sentences

2020Burdick v. Takushi, 504 U.S. 428, 434 (1992) (quoting Tashjian v. Republican Party of Conn., 479 U.S. 208, 213-14 (1986) and Anderson v. Celebrezze, 460 U.S. 780, 789 (1983)). b.

2020Burdick v. Takushi, 504 U.S. 428, 434 (1992) (quoting Tashjian v. Republican Party of Conn., 479 U.S. 208, 213-14 (1986) and Anderson v. Celebrezze, 460 U.S. 780, 789 (1983)). b.

22
State v. Terrazasgreen
texcrimapp · 1999 · cited in 2 Texas opinions naming this issue, 2018–2019
2 sentences

2019“Soft” sciences, such as psychology, are reviewed under a more flexible standard set out in Nenno v. State, 970 S.W.2d 549, 561 (Tex.Crim.App. 1998), overruled on other grounds by State v. Terrazas, 4 S.W.3d 720, 727 (Tex.Crim.App. 1999) (en banc); see Weatherred v. State, 15 S.W.3d 540, 542 (Tex.Crim.App. 2000); Holcombe, 2018 WL 6629700 , at *5 (applying the Nenno standard to expert testimony in the area of psychology).

2018App. 1998), overruled on other grounds by State v. Terrazas, 4 S.W.3d 720, 727 (Tex. Crim.

22
In Re SKAgreen
texapp · 2007 · cited in 2 Texas opinions naming this issue, 2008–2011
2 sentences

2011Id. at 334 ; Than, 901 S.W.2d at 930 . ―When the State moves to destroy weakened familial bonds, it must provide the parents with fundamentally fair procedures.‖ Santosky, 455 U.S. at 753–54. ―[T]he process due in parental rights termination proceedings turns on a balancing of the ‗three distinct factors‘ specified in Mathews. . . .‖ Id. at 754; In re S.K.A., 236 S.W.3d 875, 892 (Tex. App.—Texarkana 2007, pet. denied).

2008Id. at 334 ; Than , 901 S.W.2d at 930 . “When the State moves to destroy weakened familial bonds, it must provide the parents with fundamentally fair procedures.” Santosky , 455 U.S. at 753–54. “[T]he process due in parental rights termination proceedings turns on a balancing of the ‘three distinct factors’ specified in Mathews . . . .” Id . at 754; In re S.K.A ., 236 S.W.3d 875, 892 (Tex. App.—Texarkana 2007, pet. denied).

22
National Collegiate Athletic Ass'n v. Yeogreen
texapp · 2003 · cited in 2 Texas opinions naming this issue, 2004–2004
2 sentences

2004NCAA v. Yeo , 114 S.W.3d 584, 598 (Tex. App.--Austin 2003, pet. filed) (citing Mathews , 424 U.S. at 334 ; Goss v. Lopez , 419 U.S. 565, 578 (1975)).

2004NCAA v. Yeo, 114 S.W.3d 584, 598 (Tex. App.—Austin 2003, pet. filed) (citing Mathews, 424 U.S. at 334 ; Goss v. Lopez, 419 U.S. 565, 578 (1975)).

22
McGann v. Stategreen
texapp · 2000 · cited in 2 Texas opinions naming this issue, 2001–2001
2 sentences

2001McGann v. State, 30 S.W.3d 540, 546 (Tex.App.-Fort Worth 2000, pet. ref'd); Forte, 935 S.W.2d at 177 .

2001McGann v. State, 30 S.W.3d 540, 546 (Tex.App.—Fort Worth 2000, pet. ref'd); Forte, 935 S.W.2d at 177 .

22
Christophersen v. Allied-Signal Corporationgreen
ca5 · 1991 · cited in 2 Texas opinions naming this issue, 1996–1996
22
Miller v. United Statesgreen
scotus · 1992 · cited in 2 Texas opinions naming this issue, 1996–1996
22
Christophersen v. Allied-Signal Corp.green
scotus · 1992 · cited in 2 Texas opinions naming this issue, 1996–1996
22
EI Du Pont De Nemours & Co. v. Robinsongreen
tex · 1996 · cited in 9 Texas opinions naming this issue, 1996–2021
2 sentences

2021However, it emphasized in Robinson that “these factors are non-exclusive and that Rule 702 contemplates a flexible inquiry.” Id.

2014The Supreme Court in Mendez listed the Robinson factors that trial courts may consider in determining whether expert testimony is reliable but made clear that “these factors are non-exclusive and that Rule 702 contemplates a flexible inquiry.” 204 S.W.3d at 801 (citing Robinson, 923 S.W.2d at 557 ).

19
Forte v. Stategreen
texapp · 1996 · cited in 3 Texas opinions naming this issue, 2000–2001
2 sentences

2001McGann v. State, 30 S.W.3d 540, 546 (Tex.App.-Fort Worth 2000, pet. ref'd); Forte, 935 S.W.2d at 177 .

2001McGann v. State, 30 S.W.3d 540, 546 (Tex.App.—Fort Worth 2000, pet. ref'd); Forte, 935 S.W.2d at 177 .

13
Transcontinental Insurance Co. v. Crumpgreen
tex · 2010 · cited in 2 Texas opinions naming this issue, 2019–2022
2 sentences

2022Transcontinental Ins., 330 S.W.3d at 216 . –12– An expert’s testimony must not suffer from an analytical gap that renders it unreliable.

2019See Crump, 330 S.W.3d at 215 n.2 (citing Mendez, 204 S.W.3d at 801 ).

12
Santosky v. Kramergreen
scotus · 1982 · cited in 2 Texas opinions naming this issue, 2008–2011
2 sentences

2011Id. at 334 ; Than, 901 S.W.2d at 930 . ―When the State moves to destroy weakened familial bonds, it must provide the parents with fundamentally fair procedures.‖ Santosky, 455 U.S. at 753–54. ―[T]he process due in parental rights termination proceedings turns on a balancing of the ‗three distinct factors‘ specified in Mathews. . . .‖ Id. at 754; In re S.K.A., 236 S.W.3d 875, 892 (Tex. App.—Texarkana 2007, pet. denied).

2011Id. at 334 ; Than, 901 S.W.2d at 930 . ―When the State moves to destroy weakened familial bonds, it must provide the parents with fundamentally fair procedures.‖ Santosky, 455 U.S. at 753–54. ―[T]he process due in parental rights termination proceedings turns on a balancing of the ‗three distinct factors‘ specified in Mathews. . . .‖ Id. at 754; In re S.K.A., 236 S.W.3d 875, 892 (Tex. App.—Texarkana 2007, pet. denied).

12
Hanson v. Dencklagreen
scotus · 1958 · cited in 2 Texas opinions naming this issue, 1973–1979
12
Deen v. Stategreen
texcrimapp · 2017 · cited in 1 Texas opinions naming this issue, 2024–2024
11
in Re Interest of N.G., a Childgreen
tex · 2019 · cited in 1 Texas opinions naming this issue, 2024–2024
11
Arroyo v. Stategreen
texcrimapp · 2003 · cited in 1 Texas opinions naming this issue, 2023–2023
11
Weatherred v. Stategreen
texcrimapp · 2000 · cited in 1 Texas opinions naming this issue, 2019–2019
11
Tillman, Larry Joseph Jr.green
texcrimapp · 2011 · cited in 1 Texas opinions naming this issue, 2019–2019
11
Robinson MacHinery Inc. v. Davisgreen
texapp · 1985 · cited in 1 Texas opinions naming this issue, 2016–2016
11
Burns v. Lambgreen
texapp · 1958 · cited in 1 Texas opinions naming this issue, 2016–2016
11
Sherman Gas & Electric Co. v. Beldengreen
· 1909 · cited in 1 Texas opinions naming this issue, 2016–2016
11
Personal Care Products, Inc. v. Albert Hawkgreen
ca5 · 2011 · cited in 1 Texas opinions naming this issue, 2015–2015
11
Richardson v. City of Pasadenagreen
tex · 1974 · cited in 1 Texas opinions naming this issue, 2015–2015
11
Murray, Raymond Desmondgreen
texcrimapp · 2009 · cited in 1 Texas opinions naming this issue, 2013–2013
11
Coble v. Stategreen
texcrimapp · 2010 · cited in 1 Texas opinions naming this issue, 2012–2012
11
Allison v. Fire Insurance Exchangegreen
texapp · 2002 · cited in 1 Texas opinions naming this issue, 2012–2012
11
Guevara v. Ferrergreen
tex · 2007 · cited in 1 Texas opinions naming this issue, 2010–2010
11
Guaglieri v. New Jerseygreen
scotus · 1992 · cited in 1 Texas opinions naming this issue, 1996–1996
11
Riggins v. Stategreen
texcrimapp · 1971 · cited in 1 Texas opinions naming this issue, 1978–1978
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (23)

CaseCitedYears
Wilson v. Arkansas green
scotus · 1995
2 sentences

2003Id.

2003Id.

52003–2003
International Shoe Co. v. Washington green
scotus · 1945
2 sentences

2014In response to these changes, the requirements for personal jurisdiction over nonresidents have evolved from the rigid rule of Pennoyer v. Neff, 95 U.S. 714 , to the flexible standard of International Shoe Co. v. State of Washington, 326 U.S. 310 .

1979In response to these changes, the requirements for personal jurisdiction over nonresidents have evolved from the rigid rule of Pennoyer v. Neff, 95 U.S. 714 , 24 L.Ed. 565 , to the flexible standard of International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 , 161 A.L.R. 1057 . 3 .

31973–2014
In Re Rmt green
texapp · 2011
2 sentences

2023Id.

2022But “what process is due in any given situation is measured by a flexible standard that depends on the practical requirements of the circumstances.” R.M.T., 352 S.W.3d at 17 ; see Mathews, 424 U.S. at 349 , 96 S. Ct. at 909 .

22022–2023
Texas Transportation Commission and Ted Houghton, in His Official Capacity as Chair of the Texas Transportation Commission v. City of Jersey Village green
texapp · 2015
2 sentences

2020Comm’n, 478 S.W.3d at 875 -76 (citing Tex. Dep’t of Transp. v. Sefzik, 355 S.W.3d 618, 622 (Tex. 2011) (per curiam); Tex. Nat.

2020Comm’n, 478 S.W.3d at 875 -76 (citing Tex. Dep’t of Transp. v. Sefzik, 355 S.W.3d 618, 622 (Tex. 2011) (per curiam); Tex. Nat.

22020–2020
Anderson v. Celebrezze green
scotus · 1983
2 sentences

2020Burdick v. Takushi, 504 U.S. 428, 434 (1992) (quoting Tashjian v. Republican Party of Conn., 479 U.S. 208, 213-14 (1986) and Anderson v. Celebrezze, 460 U.S. 780, 789 (1983)). b.

2020Burdick v. Takushi, 504 U.S. 428, 434 (1992) (quoting Tashjian v. Republican Party of Conn., 479 U.S. 208, 213-14 (1986) and Anderson v. Celebrezze, 460 U.S. 780, 789 (1983)). b.

22020–2020
Anthony v. State green
texapp · 2006
2 sentences

2013Likewise, we overrule this point of error. 14 Typically, we determine what process is due using “a flexible standard that depends on the practical requirements of the circumstances.” Anthony, 209 S.W.3d at 307 .

2013“This flexible standard includes three factors: (1) the private interest that will be affected by the official action; (2) the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and (3) the government’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.” Id. (quoting Univ. of Tex. Med.

22013–2015
Pennoyer v. Neff red
· 1878
2 sentences

2014In response to these changes, the requirements for personal jurisdiction over nonresidents have evolved from the rigid rule of Pennoyer v. Neff, 95 U.S. 714 , to the flexible standard of International Shoe Co. v. State of Washington, 326 U.S. 310 .

1979In response to these changes, the requirements for personal jurisdiction over nonresidents have evolved from the rigid rule of Pennoyer v. Neff, 95 U.S. 714 , 24 L.Ed. 565 , to the flexible standard of International Shoe Co. v. Washington, 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 , 161 A.L.R. 1057 . 3 .

21979–2014
Daubert v. Merrell Dow Pharmaceuticals, Inc. green
scotus · 1993
2 sentences

2012“Rule 702 envisions a flexible inquiry focusing solely on the underlying principles and methodology, not on the conclusions they generate.” Robinson, 923 S.W.2d at 557 (citing Daubert, 509 U.S. at 593–94, 113 S. Ct. at 2797 ); see also Allison v. Fire Ins.

2012“Rule 702 envisions a flexible inquiry focusing solely on the underlying principles and methodology, not on the conclusions they generate.” Robinson, 923 S.W.2d at 557 (citing Daubert, 509 U.S. at 593–94, 113 S. Ct. at 2797 ); see also Allison v. Fire Ins.

21996–2012
Piper Aircraft Co. v. Reyno green
scotus · 1982
2 sentences

2011Piper Aircraft , 454 U.S. at 249–50, 102 S. Ct. at 263 .

2011Piper Aircraft , 454 U.S. at 249–50, 102 S. Ct. at 263 .

22010–2011
White v. Independence Bank, N.A. green
texapp · 1990
2 sentences

2005An abuse of discretion standard is a flexible standard, see id. , meaning trial courts are given significant leeway to determine whether to grant leave to file an untimely response.

2005An abuse of discretion standard is a flexible standard, see id., meaning trial courts are given significant leeway to determine whether to grant leave to file an untimely response.

22005–2005
Abilene Independent School District v. Marks green
texapp · 2008
12024–2024
Kelly v. State green
texcrimapp · 1992
12023–2023
in the Interest of A. J., a Child green
texapp · 2018
12021–2021
Ex Parte Ellis green
texcrimapp · 2010
12015–2015
Collins v. Texas Natural Resource Conservation Commission green
texapp · 2002
12015–2015
Davidson v. Great National Life Insurance green
tex · 1987
12015–2015
Turner v. Perry green
texapp · 2009
12015–2015
City of Arlington v. Centerfolds, Inc. green
texapp · 2007
12015–2015
Martinez v. Texas Department of Protective & Regulatory Services green
texapp · 2003
12014–2014
Zinermon v. Burch green
scotus · 1990
12012–2012
Longwell Transfer v. Elliott neutral
texapp · 1924
11985–1985
Travelers Insurance Company v. Miller green
texapp · 1965
11980–1980
O'Brien v. Lanpar Company green
tex · 1966
11973–1973

Statutes the citing opinions construe

TX § Tex. Fam. Code § 161.001 (12) TX § Tex. Fam. Code § 263.401 (7) TX § Tex. Fam. Code § 109.002 (6) TX § Tex. Fam. Code § 153.001 (5) TX § Tex. Penal Code § 1.07 (5) TX § Tex. Penal Code § 30.05 (5) TX § Tex. Elec. Code § 192.032 (4) TX § Tex. Elec. Code § 273.081 (4) TX § Tex. Fam. Code § 161.003 (4) TX § Tex. Lab. Code § 21.258 (4) TX § Tex. Penal Code § 7.02 (4) TX § Tex. Water Code § 5.115 (4)

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

NY 169 (1937–2026) TX 127 (1973–2025) CT 107 (1978–2026) IL 64 (1961–2026) LA 52 (1963–2022) CA 51 (1896–2026) CO 50 (1964–2026) NJ 45 (1960–2025) MN 45 (1896–2025) PA 43 (1964–2025) MI 33 (1979–2026) RI 30 (1951–2023) FL 27 (1967–2025) VT 25 (1993–2026) WI 25 (1922–2022) OH 24 (1968–2025) MD 23 (1957–2024) NC 22 (1963–2025) MO 20 (1963–2017) MA 18 (1929–2014) WA 18 (1967–2016) AK 18 (1977–2023) DC 18 (1966–2022) NM 15 (1992–2010) MT 15 (1983–2024) UT 14 (2000–2023) DE 13 (1979–2022) IA 12 (1973–2024) NH 12 (1975–2021) ME 12 (1972–2023) HI 12 (1960–2010) KS 11 (1974–2016) AL 11 (1967–2007) NE 11 (1981–2024) IN 11 (1985–2025) OK 10 (1928–2019) ID 10 (1969–2022) AZ 10 (1973–2022) TN 9 (1981–2017) OR 9 (1943–2021) GA 8 (1967–2013) WV 7 (1963–2001) VA 7 (1979–2010) SD 6 (1990–2025) SC 6 (1998–2020) WY 5 (1982–2017) AR 5 (1990–2019) KY 4 (1979–2026) MS 4 (2004–2014) ND 3 (1989–2000) NV 2 (2000–2021)

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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