vagueness challenge (Hawaii) · Go Syfert
← Hawaii issues

vagueness challenge in Hawaii

18 Hawaii opinions name it 2 courts 1919–2019 0 in the last five years

The cases below were cited by Hawaii 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 (14)

CaseFollowedCited
State v. Kaneakuagreen
haw · 1979 · cited in 5 Hawaii opinions naming this issue, 1995–2013
2 sentences

2007Whether the Camping Ordinance and the Camping Ms Are Constitutionally Overbroad “The doctrine of overbreadth, although closely related to a vagueness claim, is distinct in that while a statute may be clear and precise in its terms, it may sweep so broadly that constitutionally protected conduct as well as unprotected conduct is included in its proscriptions.” State v. Gaylord, 78 Hawai'i 127, 142 , 890 P.2d 1167, 1182 (1995) (quoting State v. Kaneakua, 61 Haw. 136, 143 , 597 P.2d 590, 594 (1979) (quotation marks omitted)).

2007Whether the Camping Ordinance and the Camping Ms Are Constitutionally Overbroad “The doctrine of overbreadth, although closely related to a vagueness claim, is distinct in that while a statute may be clear and precise in its terms, it may sweep so broadly that constitutionally protected conduct as well as unprotected conduct is included in its proscriptions.” State v. Gaylord, 78 Hawai'i 127, 142 , 890 P.2d 1167, 1182 (1995) (quoting State v. Kaneakua, 61 Haw. 136, 143 , 597 P.2d 590, 594 (1979) (quotation marks omitted)).

55
State v. Buigreen
haw · 2004 · cited in 3 Hawaii opinions naming this issue, 2006–2015
2 sentences

2006"The doctrine of overbreadth, although closely related to a vagueness claim, is distinct in that while a statute may be clear and precise in its terms, it may sweep so broadly that constitutionally protected conduct is included in its proscriptions.” State v. Bui, 104 Hawai'i 462, 465 , 92 P.3d 471, 474 (2004) (internal quotation marks and citations omitted).

2006"The doctrine of overbreadth, although closely related to a vagueness claim, is distinct in that while a statute may be clear and precise in its terms, it may sweep so broadly that constitutionally protected conduct is included in its proscriptions.” State v. Bui, 104 Hawai'i 462, 465 , 92 P.3d 471, 474 (2004) (internal quotation marks and citations omitted).

33
State v. Gaylordgreen
haw · 1995 · cited in 4 Hawaii opinions naming this issue, 1998–2007
2 sentences

2007Whether the Camping Ordinance and the Camping Ms Are Constitutionally Overbroad “The doctrine of overbreadth, although closely related to a vagueness claim, is distinct in that while a statute may be clear and precise in its terms, it may sweep so broadly that constitutionally protected conduct as well as unprotected conduct is included in its proscriptions.” State v. Gaylord, 78 Hawai'i 127, 142 , 890 P.2d 1167, 1182 (1995) (quoting State v. Kaneakua, 61 Haw. 136, 143 , 597 P.2d 590, 594 (1979) (quotation marks omitted)).

2007Whether the Camping Ordinance and the Camping Ms Are Constitutionally Overbroad “The doctrine of overbreadth, although closely related to a vagueness claim, is distinct in that while a statute may be clear and precise in its terms, it may sweep so broadly that constitutionally protected conduct as well as unprotected conduct is included in its proscriptions.” State v. Gaylord, 78 Hawai'i 127, 142 , 890 P.2d 1167, 1182 (1995) (quoting State v. Kaneakua, 61 Haw. 136, 143 , 597 P.2d 590, 594 (1979) (quotation marks omitted)).

24
State v. Batesgreen
haw · 1997 · cited in 2 Hawaii opinions naming this issue, 2015–2019
2 sentences

2019See State v. Bates, 84 Hawai‘i 211, 222, 933 P.2d 48, 59 (1997) (observing that where a case does not involve any first amendment issues, a “defendant has standing to raise a vagueness challenge only insofar as the statute is vague as applied to his or her specific conduct”)[.] In order for a defendant to succeed on an as-applied challenge, the defendant must demonstrate that the disputed statute is vague with respect to his or her conduct.

2015See State v. Bates, 84 Hawai'i 211, 222 , 933 P.2d 48, 59 (1997) (observing that where a case does not involve any first amendment issues, a “defendant has standing to raise a vagueness challenge only insofar as the statute is vague as applied to his or her specific conduct”); State v. Manzo, 58 Haw. 440 , 573 P.2d 945, 955 (1977) (“A statute may be overbroad because its vagueness extends its reach too far, and yet it may define the core of its coverage with sufficient specificity to avoid challenge for facial vagueness.”).

22
Grayned v. City of Rockfordgreen
scotus · 1972 · cited in 3 Hawaii opinions naming this issue, 1977–2001
2 sentences

2001See also Kalama, 94 Hawai'i at 64 , 8 P.3d at 1228 ("to comport with due process, penal statutes must inform a person of ordinary intelligence of what conduct is prohibited so that he or she may choose between lawful and unlawful conduct.”) A vagueness challenge may also arise where a statute "authorizes or even encourages arbitrary and discriminatory enforcement!,]” Hill, 120 S.Ct. at 2498 , by promoting application "on an ad hoc and subjective basis[.]” Grayned v. City of Rockford, 408 U.S. 104, 109 , 92 S.Ct. 2294 , 33 L.Ed.2d 222 (1972).

2001See also Kalama, 94 Hawai'i at 64 , 8 P.3d at 1228 ("to comport with due process, penal statutes must inform a person of ordinary intelligence of what conduct is prohibited so that he or she may choose between lawful and unlawful conduct.”) A vagueness challenge may also arise where a statute "authorizes or even encourages arbitrary and discriminatory enforcement!,]” Hill, 120 S.Ct. at 2498 , by promoting application "on an ad hoc and subjective basis[.]” Grayned v. City of Rockford, 408 U.S. 104, 109 , 92 S.Ct. 2294 , 33 L.Ed.2d 222 (1972).

13
State v. Beltrangreen
haw · 2007 · cited in 2 Hawaii opinions naming this issue, 2015–2016
2 sentences

2015Thus, the statement of the ICA that "before a law may be held to be unduly vague, ... it must be demonstrated that the law is impermissibly vague in all its applications,” Alangcas, 131 Hawai'i at 325 , 318 P.3d at 615 , is contrary to our prior decision in Beltran. 116 Hawai'i at 154-55 , 172 P.3d at 466-67 (permitting a vagueness challenge to "invalidate a criminal statute on its face even when it could conceivably have had some valid application”). 27 .

2015Thus, the statement of the ICA that "before a law may be held to be unduly vague, ... it must be demonstrated that the law is impermissibly vague in all its applications,” Alangcas, 131 Hawai'i at 325 , 318 P.3d at 615 , is contrary to our prior decision in Beltran. 116 Hawai'i at 154-55 , 172 P.3d at 466-67 (permitting a vagueness challenge to "invalidate a criminal statute on its face even when it could conceivably have had some valid application”). 27 .

12
State v. Manzogreen
haw · 1977 · cited in 1 Hawaii opinions naming this issue, 2015–2015
2 sentences

2015See State v. Bates, 84 Hawai'i 211, 222 , 933 P.2d 48, 59 (1997) (observing that where a case does not involve any first amendment issues, a “defendant has standing to raise a vagueness challenge only insofar as the statute is vague as applied to his or her specific conduct”); State v. Manzo, 58 Haw. 440 , 573 P.2d 945, 955 (1977) (“A statute may be overbroad because its vagueness extends its reach too far, and yet it may define the core of its coverage with sufficient specificity to avoid challenge for facial vagueness.”).

2015See State v. Bates, 84 Hawai'i 211, 222 , 933 P.2d 48, 59 (1997) (observing that where a case does not involve any first amendment issues, a “defendant has standing to raise a vagueness challenge only insofar as the statute is vague as applied to his or her specific conduct”); State v. Manzo, 58 Haw. 440 , 573 P.2d 945, 955 (1977) (“A statute may be overbroad because its vagueness extends its reach too far, and yet it may define the core of its coverage with sufficient specificity to avoid challenge for facial vagueness.”).

11
State v. Richiegreen
haw · 1998 · cited in 1 Hawaii opinions naming this issue, 2006–2006
2 sentences

2006Id. at 32 , 960 P.2d at 1240 (internal quotation marks and citation omitted).

2006Id. at 32 , 960 P.2d at 1240 (internal quotation marks and citation omitted).

11
State v. Kalamagreen
haw · 2000 · cited in 1 Hawaii opinions naming this issue, 2001–2001
2 sentences

2001See also Kalama, 94 Hawai'i at 64 , 8 P.3d at 1228 ("to comport with due process, penal statutes must inform a person of ordinary intelligence of what conduct is prohibited so that he or she may choose between lawful and unlawful conduct.”) A vagueness challenge may also arise where a statute "authorizes or even encourages arbitrary and discriminatory enforcement!,]” Hill, 120 S.Ct. at 2498 , by promoting application "on an ad hoc and subjective basis[.]” Grayned v. City of Rockford, 408 U.S. 104, 109 , 92 S.Ct. 2294 , 33 L.Ed.2d 222 (1972).

2001See also Kalama, 94 Hawai'i at 64 , 8 P.3d at 1228 ("to comport with due process, penal statutes must inform a person of ordinary intelligence of what conduct is prohibited so that he or she may choose between lawful and unlawful conduct.”) A vagueness challenge may also arise where a statute "authorizes or even encourages arbitrary and discriminatory enforcement!,]” Hill, 120 S.Ct. at 2498 , by promoting application "on an ad hoc and subjective basis[.]” Grayned v. City of Rockford, 408 U.S. 104, 109 , 92 S.Ct. 2294 , 33 L.Ed.2d 222 (1972).

11
Hill v. Coloradogreen
scotus · 2000 · cited in 1 Hawaii opinions naming this issue, 2001–2001
1 sentence

2001See also Kalama, 94 Hawai'i at 64 , 8 P.3d at 1228 ("to comport with due process, penal statutes must inform a person of ordinary intelligence of what conduct is prohibited so that he or she may choose between lawful and unlawful conduct.”) A vagueness challenge may also arise where a statute "authorizes or even encourages arbitrary and discriminatory enforcement!,]” Hill, 120 S.Ct. at 2498 , by promoting application "on an ad hoc and subjective basis[.]” Grayned v. City of Rockford, 408 U.S. 104, 109 , 92 S.Ct. 2294 , 33 L.Ed.2d 222 (1972).

11
cluster 546225green
ca3 · 1990 · cited in 1 Hawaii opinions naming this issue, 1997–1997
1 sentence

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

11
United States v. Andrewsgreen
ilnd · 1990 · cited in 1 Hawaii opinions naming this issue, 1997–1997
2 sentences

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

11
New York v. Ferbergreen
scotus · 1982 · cited in 1 Hawaii opinions naming this issue, 1997–1997
2 sentences

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

11
State v. Kameenuigreen
haw · 1988 · cited in 1 Hawaii opinions naming this issue, 1995–1995
2 sentences

1995See also Kameenui, 69 Haw. at 623 , 753 P.2d at 1252 ; Kam, 69 Haw. at 487, 748 P.2d at 375 .

1995See also Kameenui, 69 Haw. at 623 , 753 P.2d at 1252 ; Kam, 69 Haw. at 487, 748 P.2d at 375 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (22)

CaseCitedYears
State v. Alangcas green
hawapp · 2013
2 sentences

2015Thus, the statement of the ICA that "before a law may be held to be unduly vague, ... it must be demonstrated that the law is impermissibly vague in all its applications,” Alangcas, 131 Hawai'i at 325 , 318 P.3d at 615 , is contrary to our prior decision in Beltran. 116 Hawai'i at 154-55 , 172 P.3d at 466-67 (permitting a vagueness challenge to "invalidate a criminal statute on its face even when it could conceivably have had some valid application”). 27 .

2015Thus, the statement of the ICA that "before a law may be held to be unduly vague, ... it must be demonstrated that the law is impermissibly vague in all its applications,” Alangcas, 131 Hawai'i at 325 , 318 P.3d at 615 , is contrary to our prior decision in Beltran. 116 Hawai'i at 154-55 , 172 P.3d at 466-67 (permitting a vagueness challenge to "invalidate a criminal statute on its face even when it could conceivably have had some valid application”). 27 .

12015–2015
Tauese v. State, Department of Labor & Industrial Relations green
haw · 2006
2 sentences

2007Relations, 113 Hawai'i 1 , 28 n. 27, 147 P.3d 785 , 811 n. 27 (2006) (quoting State v. Bui, 104 Hawai'i 462, 465 , 92 P.3d 471, 474 (2004) (internal quotation marks and citations omitted)).

2007Relations, 113 Hawai'i 1 , 28 n. 27, 147 P.3d 785 , 811 n. 27 (2006) (quoting State v. Bui, 104 Hawai'i 462, 465 , 92 P.3d 471, 474 (2004) (internal quotation marks and citations omitted)).

12007–2007
Chapman v. United States green
scotus · 1991
2 sentences

2004Chapman v. United States, 500 U.S. 453, 467 , 111 S.Ct. 1919 , 114 L.Ed.2d 524 (1991); United States v. Powell, 423 U.S. 87, 92 , 96 S.Ct. 316 , 46 L.Ed.2d 228 (1975).

2004Chapman v. United States, 500 U.S. 453, 467 , 111 S.Ct. 1919 , 114 L.Ed.2d 524 (1991); United States v. Powell, 423 U.S. 87, 92 , 96 S.Ct. 316 , 46 L.Ed.2d 228 (1975).

12004–2004
United States v. Powell green
scotus · 1975
2 sentences

2004Chapman v. United States, 500 U.S. 453, 467 , 111 S.Ct. 1919 , 114 L.Ed.2d 524 (1991); United States v. Powell, 423 U.S. 87, 92 , 96 S.Ct. 316 , 46 L.Ed.2d 228 (1975).

2004Chapman v. United States, 500 U.S. 453, 467 , 111 S.Ct. 1919 , 114 L.Ed.2d 524 (1991); United States v. Powell, 423 U.S. 87, 92 , 96 S.Ct. 316 , 46 L.Ed.2d 228 (1975).

12004–2004
State v. Kane green
haw · 1998
2 sentences

2004This court, in State v. Kane, 87 Hawai'i 71 , 951 P.2d 934 (1998), explained that a defendant who raises an overbreadth claim must establish that he or she is personally affected: “The doctrine of overbreadth, although closely related to a vagueness claim, is distinct in that while a statute may be clear and precise in its terms, it may sweep so broadly that constitutionally protected conduct is included in its proscriptions.” [State v.]Gaylord, 78 Hawai'i [127,] 142, 890 P.2d [1167,] 1182 [ (1995) ].

2004This court, in State v. Kane, 87 Hawai'i 71 , 951 P.2d 934 (1998), explained that a defendant who raises an overbreadth claim must establish that he or she is personally affected: “The doctrine of overbreadth, although closely related to a vagueness claim, is distinct in that while a statute may be clear and precise in its terms, it may sweep so broadly that constitutionally protected conduct is included in its proscriptions.” [State v.]Gaylord, 78 Hawai'i [127,] 142, 890 P.2d [1167,] 1182 [ (1995) ].

12004–2004
Columbia Natural Resources, Inc. v. Tatum green
ca6 · 1995
1 sentence

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

11997–1997
United States v. Harriss green
scotus · 1954
2 sentences

1997Id. at 1523; Ferber, 458 U.S. at 767-68 , 102 S.Ct. at 3360-61 ; Harriss, 347 U.S. at 617 , 74 S.Ct. at 811-12 ; Parness, 503 F.2d at 442 ; Paccione, 738 F.Supp. at 698 .

1997Id. at 1523; Ferber, 458 U.S. at 767-68 , 102 S.Ct. at 3360-61 ; Harriss, 347 U.S. at 617 , 74 S.Ct. at 811-12 ; Parness, 503 F.2d at 442 ; Paccione, 738 F.Supp. at 698 .

11997–1997
United States v. Paccione green
nysd · 1990
1 sentence

1997Id. at 1523; Ferber, 458 U.S. at 767-68 , 102 S.Ct. at 3360-61 ; Harriss, 347 U.S. at 617 , 74 S.Ct. at 811-12 ; Parness, 503 F.2d at 442 ; Paccione, 738 F.Supp. at 698 .

11997–1997
Counts v. Brown green
scotus · 1996
1 sentence

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

11997–1997
Polk County v. Brown green
scotus · 1996
1 sentence

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

11997–1997
Union Bank v. Wolas green
scotus · 1991
1 sentence

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

11997–1997
United States v. Milton Parness and Barbara Parness green
ca2 · 1975
1 sentence

1997Id. at 1523; Ferber, 458 U.S. at 767-68 , 102 S.Ct. at 3360-61 ; Harriss, 347 U.S. at 617 , 74 S.Ct. at 811-12 ; Parness, 503 F.2d at 442 ; Paccione, 738 F.Supp. at 698 .

11997–1997
Immigration & Naturalization Service v. Elias-Zacarias green
scotus · 1991
1 sentence

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

11997–1997
South Dakota v. Rosebud Sioux Tribe green
scotus · 1991
1 sentence

1997See also, United States v. Andrews, 749 F.Supp. 1520, 1522-23 (N.D.Ill.1990) (rejecting appellant’s claim that the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1962 (c) was void “on its face” because first amendment freedoms were not implicated; “[t]hus, because there is no conceivable implication of the First Amendment here, it is irrelevant that RICO may be unconstitutional with respect to theoretical and marginal cases before this Court.”). *222 Because this case does not involve any first amendment issues, the defendant “has standing to raise a vagueness challenge

11997–1997
State v. Kam green
haw · 1988
2 sentences

1995See also Kameenui, 69 Haw. at 623 , 753 P.2d at 1252 ; Kam, 69 Haw. at 487, 748 P.2d at 375 .

1995See also Kameenui, 69 Haw. at 623 , 753 P.2d at 1252 ; Kam, 69 Haw. at 487, 748 P.2d at 375 .

11995–1995
State v. Shigematsu green
haw · 1971
11979–1979
State v. Marley green
haw · 1973
1 sentence

1979Grayned v. City of Rockford, supra; State v. Manzo, supra; State v. Marley, supra. In State v. Shigematsu, 52 Haw. 604 , 483 P.2d 997 (1971), this court examined a statute which proscribed presence in a “barricaded place” where gambling implements were exhibited.

11979–1979
United States v. Petrillo green
scotus · 1947
11977–1977
Bloom v. Municipal Court green
cal · 1976
11977–1977
Parker v. Levy green
scotus · 1974
11977–1977
Young v. American Mini Theatres, Inc. green
scotus · 1976
11977–1977
Koch & Dryfus v. Bridges green
miss · 1871
11919–1919

Statutes the citing opinions construe

HI § Haw. Rev. Stat. § 702-204 (4) HI § Haw. Rev. Stat. § 701-105 (3) HI § Haw. Rev. Stat. § 701-114 (3) HI § Haw. Rev. Stat. § 705-500 (3) HI § Haw. Rev. Stat. § 707-700 (3) HI § Haw. Rev. Stat. § 707-730 (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

CA 356 (1975–2026) WA 312 (1973–2026) TX 223 (1969–2026) IL 160 (1980–2026) CT 116 (1978–2026) OH 102 (1973–2026) CO 99 (1973–2026) FL 91 (1973–2025) NY 87 (1969–2026) NJ 79 (1979–2026) PA 77 (1976–2026) OR 75 (1976–2025) MI 70 (1906–2026) WI 67 (1979–2026) GA 57 (1981–2026) IA 52 (1976–2024) MO 48 (1977–2024) IN 46 (1979–2026) AZ 45 (1978–2026) MA 44 (1958–2026) NM 44 (1971–2023) NV 37 (1987–2026) MN 37 (1973–2024) MD 36 (1976–2024) TN 35 (1973–2025) KS 30 (1978–2026) ID 29 (1985–2025) DC 29 (1972–2021) VA 29 (1975–2024) AL 28 (1982–2016) ND 24 (1975–2025) NE 21 (1897–2023) UT 20 (1988–2026) ME 19 (1981–2024) HI 18 (1919–2019) AK 17 (1972–2026) AR 14 (1987–2015) MS 13 (1985–2020) NH 13 (1974–2025) LA 13 (1985–2023) WV 13 (1982–2023) WY 12 (1979–2014) DE 11 (1978–2024) RI 11 (1978–2015) NC 10 (1981–2026) KY 10 (1985–2020) VT 10 (1999–2026) MT 9 (1994–2026) SC 6 (1990–2025) OK 5 (1978–2005) SD 5 (2003–2014)

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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