120 Washington opinions name it 2 courts 1908–2025 4 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.
| Case | Followed | Cited |
|---|---|---|
State v. Lyndgreen2 sentences2007Lawson, 135 Wash.App. at 435 , 144 P.3d 377 (citing State v. Lynd, 54 Wash.App. 18, 22 , 771 P.2d 770 (1989)). ¶ 15 When invoking the emergency exception, the State must show that the claimed emergency is not merely a pretext for conducting an evidentiary search. 2007App. 18, 22 , 771 P.2d 770 (1989)). ¶15 When invoking the emergency exception, the State must show that the claimed emergency is not merely a pretext for conducting an evidentiary search. | 4 | 12 |
State v. Walkergreen2 sentences2006See Walker, 136 Wash.2d at 772 , 966 P.2d 883 . ¶ 28 The emergency doctrine applies when a person has been placed in a position of peril and must make an instinctive choice between courses of action after the peril has arisen. 2006See Walker, 136 Wn.2d at 772 . ¶28 The emergency doctrine applies when a person has been placed in a position of peril and must make an instinctive choice between courses of action after the peril has arisen. | 4 | 4 |
United States v. Rhigergreen2 sentences2007NOTES [1] Miranda v. Arizona, 384 U.S. 436, 444, 479 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 (1966). [2] In their search of Leffler's property, Deputies Clark and Banach discovered evidence of two methods of methamphetamine manufacturethe lithium anhydrous ammonia method and the red phosphorus iodine method. [3] The Tenth Circuit also allows application of the emergency exception where there is risk to persons or propertyspecifically, where "the law enforcement officers must have reasonable grounds to believe that there is immediate need to protect their lives or others or their property or that of 2007NOTES [1] Miranda v. Arizona, 384 U.S. 436, 444, 479 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 (1966). [2] In their search of Leffler's property, Deputies Clark and Banach discovered evidence of two methods of methamphetamine manufacture the lithium anhydrous ammonia method and the red phosphorus iodine method. [3] The Tenth Circuit also allows application of the emergency exception where there is risk to persons or property specifically, where "the law enforcement officers must have reasonable grounds to believe that there is immediate need to protect their lives or others or their property or tha | 4 | 4 |
State v. Gockengreen2 sentences2007Lawson, 135 Wash.App. at 437 , 144 P.3d 377 ; see, e.g., Lynd, 54 Wash.App. at 22-23 , 771 P.2d 770 (where a police officer had knowledge of a 911 hang-up call from defendant's home, the phone line remained busy after the 911 call, a domestic violence incident between spouses had just occurred, defendant was loading his things into his vehicle and preparing to leave, and defendant did not want the officer to enter the home to check on his wife, emergency exception justified warrantless entry into defendant's home to investigate the wife's well-being); see also State v. Gocken, 71 Wash.App. 267 2007App. 267, 272-77, 857 P.2d 1074 (1993) (the emergency exception justified a warrantless search where police officers entered the defendant and victim’s condominium and kicked in the victim’s bedroom door to perform a “routine check on [the victim’s] welfare” after reports of decaying flesh odor and reports from family and friends that they had not seen the victim for several weeks). | 3 | 12 |
State v. Downeygreen2 sentences2007See Downey, 53 Wash.App. at 544-45 , 768 P.2d 502 (emergency exception applies when entry is based on knowledge that dangerous chemicals exist that may imminently cause harm); State v. Nichols, 20 Wash.App. 462, 465-66 , 581 P.2d 1371 (1978) (police must have reasonable grounds to believe there is an emergency at hand, and there must be a reasonable basis to associate the emergency with the area searched). ¶ 20 In sum, the emergency exception only applies where there is an imminent threat of substantial injury to persons or property. 2007See Downey, 53 Wash.App. at 544-45 , 768 P.2d 502 (emergency exception applies when entry is based on knowledge that dangerous chemicals exist that may imminently cause harm); State v. Nichols, 20 Wash.App. 462, 465-66 , 581 P.2d 1371 (1978) (police must have reasonable grounds to believe there is an emergency at hand, and there must be a reasonable basis to associate the emergency with the area searched). ¶ 20 In sum, the emergency exception only applies where there is an imminent threat of substantial injury to persons or property. | 3 | 8 |
| United States v. Wicksgreen | 3 | 3 |
| State v. Rossgreen | 3 | 3 |
State v. Menzgreen2 sentences2009Menz also clarifies the purpose of this emergency exception, which “recognizes the community caretaking function of officers, and exists so officers can assist citizens and protect property.” Id. at 353-54 (citing State v. Swenson, 59 Wn. 2009Menz also clarifies the purpose of this emergency exception, which "recognizes the community caretaking function of officers, and exists so officers can assist citizens and protect property." Menz, 75 Wash.App. at 353-54 , 880 P.2d 48 (citing State v. Swenson, 59 Wash.App. 586, 589 , 799 P.2d 1188 (1990)); see also State v. Hutchison, 56 Wash. App. 863, 865-66 , 785 P.2d 1154 (1990)); State v. Sanders, 8 Wash.App. 306, 310 , 506 P.2d 892 , review denied, 82 Wash.2d 1002 (1973) ("Police officers may enter a dwelling without a warrant to render emergency aid and assistance to a person whom they | 2 | 11 |
Brown v. FIRE PROTEC. DIST.green2 sentences2024Brown, 100 Wn.2d at 197 (citing Zook, 9 Wn. 2024WPI 12.02; Brown, 100 Wn.2d at 197 ; Zook, 9 Wn. | 2 | 8 |
State ex rel. Brislawn v. Meathgreen2 sentences2025We first considered the validity of an emergency clause in Brislawn, 84 Wash. 302 . 2025We agreed with the petitioners and held the emergency clause invalid, finding that the bill did not touch on the “immediate preservation of the public peace, health, or safety.” Id. at 322-23 . | 2 | 5 |
State v. Angelosgreen2 sentences2011Ladson observes that in the analogous context of suppressing evidence obtained in pretextual searches that rely on the emergency exception, Washington courts have held that the search "`must not be primarily motivated by intent to arrest and seize evidence.'" 138 Wash.2d at 357 , 979 P.2d 833 (emphasis added) (quoting State v. Angelos, 86 Wash. App. 253, 256-57 , 936 P.2d 52 (1997) (citing State v. Nichols, 20 Wash.App. 462, 464 , 581 P.2d 1371 , review denied, 91 Wash.2d 1004 , 1978 WL 61436 (1978)), review denied, 133 Wash.2d 1034 , 950 P.2d 478 (1998)). 2011Ladson observes that in the analogous context of suppressing evidence obtained in pretextual searches that rely on the emergency exception, Washington courts have held that the search "`must not be primarily motivated by intent to arrest and seize evidence.'" 138 Wash.2d at 357 , 979 P.2d 833 (emphasis added) (quoting State v. Angelos, 86 Wash. App. 253, 256-57 , 936 P.2d 52 (1997) (citing State v. Nichols, 20 Wash.App. 462, 464 , 581 P.2d 1371 , review denied, 91 Wash.2d 1004 , 1978 WL 61436 (1978)), review denied, 133 Wash.2d 1034 , 950 P.2d 478 (1998)). | 2 | 5 |
State v. Acreygreen2 sentences2018The better approach is to recognize that the lead opinion in Smith does exactly what it says it is doing: establishes a test that specifically applies to "the emergency exception to the warrant requirement, also known as the 'save life' exception, a subset of the community caretaking exception to the warrant requirement." Smith, at 541 (citing State v. Acrey, 148 Wn.2d 738, 748 , 64 P.3d 594 (2003)). 2018The better approach is to recognize that the lead opinion in Smith does exactly what it says it is doing: establishes a test that specifically applies to "the emergency exception to the warrant requirement, also known as the 'save life' exception, a subset of the community caretaking exception to the warrant requirement." Smith, at 541 (citing State v. Acrey, 148 Wn.2d 738, 748 , 64 P.3d 594 (2003)). | 2 | 4 |
State v. Acreygreen2 sentences2018The better approach is to recognize that the lead opinion in Smith does exactly what it says it is doing: establishes a test that specifically applies to "the emergency exception to the warrant requirement, also known as the 'save life' exception, a subset of the community caretaking exception to the warrant requirement." Smith, at 541 (citing State v. Acrey, 148 Wn.2d 738, 748 , 64 P.3d 594 (2003)). 2018The better approach is to recognize that the lead opinion in Smith does exactly what it says it is doing: establishes a test that specifically applies to "the emergency exception to the warrant requirement, also known as the 'save life' exception, a subset of the community caretaking exception to the warrant requirement." Smith, at 541 (citing State v. Acrey, 148 Wn.2d 738, 748 , 64 P.3d 594 (2003)). | 2 | 4 |
State v. Davisgreen2 sentences2001The emergency exception recognizes the "community caretaking function of police officers, and exists so officers can assist citizens and protect property." State v. Menz, 75 Wash.App. 351, 353 , 880 P.2d 48 (1994); See also Davis, 86 Wash.App. at 420 , 937 P.2d 1110 . 2001The emergency exception recognizes the "community caretaking function of police officers, and exists so officers can assist citizens and protect property." State v. Menz, 75 Wash.App. 351, 353 , 880 P.2d 48 (1994); See also Davis, 86 Wash.App. at 420 , 937 P.2d 1110 . | 2 | 4 |
| State v. Sandersgreen | 2 | 3 |
| Miranda v. Arizonagreen | 2 | 3 |
| State v. Garcia-Salgadogreen | 2 | 2 |
| City of Tacoma v. Durhamgreen | 2 | 2 |
| State v. Hutchisongreen | 2 | 2 |
| State v. Athangreen | 2 | 2 |
| State v. Walkergreen | 2 | 2 |
| State v. Athangreen | 2 | 2 |
| Holt v. Nelsongreen | 2 | 2 |
| State v. Rossgreen | 2 | 2 |
| Kreidler v. Eikenberrygreen | 2 | 2 |
| McCluskey v. Handorff-Shermangreen | 2 | 2 |
| First Nat. Bank of Boston v. Bellottigreen | 2 | 2 |
Zook v. Baiergreen2 sentences2015In Zook, the defendant struck the plaintiff as she walked through the snow to a gas station on a dark morning.15 The defendant testified that he was traveling at 20 miles per hour, saw the plaintiff when she was 35 feet from him, applied his brakes, and tried to turn away but slid into her.16 This court held that the emergency doctrine did not apply for two reasons—one relevant to our case—the driver had no available alternatives, "only an instant of time on a slippery road for a single instinctive reaction."17 And in Brown, a driver suddenly confronted with a fire engine reacted instinctively 2013The emergency rule "is applicable only after a person has been placed in a position of peril and there is a choice between courses of action after the peril has arisen." Zook v. Baier, 9 Wn. | 1 | 9 |
State Ex Rel. Humiston v. Meyersgreen2 sentences2025If there is any doubt about the validity of the emergency clause, we give the legislature “every favorable presumption.” Id. at 812 . 2005Humiston v. Meyers, 61 Wn.2d 772, 776 , 380 P.2d 735 (1963). ¶46 In Humiston, the court also ruled that the validity of the emergency clause was a judicial question. | 1 | 6 |
State v. Bakkegreen2 sentences2014App. 830, 832, 839-40 , 723 P.2d 534 (1986) (stating that the question presented is whether the entry fell "within the emergency exception," but holding that "exigent circumstances" justified the entry). 2002See also State v. Bakke, 44 Wash.App. 830, 834 , 723 P.2d 534 (1986) ("The need to protect or preserve life, avoid serious injury, or protect property in danger of damage justifies an entry that would otherwise be illegal absent an exigency or emergency."). *149 To justify application of the emergency exception, the State must show that: "(1) the searching officer subjectively believed an emergency existed; and (2) a reasonable person in the same circumstances would have thought an emergency existed." Downey, 53 Wash.App. at 545 , 768 P.2d 502 . | 1 | 6 |
State v. Kinzygreen2 sentences2015Id. at 381-82 . ¶19 Our Supreme Court reversed, noting that the community caretaking function involves a situation of lesser urgency and searches resulting in less intrusion than the emergency exception. 2015Id. at 386 . | 1 | 5 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Loewen
green
2 sentences1992The Lynd court formulated the rule for the emergency exception as follows: In order for a search to come within the emergency exception, we must be satisfied that the claimed emergency was not simply a pretext for conducting an evidentiary search and instead was "actually motivated by a perceived need to render aid or assistance." [State v.] Loewen, 97 Wn.2d [562,] at 568 [, 647 P.2d 489 (1982)]. 1992The court held that for a search to come within the emergency exception: *155 we must be satisfied that the claimed emergency was not simply a pretext for conducting an evidentiary search and instead was "actually motivated by a perceived need to render aid or assistance." [State v. Loewen, 97 Wn.2d 562, 568 , 647 P.2d 489 (1982).] To that end, the State must show that: (1) the searching officer subjectively believed an emergency existed; and (2) a reasonable person in the same circumstances would have thought an emergency existed. | 10 | 1989–1999 |
State v. Nichols
green
2 sentences2011Ladson observes that in the analogous context of suppressing evidence obtained in pretextual searches that rely on the emergency exception, Washington courts have held that the search "`must not be primarily motivated by intent to arrest and seize evidence.'" 138 Wash.2d at 357 , 979 P.2d 833 (emphasis added) (quoting State v. Angelos, 86 Wash. App. 253, 256-57 , 936 P.2d 52 (1997) (citing State v. Nichols, 20 Wash.App. 462, 464 , 581 P.2d 1371 , review denied, 91 Wash.2d 1004 , 1978 WL 61436 (1978)), review denied, 133 Wash.2d 1034 , 950 P.2d 478 (1998)). 2011Ladson observes that in the analogous context of suppressing evidence obtained in pretextual searches that rely on the emergency exception, Washington courts have held that the search "`must not be primarily motivated by intent to arrest and seize evidence.'" 138 Wash.2d at 357 , 979 P.2d 833 (emphasis added) (quoting State v. Angelos, 86 Wash. App. 253, 256-57 , 936 P.2d 52 (1997) (citing State v. Nichols, 20 Wash.App. 462, 464 , 581 P.2d 1371 , review denied, 91 Wash.2d 1004 , 1978 WL 61436 (1978)), review denied, 133 Wash.2d 1034 , 950 P.2d 478 (1998)). | 9 | 1985–2011 |
Sandberg v. Spoelstra
green
2 sentences2024The purpose of issuing an emergency doctrine instruction is that it “‘requires a jury to consider the fact of sudden peril as a circumstance in determining the reasonableness of a person’s response thereto.’” Sandberg, 46 Wn.2d at 783 (quoting Trudeau, 241 Minn. at 84 (citing PROSSER, supra, § 37; RESTATEMENT OF TORTS § 296)). 2001Sandberg v. Spoelstra, 46 Wn.2d 776, 782 , 285 P.2d 564 (1955). | 8 | 1956–2024 |
CLEAN v. State
green
2 sentences2025In CLEAN, we considered whether an emergency clause included in the “Stadium Act,” which concerned the financing of a new stadium for the Seattle Mariners, violated the people’s constitutionally protected right to referendum. 130 Wn.2d 782 . 2005In CLEAN v. State, 130 Wn.2d 782 , 928 P.2d 1054 (1996), we examined whether an emergency clause included in the stadium act, which provided the means for financing construction of SAFECO Field, violated citizens’ constitutionally protected right to referendum. | 7 | 1997–2025 |
State v. Schlieker
green
2 sentences2008"When invoking the emergency exception, the State must show that the claimed emergency is not merely a pretext for conducting an evidentiary search." State v. Leffler, 142 Wash.App. 175, 182 , 178 P.3d 1042 (2007) (citing State v. Schlieker, 115 Wash.App. 264, 270 , 62 P.3d 520 (2003)). ¶ 47 Here, when the officers entered Sadler's house, they knew the following facts: (1) a 14-year-old girl had "disappeared" from her foster home in another county, (2) she had been missing for some time, (3) she was suspected to be involved in sadomasochistic sex, (4) she was inside the home of a significantly 2007I write separately because the majority repeats our dicta in Schlieker that the emergency exception recognizes the “ ‘community caretaking function of police officers, and exists so officers can assist citizens and protect property.’ ” Majority at 181 (internal quotation marks omitted) (quoting State v. Schlieker, 115 Wn. | 7 | 2006–2008 |
Bell v. Wheeler
neutral
2 sentences2024App. 30, 34 , 678 P.2d 358 (1984) (citing Bell v. Wheeler, 14 Wn. 2013Bell v. Wheeler, 14 Wn. | 6 | 1975–2024 |
Seholm v. Hamilton
green
2 sentences2024Seholm v. Hamilton, 69 Wn.2d 604 , 419 P.2d 328 (1966). 2024Seholm v. Hamilton, 69 Wn.2d 604 , 419 P.2d 328 (1966). | 6 | 1973–2024 |
State v. Swenson
green
2 sentences2009Menz also clarifies the purpose of this emergency exception, which “recognizes the community caretaking function of officers, and exists so officers can assist citizens and protect property.” Id. at 353-54 (citing State v. Swenson, 59 Wn. 2009Menz also clarifies the purpose of this emergency exception, which "recognizes the community caretaking function of officers, and exists so officers can assist citizens and protect property." Menz, 75 Wash.App. at 353-54 , 880 P.2d 48 (citing State v. Swenson, 59 Wash.App. 586, 589 , 799 P.2d 1188 (1990)); see also State v. Hutchison, 56 Wash. App. 863, 865-66 , 785 P.2d 1154 (1990)); State v. Sanders, 8 Wash.App. 306, 310 , 506 P.2d 892 , review denied, 82 Wash.2d 1002 (1973) ("Police officers may enter a dwelling without a warrant to render emergency aid and assistance to a person whom they | 6 | 2007–2019 |
State v. Schlieker
green
2 sentences2008"When invoking the emergency exception, the State must show that the claimed emergency is not merely a pretext for conducting an evidentiary search." State v. Leffler, 142 Wash.App. 175, 182 , 178 P.3d 1042 (2007) (citing State v. Schlieker, 115 Wash.App. 264, 270 , 62 P.3d 520 (2003)). ¶ 47 Here, when the officers entered Sadler's house, they knew the following facts: (1) a 14-year-old girl had "disappeared" from her foster home in another county, (2) she had been missing for some time, (3) she was suspected to be involved in sadomasochistic sex, (4) she was inside the home of a significantly 2007The emergency doctrine applies only where the entering officer subjectively believes that "someone likely need[s] assistance for health or safety reasons." Schlieker, 115 Wash.App. at 270 , 62 P.3d 520 . | 5 | 2006–2008 |
Dove v. North Carolina State Employees Credit Union
green
2 sentences2007NOTES [1] Miranda v. Arizona, 384 U.S. 436, 444, 479 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 (1966). [2] In their search of Leffler's property, Deputies Clark and Banach discovered evidence of two methods of methamphetamine manufacture the lithium anhydrous ammonia method and the red phosphorus iodine method. [3] The Tenth Circuit also allows application of the emergency exception where there is risk to persons or property specifically, where "the law enforcement officers must have reasonable grounds to believe that there is immediate need to protect their lives or others or their property or tha 2007The Tenth Circuit also allows application of the emergency exception where there is risk to persons or property—specifically, where “ ‘the law enforcement officers must have reasonable grounds to believe that there is immediate need to protect their lives or others or their property or that of others.’ ” United States v. Rhiger, 815 F.3d 1283, 1288 (10th Cir.) (quoting United States v. Wicks, 995 F.2d 964, 970 (10th Cir.), cert. denied, 510 U.S. 982 (1993)), cert. denied, 540 U.S. 836 (2003). | 5 | 2006–2007 |
State v. Kinzy
green
2 sentences2007Lawson, 135 Wash. App. at 434-35 , 144 P.3d 377 (citing State v. Kinzy, 141 Wash.2d 373, 386-87 , 5 P.3d 668 (2000)). 2007Lawson, 135 Wash. App. at 434-35 , 144 P.3d 377 (citing State v. Kinzy, 141 Wash.2d 373, 386-87 , 5 P.3d 668 (2000)). | 4 | 2006–2007 |
Mills v. Park
green
2 sentences2006Brown, 100 Wn.2d at 197 (citing Mills v. Park, 67 Wn.2d 717 , 409 P.2d 646 (1966)). “ ‘The doctrine excuses an unfortunate human choice of action that would be subject to criticism as negligent were it not that the party was suddenly faced with a situation which gave him no time to reflect upon which choice was the best.’ ” Brown, 100 Wn.2d at 197 (quoting Zook v. Baier, 9 Wn. 2006Brown, 100 Wn.2d at 197 (citing Mills v. Park, 67 Wn.2d 717 , 409 P.2d 646 (1966)). “ ‘The doctrine excuses an unfortunate human choice of action that would be subject to criticism as negligent were it not that the party was suddenly faced with a situation which gave him no time to reflect upon which choice was the best.’ ” Brown, 100 Wn.2d at 197 (quoting Zook v. Baier, 9 Wn. | 4 | 1983–2006 |
Clean v. State
green
2 sentences2005In CLEAN v. State, 130 Wn.2d 782 , 928 P.2d 1054 (1996), we examined whether an emergency clause included in the stadium act, which provided the means for financing construction of SAFECO Field, violated citizens’ constitutionally protected right to referendum. 2005In CLEAN v. State, 130 Wash.2d 782 , 928 P.2d 1054 (1996), we examined whether an emergency clause included in the Stadium Act, which provided the means for financing construction of SAFECO Field, violated citizens' constitutionally protected right to referendum. | 4 | 1997–2005 |
Heilig v. City Council of Puyallup
green
2 sentences1942Co. v. Hart, 127 Wash. 541 , 221 Pac. 615 .” We have also expressed our opinion relative to an emergency clause, in the following language in Spokane County v. Certain Lots in Spokane, 153 Wash. 462 , 279 Pac. 724 , quoted from the early case of Heilig v. City Council of Puyallup, 7 Wash. 29 , 34 Pac. 164 : “ ‘But we are also of the opinion that where two conflicting acts upon the same subject-matter are passed at the same session of the legislature, and their conflict is such that they cannot be harmonized and stand together, and one of them contains an emergency clause and the other does not 1942Co. v. Hart, 127 Wash. 541 , 221 Pac. 615 .” We have also expressed our opinion relative to an emergency clause, in the following language in Spokane County v. Certain Lots in Spokane, 153 Wash. 462 , 279 Pac. 724 , quoted from the early case of Heilig v. City Council of Puyallup, 7 Wash. 29 , 34 Pac. 164 : “ ‘But we are also of the opinion that where two conflicting acts upon the same subject-matter are passed at the same session of the legislature, and their conflict is such that they cannot be harmonized and stand together, and one of them contains an emergency clause and the other does not | 4 | 1914–1942 |
| Washington State Labor Council v. Reed green | 3 | 2005–2025 |
| DeKoning v. Williams green | 3 | 1964–2020 |
| Tuttle v. Allstate Ins. Co. green | 3 | 2007–2009 |
| Tuttle v. Allstate Insurance green | 3 | 2007–2009 |
| Benson v. Oklahoma green | 3 | 2006–2007 |
| Hieu Van Huynh v. Dretke, Director, Texas Department of Criminal Justice, Correctional Institutions Division green | 3 | 2006–2007 |
| State v. Johnson green | 3 | 2007–2007 |
| Austin v. Linahan, Warden green | 3 | 2007–2007 |
| State v. Levy green | 3 | 2007–2007 |
| State v. Levy green | 3 | 2007–2007 |
| State v. Lawson green | 3 | 2007–2007 |
| State v. Muir green | 3 | 2007–2007 |
| State Ex Rel. Kennedy v. Reeves green | 3 | 1991–1997 |
| Babcock v. State green | 2 | 1994–2024 |
| State v. Judge green | 2 | 2016–2016 |
| Kappelman v. Lutz green | 2 | 2013–2015 |
| State v. Plaggemeier green | 2 | 2009–2009 |
| Kappelman v. Lutz green | 2 | 2009–2009 |
| State v. Leffler green | 2 | 2008–2008 |
| State v. Leffler neutral | 2 | 2008–2008 |
| Shine v. Vega green | 2 | 2007–2007 |
| Lechuga v. United States green | 2 | 2007–2007 |
| Zack v. United States green | 2 | 2007–2007 |
| State v. Lawson neutral | 2 | 2007–2007 |
| Jerry W. Canterbury v. William Thornton Spence and the Washington Hospital Center, a Body Corporate green | 2 | 2007–2007 |
| Harbeson v. Parke-Davis, Inc. green | 2 | 2007–2007 |
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.
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.