fundamental principle (Wyoming) · Go Syfert
← Wyoming issues

fundamental principle in Wyoming

116 Wyoming opinions name it 1 courts 1898–2025 6 in the last five years

The cases below were cited by Wyoming 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 (46)

CaseFollowedCited
McCreary v. Weastgreen
wyo · 1999 · cited in 4 Wyoming opinions naming this issue, 1999–2012
2 sentences

2012"The fundamental rule we invoke in the interpretation of a statute is that we must ascertain, if possible, what the legislature intended by the language it used." Juarez, ¶ 5, 256 P.3d at 518 (citing McCreary v. Weast, 971 P.2d 974, 979 (Wyo.1999)).

2011"The fundamental rule we invoke in the interpretation of a statute is that we must ascertain, if possible, what the legislature intended by the language it used." McCreary v. Weast, 971 P.2d 974, 979 (Wyo.1999).

44
Granzer v. Stategreen
wyo · 2008 · cited in 6 Wyoming opinions naming this issue, 2010–2019
2 sentences

2019Noting our earlier opinions which held this to be a fundamental error, we concluded the error was "not a structural or fundamental error, but rather a trial error" to which "we will not apply an 'error per se' type analysis." Id . ¶ 18, 193 P.3d at 271 -72 .

2016Where the trial court fails to instruct the jury on an essential element of a crime, we have held that "a trial court's failure to instruct on an element of a crime is not a fundamental error requiring automatic reversal, but rather a trial-type error subject to harmless error analysis." Jones v. State, 2011 WY 114, ¶ 14 , 256 P.3d 527, 532 (Wyo.2011) (citing Granzer v. State, 2008 WY 118, ¶ 18 , 193 P.3d 266, 271-72 (Wyo.2008)).

36
Stringer v. Board of County Com'rs of Big Horn Countygreen
wyo · 1959 · cited in 4 Wyoming opinions naming this issue, 1963–1985
2 sentences

1985“It is a fundamental principle of statutory construction that to ascertain the meaning of a given law all statutes relating to the same subject or having the same general purpose shall be read in connection with it as constituting one law. * ⅜ * ” Stringer v. Board of County Commissioners of Big Horn County, Wyo., 347 P.2d 197, 200 (1959).

1985"It is a fundamental principle of statutory construction that to ascertain the meaning of a given law all statutes relating to the same subject or having the same general purpose shall be read in connection with it as constituting one law. * * *" Stringer v. Board of County Commissioners of Big Horn County, Wyo., 347 P.2d 197, 200 (1959).

24
Jones v. Stategreen
wyo · 2011 · cited in 3 Wyoming opinions naming this issue, 2012–2018
2 sentences

2018An erroneous instruction on an essential element *263 of the charged offense "is not a fundamental error requiring automatic reversal, but rather a trial-type error subject to harmless error analysis." Bean v. State , 2016 WY 48 , ¶ 61 n.6, 373 P.3d 372 , 391 n.6 (Wyo. 2016) (quoting Jones v. State , 2011 WY 114 , ¶ 14, 256 P.3d 527 , 532 (Wyo. 2011) ). [¶22] Subsection (a)(i) defines the crime of attempted battery as follows: (a) A person is guilty of aggravated assault and battery if he: (i) Causes or attempts to cause serious bodily injury to another intentionally, knowingly or recklessly u

2018An erroneous instruction on an essential element *263 of the charged offense "is not a fundamental error requiring automatic reversal, but rather a trial-type error subject to harmless error analysis." Bean v. State , 2016 WY 48 , ¶ 61 n.6, 373 P.3d 372 , 391 n.6 (Wyo. 2016) (quoting Jones v. State , 2011 WY 114 , ¶ 14, 256 P.3d 527 , 532 (Wyo. 2011) ). [¶22] Subsection (a)(i) defines the crime of attempted battery as follows: (a) A person is guilty of aggravated assault and battery if he: (i) Causes or attempts to cause serious bodily injury to another intentionally, knowingly or recklessly u

23
Hunt v. Thompsongreen
· 1912 · cited in 3 Wyoming opinions naming this issue, 1964–1989
2 sentences

1964But as there indicated, the rule *135 is not entirely inflexible and consideration must always be given to the basic fundamental principle “that the person injured shall receive a compensation commensurate with his loss and no more.” Hunt v. Thompson, 19 Wyo. 523 , 120 P. 181, 184 , rehearing denied 122 P. 624 .

1964But as there indicated, the rule *135 is not entirely inflexible and consideration must always be given to the basic fundamental principle “that the person injured shall receive a compensation commensurate with his loss and no more.” Hunt v. Thompson, 19 Wyo. 523 , 120 P. 181, 184 , rehearing denied 122 P. 624 .

23
Bader v. Mills & Baker Co.green
· 1921 · cited in 2 Wyoming opinions naming this issue, 2023–2023
2 sentences

2023See Bader v. Mills & Baker Co., 28 Wyo. 191 , 201 P. 1012, 1014 (1921) (“It is a fundamental rule of the law of tort, including trespass, that all who participate in the wrong are equally liable).

2023See Bader v. Mills & Baker Co., 28 Wyo. 191 , 201 P. 1012, 1014 (1921) (“It is a fundamental rule of the law of tort, including trespass, that all who participate in the wrong are equally liable).

22
Hernandez v. New Yorkgreen
scotus · 1991 · cited in 2 Wyoming opinions naming this issue, 2018–2020
2 sentences

2020It implies that the decisionmaker . . . selected . . . a particular course of action at least in part ‘because of,’ not merely ‘in spite of,’ its adverse effects upon an identifiable group.” Hernandez, 500 U.S. at 359–60, 111 S.Ct. at 1866 (internal citations omitted).

2020It implies that the decisionmaker . . . selected . . . a particular course of action at least in part ‘because of,’ not merely ‘in spite of,’ its adverse effects upon an identifiable group.” Hernandez, 500 U.S. at 359–60, 111 S.Ct. at 1866 (internal citations omitted).

22
U. States v. Job L. Barbergreen
· 1815 · cited in 2 Wyoming opinions naming this issue, 2013–2018
2 sentences

2018See also The Adeline , 13 U.S. (9 Cranch) 244, 253 , 3 L.Ed. 719 (1815) ("Now the construction must depend on the evident meaning and intent of the legislature, as clearly to be gathered from a view of the whole provision; and it may be adopted as a fundamental rule, that where there is an express provision, there shall not be a provision by implication; expressio unius est exclusio alterius .").

2013See also The Adeline, 13 U.S. (9 Cranch) 244, 253 , 3 L.Ed. 719 (1815) ("Now the construction must depend on the evident meaning and intent of the legislature, as clearly to be gathered from a view of the whole provision; and it may be adopted as a fundamental rule, that where there is an express provision, there shall not be a provision by implication; ex-pressio unius est exclusio alterius."). [119] The legislature rationally chose to require the advisements listed in § 31-6-102(a)(ii), and the arresting officer complied with the statute by giving them.

22
The Schooner Adeline & Cargogreen
· 1815 · cited in 2 Wyoming opinions naming this issue, 2013–2018
2 sentences

2018See also The Adeline , 13 U.S. (9 Cranch) 244, 253 , 3 L.Ed. 719 (1815) ("Now the construction must depend on the evident meaning and intent of the legislature, as clearly to be gathered from a view of the whole provision; and it may be adopted as a fundamental rule, that where there is an express provision, there shall not be a provision by implication; expressio unius est exclusio alterius .").

2013See also The Adeline, 13 U.S. (9 Cranch) 244, 253 , 3 L.Ed. 719 (1815) ("Now the construction must depend on the evident meaning and intent of the legislature, as clearly to be gathered from a view of the whole provision; and it may be adopted as a fundamental rule, that where there is an express provision, there shall not be a provision by implication; ex-pressio unius est exclusio alterius."). [119] The legislature rationally chose to require the advisements listed in § 31-6-102(a)(ii), and the arresting officer complied with the statute by giving them.

22
RME Petroleum Co. v. Wyoming Department of Revenuegreen
wyo · 2007 · cited in 2 Wyoming opinions naming this issue, 2014–2014
2 sentences

2014Dep't of Revenue, 2007 WY 16, ¶¶ 25, 28 , 150 P.3d 673, 683-84 (Wyo.2007)) (internal citations omitted). "[I]t is a fundamental rule of statutory interpretation that all portions of an act must be read in pari materia, and every word, clause, and sentence must be construed so that no part is inoperative or superfluous." State ex rel.

2014Dep't of Revenue, 2007 WY 16, ¶¶ 25, 28 , 150 P.3d 673, 683-84 (Wyo.2007)) (internal citations omitted). "[I]t is a fundamental rule of statutory interpretation that all portions of an act must be read in pari materia, and every word, clause, and sentence must be construed so that no part is inoperative or superfluous." State ex rel.

22
UNC Teton Exploration Drilling, Inc. v. Peytongreen
wyo · 1989 · cited in 2 Wyoming opinions naming this issue, 1993–1993
2 sentences

1993UNC Teton Exploration Drilling, Inc. v. Peyton, 774 P.2d 584, 592 (Wyo.1989).

1993UNC Teton Exploration Drilling, Inc. v. Peyton, 774 P.2d 584, 592 (Wyo.1989).

22
Matter of Paternity of JRWgreen
wyo · 1991 · cited in 2 Wyoming opinions naming this issue, 1991–1992
2 sentences

1992Furthermore, it is a fundamental rule of statutory interpretation that all portions of an act must be read in pari materia, and every word, clause, and sentence must be construed so that no part is inoperative or superfluous.'" Matter of Paternity of JRW, 814 P.2d 1256, 1262-63 (Wyo.1991), quoting Deloges v. State ex rel.

1992Furthermore, it is a fundamental rule of statutory interpretation that all portions of an act must be read in pari materia, and every word, clause, and sentence must be construed so that no part is inoperative or superfluous.’ ” Matter of Paternity of JRW, 814 P.2d 1256, 1262-63 (Wyo.1991), quoting Deloges v. State ex rel.

22
Rocky Mountain Packing Co. v. Branneygreen
wyo · 1964 · cited in 2 Wyoming opinions naming this issue, 1988–1989
2 sentences

1989Rocky Mountain Packing Co. v. Branney, Wyo., 393 P.2d 131, 135 (1964); Hunt v. Thompson, 19 Wyo. 523 , 120 P. 181, 184 (1912).

1988Rocky Mountain Packing Co. v. Branney, Wyo., 393 P.2d 131, 135 (1964); Hunt v. Thompson, 19 Wyo. 523 , 120 P. 181, 184 (1912).

22
Hughes v. Stategreen
wyo · 1983 · cited in 3 Wyoming opinions naming this issue, 1986–2025
2 sentences

2025When a defendant refuses to speak to authorities, the prosecutor may not refer to his silence to infer that he is guilty.” (citations omitted)); Hughes v. State, 658 P.2d 1294 , 1295–96 (Wyo. 1983) (“It is a fundamental rule that it is 4 impermissible to penalize an individual for exercising his Fifth Amendment privilege to remain silent . . . .

2025When a defendant refuses to speak to authorities, the prosecutor may not refer to his silence to infer that he is guilty.” (citations omitted)); Hughes v. State, 658 P.2d 1294 , 1295–96 (Wyo. 1983) (“It is a fundamental rule that it is 4 impermissible to penalize an individual for exercising his Fifth Amendment privilege to remain silent . . . .

13
Thompson v. Stategreen
wyo · 2018 · cited in 2 Wyoming opinions naming this issue, 2018–2021
2 sentences

2021Thompson, ¶ 24, 408 P.3d at 763 (“Generally, in the absence of a fundamental error affecting a substantial right of the appellant, an issue raised for the first time on appeal will not be considered.

2018Thompson v. State , 2018 WY 3 , ¶ 24, 408 P.3d 756 , 763 (Wyo. 2018) (quoting Belden v. State , 2003 WY 89 , ¶ 55, 73 P.3d 1041 (Wyo. 2003) ).

12
Batson v. Kentuckygreen
scotus · 1986 · cited in 2 Wyoming opinions naming this issue, 2018–2020
2 sentences

2020Batson, 476 U.S. at 93, 96 , 106 S.Ct. 1721 , 1723 (internal citation and quotation marks omitted). [¶19] The court must keep in mind the fundamental principle that . . . “[p]roof of racially discriminatory intent or purpose is required to show a violation of the Equal Protection Clause.” “‘Discriminatory purpose’ . . . implies more than intent as volition or intent as awareness of consequences.

2018It implies that the decisionmaker ... selected ... a particular course of action at least in part 'because of,' not merely 'in spite of,' its adverse effects upon an identifiable group." Hernandez , 500 U.S. at 359 -60 , 111 S.Ct. at 1866 (internal citations omitted). [¶18] A trial court's determination of discriminatory intent "largely will turn on evaluation of credibility." Hernandez , 500 U.S. at 365 , 111 S.Ct. at 1869 (quoting Batson , 476 U.S. at 98 , n.21 , 106 S.Ct. at 1724 , n.21 ).

12
Lopez v. Stategreen
wyo · 1976 · cited in 2 Wyoming opinions naming this issue, 1984–1987
2 sentences

1987The method of determining if a juror is qualified and can reasonably be expected to be fair and impartial is through voir dire examination.” Lopez v. State, Wyo., 544 P.2d 855, 860 (1976): “This Court does not question the fundamental principle that parties to any action are entitled to a fair and impartial jury.

1987The method of determining if a juror is qualified and can reasonably be expected to be fair and impartial is through voir dire examination." Lopez v. State, Wyo., 544 P.2d 855, 860 (1976): "This Court does not question the fundamental principle that parties to any action are entitled to a fair and impartial jury.

12
Alexander v. Stategreen
mdctspecapp · 1982 · cited in 1 Wyoming opinions naming this issue, 2021–2021
1 sentence

2021Others have criticized it because it discourages an onlooker from coming to the aid of one being violently assaulted for fear of “legal peril.” Id. at 159; see also Alexander v. State, 447 A.2d 880, 881 (Md.

11
State v. Piersongreen
conn · 1986 · cited in 1 Wyoming opinions naming this issue, 2020–2020
11
Kindred Healthcare Operating, Inc. v. Boydgreen
wyo · 2017 · cited in 1 Wyoming opinions naming this issue, 2020–2020
11
Baird v. Stategreen
ind · 1992 · cited in 1 Wyoming opinions naming this issue, 2020–2020
1 sentence

2020State v. Almaguer, 303 P.3d 84, 91 (Ariz. Ct. App. 2013) (“An instruction that the state must prove the defendant committed a voluntary act is appropriate only if there is evidence to support a finding of bodily movement performed unconsciously and without effort and determination . . . .”); State v. Pierson, 514 A.2d 724, 728 (Conn. 1986) (“Our acknowledgement of the fundamental principle that a criminal act must be volitional does not mean that a charge to a jury that omits reference to this principle is constitutionally defective where the evidence at trial contains no suggestion that the d

11
State of Arizona v. Jesus Xavier Almaguergreen
arizctapp · 2013 · cited in 1 Wyoming opinions naming this issue, 2020–2020
11
Lane v. Stategreen
wyo · 2000 · cited in 1 Wyoming opinions naming this issue, 2019–2019
11
FGL & L Property Corp. v. City of Ryegreen
nyappdiv · 1985 · cited in 1 Wyoming opinions naming this issue, 2018–2018
11
In Re Loberggreen
wyo · 2004 · cited in 1 Wyoming opinions naming this issue, 2016–2016
11
Collins v. Loiselgreen
scotus · 1923 · cited in 1 Wyoming opinions naming this issue, 2016–2016
11
Jennings v. Stategreen
wyo · 2000 · cited in 1 Wyoming opinions naming this issue, 2016–2016
11
United States v. The Denver and Rio Grande Western Railroad Companygreen
ca10 · 1977 · cited in 1 Wyoming opinions naming this issue, 2015–2015
11
Kuntz v. Kinnegreen
wyo · 1964 · cited in 1 Wyoming opinions naming this issue, 2012–2012
11
Hede v. Gilstrapgreen
wyo · 2005 · cited in 1 Wyoming opinions naming this issue, 2012–2012
11
Leiker v. Stategreen
wyo · 1999 · cited in 1 Wyoming opinions naming this issue, 2010–2010
11
Reilly v. Stategreen
wyo · 2002 · cited in 1 Wyoming opinions naming this issue, 2008–2008
11
Heywood v. Stategreen
wyo · 2007 · cited in 1 Wyoming opinions naming this issue, 2008–2008
11
Compton v. Stategreen
wyo · 1997 · cited in 1 Wyoming opinions naming this issue, 2007–2007
11
Ex Parte Slavingreen
tex · 1967 · cited in 1 Wyoming opinions naming this issue, 2007–2007
11
Southwest Gas Corp. v. FLINTKOTE CO.-US LIMEgreen
nev · 1983 · cited in 1 Wyoming opinions naming this issue, 2007–2007
11
Commonwealth v. Maldonadogreen
pa · 2003 · cited in 1 Wyoming opinions naming this issue, 2006–2006
11
Union Pacific Resources Co. v. Dolencgreen
wyo · 2004 · cited in 1 Wyoming opinions naming this issue, 2004–2004
11
Puig Morales v. Redemptorist Fathers of Porto Ricogreen
prsupreme · 1937 · cited in 1 Wyoming opinions naming this issue, 1999–1999
11
Stephens v. Stategreen
wyo · 1989 · cited in 1 Wyoming opinions naming this issue, 1999–1999
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Clenin v. Statered
wyo · 1978 · cited in 2 Wyoming opinions naming this issue, 2025–2025
2 sentences

2025The prosecution, therefore, may not use at trial the fact that an accused remained silent or claimed his Fifth Amendment right in the face of accusation.”). [¶12] In Clenin v. State, 573 P.2d 844, 846 (Wyo. 1978), overruled by Richter v. State, 642 P.2d 1269 (Wyo. 1982), we held an improper comment on a defendant’s constitutional right to remain silent is prejudicial per se and requires reversal of the defendant’s conviction.

2025The prosecution, therefore, may not use at trial the fact that an accused remained silent or claimed his Fifth Amendment right in the face of accusation.”). [¶12] In Clenin v. State, 573 P.2d 844, 846 (Wyo. 1978), overruled by Richter v. State, 642 P.2d 1269 (Wyo. 1982), we held an improper comment on a defendant’s constitutional right to remain silent is prejudicial per se and requires reversal of the defendant’s conviction.

22

Also cited on this issue (33)

CaseCitedYears
Richter v. State red
wyo · 1982
2 sentences

2025The prosecution, therefore, may not use at trial the fact that an accused remained silent or claimed his Fifth Amendment right in the face of accusation.”). [¶12] In Clenin v. State, 573 P.2d 844, 846 (Wyo. 1978), overruled by Richter v. State, 642 P.2d 1269 (Wyo. 1982), we held an improper comment on a defendant’s constitutional right to remain silent is prejudicial per se and requires reversal of the defendant’s conviction.

2025The prosecution, therefore, may not use at trial the fact that an accused remained silent or claimed his Fifth Amendment right in the face of accusation.”). [¶12] In Clenin v. State, 573 P.2d 844, 846 (Wyo. 1978), overruled by Richter v. State, 642 P.2d 1269 (Wyo. 1982), we held an improper comment on a defendant’s constitutional right to remain silent is prejudicial per se and requires reversal of the defendant’s conviction.

22025–2025
Chapman v. California red
scotus · 1967
2 sentences

2010If a proper objection is made at trial, as in this case, an instructional error is evaluated in accordance with the harmless constitutional error standard described in Chapman v. California, 386 U.S. 18, 23-24 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705 (1967).

2010If a proper objection is made at trial, as in this case, an instructional error is evaluated in accordance with the harmless constitutional error standard described in Chapman v. California, 386 U.S. 18, 23-24 , 87 S.Ct. 824, 827-28 , 17 L.Ed.2d 705 (1967).

22010–2010
Lapp v. State green
wyo · 2004
2 sentences

2008Lapp, ¶ 10, 100 P.3d at 865 ; Reilly v. State, 2002 WY 156, ¶ 20 , 55 P.3d 1259, 1267 (Wyo.2002).

2008Lapp, ¶10, 100 P.3d at 865 ; Reilly v. State, 2002 WY 156, 20 , 55 P.3d 1259, 1267 (Wyo.2002).

22007–2008
Crowley v. Christensen green
idaho · 1890
2 sentences

2001Crowley v. Christensen, 137 U.S. 86 , 11 S.Ct. 13 , 34 L.Ed. 620 ; Ex parte Levy, 48 Ark. 42 .

2001Crowley v. Christensen, 137 U.S. 86 , 11 S.Ct. 13 , 34 L.Ed. 620 ; Ex parte Levy, 48 Ark. 42 .

21898–2001
State v. Stovall green
wyo · 1982
2 sentences

1999Id. at 545 .

1985State Board of Equalization v. Tenneco Oil Company, supra; State v. Stovall, Wyo., 648 P.2d 543 (1982).

21985–1999
Hamlin v. Transcon Lines green
wyo · 1985
2 sentences

1988Hamlin v. Transcon Lines, Wyo., 701 P.2d 1139 (1985).

1988Hamlin v. Transcon Lines, Wyo., 701 P.2d 1139 (1985).

21988–1988
Vivion v. Brittain green
wyo · 1973
2 sentences

1987Vivion v. Brittain, [supra]; and Redwine v. Fitzhugh, [supra].

1987Vivion v. Brittain, [supra]; and Redwine v. Fitzhugh, [supra].

21976–1987
SCHOOL DISTRICTS NOS. 2, 3, 6, 9, AND 10 v. Cook green
wyo · 1967
2 sentences

1982School Districts Nos. 2, 3, 6, 9, and 10, in County of Campbell v. Cook, Wyo., 424 P.2d 751 (1967).

1977In School Districts Nos. 2, 3, 6, 9, and 10 v. Cook, Wyo., 424 P.2d 751, 756-757 , we observed: “In pursuing this matter we need scarcely^ remind that the fundamental rule in the construction of a statute is to ascertain, if possible, what the legislature intended by the language used, viewed in the light of the objects and purposes to be accomplished.

21977–1982
Hoffmeister v. McIntosh neutral
wyo · 1961
2 sentences

1977Hoffmeister v. McIntosh, Wyo., 361 P.2d 678, 679 , rehearing denied 364 P.2d 823 .

1967Hoffmeister v. McIntosh, Wyo., 361 P.2d 678, 679 , rehearing denied 364 P.2d 823 .

21967–1977
Hoffmeister v. McIntosh green
wyo · 1961
2 sentences

1977Hoffmeister v. McIntosh, Wyo., 361 P.2d 678, 679 , rehearing denied 364 P.2d 823 .

1967Hoffmeister v. McIntosh, Wyo., 361 P.2d 678, 679 , rehearing denied 364 P.2d 823 .

21967–1977
Belden v. State green
wyo · 2003
12018–2018
Lance David Bean v. State green
wyo · 2016
12018–2018
State v. Juarez green
wyo · 2011
12012–2012
Miller v. State green
wyo · 1995
12011–2011
Neder v. United States green
scotus · 1999
12011–2011
Deloges v. STATE EX REL. WKR'S COMP. DIV. green
wyo · 1988
12011–2011
Stevie Cole v. Warren Young, Superintendent and the Attorney General of the State of Wisconsin green
ca7 · 1987
12008–2008
Pedro/Aspen, Ltd. v. Board of County Commissioners green
wyo · 2004
12007–2007
Commonwealth v. Pennsylvania Labor Relations Board green
pa · 1996
12003–2003
O'Bryan v. State neutral
· 1886
12001–2001
Harper v. State green
wyo · 1998
11999–1999
Rasmussen v. Baker green
wyo · 1897
11999–1999
Corkill v. Knowles green
wyo · 1998
11999–1999
Sturgis v. Mississippi green
scotus · 1980
11996–1996
Andrews v. United States green
scotus · 1980
11996–1996
Koennecke v. Seaboard Air Line Railway green
· 1915
11996–1996
Dean v. State green
wyo · 1993
11995–1995
Sorrells v. United States green
scotus · 1932
11993–1993
New Hampshire v. Louisiana green
· 1883
11991–1991
United States v. Beebe green
· 1888
11991–1991
Miller v. State green
ala · 1863
11991–1991
In re Cameron green
tenn · 1912
11991–1991
Twing v. Schott green
wyo · 1959
11990–1990

Statutes the citing opinions construe

WY § Wyo. Stat. § 6-3-402 (6) WY § Wyo. Stat. § 6-2-101 (5) WY § Wyo. Stat. § 6-2-302 (4) WY § Wyo. Stat. § 7-11-105 (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

CA 2851 (1859–2026) IN 1774 (1868–2026) FL 1771 (1926–2026) TX 1721 (1867–2026) IL 1588 (1871–2026) PA 1300 (1864–2026) IA 977 (1879–2026) NY 938 (1815–2026) KS 901 (1895–2026) NM 857 (1914–2026) NC 724 (1876–2026) AZ 704 (1908–2026) CT 693 (1899–2026) OH 653 (1876–2026) ID 554 (1905–2026) AL 485 (1876–2026) MI 474 (1851–2026) AR 430 (1899–2026) OK 424 (1893–2026) WA 388 (1890–2026) NJ 378 (1881–2026) LA 344 (1859–2026) GA 337 (1901–2026) MO 321 (1884–2025) MD 297 (1884–2026) MA 280 (1855–2026) SD 271 (1897–2026) WI 248 (1849–2026) KY 245 (1860–2026) NE 243 (1885–2026) TN 217 (1897–2026) WV 199 (1870–2026) OR 185 (1881–2026) MS 178 (1909–2026) MN 177 (1891–2026) VA 177 (1843–2025) CO 173 (1890–2026) ME 171 (1839–2026) MT 166 (1891–2026) SC 165 (1911–2026) RI 154 (1895–2026) UT 148 (1905–2026) HI 141 (1920–2026) VT 120 (1844–2026) WY 116 (1898–2025) DC 111 (1933–2026) ND 99 (1898–2025) DE 90 (1930–2026) NV 56 (1878–2023) NH 43 (1902–2025) AK 40 (1977–2025) VI 16 (1968–2025) PR 12 (1916–2010) MP 4 (1986–1993)

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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