comparative negligence doctrine (Alaska) · Go Syfert
← Alaska issues

comparative negligence doctrine in Alaska

16 Alaska opinions name it 1 courts 1975–2008 0 in the last five years

The cases below were cited by Alaska 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 (19)

CaseFollowedCited
Kaatz v. Stategreen
alaska · 1975 · cited in 6 Alaska opinions naming this issue, 1976–1991
2 sentences

1991To give continued life to that principle would defeat the very purpose of the comparative negligence rule — the apportionment of damages according to the degree of mutual fault." Id. at 1050 .

1991To give continued life to that principle would defeat the very purpose of the comparative negligence rule — the apportionment of damages according to the degree of mutual fault.” Id. at 1050 .

56
Ferrell v. Baxtergreen
alaska · 1971 · cited in 2 Alaska opinions naming this issue, 1976–2008
2 sentences

2008See Ferrell, 484 P.2d at 259 (traffic laws "set the standard of a reasonable man and thereby require a finding of negligence in a tort action if the plaintiff can prove that the defendant committed an unexcused violation"). 45 .

1976In view of the adoption of the doctrine of comparative negligence, I would overrule Ferrell, Breitkreutz and their progeny following the negligence per se standard and announce, at the very least, that in future cases we would follow the “evidence of negligence” path. . 484 P.2d 250 (Alaska 1971). . 514 P.2d 17 (Alaska 1973). .

22
Vance v. United Statesgreen
akd · 1973 · cited in 2 Alaska opinions naming this issue, 1991–2008
2 sentences

2008Serv., Inc., 401 P.2d 430, 435-36 (Alaska 1965) (finding no error in the trial court's comparative negligence instruction despite evidence showing that defendant was driving more slowly than the posted speed limit); Vance v. United States, 355 F.Supp. 756, 760 (D.Alaska 1973) ("Compliance with the statute does not relieve defendant from liability if defendant was negligent in failing to take additional precautions.”); see also Restatement (Second) of Torts § 288C (1965) ("Compliance with a legislative enactment or an administrative regulation does not prevent a finding of negligence where a re

1991See, e.g., Lyons v. Nasby, 770 P.2d 1250, 1259 (Colo.1989) (to prohibit defendant tavern owner from asserting the comparative negligence defense runs counter to the traditional tort principle that there be fault on the defendant’s part and that this fault contribute to a plaintiff’s harm); Sagadin v. Ripper, 175 Cal.App.3d 1141 , 221 Cal.Rptr. 675 (1985). 1 The majority relies on Vance v. United States, 355 F.Supp. 756 (D.Alaska 1973), and Morris v. Farley Enters., 661 P.2d 167 (Alaska 1983), for the general proposition that we have been unwilling to consider a minor’s contributory negligence

12
Butaud v. Suburban Marine & Sporting Goods, Inc.green
alaska · 1976 · cited in 2 Alaska opinions naming this issue, 1984–1998
2 sentences

1998See id. at 403. 6 Dura ⅛ language represents the law of this state as it was established in Butaud v. Suburban Marine & Sporting Goods, Inc., 555 P.2d 42, 46 (Alaska 1976).

1984Goods, Inc., 555 P.2d 42 (Alaska 1976), we held that the comparative negligence defense is applicable to strict liability cases.

12
Nga Li v. Yellow Cab Co.green
cal · 1975 · cited in 2 Alaska opinions naming this issue, 1975–1979
2 sentences

1979The Supreme Court of California also has directly addressed this issue. [24] Li v. Yellow Cab Company, 13 Cal.3d 804 , 119 Cal. Rptr. 858 , 532 P.2d 1226 (1975), abrogated the doctrine of contributory negligence in California and replaced it with a comparative negligence rule of liability.

1979The Supreme Court of California also has directly addressed this issue. [24] Li v. Yellow Cab Company, 13 Cal.3d 804 , 119 Cal. Rptr. 858 , 532 P.2d 1226 (1975), abrogated the doctrine of contributory negligence in California and replaced it with a comparative negligence rule of liability.

12
Hoffman v. Jonesgreen
fla · 1973 · cited in 2 Alaska opinions naming this issue, 1975–1979
2 sentences

1979Hoffman v. Jones, 280 So.2d 431, 439 (Fla. 1973). [22] Fla. Stat. § 768.31 (1975). [23] Lincenberg v. Issen, 318 So.2d 386, 393-94 (Fla. 1975).

1975In many instances the rule has been adopted through legislative action, but increasingly it is perceived that a rule which is judicial in origin can be, and appropriately should be, 25 altered by the institution which was its creator. 26 Thus Florida in Hoffman v. Jones, 280 So.2d 431 (Fla.1973), and California in Li v. Yellow Cab Co., 13 Cal.3d 804 , 119 Cal. Rptr. 858 , 532 P.2d 1226 (1975), through the judicial process have overturned the contributory negligence rule and have replaced it with the comparative negligence principle.

12
Meyst v. East Fifth Avenue Service, Inc.green
alaska · 1965 · cited in 1 Alaska opinions naming this issue, 2008–2008
1 sentence

2008Serv., Inc., 401 P.2d 430, 435-36 (Alaska 1965) (finding no error in the trial court's comparative negligence instruction despite evidence showing that defendant was driving more slowly than the posted speed limit); Vance v. United States, 355 F.Supp. 756, 760 (D.Alaska 1973) ("Compliance with the statute does not relieve defendant from liability if defendant was negligent in failing to take additional precautions.”); see also Restatement (Second) of Torts § 288C (1965) ("Compliance with a legislative enactment or an administrative regulation does not prevent a finding of negligence where a re

11
Smith v. Ingersoll-Rand Co.green
alaska · 2000 · cited in 1 Alaska opinions naming this issue, 2007–2007
1 sentence

2007See Smith v. Ingersoll-Rand Co., 14 P.3d 990, 992-93 (Alaska 2000) (recognizing that, under AS 09.17.060, Alaska relies on a system of comparative fault similar to the doctrine of comparative negligence). 32 .

11
Caterpillar Tractor Co. v. Beckgreen
alaska · 1981 · cited in 1 Alaska opinions naming this issue, 1998–1998
1 sentence

1998“Where two issues are interwoven and not reasonably divisible ... a new trial on both issues is required.” Caterpillar Tractor Co. v. Beck, 624 P.2d 790, 795 (Alaska 1981).

11
City of Cordova v. Medicaid Rate Commissiongreen
alaska · 1990 · cited in 1 Alaska opinions naming this issue, 1991–1991
1 sentence

1991In 1986, six years after the most recent inherent risk of skiing statute was passed (Ch. 80, SLA 1980), our legislature enacted a comparative negligence statute. 17 While we generally give preference to a specific statute over a more general one, City of Cordova v. Medicaid Rate Comm’n., 789 P.2d 346, 352 (Alaska 1990), we must harmonize the two statutes if possible.

11
Sagadin v. Rippergreen
calctapp · 1985 · cited in 1 Alaska opinions naming this issue, 1991–1991
2 sentences

1991See, e.g., Lyons v. Nasby, 770 P.2d 1250, 1259 (Colo.1989) (to prohibit defendant tavern owner from asserting the comparative negligence defense runs counter to the traditional tort principle that there be fault on the defendant’s part and that this fault contribute to a plaintiff’s harm); Sagadin v. Ripper, 175 Cal.App.3d 1141 , 221 Cal.Rptr. 675 (1985). 1 The majority relies on Vance v. United States, 355 F.Supp. 756 (D.Alaska 1973), and Morris v. Farley Enters., 661 P.2d 167 (Alaska 1983), for the general proposition that we have been unwilling to consider a minor’s contributory negligence

1991See, e.g., Lyons v. Nasby, 770 P.2d 1250, 1259 (Colo.1989) (to prohibit defendant tavern owner from asserting the comparative negligence defense runs counter to the traditional tort principle that there be fault on the defendant’s part and that this fault contribute to a plaintiff’s harm); Sagadin v. Ripper, 175 Cal.App.3d 1141 , 221 Cal.Rptr. 675 (1985). 1 The majority relies on Vance v. United States, 355 F.Supp. 756 (D.Alaska 1973), and Morris v. Farley Enters., 661 P.2d 167 (Alaska 1983), for the general proposition that we have been unwilling to consider a minor’s contributory negligence

11
Lyons v. Nasbygreen
colo · 1989 · cited in 1 Alaska opinions naming this issue, 1991–1991
2 sentences

1991See, e.g., Lyons v. Nasby, 770 P.2d 1250, 1259 (Colo. 1989) (to prohibit defendant tavern owner from asserting the comparative negligence defense runs counter to the traditional tort principle that there be fault on the defendant's part and that this fault contribute to a plaintiff's harm); Sagadin v. Ripper, 175 Cal. App.3d 1141 , 221 Cal. Rptr. 675 (1985). [1] The majority relies on Vance v. United States, 355 F. Supp. 756 (D.Alaska 1973), and Morris v. Farley Enters., 661 P.2d 167 (Alaska 1983), for the general proposition that we have been unwilling to consider a minor's contributory negli

1991See, e.g., Lyons v. Nasby, 770 P.2d 1250, 1259 (Colo.1989) (to prohibit defendant tavern owner from asserting the comparative negligence defense runs counter to the traditional tort principle that there be fault on the defendant’s part and that this fault contribute to a plaintiff’s harm); Sagadin v. Ripper, 175 Cal.App.3d 1141 , 221 Cal.Rptr. 675 (1985). 1 The majority relies on Vance v. United States, 355 F.Supp. 756 (D.Alaska 1973), and Morris v. Farley Enters., 661 P.2d 167 (Alaska 1983), for the general proposition that we have been unwilling to consider a minor’s contributory negligence

11
Lincenberg v. Issengreen
fla · 1975 · cited in 1 Alaska opinions naming this issue, 1979–1979
1 sentence

1979Hoffman v. Jones, 280 So.2d 431, 439 (Fla. 1973). [22] Fla. Stat. § 768.31 (1975). [23] Lincenberg v. Issen, 318 So.2d 386, 393-94 (Fla. 1975).

11
American Motorcycle Assn. v. Superior Courtgreen
cal · 1978 · cited in 1 Alaska opinions naming this issue, 1979–1979
2 sentences

1979Id., 146 Cal. Rptr. at 188-189, 578 P.2d at 905-06 (citations omitted) (footnote omitted). [27] However, we have considered and reject judicial creation of a partial indemnity rule of law, adopted by the California Supreme Court in American Motorcycle Ass'n v. Superior Court, 20 Cal.3d 578 , 146 Cal. Rptr. 182, 195 , 578 P.2d 899, 912 (1978). [28] See note 26 supra. [29] See State v. Guinn, 555 P.2d 530 , 547 n. 42 (Alaska 1976) (recognizing that judicial adoption of the doctrine of comparative negligence in Kaatz v. State, 540 P.2d 1037, 1042 (Alaska 1975), will require legislative amendment

1979Id., 146 Cal. Rptr. at 188-189, 578 P.2d at 905-06 (citations omitted) (footnote omitted). [27] However, we have considered and reject judicial creation of a partial indemnity rule of law, adopted by the California Supreme Court in American Motorcycle Ass'n v. Superior Court, 20 Cal.3d 578 , 146 Cal. Rptr. 182, 195 , 578 P.2d 899, 912 (1978). [28] See note 26 supra. [29] See State v. Guinn, 555 P.2d 530 , 547 n. 42 (Alaska 1976) (recognizing that judicial adoption of the doctrine of comparative negligence in Kaatz v. State, 540 P.2d 1037, 1042 (Alaska 1975), will require legislative amendment

11
Tenore v. Nu Car Carriers, Inc.green
nj · 1975 · cited in 1 Alaska opinions naming this issue, 1976–1976
2 sentences

1976See also United States v. English, 521 F.2d 63 (9th Cir.1975); Turcotte v. Ford Motor Co., 494 F.2d 173, 184-186 (1st Cir.1974); Tenore v. Nu Car Carriers, Inc., 67 N.J. 466 , 341 A.2d 613, 623-629 (1975); Floyd v. Fruit Industries, Inc., 144 Conn. 659 , 136 A.2d 918, 925-926 (1957); Dempsey v. Thompson, 363 Mo. 339 , 251 S.W.2d 42, 44-46 (1952).

1976See also United States v. English, 521 F.2d 63 (9th Cir.1975); Turcotte v. Ford Motor Co., 494 F.2d 173, 184-186 (1st Cir.1974); Tenore v. Nu Car Carriers, Inc., 67 N.J. 466 , 341 A.2d 613, 623-629 (1975); Floyd v. Fruit Industries, Inc., 144 Conn. 659 , 136 A.2d 918, 925-926 (1957); Dempsey v. Thompson, 363 Mo. 339 , 251 S.W.2d 42, 44-46 (1952).

11
Dempsey v. Thompsongreen
mo · 1952 · cited in 1 Alaska opinions naming this issue, 1976–1976
2 sentences

1976See also United States v. English, 521 F.2d 63 (9th Cir.1975); Turcotte v. Ford Motor Co., 494 F.2d 173, 184-186 (1st Cir.1974); Tenore v. Nu Car Carriers, Inc., 67 N.J. 466 , 341 A.2d 613, 623-629 (1975); Floyd v. Fruit Industries, Inc., 144 Conn. 659 , 136 A.2d 918, 925-926 (1957); Dempsey v. Thompson, 363 Mo. 339 , 251 S.W.2d 42, 44-46 (1952).

1976See also United States v. English, 521 F.2d 63 (9th Cir.1975); Turcotte v. Ford Motor Co., 494 F.2d 173, 184-186 (1st Cir.1974); Tenore v. Nu Car Carriers, Inc., 67 N.J. 466 , 341 A.2d 613, 623-629 (1975); Floyd v. Fruit Industries, Inc., 144 Conn. 659 , 136 A.2d 918, 925-926 (1957); Dempsey v. Thompson, 363 Mo. 339 , 251 S.W.2d 42, 44-46 (1952).

11
Robert L. Turcotte, Administrator of the Estate of Gerard P. Turcotte v. Ford Motor Companygreen
ca1 · 1974 · cited in 1 Alaska opinions naming this issue, 1976–1976
1 sentence

1976See also United States v. English, 521 F.2d 63 (9th Cir.1975); Turcotte v. Ford Motor Co., 494 F.2d 173, 184-186 (1st Cir.1974); Tenore v. Nu Car Carriers, Inc., 67 N.J. 466 , 341 A.2d 613, 623-629 (1975); Floyd v. Fruit Industries, Inc., 144 Conn. 659 , 136 A.2d 918, 925-926 (1957); Dempsey v. Thompson, 363 Mo. 339 , 251 S.W.2d 42, 44-46 (1952).

11
United States v. Alice L. Englishgreen
ca9 · 1975 · cited in 1 Alaska opinions naming this issue, 1976–1976
1 sentence

1976See also United States v. English, 521 F.2d 63 (9th Cir.1975); Turcotte v. Ford Motor Co., 494 F.2d 173, 184-186 (1st Cir.1974); Tenore v. Nu Car Carriers, Inc., 67 N.J. 466 , 341 A.2d 613, 623-629 (1975); Floyd v. Fruit Industries, Inc., 144 Conn. 659 , 136 A.2d 918, 925-926 (1957); Dempsey v. Thompson, 363 Mo. 339 , 251 S.W.2d 42, 44-46 (1952).

11
Floyd v. Fruit Industries, Inc.green
conn · 1957 · cited in 1 Alaska opinions naming this issue, 1976–1976
2 sentences

1976See also United States v. English, 521 F.2d 63 (9th Cir.1975); Turcotte v. Ford Motor Co., 494 F.2d 173, 184-186 (1st Cir.1974); Tenore v. Nu Car Carriers, Inc., 67 N.J. 466 , 341 A.2d 613, 623-629 (1975); Floyd v. Fruit Industries, Inc., 144 Conn. 659 , 136 A.2d 918, 925-926 (1957); Dempsey v. Thompson, 363 Mo. 339 , 251 S.W.2d 42, 44-46 (1952).

1976See also United States v. English, 521 F.2d 63 (9th Cir.1975); Turcotte v. Ford Motor Co., 494 F.2d 173, 184-186 (1st Cir.1974); Tenore v. Nu Car Carriers, Inc., 67 N.J. 466 , 341 A.2d 613, 623-629 (1975); Floyd v. Fruit Industries, Inc., 144 Conn. 659 , 136 A.2d 918, 925-926 (1957); Dempsey v. Thompson, 363 Mo. 339 , 251 S.W.2d 42, 44-46 (1952).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (13)

CaseCitedYears
Ardinger v. Hummell green
alaska · 1999
1 sentence

2007Ardinger, 982 P.2d at 735 (quoting W.

12007–2007
Morris v. Farley Enterprises, Inc. green
alaska · 1983
2 sentences

1991See, e.g., Lyons v. Nasby, 770 P.2d 1250, 1259 (Colo. 1989) (to prohibit defendant tavern owner from asserting the comparative negligence defense runs counter to the traditional tort principle that there be fault on the defendant's part and that this fault contribute to a plaintiff's harm); Sagadin v. Ripper, 175 Cal. App.3d 1141 , 221 Cal. Rptr. 675 (1985). [1] The majority relies on Vance v. United States, 355 F. Supp. 756 (D.Alaska 1973), and Morris v. Farley Enters., 661 P.2d 167 (Alaska 1983), for the general proposition that we have been unwilling to consider a minor's contributory negli

1991See, e.g., Lyons v. Nasby, 770 P.2d 1250, 1259 (Colo.1989) (to prohibit defendant tavern owner from asserting the comparative negligence defense runs counter to the traditional tort principle that there be fault on the defendant’s part and that this fault contribute to a plaintiff’s harm); Sagadin v. Ripper, 175 Cal.App.3d 1141 , 221 Cal.Rptr. 675 (1985). 1 The majority relies on Vance v. United States, 355 F.Supp. 756 (D.Alaska 1973), and Morris v. Farley Enters., 661 P.2d 167 (Alaska 1983), for the general proposition that we have been unwilling to consider a minor’s contributory negligence

11991–1991
Dura Corp. v. Harned green
alaska · 1985
1 sentence

1986Dura, 703 P.2d at 404-05 .

11986–1986
Bielski v. Schulze green
wis · 1962
2 sentences

1979Bielski v. Schulze, 16 Wis.2d 1 , 114 N.W.2d 105 (1962).

1979Bielski v. Schulze, 16 Wis.2d 1 , 114 N.W.2d 105 (1962).

11979–1979
Luque v. McLean green
cal · 1972
2 sentences

1979COMPARATIVE NEGLIGENCE The trial court ruled that it would adopt the doctrine of comparative negligence. 53 The judge instructed the jury that if decedent Deraid Beck “voluntarily and unreasonably assumed” a known risk of injury because of the alleged design defect, 54 the jury should then reduce his damages by comparing “in percentage terms decedent’s own fault which has contributed to his death with the fault of the manufacturer in placing a defective product on the market.” 55 We held in Butaud I 56 that the defense of contributory negligence “depends on proving the user’s actual awareness

1979COMPARATIVE NEGLIGENCE The trial court ruled that it would adopt the doctrine of comparative negligence. 53 The judge instructed the jury that if decedent Deraid Beck “voluntarily and unreasonably assumed” a known risk of injury because of the alleged design defect, 54 the jury should then reduce his damages by comparing “in percentage terms decedent’s own fault which has contributed to his death with the fault of the manufacturer in placing a defective product on the market.” 55 We held in Butaud I 56 that the defense of contributory negligence “depends on proving the user’s actual awareness

11979–1979
State v. Guinn green
alaska · 1976
1 sentence

1979Id., 146 Cal. Rptr. at 188-189, 578 P.2d at 905-06 (citations omitted) (footnote omitted). [27] However, we have considered and reject judicial creation of a partial indemnity rule of law, adopted by the California Supreme Court in American Motorcycle Ass'n v. Superior Court, 20 Cal.3d 578 , 146 Cal. Rptr. 182, 195 , 578 P.2d 899, 912 (1978). [28] See note 26 supra. [29] See State v. Guinn, 555 P.2d 530 , 547 n. 42 (Alaska 1976) (recognizing that judicial adoption of the doctrine of comparative negligence in Kaatz v. State, 540 P.2d 1037, 1042 (Alaska 1975), will require legislative amendment

11979–1979
Butaud v. Suburban Marine & Sporting Goods, Inc. green
alaska · 1975
2 sentences

1979COMPARATIVE NEGLIGENCE The trial court ruled that it would adopt the doctrine of comparative negligence. 53 The judge instructed the jury that if decedent Deraid Beck “voluntarily and unreasonably assumed” a known risk of injury because of the alleged design defect, 54 the jury should then reduce his damages by comparing “in percentage terms decedent’s own fault which has contributed to his death with the fault of the manufacturer in placing a defective product on the market.” 55 We held in Butaud I 56 that the defense of contributory negligence “depends on proving the user’s actual awareness

1979COMPARATIVE NEGLIGENCE The trial court ruled that it would adopt the doctrine of comparative negligence. [53] The judge instructed the jury that if decedent Derald Beck "voluntarily and unreasonably assumed" a known risk of injury because of the alleged design defect, [54] the *888 jury should then reduce his damages by comparing "in percentage terms decedent's own fault which has contributed to his death with the fault of the manufacturer in placing a defective product on the market." [55] We held in Butaud I [56] that the defense of contributory negligence "depends on proving the user's actu

11979–1979
Sloan v. Atlantic Richfield Company green
alaska · 1975
11976–1976
Lucas v. Southern Pacific Co. green
calctapp · 1971
2 sentences

1976This “annuity analysis” was used in one California decision cited by appellant, Lúeas v. Southern Pacific R.R., 19 Cal.App.3d 124 , 96 Cal.Rptr. 356 (1971). .We are cognizant that this court’s adoption of the doctrine of comparative negligence in Kaatg v. State, 540 P.2d 1037, 1042 (Alaska 1975), will require amendment of Alaska’s Uniform Contribution Among Tortfeasors Act (AS 09.10.010). . 434 P.2d 665 (Alaska 1967).

1976This “annuity analysis” was used in one California decision cited by appellant, Lúeas v. Southern Pacific R.R., 19 Cal.App.3d 124 , 96 Cal.Rptr. 356 (1971). .We are cognizant that this court’s adoption of the doctrine of comparative negligence in Kaatg v. State, 540 P.2d 1037, 1042 (Alaska 1975), will require amendment of Alaska’s Uniform Contribution Among Tortfeasors Act (AS 09.10.010). . 434 P.2d 665 (Alaska 1967).

11976–1976
Clabaugh v. Bottcher green
alaska · 1976
11976–1976
McLinn v. Kodiak Electric Association, Inc. green
alaska · 1976
1 sentence

1976McLinn v. Kodiak Electric Association, Inc., 546 P.2d 1305 (Alaska 1976); Clabaugh v. Bottcher, 545 P.2d 172 (Alaska 1976). . 484 P.2d 250, 271 (Alaska 1971). .

11976–1976
Beaulieu v. Elliott green
alaska · 1967
2 sentences

1976This “annuity analysis” was used in one California decision cited by appellant, Lúeas v. Southern Pacific R.R., 19 Cal.App.3d 124 , 96 Cal.Rptr. 356 (1971). .We are cognizant that this court’s adoption of the doctrine of comparative negligence in Kaatg v. State, 540 P.2d 1037, 1042 (Alaska 1975), will require amendment of Alaska’s Uniform Contribution Among Tortfeasors Act (AS 09.10.010). . 434 P.2d 665 (Alaska 1967).

1976Since the issue is not raised in the instant appeal, we deemed inappropriate any comment on the merits of such contention. [41] This "annuity analysis" was used in one California decision cited by appellant, Lucas v. Southern Pacific R.R., 19 Cal. App.3d 124 , 96 Cal. Rptr. 356 (1971). [42] We are cognizant that this court's adoption of the doctrine of comparative negligence in Kaatz v. State, 540 P.2d 1037, 1042 (Alaska 1975), will require amendment of Alaska's Uniform Contribution Among Tortfeasors Act (AS 09.10.010). [1] 434 P.2d 665 (Alaska 1967). [2] Comment "Wrongful Death Damages," 47 M

11976–1976
Breitkreutz v. Baker green
alaska · 1973
1 sentence

1976In view of the adoption of the doctrine of comparative negligence, I would overrule Ferrell, Breitkreutz and their progeny following the negligence per se standard and announce, at the very least, that in future cases we would follow the “evidence of negligence” path. . 484 P.2d 250 (Alaska 1971). . 514 P.2d 17 (Alaska 1973). .

11976–1976

Where else courts name it

FL 116 (1918–2024) IL 100 (1869–2021) MI 86 (1898–2025) CA 74 (1917–2026) GA 67 (1907–2024) MS 44 (1939–2024) LA 43 (1932–2022) NY 40 (1908–2026) NM 37 (1952–2012) OH 37 (1931–2025) WV 35 (1931–2024) CT 33 (1979–2017) NJ 28 (1960–2020) PA 24 (1947–2025) CO 22 (1973–2017) NE 21 (1934–1998) KY 21 (1938–2022) SC 17 (1991–2023) TX 17 (1946–2023) IA 16 (1980–2016) AK 16 (1975–2008) KS 13 (1883–1995) MO 12 (1888–2007) WI 11 (1957–2011) NV 9 (1992–2022) WA 9 (1904–2018) TN 9 (1971–2001) ME 9 (1968–2017) AL 9 (1989–2017) ND 8 (1974–2012) MT 8 (1948–2025) MD 7 (1982–2016) AZ 7 (1956–2010) VA 7 (1930–2003) WY 6 (1979–2002) MN 6 (1959–1989) DE 6 (1991–2021) DC 5 (1982–2011) HI 5 (1968–2006) ID 5 (1990–2017) OK 5 (1989–2012) AR 4 (1925–1988) MA 4 (1998–2010) NC 4 (1968–2012) VT 3 (1977–2006) OR 3 (1970–2006) IN 3 (1974–1999) SD 2 (1934–1983) VI 2 (2014–2017) UT 2 (1983–1995) NH 2 (1997–2001)

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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