policy rule (Connecticut) · Go Syfert
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policy rule in Connecticut

16 Connecticut opinions name it 3 courts 1963–2025 3 in the last five years

The cases below were cited by Connecticut 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 (6)

CaseFollowedCited
Benedict v. Town of Norfolkgreen
conn · 2010 · cited in 5 Connecticut opinions naming this issue, 2012–2021
2 sentences

2021Moreover, the existence of such policies reveals a belief that certain situations do not justify the creation of the risk attendant to police chases.’’ Mumm v. Mornson, 708 N.W.2d 475, 493 (Minn. 2006); see id., 491–92 (officers violated ministerial duty by failing to discontinue pursuit when language of department policy mandated termination of pursuit, identity of pursued party was known, and pursued party was not suspected of certain violent felonies); see also Benedict v. Norfolk, 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (municipal acts are ‘‘deemed ministerial [only] if a policy or ru

2021Moreover, the existence of such policies reveals a belief that certain situations do not justify the creation of the risk attendant to police chases.’’ Mumm v. Mornson, 708 N.W.2d 475, 493 (Minn. 2006); see id., 491–92 (officers violated ministerial duty by failing to discontinue pursuit when language of department policy mandated termination of pursuit, identity of pursued party was known, and pursued party was not suspected of certain violent felonies); see also Benedict v. Norfolk, 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (municipal acts are ‘‘deemed ministerial [only] if a policy or ru

45
Mumm v. Mornsongreen
minn · 2006 · cited in 1 Connecticut opinions naming this issue, 2021–2021
2 sentences

2021Moreover, the existence of such policies reveals a belief that certain situations do not justify the creation of the risk attendant to police chases.’’ Mumm v. Mornson, 708 N.W.2d 475, 493 (Minn. 2006); see id., 491–92 (officers violated ministerial duty by failing to discontinue pursuit when language of department policy mandated termination of pursuit, identity of pursued party was known, and pursued party was not suspected of certain violent felonies); see also Benedict v. Norfolk, 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (municipal acts are ‘‘deemed ministerial [only] if a policy or ru

2021Moreover, the existence of such policies reveals a belief that certain situations do not justify the creation of the risk attendant to police chases.’’ Mumm v. Mornson, 708 N.W.2d 475, 493 (Minn. 2006); see id., 491–92 (officers violated ministerial duty by failing to discontinue pursuit when language of department policy mandated termination of pursuit, identity of pursued party was known, and pursued party was not suspected of certain violent felonies); see also Benedict v. Norfolk, 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (municipal acts are ‘‘deemed ministerial [only] if a policy or ru

11
Grignano v. City of Milfordgreen
connappct · 2008 · cited in 1 Connecticut opinions naming this issue, 2017–2017
2 sentences

2017Moreover, as stated, a plaintiff seeking to avoid the immunity typically afforded to police officers must demonstrate that "by statute or other rule of law the official's duty is clearly ministerial rather than discretionary ...." (Emphasis added; internal quotation marks omitted.) Mills v. Solution, LLC , supra, 138 Conn.App. at 48 , 50 A.3d 381 ; see also Grignano v. Milford , supra, 106 Conn.App. at 654 , 943 A.2d 507 .

2017Moreover, as stated, a plaintiff seeking to avoid the immunity typically afforded to police officers must demonstrate that "by statute or other rule of law the official's duty is clearly ministerial rather than discretionary ...." (Emphasis added; internal quotation marks omitted.) Mills v. Solution, LLC , supra, 138 Conn.App. at 48 , 50 A.3d 381 ; see also Grignano v. Milford , supra, 106 Conn.App. at 654 , 943 A.2d 507 .

11
Gordon v. Bridgeport Housing Authoritygreen
conn · 1988 · cited in 1 Connecticut opinions naming this issue, 2012–2012
2 sentences

2012See Gordon v. Bridgeport Housing Authority, 208 Conn. 161, 179 , 544 A.2d 1185 (1988). 11 Our Supreme Court recently held that “for the purposes of § 52-557n, municipal acts that would otherwise be considered discretionary will only be deemed ministerial if a policy or rule limiting discretion in the completion of such acts exists.” Benedict v. Norfolk, 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010); see also Violano v. Fernandez, supra, 280 Conn. 323 -24.

2012See Gordon v. Bridgeport Housing Authority, 208 Conn. 161, 179 , 544 A.2d 1185 (1988). 11 Our Supreme Court recently held that “for the purposes of § 52-557n, municipal acts that would otherwise be considered discretionary will only be deemed ministerial if a policy or rule limiting discretion in the completion of such acts exists.” Benedict v. Norfolk, 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010); see also Violano v. Fernandez, supra, 280 Conn. 323 -24.

11
Veazey v. Elmwood Plantation Associates, Ltd.green
la · 1995 · cited in 1 Connecticut opinions naming this issue, 1998–1998
1 sentence

1998Specifically, the plaintiff claims that the policy factors identified by the Louisiana Supreme Court in Veazey v. Elmwood Plantation Associates, Ltd., 650 So.2d 712, 719-20 (La. 1994), denying apportionment in a negligence action between a negligent and an intentional tortfeasor compel a similar conclusion by this court.

11
Wong Sun and James Wah Toy v. United Statesgreen
ca9 · 1961 · cited in 1 Connecticut opinions naming this issue, 1963–1963
1 sentence

1963In Wong Sun , the United States Supreme Court reversed the Court of Appeals Avhich, in 288 F.2d 366, 371 (9th Cir.), had held that Toy’s declarations were voluntary.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (22)

CaseCitedYears
State v. Burge green
conn · 1985
2 sentences

2025Principally, the defendant relies on an article in the Connecticut Law Review and argues that it is far more likely (and less speculative) that a suspect will lie or confess falsely in a prearrest inter- view, given the fear and power imbalances inherent in custodial interrogation, which have a particularly strong effect on ‘‘ ‘members of social groups with dispropor- tionately high conviction rates, such as young black men, [who] may despair of release and conclude they must confess to something to escape a worse fate.’ ’’10 ment purposes’’); State v. Burge, 195 Conn. 232 , 250–51, 487 A.2d 5

2025Principally, the defendant relies on an article in the Connecticut Law Review and argues that it is far more likely (and less speculative) that a suspect will lie or confess falsely in a prearrest inter- view, given the fear and power imbalances inherent in custodial interrogation, which have a particularly strong effect on ‘‘ ‘members of social groups with dispropor- tionately high conviction rates, such as young black men, [who] may despair of release and conclude they must confess to something to escape a worse fate.’ ’’10 ment purposes’’); State v. Burge, 195 Conn. 232 , 250–51, 487 A.2d 5

12025–2025
Klug v. Inland Wetlands Commission of Torrington green
conn · 1989
1 sentence

2025Principally, the defendant relies on an article in the Connecticut Law Review and argues that it is far more likely (and less speculative) that a suspect will lie or confess falsely in a prearrest inter- view, given the fear and power imbalances inherent in custodial interrogation, which have a particularly strong effect on ‘‘ ‘members of social groups with dispropor- tionately high conviction rates, such as young black men, [who] may despair of release and conclude they must confess to something to escape a worse fate.’ ’’10 ment purposes’’); State v. Burge, 195 Conn. 232 , 250–51, 487 A.2d 5

12025–2025
State v. Reyes green
conn · 1989
1 sentence

2025Principally, the defendant relies on an article in the Connecticut Law Review and argues that it is far more likely (and less speculative) that a suspect will lie or confess falsely in a prearrest inter- view, given the fear and power imbalances inherent in custodial interrogation, which have a particularly strong effect on ‘‘ ‘members of social groups with dispropor- tionately high conviction rates, such as young black men, [who] may despair of release and conclude they must confess to something to escape a worse fate.’ ’’10 ment purposes’’); State v. Burge, 195 Conn. 232 , 250–51, 487 A.2d 5

12025–2025
Ryan Transportation, Inc. v. M & G Associates green
conn · 2003
2 sentences

2025One exception to this general rule arises when a definite relationship between the parties is of such a character that public policy justifies the imposition of a duty to aid or to protect another.’’ (Citation omitted.) Ryan Transportation, Inc. v. M & G Associates, 266 Conn. 520, 526 , 832 A.2d 1180 (2003). ‘‘In delineating more precisely the parameters of this limited exception to the general rule, [our Supreme Court] has concluded that, [in the absence of] a special relationship of cus- tody or control, there is no duty to protect a third person . . . .’’ (Emphasis in original; internal quo

2025One exception to this general rule arises when a definite relationship between the parties is of such a character that public policy justifies the imposition of a duty to aid or to protect another.’’ (Citation omitted.) Ryan Transportation, Inc. v. M & G Associates, 266 Conn. 520, 526 , 832 A.2d 1180 (2003). ‘‘In delineating more precisely the parameters of this limited exception to the general rule, [our Supreme Court] has concluded that, [in the absence of] a special relationship of cus- tody or control, there is no duty to protect a third person . . . .’’ (Emphasis in original; internal quo

12025–2025
State v. Rollins neutral
connappct · 1989
2 sentences

2025Principally, the defendant relies on an article in the Connecticut Law Review and argues that it is far more likely (and less speculative) that a suspect will lie or confess falsely in a prearrest inter- view, given the fear and power imbalances inherent in custodial interrogation, which have a particularly strong effect on ‘‘ ‘members of social groups with dispropor- tionately high conviction rates, such as young black men, [who] may despair of release and conclude they must confess to something to escape a worse fate.’ ’’10 ment purposes’’); State v. Burge, 195 Conn. 232 , 250–51, 487 A.2d 5

2025Principally, the defendant relies on an article in the Connecticut Law Review and argues that it is far more likely (and less speculative) that a suspect will lie or confess falsely in a prearrest inter- view, given the fear and power imbalances inherent in custodial interrogation, which have a particularly strong effect on ‘‘ ‘members of social groups with dispropor- tionately high conviction rates, such as young black men, [who] may despair of release and conclude they must confess to something to escape a worse fate.’ ’’10 ment purposes’’); State v. Burge, 195 Conn. 232 , 250–51, 487 A.2d 5

12025–2025
State v. Gonzalez green
conn · 2011
2 sentences

2025Principally, the defendant relies on an article in the Connecticut Law Review and argues that it is far more likely (and less speculative) that a suspect will lie or confess falsely in a prearrest inter- view, given the fear and power imbalances inherent in custodial interrogation, which have a particularly strong effect on ‘‘ ‘members of social groups with dispropor- tionately high conviction rates, such as young black men, [who] may despair of release and conclude they must confess to something to escape a worse fate.’ ’’10 ment purposes’’); State v. Burge, 195 Conn. 232 , 250–51, 487 A.2d 5

2025Principally, the defendant relies on an article in the Connecticut Law Review and argues that it is far more likely (and less speculative) that a suspect will lie or confess falsely in a prearrest inter- view, given the fear and power imbalances inherent in custodial interrogation, which have a particularly strong effect on ‘‘ ‘members of social groups with dispropor- tionately high conviction rates, such as young black men, [who] may despair of release and conclude they must confess to something to escape a worse fate.’ ’’10 ment purposes’’); State v. Burge, 195 Conn. 232 , 250–51, 487 A.2d 5

12025–2025
St. Pierre v. Town of Plainfield green
conn · 2017
2 sentences

2021Pierre v. Plainfield, 326 Conn. 420 , 434 n.13, 165 A.3d 148 (2017). 20 The dissent raises some compelling observations about what it considers to be this court’s unduly restrictive approach to the first prong of the test, under which ‘‘we [generally] have held that a party is an identifiable person when he or she is compelled to be somewhere,’’ and ‘‘[t]he only identifiable class of foreseeable victims that we have recognized . . . is that of school- children attending public schools during school hours because: they were intended to be the beneficiaries of particular duties of care imposed b

2021Pierre v. Plainfield, 326 Conn. 420 , 434 n.13, 165 A.3d 148 (2017). 20 The dissent raises some compelling observations about what it considers to be this court’s unduly restrictive approach to the first prong of the test, under which ‘‘we [generally] have held that a party is an identifiable person when he or she is compelled to be somewhere,’’ and ‘‘[t]he only identifiable class of foreseeable victims that we have recognized . . . is that of school- children attending public schools during school hours because: they were intended to be the beneficiaries of particular duties of care imposed b

12021–2021
Pluhowsky v. City of New Haven green
conn · 1964
2 sentences

2019"A ministerial act is one which a person performs in a given state of facts, in a prescribed manner, in obedience to the mandate of legal authority, without regard to or the exercise of his own judgment [or discretion] upon the propriety of the act being done." 7 (Internal quotation marks omitted.) Blake v. Mason , 82 Conn. 324 , 327, 73 A. 782 (1909) ; see also Benedict v. Norfolk , 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (municipal acts are "deemed ministerial if a policy or rule limiting discretion in the completion of such acts exists"); Pluhowsky v. New Haven , 151 Conn. 337 , 347, 1

2019"A ministerial act is one which a person performs in a given state of facts, in a prescribed manner, in obedience to the mandate of legal authority, without regard to or the exercise of his own judgment [or discretion] upon the propriety of the act being done." 7 (Internal quotation marks omitted.) Blake v. Mason , 82 Conn. 324 , 327, 73 A. 782 (1909) ; see also Benedict v. Norfolk , 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (municipal acts are "deemed ministerial if a policy or rule limiting discretion in the completion of such acts exists"); Pluhowsky v. New Haven , 151 Conn. 337 , 347, 1

12019–2019
Blake v. Mason green
conn · 1909
2 sentences

2019"A ministerial act is one which a person performs in a given state of facts, in a prescribed manner, in obedience to the mandate of legal authority, without regard to or the exercise of his own judgment [or discretion] upon the propriety of the act being done." 7 (Internal quotation marks omitted.) Blake v. Mason , 82 Conn. 324 , 327, 73 A. 782 (1909) ; see also Benedict v. Norfolk , 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (municipal acts are "deemed ministerial if a policy or rule limiting discretion in the completion of such acts exists"); Pluhowsky v. New Haven , 151 Conn. 337 , 347, 1

2019"A ministerial act is one which a person performs in a given state of facts, in a prescribed manner, in obedience to the mandate of legal authority, without regard to or the exercise of his own judgment [or discretion] upon the propriety of the act being done." 7 (Internal quotation marks omitted.) Blake v. Mason , 82 Conn. 324 , 327, 73 A. 782 (1909) ; see also Benedict v. Norfolk , 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (municipal acts are "deemed ministerial if a policy or rule limiting discretion in the completion of such acts exists"); Pluhowsky v. New Haven , 151 Conn. 337 , 347, 1

12019–2019
Bonington v. Town of Westport green
conn · 2010
2 sentences

2019This court previously *48 has held that a municipality may be held liable for the negligent performance of a duty only if the "the official's duty is clearly ministerial." (Emphasis added; internal quotation marks omitted.) Bonington v. Westport , supra, 297 Conn. at 308 , 999 A.2d 700 .

2019This court previously *48 has held that a municipality may be held liable for the negligent performance of a duty only if the "the official's duty is clearly ministerial." (Emphasis added; internal quotation marks omitted.) Bonington v. Westport , supra, 297 Conn. at 308 , 999 A.2d 700 .

12019–2019
Ocean Winds Council of Co-Owners, Inc. v. Auto-Owner Insurance green
sc · 2002
2 sentences

2019Co., 350 S.C. 268, 271 , 565 S.E.2d 306 (2002) (‘‘[w]e find a requirement of imminent collapse is the most reasonable construction of the policy clause covering risks of direct physical loss involving collapse’’ (internal quotation marks omitted)).

2019Co., 350 S.C. 268, 271 , 565 S.E.2d 306 (2002) (‘‘[w]e find a requirement of imminent collapse is the most reasonable construction of the policy clause covering risks of direct physical loss involving collapse’’ (internal quotation marks omitted)).

12019–2019
Mills v. Solution, LLC green
connappct · 2012
2 sentences

2017Moreover, as stated, a plaintiff seeking to avoid the immunity typically afforded to police officers must demonstrate that "by statute or other rule of law the official's duty is clearly ministerial rather than discretionary ...." (Emphasis added; internal quotation marks omitted.) Mills v. Solution, LLC , supra, 138 Conn.App. at 48 , 50 A.3d 381 ; see also Grignano v. Milford , supra, 106 Conn.App. at 654 , 943 A.2d 507 .

2017Moreover, as stated, a plaintiff seeking to avoid the immunity typically afforded to police officers must demonstrate that "by statute or other rule of law the official's duty is clearly ministerial rather than discretionary ...." (Emphasis added; internal quotation marks omitted.) Mills v. Solution, LLC , supra, 138 Conn.App. at 48 , 50 A.3d 381 ; see also Grignano v. Milford , supra, 106 Conn.App. at 654 , 943 A.2d 507 .

12017–2017
Spitzer v. City of Waterbury green
conn · 1931
2 sentences

2012In support of their argument that the defendants’ maintenance of the storm drains and sewers in the HiUcrest Park neighborhood is ministerial in nature, the *272 plaintiffs rely on Spitzer v. Waterbury, 113 Conn. 84 , 154 A. 157 (1931).

2012In support of their argument that the defendants’ maintenance of the storm drains and sewers in the HiUcrest Park neighborhood is ministerial in nature, the *272 plaintiffs rely on Spitzer v. Waterbury, 113 Conn. 84 , 154 A. 157 (1931).

12012–2012
Violano v. Fernandez green
conn · 2006
2 sentences

2012If the acts or omissions complained of are not imposed in the form of a general legal duty, they must, in order to be characterized as ministerial, be “required by [a] . . . charter provision, ordinance, regulation, rule, policy, or any other directive . . . that prescribe [s] the manner in which [they are to be performed].” (Citations omitted.) Violano v. Fernandez, 280 Conn. 310, 323-24 , 907 A.2d 1188 (2006); see also Benedict v. Norfolk, 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (“for the purposes of § 52-557n, municipal acts that would otherwise be considered discretionary will only be

2012If the acts or omissions complained of are not imposed in the form of a general legal duty, they must, in order to be characterized as ministerial, be “required by [a] . . . charter provision, ordinance, regulation, rule, policy, or any other directive . . . that prescribe [s] the manner in which [they are to be performed].” (Citations omitted.) Violano v. Fernandez, 280 Conn. 310, 323-24 , 907 A.2d 1188 (2006); see also Benedict v. Norfolk, 296 Conn. 518 , 520 n.4, 997 A.2d 449 (2010) (“for the purposes of § 52-557n, municipal acts that would otherwise be considered discretionary will only be

12012–2012
Vacco v. Microsoft Corp. green
conn · 2002
2 sentences

2002Vacco v. Microsoft Corp. , 260 Conn. 59 , 90-92 , 793 A.2d 1048 (2002).

2002The Supreme Court specifically held that "applying the three-part policy analysis to the facts of the present case, we are convinced that the plaintiff's claimed injuries are too indirect and remote with respect to the defendant's alleged anticompetitive conduct for the plaintiff to recover under CUTPA." Id., 90 .

12002–2002
Bridgeport Bowl-O-Rama, Inc. v. Zoning Board of Appeals green
conn · 1985
2 sentences

2001"A statutory right to appeal may be taken advantage of only by strict compliance with the statutory provisions by which it is created." (Internal quotation marks omitted.) Bridgeport Bowl-O-Rama, Inc. v. Zoning Board of Appeals , 195 Conn. 276 , 283 , 487 A.2d 559 (1985).

2001"A statutory right to appeal may be taken advantage of only by strict compliance with the statutory provisions by which it is created." (Internal quotation marks omitted.) Bridgeport Bowl-O-Rama, Inc. v. Zoning Board of Appeals , 195 Conn. 276 , 283 , 487 A.2d 559 (1985).

12001–2001
Town of South Windsor v. South Windsor Police Union Local 1480 green
conn · 2001
1 sentence

2001The policy exception is narrowly construed and applies only when the award would violate some explicit public policy that is well defined and dominant, and that is ascertained by reference to the laws and legal precedents and not from general considerations of supposed public interest." South Windsor v. Police Union Local 480, 255 Conn. 800 , 815 (2001).

12001–2001
State v. Pollitt green
conn · 1987
2 sentences

1994State v. Pollitt, 205 Conn. 61, 73 , 530 A.2d 155 (1987); Robinson v. Faulkner, 163 Conn. 365, 374 , 306 A.2d 857 (1972). “[W]e have followed the policy that inquiry on insurance interest and its extent is within the sound discretion of the trial court.” Robinson v. Faulkner, supra, 374 .

1994State v. Pollitt, 205 Conn. 61, 73 , 530 A.2d 155 (1987); Robinson v. Faulkner, 163 Conn. 365, 374 , 306 A.2d 857 (1972). “[W]e have followed the policy that inquiry on insurance interest and its extent is within the sound discretion of the trial court.” Robinson v. Faulkner, supra, 374 .

11994–1994
Robinson v. Faulkner green
conn · 1972
2 sentences

1994State v. Pollitt, 205 Conn. 61, 73 , 530 A.2d 155 (1987); Robinson v. Faulkner, 163 Conn. 365, 374 , 306 A.2d 857 (1972). “[W]e have followed the policy that inquiry on insurance interest and its extent is within the sound discretion of the trial court.” Robinson v. Faulkner, supra, 374 .

1994State v. Pollitt, 205 Conn. 61, 73 , 530 A.2d 155 (1987); Robinson v. Faulkner, 163 Conn. 365, 374 , 306 A.2d 857 (1972). “[W]e have followed the policy that inquiry on insurance interest and its extent is within the sound discretion of the trial court.” Robinson v. Faulkner, supra, 374 .

11994–1994
Cohn v. Pacific Employers Insurance green
conn · 1990
1 sentence

1990Cohn, 213 Conn. at 547 -48 .

11990–1990
Lowell v. Daly green
conn · 1961
2 sentences

1972Lowell v. Daly, 148 Conn. 266, 268 , 169 A.2d 888 ; Girard v. *375 Grosvenordale Co., 82 Conn. 271, 279 , 73 A. 747 .

1972Lowell v. Daly, 148 Conn. 266, 268 , 169 A.2d 888 ; Girard v. *375 Grosvenordale Co., 82 Conn. 271, 279 , 73 A. 747 .

11972–1972
Girard v. Grosvenordale Co. green
conn · 1909
2 sentences

1972Lowell v. Daly, 148 Conn. 266, 268 , 169 A.2d 888 ; Girard v. *375 Grosvenordale Co., 82 Conn. 271, 279 , 73 A. 747 .

1972Lowell v. Daly, 148 Conn. 266, 268 , 169 A.2d 888 ; Girard v. *375 Grosvenordale Co., 82 Conn. 271, 279 , 73 A. 747 .

11972–1972

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 52-557n (5)

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 183 (1891–2026) TX 176 (1904–2026) IL 160 (1895–2026) NY 98 (1863–2025) LA 75 (1907–2023) PA 73 (1891–2026) MO 56 (1875–2021) WV 54 (1901–2026) MI 53 (1895–2024) NJ 49 (1902–2023) WA 48 (1894–2025) FL 47 (1936–2022) OH 44 (1912–2024) WI 43 (1953–2026) NC 34 (1915–2025) MD 30 (1933–2021) GA 29 (1921–2025) KS 29 (1917–2025) WY 29 (1978–2026) AZ 28 (1927–2022) MA 28 (1857–2021) AR 27 (1909–2025) IN 27 (1874–2024) IA 24 (1897–2016) KY 23 (1903–2025) MS 22 (1951–2015) AL 21 (1834–2018) MN 20 (1976–2014) NE 19 (1896–2022) OR 19 (1905–2023) TN 19 (1927–2021) NM 18 (1933–2016) VA 18 (1926–2025) CT 16 (1963–2025) VT 15 (1899–2024) DE 14 (1961–2024) CO 12 (1908–2017) OK 12 (1923–2022) UT 12 (1933–2022) SC 11 (1933–2026) AK 10 (1960–2004) ID 9 (1987–2022) NH 8 (1936–1999) ND 7 (1901–2024) DC 7 (1978–2025) SD 6 (1972–2026) MT 6 (1935–2016) NV 5 (2011–2022) RI 5 (1970–2004) ME 4 (1963–2002) HI 4 (1964–2015)

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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