cognizable claim (Ohio) · Go Syfert
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cognizable claim in Ohio

107 Ohio opinions name it 2 courts 1981–2026 26 in the last five years

The cases below were cited by Ohio 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 (26)

CaseFollowedCited
State v. Kappergreen
ohio · 1983 · cited in 20 Ohio opinions naming this issue, 1998–2025
2 sentences

2020Cuyahoga No. 98680, 2013-Ohio-826 , and State v. Kapper, 5 Ohio St.3d 36, 37-38 , 448 N.E.2d 823 (1983) (finding the trial court’s consideration of the state’s untimely brief in opposition to the defendant’s petition for postconviction relief was harmless because the defendant failed to provide evidence of sufficient operative facts demonstrating a cognizable claim of a constitutional error).

2020Cuyahoga No. 98680, 2013-Ohio-826 , and State v. Kapper, 5 Ohio St.3d 36, 37-38 , 448 N.E.2d 823 (1983) (finding the trial court’s consideration of the state’s untimely brief in opposition to the defendant’s petition for postconviction relief was harmless because the defendant failed to provide evidence of sufficient operative facts demonstrating a cognizable claim of a constitutional error).

220
Feldman v. Law Enforcement Associates Corp.green
ca4 · 2014 · cited in 2 Ohio opinions naming this issue, 2023–2025
2 sentences

2025See, e.g., Feldman v. Law Enforcement Associates Corp., 752 F.3d 339, 344 (4th Cir. 2014). [Redding] does not allege he was engaged in a protected activity when he filed complaints with the FAA or when he was denied membership.

2023See, e.g., Feldman v. Law Enforcement Associates Corp., 752 F.3d 339, 344 (4th Cir.2014).

22
State v. Perrygreen
ohio · 1967 · cited in 8 Ohio opinions naming this issue, 2002–2008
2 sentences

2006Specifically, he has argued that: (1) he was denied effective assistance of counsel because his attorney failed to research and properly advise him of a double jeopardy issue; and (2) his constitutional right pursuant to the double jeopardy clause was violated when he was prosecuted for theft of a truck for which he had already been convicted of receiving in another county (collectively the "Errors"). {¶ 4} "A petitioner for post-conviction relief has an initial burden of providing evidence of sufficient operative facts to demonstrate a cognizable claim of a constitutional error." State v. McN

2006Specifically, he has argued that: (1) he was denied effective assistance of counsel because his attorney failed to research and properly advise him of a double jeopardy issue; and (2) his constitutional right pursuant to the double jeopardy clause was violated when he was prosecuted for theft of a truck for which he had already been convicted of receiving in another county (collectively the "Errors"). {¶ 4} "A petitioner for post-conviction relief has an initial burden of providing evidence of sufficient operative facts to demonstrate a cognizable claim of a constitutional error." State v. McN

18
State v. McNeillgreen
ohioctapp · 2000 · cited in 4 Ohio opinions naming this issue, 2003–2015
2 sentences

2015In light of this gatekeeping role, the Supreme Court of Ohio has previously declared that “a trial court properly denies a defendant’s petition for postconviction relief without holding an evidentiary hearing where the petition, the supporting affidavits, the documentary evidence, the files, and the records do not demonstrate petitioner set forth sufficient operative facts to establish substantive grounds for relief.” Calhoun at paragraph two of the syllabus; accord State v. McNeill, 137 Ohio App.3d 34, 40 (9th Dist.2000) (“A petitioner for post-conviction relief has an initial burden of provi

2006Specifically, he has argued that: (1) he was denied effective assistance of counsel because his attorney failed to research and properly advise him of a double jeopardy issue; and (2) his constitutional right pursuant to the double jeopardy clause was violated when he was prosecuted for theft of a truck for which he had already been convicted of receiving in another county (collectively the "Errors"). {¶ 4} "A petitioner for post-conviction relief has an initial burden of providing evidence of sufficient operative facts to demonstrate a cognizable claim of a constitutional error." State v. McN

14
State v. Hillgreen
ohioctapp · 2021 · cited in 2 Ohio opinions naming this issue, 2021–2026
2 sentences

2026Id.

2021Franklin No. 21AP-16, 2021-Ohio-3899, ¶ 15 (“To warrant an evidentiary hearing, the petitioner bears the initial burden of providing evidence that demonstrates a cognizable claim of constitutional error.”). {¶19} “Under Ohio law, ‘a properly licensed attorney is presumed to carry out his duties in a competent manner.’” State v. Harvey, 3d Dist.

12
Park v. Ambrosegreen
ohioctapp · 1993 · cited in 2 Ohio opinions naming this issue, 1997–2002
2 sentences

2002Park v. Ambrose (1993), 85 Ohio App.3d 179 , 183 , 619 N.E.2d 469 , 472 , fn. 1. {¶ 15} "We hold today that in order to present a cognizable claim for back support, an action for support or an action which triggers the duty to support must have been commenced during the child's minority when the legal duty to support exists.

2002Park v. Ambrose (1993), 85 Ohio App.3d 179 , 183 , 619 N.E.2d 469 , 472 , fn. 1. {¶ 15} "We hold today that in order to present a cognizable claim for back support, an action for support or an action which triggers the duty to support must have been commenced during the child's minority when the legal duty to support exists.

12
Consolidated Rail Corporation v. Gottshallgreen
scotus · 1994 · cited in 2 Ohio opinions naming this issue, 1995–1995
2 sentences

1995The court chose the “zone of danger” test as the proper test to be applied in determining whether, as a threshold matter, a plaintiff has stated a cognizable claim under the FELA. 512 U.S. at-, 114 S.Ct. at 2410 , 129 L.Ed.2d at 447 .

1995The court chose the “zone of danger” test as the proper test to be applied in determining whether, as a threshold matter, a plaintiff has stated a cognizable claim under the FELA. 512 U.S. at-, 114 S.Ct. at 2410 , 129 L.Ed.2d at 447 .

12
Thompson v. Donnelly (Slip Opinion)green
ohio · 2018 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See Thompson v. Donnelly, 2018-Ohio-4073, ¶ 6 (holding that direct appeal was an adequate remedy to challenge voluntariness of plea). {¶ 10} Because Wright has failed to state a cognizable claim in mandamus, the Twelfth District correctly granted the clerk’s motion to dismiss.

11
Bell v. McConahaygreen
ohio · 2023 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See Bell v. McConahay, 2023-Ohio-693, ¶ 10-12 (habeas petitioner had an adequate remedy in the ordinary course of the law to raise claims that he was denied his constitutional rights of due process and effective assistance of counsel and to challenge trial court’s alleged failure to conduct plea colloquy). {¶ 17} Because Wright failed to state a cognizable claim in mandamus, the Tenth District correctly granted the clerk’s motion to dismiss, and we therefore affirm the Tenth District’s judgment dismissing Wright’s petition.

11
Colon v. Fortune, 89527 (2-14-2008)green
ohioctapp · 2008 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026The court then concluded that Appellants’ complaint must be dismissed under Civ.R. 12(B)(6), failure to state a cognizable claim. {¶15} “An appellate court applies a de novo standard of review to dismissals for failure to comply with Civ.R. 10(D).” Colon v. Fortune, 2008-Ohio-576, ¶ 8 (8th Dist.). {¶16} Appellants clearly did not comply with Civ.R. 10(D).

11
Edwards v. Kelleygreen
· 2021 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026Law and Analysis In his sole assignment of error, Dr. Joy argues that the trial court erred in granting MetroHealth’s motion for judgment on the pleadings since the “complaint alleged facts that, when assumed as true, supported a cognizable claim for retaliatory termination in violation of [MetroHealth’s] policies and . . . public policy.” A motion for judgment on the pleadings only presents questions of law and tests “the legal sufficiency of the claims asserted.” Crenshaw v. Howard, 2022-Ohio-3914, ¶ 13 (8th Dist.), citing Edwards v. Kelley, 2021-Ohio-2933, ¶ 7 (8th Dist.).

11
Crenshaw v. Howardgreen
ohioctapp · 2022 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026Law and Analysis In his sole assignment of error, Dr. Joy argues that the trial court erred in granting MetroHealth’s motion for judgment on the pleadings since the “complaint alleged facts that, when assumed as true, supported a cognizable claim for retaliatory termination in violation of [MetroHealth’s] policies and . . . public policy.” A motion for judgment on the pleadings only presents questions of law and tests “the legal sufficiency of the claims asserted.” Crenshaw v. Howard, 2022-Ohio-3914, ¶ 13 (8th Dist.), citing Edwards v. Kelley, 2021-Ohio-2933, ¶ 7 (8th Dist.).

11
State v. Lei, Unpublished Decision (5-25-2006)green
ohioctapp · 2006 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026State v. Lei, 2006-Ohio-2608, ¶ 25 (10th Dist.).

11
State ex rel. Robinson v. Pagegreen
ohioctapp · 2024 · cited in 1 Ohio opinions naming this issue, 2025–2025
2 sentences

2025The magistrate assigned to the case issued a decision recommending that the county’s motion be granted because Robinson had not articulated a cognizable claim in mandamus or prohibition and because his complaint did not meet the filing requirements of R.C. 2969.25(C)(1). 2024-Ohio-4468, ¶ 24 and 34-35 (10th Dist.).

2025The magistrate assigned to the case issued a decision recommending that the county’s motion be granted because Robinson had not articulated a cognizable claim in mandamus or prohibition and because his complaint did not meet the filing requirements of R.C. 2969.25(C)(1). 2024-Ohio-4468, ¶ 24, 34-35 (10th Dist.).

11
State v. Turner, Unpublished Decision (3-19-2004)green
ohioctapp · 2004 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025See also State v. Roberts, 2011-Ohio-2534, ¶ 9 (8th Dist.) and State v. Turner, 2004-Ohio-1545, ¶ 108 (7th Dist.) (“[T]he issue of whether the delay in the appeal violated an appellant’s due process right is a cognizable claim on direct appeal.”). {¶ 15} Upon review, Bulger argues that his right to due process was denied and he was denied the effective assistance of counsel because the trial court did not mention appointing appellate counsel at his sentencing hearing, and his appointed trial counsel did not file a timely appeal on his behalf.

11
State v. Harris, 07ap-972 (6-12-2008)green
ohioctapp · 2008 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025Canas at ¶ 12 , citing State v. Harris, 2008-Ohio-2837, ¶ 7 (10th Dist.). {¶ 9} Generally, we review the trial court’s denial of a petition for postconviction relief without a hearing for an abuse of discretion.

11
State v. Robertsgreen
ohioctapp · 2011 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025See also State v. Roberts, 2011-Ohio-2534, ¶ 9 (8th Dist.) and State v. Turner, 2004-Ohio-1545, ¶ 108 (7th Dist.) (“[T]he issue of whether the delay in the appeal violated an appellant’s due process right is a cognizable claim on direct appeal.”). {¶ 15} Upon review, Bulger argues that his right to due process was denied and he was denied the effective assistance of counsel because the trial court did not mention appointing appellate counsel at his sentencing hearing, and his appointed trial counsel did not file a timely appeal on his behalf.

11
State v. Hattongreen
ohio · 2022 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See State v. Bethel, 167 Ohio St.3d 362, 2022-Ohio-783, 192 N.E.3d 470, ¶ 20; State v. Hatton, 169 Ohio St.3d 446, 2022-Ohio-3991, 205 N.E.3d 513, ¶ 37.

2024See State v. Bethel, 167 Ohio St.3d 362, 2022-Ohio-783, 192 N.E.3d 470, ¶ 20; State v. Hatton, 169 Ohio St.3d 446, 2022-Ohio-3991, 205 N.E.3d 513, ¶ 37.

11
State v. Bethel (Slip Opinion)green
ohio · 2022 · cited in 1 Ohio opinions naming this issue, 2024–2024
2 sentences

2024See State v. Bethel, 167 Ohio St.3d 362, 2022-Ohio-783, 192 N.E.3d 470, ¶ 20; State v. Hatton, 169 Ohio St.3d 446, 2022-Ohio-3991, 205 N.E.3d 513, ¶ 37.

2024See State v. Bethel, 167 Ohio St.3d 362, 2022-Ohio-783, 192 N.E.3d 470, ¶ 20; State v. Hatton, 169 Ohio St.3d 446, 2022-Ohio-3991, 205 N.E.3d 513, ¶ 37.

11
State ex rel. Norris v. Wainwright (Slip Opinion)green
ohio · 2019 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024Norris v. Wainwright, 158 Ohio St.3d 20 , 2019-Ohio-4138, ¶ 9 (“If a petitioner claims he is entitled to an earlier release date but not to immediate release from prison, he does not state a cognizable claim in habeas corpus.”).

11
Fortner v. Thomasgreen
ohio · 1970 · cited in 1 Ohio opinions naming this issue, 2023–2023
1 sentence

2023See Fortner v. Thomas, 22 Ohio St.2d 13, 14 (1970) (“It has been long and well established that it is the duty of every judicial tribunal to decide actual controversies between parties legitimately affected by specific facts and to render judgments which can be carried into effect.”) {¶14} Appellants further posit that but for the Amendment passed at the Special Meeting, Appellant Cody Barack would have been elected to the Board at the Annual Meeting.

11
Hynd v. Roeschgreen
ohioctapp · 2016 · cited in 1 Ohio opinions naming this issue, 2016–2016
11
Doner v. Snappgreen
ohioctapp · 1994 · cited in 1 Ohio opinions naming this issue, 2015–2015
11
Newell v. Rolling Hills Apartmentsgreen
iand · 2001 · cited in 1 Ohio opinions naming this issue, 2013–2013
11
Malone v. Lanegreen
ohio · 2002 · cited in 1 Ohio opinions naming this issue, 2003–2003
11
Lewis v. Chapingreen
ohioctapp · 1994 · cited in 1 Ohio opinions naming this issue, 1997–1997
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (54)

CaseCitedYears
State v. Jackson green
ohio · 1980
2 sentences

2019Id., citing State v. Jackson (1980), 64 Ohio St.2d 107 , * * *. {¶19} “To warrant a hearing, a petitioner must first provide evidence which demonstrates a cognizable claim of constitutional error.

2018State v. Jackson (1980), 64 Ohio St.2d 107 . {¶5} “To warrant a hearing, a petitioner must first provide evidence which demonstrates a cognizable claim of constitutional error.

222005–2023
Marquez v. United States green
scotus · 1983
2 sentences

2001State v. Kapper (1983), 5 Ohio St.3d 36 , 37-38 , certiorari denied (1983), 464 U.S. 856 , 104 S.Ct. 174 .

2001State v. Kapper (1983), 5 Ohio St.3d 36 , 37-38 , certiorari denied (1983), 464 U.S. 856 , 104 S.Ct. 174 .

61998–2001
Bruni v. Tatsumi green
ohio · 1976
2 sentences

2013Bruni v. Tatsumi, 46 Ohio St.2d 127 , 346 N.E.2d 673 (1976). {¶25} In Bruni, the Ohio Supreme Court explained a plaintiff’s burden as follows: Under Ohio law, as it has developed, in order to establish medical malpractice, it must be shown by a preponderance of the evidence that the injury complained of was caused by the doing of some particular thing or things that a physician or surgeon of ordinary skill, care and diligence would not have done under like or similar conditions or circumstances, or by the failure or commission to do some particular thing or things that such a physician or surg

2000In order to establish a cognizable claim of medical malpractice, "it must be shown by a preponderance of evidence that the injury complained of was caused by the doing of some particular thing or things that a physician or surgeon of ordinary skill, care and diligence would not have done under like or similar conditions or circumstances, or by the failure or omission to do some particular thing or things that such a physician or surgeon would have done under like or similar conditions and circumstances, and that the injury complained of was the direct and proximate result of such doing or fail

51993–2013
Rose v. Moore green
scotus · 2000
2 sentences

2006Specifically, he has argued that: (1) he was denied effective assistance of counsel because his attorney failed to research and properly advise him of a double jeopardy issue; and (2) his constitutional right pursuant to the double jeopardy clause was violated when he was prosecuted for theft of a truck for which he had already been convicted of receiving in another county (collectively the "Errors"). {¶ 4} "A petitioner for post-conviction relief has an initial burden of providing evidence of sufficient operative facts to demonstrate a cognizable claim of a constitutional error." State v. McN

2006This appeal, filed subsequent to Defendant's direct appeal, asserts a jurisdictional defect and thus shall be treated as a motion for post-conviction relief under R.C. 2953.21 . {¶ 7} "A petitioner for post-conviction relief has an initial burden of providing evidence of sufficient operative facts to demonstrate a cognizable claim of a constitutional error." State v. McNeill (2000), 137 Ohio App.3d 34 , 40 , 738 N.E.2d 23 , appeal not allowed (2000), 89 Ohio St.3d 1453 , certiorari denied (2000), 531 U.S. 1041 .

32003–2006
Ronnie L. Chatman v. James Slagle, Richard Unger green
ca6 · 1997
2 sentences

1999Heck v. Humphrey (1994), 512 U.S. 477 , 486-87 ; Chatman v. Slagle (6th Cir. 1997), 107 F.3d 380 , 382 .

1999Heck v. Humphrey (1994), 512 U.S. 477 , 486-87 ; Chatman v. Slagle (6th Cir. 1997), 107 F.3d 380 , 382 .

21999–1999
Heck v. Humphrey green
scotus · 1994
2 sentences

1999Heck v. Humphrey (1994), 512 U.S. 477 , 486-87 ; Chatman v. Slagle (6th Cir. 1997), 107 F.3d 380 , 382 .

1999Heck v. Humphrey (1994), 512 U.S. 477 , 486-87 ; Chatman v. Slagle (6th Cir. 1997), 107 F.3d 380 , 382 .

21999–1999
State v. Bunch green
ohio · 2022
1 sentence

2026State v. Bunch, 2022-Ohio-4723, ¶ 23 .

12026–2026
Brady v. Maryland green
scotus · 1963
2 sentences

2024“Constitutional Error” {¶ 47} Johnson argues that he adequately raised a cognizable claim of constitutional error through Keith’s affidavit, which he says establishes that Keith committed perjury at his trial and that the perjured testimony was a result of police coercion and pressure to misidentify Johnson as the attacker, and he argues that the 19 SUPREME COURT OF OHIO state’s failure to disclose that coercion violated the Supreme Court of the United States’s holding in Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963).

2024“Constitutional Error” {¶ 47} Johnson argues that he adequately raised a cognizable claim of constitutional error through Keith’s affidavit, which he says establishes that Keith committed perjury at his trial and that the perjured testimony was a result of police coercion and pressure to misidentify Johnson as the attacker, and he argues that the 19 SUPREME COURT OF OHIO state’s failure to disclose that coercion violated the Supreme Court of the United States’s holding in Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963).

12024–2024
State v. Calhoun green
ohio · 1999
2 sentences

2024State v. Calhoun, 86 Ohio St.3d 279, 282-283 , 714 N.E.2d 905 (1999).” State v. McFeeture, 159 Ohio St.3d 1468 , 2020-Ohio-3885 , 150 N.E.3d 123 .

2024State v. Calhoun, 86 Ohio St.3d 279, 282-283 , 714 N.E.2d 905 (1999).” State v. McFeeture, 159 Ohio St.3d 1468 , 2020-Ohio-3885 , 150 N.E.3d 123 .

12024–2024
State ex rel. Payne v. Rose green
ohio · 2023
12023–2023
Smith v. Smith green
ohioctapp · 2019
12022–2022
State v. Harvey green
ohioctapp · 2020
12021–2021
State v. West neutral
ohioctapp · 2013
12020–2020
State v. Steffen green
ohio · 1994
12019–2019
Johnson v. Crutchfield (Slip Opinion) green
ohio · 2014
12019–2019
George Jones v. Select Portfolio Servicing green
ca6 · 2016
12017–2017
Byers DiPaola Castle, L.L.C. v. Portage Cty. Commrs. green
ohioctapp · 2015
12016–2016
Salata v. Vallas green
ohioctapp · 2004
12015–2015
State v. Gondor green
ohio · 2006
12014–2014
Yvonne C. Edwards v. Nathan Habib green
cadc · 1968
12013–2013
W.W.G. Corp. v. Hughes neutral
coloctapp · 1998
12013–2013
Blakemore v. Blakemore green
ohio · 1983
12013–2013
Bradley v. Sprenger Enterprises, Inc., 07ca009238 (4-28-2008) green
ohioctapp · 2008
12013–2013
Farmer v. Brennan green
scotus · 1994
12012–2012
Tucker v. Collins green
ohio · 1992
12012–2012
State ex rel. Nagle v. Olin green
ohio · 1980
12011–2011
Rakas v. Illinois green
scotus · 1979
12009–2009
State v. Tibbetts green
ohio · 2001
12009–2009
Mitchell v. Mitchell green
ohio · 1980
12008–2008
State v. Szefcyk green
ohio · 1996
12006–2006
Harris v. Ron Champion green
ca10 · 1994
12004–2004
United States v. Jerry Lee Smith green
ca6 · 1996
12004–2004
Norman Simmons v. Edward F. Reynolds, Superintendent, Oneida Correctional Facility, and the People of the State of New York green
ca2 · 1990
12004–2004
State ex rel. Kreps v. Christiansen green
ohio · 2000
12004–2004
Universal Coach, Inc. v. New York City Transit Authority, Inc. green
ohioctapp · 1993
12004–2004
Roberts v. Luebbers green
scotus · 2000
12003–2003
State ex rel. Beaver v. Konteh green
ohio · 1998
12003–2003
State v. Richardson neutral
ohio · 1996
12002–2002
Hartmann v. Duffey green
ohio · 2002
12002–2002
State v. Cheren green
ohio · 1995
12002–2002

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2953.21 (32) OH § Ohio Rev. Code § 2953.23 (8) OH § Ohio Rev. Code § 2903.01 (6) OH § Ohio Rev. Code § 2903.02 (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

TN 279 (1994–2026) PA 185 (1976–2026) NY 168 (1973–2026) OH 107 (1981–2026) IL 87 (1973–2026) CA 86 (1985–2026) FL 82 (1981–2025) TX 62 (1986–2026) CT 45 (1990–2026) DE 43 (1997–2026) MO 38 (1988–2025) AR 35 (1991–2025) MI 33 (1981–2026) AZ 32 (1986–2025) NJ 31 (1983–2026) OR 30 (1981–2026) CO 29 (1982–2026) WA 29 (1987–2026) IN 28 (1986–2023) GA 27 (1987–2026) MA 25 (1986–2025) AL 24 (1985–2025) MS 19 (1994–2022) KY 18 (1995–2026) ME 15 (1986–2025) MD 14 (2000–2024) OK 12 (1987–2017) NC 12 (1986–2021) DC 12 (1980–2024) NM 12 (1992–2023) WV 11 (1991–2024) MT 10 (1997–2025) KS 10 (1995–2024) WI 10 (1994–2023) WY 9 (1994–2026) NV 8 (1994–2014) LA 8 (1994–2020) MN 8 (1988–2026) VA 7 (1986–2026) SC 7 (2011–2023) UT 7 (1986–2025) ID 6 (1998–2023) VT 6 (2016–2026) RI 5 (1979–2019) HI 5 (1978–2018) IA 5 (2016–2022) NE 5 (1990–2026) VI 5 (1998–2026) AK 3 (2012–2024) SD 3 (1989–1998) NH 2 (2013–2015)

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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