double jeopardy clause (North Carolina) · Go Syfert
← North Carolina issues

double jeopardy clause in North Carolina

104 North Carolina opinions name it 2 courts 1972–2026 9 in the last five years

The cases below were cited by North Carolina 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 (48)

CaseFollowedCited
State v. Gardnergreen
nc · 1986 · cited in 6 North Carolina opinions naming this issue, 1986–2014
2 sentences

2008The Double Jeopardy clause of the U.S. Constitution protects an individual “against (1) a second prosecution for the same offense after acquittal, (2) a second prosecution for the same offense after conviction, and (3) multiple punishments for the same offense.” State v. Gardner, 315 N.C. 444, 451 , 340 S.E.2d 701, 707 (1986).

2008The Double Jeopardy clause of the U.S. Constitution protects an individual “against (1) a second prosecution for the same offense after acquittal, (2) a second prosecution for the same offense after conviction, and (3) multiple punishments for the same offense.” State v. Gardner, 315 N.C. 444, 451 , 340 S.E.2d 701, 707 (1986).

46
State v. Ezellgreen
ncctapp · 2003 · cited in 4 North Carolina opinions naming this issue, 2007–2026
2 sentences

2013“The double jeopardy clause prohibits ... multiple convictions for the same offense.” State v. Ezell, 159 N.C.

2013“The double jeopardy clause prohibits . . . multiple convictions for the same offense.” State v. Ezell, 159 N.C.

44
State v. Oglesbygreen
ncctapp · 2005 · cited in 4 North Carolina opinions naming this issue, 2021–2022
2 sentences

2022On direct appeal, the Court of Appeals ordered the trial court to arrest judgment on either Oglesby’s conviction for attempted robbery with a dangerous weapon or his conviction for first-degree kidnapping to avoid a double jeopardy violation, State v. Oglesby, 174 N.C.

2022On direct appeal, the Court of Appeals ordered the trial court to arrest judgment on either Oglesby’s conviction for attempted robbery with a dangerous weapon or his conviction for first-degree kidnapping to avoid a double jeopardy violation, State v. Oglesby, 174 N.C.

44
State v. Freelandgreen
nc · 1986 · cited in 5 North Carolina opinions naming this issue, 1986–2022
2 sentences

1986In Freeland we said: "The general rule is that the double jeopardy clause of the Federal Constitution protects an individual `"from being subjected to the hazards of trial and possible conviction more than once for an alleged offense."`" Freeland, 316 N.C. at 21 , 340 S.E.2d at 39 , quoting Missouri v. Hunter, 459 U.S. 359, 365 , 103 S.Ct. 673, 678 , 74 L.Ed.2d 535, 542 (1983) (emphasis ours).

1986In Freeland we said: "The general rule is that the double jeopardy clause of the Federal Constitution protects an individual `"from being subjected to the hazards of trial and possible conviction more than once for an alleged offense."`" Freeland, 316 N.C. at 21 , 340 S.E.2d at 39 , quoting Missouri v. Hunter, 459 U.S. 359, 365 , 103 S.Ct. 673, 678 , 74 L.Ed.2d 535, 542 (1983) (emphasis ours).

35
Blockburger v. United Statesgreen
scotus · 1931 · cited in 4 North Carolina opinions naming this issue, 1990–2014
2 sentences

1990However, the court did apply the test set forth in Blockburger v. United States, 284 U.S. 299, 304 , 52 S.Ct. 180, 182 , 76 L.Ed. 306, 309 (1932) to determine whether the offenses are not the "same offense" within the meaning of the double jeopardy clause.

1990However, the court did apply the test set forth in Blockburger v. United States, 284 U.S. 299, 304 , 52 S.Ct. 180, 182 , 76 L.Ed. 306, 309 (1932) to determine whether the offenses are not the "same offense" within the meaning of the double jeopardy clause.

34
State v. Ballardgreen
nc · 1972 · cited in 4 North Carolina opinions naming this issue, 1977–2005
2 sentences

2005“The double jeopardy clause prohibits (1) a second prosecution for the same offenses after acquittal; (2) a second prosecution for the same offense after conviction; and (3) multiple convictions for the same offense.” Id.

2004See also State v. Ballard, 280 N.C. 479 , 186 S.E.2d 372 (1972).

34
United States v. Wilsongreen
scotus · 1975 · cited in 3 North Carolina opinions naming this issue, 2020–2020
2 sentences

2020App. at 285 , 551 S.E.2d at 918 , and that the State’s appeal did not result in a double jeopardy violation because “reversal would only serve to reinstate the verdict rendered by the jury,” with “defendant [being] in no danger of re[-]prosecution [because] the appeal does not place the defendant in double jeopardy.” Id. at 286 , 551 S.E.2d at 918 (citing Wilson, 420 U.S. at 344–45, 95 S. Ct. at 1022–23, 43 L.

2020App. at 285 , 551 S.E.2d at 918 , and that the State’s appeal did not result in a double jeopardy violation because “reversal would only serve to reinstate the verdict rendered by the jury,” with “defendant [being] in no danger of re[-]prosecution [because] the appeal does not place the defendant in double jeopardy.” Id. at 286 , 551 S.E.2d at 918 (citing Wilson, 420 U.S. at 344–45, 95 S. Ct. at 1022–23, 43 L.

33
State v. Tiradogreen
nc · 2004 · cited in 3 North Carolina opinions naming this issue, 2006–2014
2 sentences

2014See State v. Tirado, 358 N.C. 551, 571 , 599 S.E.2d 515, 529 (2004).

2014The Supreme Court further clarified the double jeopardy analysis in State v. Tirado, 358 N.C. 551, 579 , 599 S.E.2d 515, 534 (2004), cert. denied sub nom.

33
Hudson v. United Statesgreen
scotus · 1997 · cited in 4 North Carolina opinions naming this issue, 1998–2004
2 sentences

2004In Hudson v. United States, 522 U.S. 93 (1997), the United States Supreme Court modified the standard for Double Jeopardy analysis.

2004In Hudson v. United States, 522 U.S. 93 (1997), the United States Supreme Court modified the standard for Double Jeopardy analysis.

24
North Carolina v. Pearcered
scotus · 1969 · cited in 4 North Carolina opinions naming this issue, 1981–2003
2 sentences

1994In the ruling relied on by Beauchamp, the Supreme Court held that this denial of credit violates the double jeopardy clause’s prohibition against “multiple punishments for the same offense,” 395 U.S. at 717 , 89 S.Ct. at 2076 , observing: [T]his basic constitutional guarantee is violated when punishment already exacted for an offense is not fully “credited” in imposing sentence upon a new conviction for the same offense.

1994In the ruling relied on by Beauchamp, the Supreme Court held that this denial of credit violates the double jeopardy clause’s prohibition against “multiple punishments for the same offense,” 395 U.S. at 717 , 89 S.Ct. at 2076 , observing: [T]his basic constitutional guarantee is violated when punishment already exacted for an offense is not fully “credited” in imposing sentence upon a new conviction for the same offense.

24
State v. Hicksgreen
nc · 1951 · cited in 4 North Carolina opinions naming this issue, 1972–1982
2 sentences

1982This test is defined in State v. Hicks, 233 N.C. 511, 516 , 64 S.E. 2d 871, 875 (1951), in opinion by Justice Ervin, as follows: ‘Whether the facts alleged in the second indictment, if given in evidence, would have sustained a conviction under the first indictment [citations], or whether the same evidence would support a conviction in each case. [Citations.]’ 280 N.C. 479, 485 , 186 S.E. 2d 372, 375 (1972).

1982This test is defined in State v. Hicks, 233 N.C. 511, 516 , 64 S.E. 2d 871, 875 (1951), in opinion by Justice Ervin, as follows: ‘Whether the facts alleged in the second indictment, if given in evidence, would have sustained a conviction under the first indictment [citations], or whether the same evidence would support a conviction in each case. [Citations.]’ 280 N.C. 479, 485 , 186 S.E. 2d 372, 375 (1972).

24
State v. Olivergreen
nc · 1996 · cited in 3 North Carolina opinions naming this issue, 1998–2013
2 sentences

1998See also State v. Oliver, 343 N.C. 202 , 470 S.E.2d 16 (1996) (holding that ten-day driver’s license revocation and $50.00 license restoration fee do not constitute punishment barring subsequent DWI prosecution under the double jeopardy clause).

1998See also State v. Oliver, 343 N.C. 202 , 470 S.E.2d 16 (1996) (holding that ten-day driver’s license revocation and $50.00 license restoration fee do not constitute punishment barring subsequent DWI prosecution under the double jeopardy clause).

23
Missouri v. Huntergreen
scotus · 1983 · cited in 3 North Carolina opinions naming this issue, 1986–1986
2 sentences

1986In Freeland we said: "The general rule is that the double jeopardy clause of the Federal Constitution protects an individual `"from being subjected to the hazards of trial and possible conviction more than once for an alleged offense."`" Freeland, 316 N.C. at 21 , 340 S.E.2d at 39 , quoting Missouri v. Hunter, 459 U.S. 359, 365 , 103 S.Ct. 673, 678 , 74 L.Ed.2d 535, 542 (1983) (emphasis ours).

1986In Freeland we said: "The general rule is that the double jeopardy clause of the Federal Constitution protects an individual `"from being subjected to the hazards of trial and possible conviction more than once for an alleged offense."`" Freeland, 316 N.C. at 21 , 340 S.E.2d at 39 , quoting Missouri v. Hunter, 459 U.S. 359, 365 , 103 S.Ct. 673, 678 , 74 L.Ed.2d 535, 542 (1983) (emphasis ours).

23
State v. Oglesbygreen
nc · 2007 · cited in 2 North Carolina opinions naming this issue, 2022–2022
2 sentences

2022App. 658, 665 (2005), and we did not disturb that order, see 361 N.C. 550, 556 (2007).

2022App. 658, 665 (2005), and we did not disturb that order, see 361 N.C. 550, 556 (2007).

22
State v. . Mansfieldgreen
nc · 1934 · cited in 2 North Carolina opinions naming this issue, 2016–2016
2 sentences

2016See State v. Mansfield, 207 N.C. 233 , 176 S.E. 761 (1934).

2016See State v. Mansfield, 207 N.C. 233 , 176 S.E. 761 (1934).

22
State v. Muhammadgreen
ncctapp · 2001 · cited in 2 North Carolina opinions naming this issue, 2005–2016
2 sentences

2016Upon review, this Court recognized that " 'the key question in a double jeopardy analysis is whether the kidnapping charge is supported by evidence from which a jury could reasonably find that the necessary restraint for kidnapping exposed the victim to greater danger than that inherent in the underlying felony itself.' " Id. at 457 , 617 S.E.2d at 109 (quoting State v. Muhammad, 146 N.C.App. 292 , 295, 552 S.E.2d 236 , 237 (2001) ) (brackets omitted).

2016Upon review, this Court recognized that " 'the key question in a double jeopardy analysis is whether the kidnapping charge is supported by evidence from which a jury could reasonably find that the necessary restraint for kidnapping exposed the victim to greater danger than that inherent in the underlying felony itself.' " Id. at 457 , 617 S.E.2d at 109 (quoting State v. Muhammad, 146 N.C.App. 292 , 295, 552 S.E.2d 236 , 237 (2001) ) (brackets omitted).

22
State v. Roopegreen
ncctapp · 1998 · cited in 2 North Carolina opinions naming this issue, 2005–2014
2 sentences

2014Failure to do so precludes reliance on the defense on appeal.” McKenzie, 292 N.C. at 175 , 232 S.E.2d at 428 ; see also State v. Roope, 130 N.C.

2005See State v. Roope, 130 N.C.

22
United States v. Parthenya Whitneygreen
ca5 · 1981 · cited in 2 North Carolina opinions naming this issue, 1999–2007
22
Albernaz v. United Statesgreen
scotus · 1981 · cited in 2 North Carolina opinions naming this issue, 1981–1986
22
State v. Tiradogreen
sc · 2004 · cited in 3 North Carolina opinions naming this issue, 2006–2014
2 sentences

2014See State v. Tirado, 358 N.C. 551, 571 , 599 S.E.2d 515, 529 (2004).

2014The Supreme Court further clarified the double jeopardy analysis in State v. Tirado, 358 N.C. 551, 579 , 599 S.E.2d 515, 534 (2004), cert. denied sub nom.

13
Department of Revenue of Mont. v. Kurth Ranchgreen
scotus · 1994 · cited in 3 North Carolina opinions naming this issue, 1996–2001
2 sentences

1996In summary, the Court concluded that "[t]aken as a whole, this drug tax is a concoction of anomalies, too far-removed in crucial respects from a standard tax assessment to escape characterization as punishment for the purpose of Double Jeopardy analysis." Id.

1996Rather, the Court held that "[t]aken as a whole, [the Montana] drug tax is a concoction of anomalies, too far-removed in crucial respects from a standard tax assessment to escape characterization as punishment for the purpose of Double Jeopardy analysis." Montana Dept. of Rev. v. Kurth Ranch, 511 U.S. ___ , ___, 114 S.Ct. 1937, 1948 , 128 L.Ed.2d 767, 781 (1994).

13
State v. Dowgreen
ncctapp · 1984 · cited in 2 North Carolina opinions naming this issue, 2007–2017
2 sentences

2017It is true that "where judgment must be arrested upon one of two sentences of equal severity because of a double jeopardy violation, the sentence which appears later on the docket, or is second of two counts of a single indictment, or is the second of two indictments, will be stricken." State v. Dow , 70 N.C.

2007In State v. Dow, this Court stated: "where judgment must be arrested upon one of two sentences of equal severity because of a double jeopardy violation, the sentence which appears later on the docket, or is second of two counts of a single indictment, or is the second of two indictments, will be stricken." 70 N.C.App. 82, 87 , 318 S.E.2d 883, 887 (1984)(internal citation and quotation omitted).

12
State v. McKenziegreen
nc · 1977 · cited in 2 North Carolina opinions naming this issue, 1984–2014
2 sentences

2014“The procedure required in criminal trials to assert a double jeopardy defense is well established[.]” State v. McKenzie, 292 N.C. 170, 175 , 232 S.E.2d 424, 428 (1977).

2014“The procedure required in criminal trials to assert a double jeopardy defense is well established[.]” State v. McKenzie, 292 N.C. 170, 175 , 232 S.E.2d 424, 428 (1977).

12
State v. Etheridgegreen
nc · 1987 · cited in 2 North Carolina opinions naming this issue, 2007–2009
12
Brown v. Ohiogreen
scotus · 1977 · cited in 2 North Carolina opinions naming this issue, 1981–1986
12
State v. Muldergreen
ncctapp · 2014 · cited in 1 North Carolina opinions naming this issue, 2026–2026
11
Downum v. United Statesgreen
scotus · 1963 · cited in 1 North Carolina opinions naming this issue, 2019–2019
11
State v. Lachatgreen
nc · 1986 · cited in 1 North Carolina opinions naming this issue, 2019–2019
11
Richardson v. United Statesgreen
scotus · 1984 · cited in 1 North Carolina opinions naming this issue, 2019–2019
11
United States v. Willie E. Sloangreen
ca4 · 1994 · cited in 1 North Carolina opinions naming this issue, 2016–2016
11
State v. Ripleygreen
ncctapp · 2005 · cited in 1 North Carolina opinions naming this issue, 2016–2016
11
State v. Murrellgreen
ncctapp · 1981 · cited in 1 North Carolina opinions naming this issue, 2015–2015
11
State v. Sparksgreen
ncctapp · 2007 · cited in 1 North Carolina opinions naming this issue, 2014–2014
11
State v. Andersongreen
ncctapp · 2009 · cited in 1 North Carolina opinions naming this issue, 2014–2014
11
State v. Hamrickgreen
· 1993 · cited in 1 North Carolina opinions naming this issue, 2014–2014
11
State v. Lewisgreen
ncctapp · 1977 · cited in 1 North Carolina opinions naming this issue, 2013–2013
11
State v. Reidgreen
ncctapp · 2002 · cited in 1 North Carolina opinions naming this issue, 2013–2013
11
State v. Newmangreen
· 2007 · cited in 1 North Carolina opinions naming this issue, 2011–2011
11
State v. Madricgreen
nc · 1991 · cited in 1 North Carolina opinions naming this issue, 2010–2010
11
State v. Hughesgreen
ncctapp · 1999 · cited in 1 North Carolina opinions naming this issue, 2009–2009
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (32)

CaseCitedYears
Benton v. Maryland green
scotus · 1969
2 sentences

1988In Benton v. Maryland, 395 U.S. 784 , 23 L.Ed. 2d 707 (1969), the United States Supreme Court held that the double jeopardy clause of the Fifth Amendment is made applicable to the states by the Fourteenth Amendment. *616 In Ashe v. Swenson, 397 U.S. 436 , 25 L.Ed. 2d 469 (1970), the United States Supreme Court held that collateral estoppel is a part of the Fifth Amendment’s guarantee against double jeopardy.

1988In Benton v. Maryland, 395 U.S. 784 , 23 L.Ed. 2d 707 (1969), the United States Supreme Court held that the double jeopardy clause of the Fifth Amendment is made applicable to the states by the Fourteenth Amendment. *616 In Ashe v. Swenson, 397 U.S. 436 , 25 L.Ed. 2d 469 (1970), the United States Supreme Court held that collateral estoppel is a part of the Fifth Amendment’s guarantee against double jeopardy.

71972–1988
State v. Scott green
nc · 2002
2 sentences

2020In rejecting the defendant’s contention that the State had no right to note an appeal from the trial court’s dismissal order and that allowing the State’s appeal would result in a double jeopardy violation, id. at 285–86, 551 S.E.2d at 918–19, the Court of Appeals began by recognizing that, “[a]t common law, the State had no right to bring an appeal” and could only be “authorized to do so by statute.” Id. at 285, 551 S.E.2d at 918 .

2020In rejecting the defendant’s contention that the State had no right to note an appeal from the trial court’s dismissal order and that allowing the State’s appeal would result in a double jeopardy violation, id. at 285–86, 551 S.E.2d at 918–19, the Court of Appeals began by recognizing that, “[a]t common law, the State had no right to bring an appeal” and could only be “authorized to do so by statute.” Id. at 285, 551 S.E.2d at 918 .

32020–2020
Sattazahn v. Pennsylvania green
scotus · 2003
2 sentences

2020ROBINSON Newby, J., dissenting that “it is not the mere imposition of a life sentence that raises a double-jeopardy bar,” id. at 107 , 123 S. Ct. at 737 .

2020ROBINSON Newby, J., dissenting that “it is not the mere imposition of a life sentence that raises a double-jeopardy bar,” id. at 107 , 123 S. Ct. at 737 .

32020–2020
State v. Scott green
ncctapp · 2001
2 sentences

2020In rejecting the defendant’s contention that the State had no right to note an appeal from the trial court’s dismissal order and that allowing the State’s appeal would result in a double jeopardy violation, id. at 285–86, 551 S.E.2d at 918–19, the Court of Appeals began by recognizing that, “[a]t common law, the State had no right to bring an appeal” and could only be “authorized to do so by statute.” Id. at 285, 551 S.E.2d at 918 .

2020In rejecting the defendant’s contention that the State had no right to note an appeal from the trial court’s dismissal order and that allowing the State’s appeal would result in a double jeopardy violation, id. at 285–86, 551 S.E.2d at 918–19, the Court of Appeals began by recognizing that, “[a]t common law, the State had no right to bring an appeal” and could only be “authorized to do so by statute.” Id. at 285, 551 S.E.2d at 918 .

32020–2020
State v. Rambert green
nc · 1995
2 sentences

2013A double jeopardy claim that the defendant is being punished more than once for the same offense must demonstrate that the multiple punishments stem from “ ‘the “same offense” both in law and in fact.' ” Id. (quoting State v. Lewis, 32 N.C.

2008This same argument, however, was rejected in State v. Rambert, 341 N.C. 173 , 459 S.E.2d 510 , in which our Supreme Court was presented with a double jeopardy challenge to multiple indictments under section 14-34.1.

32008–2019
Miller v. Alabama green
scotus · 2012
2 sentences

2021In compliance with this Court’s mandate, on remand the trial court consequently arrested judgment on Defendant’s attempted robbery conviction (based on the double jeopardy violation). ¶8 On 9 April 2013, Defendant filed a motion for appropriate relief (“MAR”) in Forsyth County Superior Court based on the newly-issued United States Supreme Court decision in Miller v. Alabama, 567 U.S. 460 (2012), which held that a juvenile offender may not be sentenced to mandatory LWOP.

2021In compliance with this Court’s mandate, on remand the trial court consequently arrested judgment on Defendant’s attempted robbery conviction (based on the double jeopardy violation). ¶8 On 9 April 2013, Defendant filed a motion for appropriate relief (“MAR”) in Forsyth County Superior Court based on the newly-issued United States Supreme Court decision in Miller v. Alabama, 567 U.S. 460 (2012), which held that a juvenile offender may not be sentenced to mandatory LWOP.

22021–2021
State v. RAHAMAN green
ncctapp · 2010
2 sentences

2014App. 45, 47 , 641 S.E.2d 339, 341 (2007) (citation and internal quotation marks omitted). “[T]he Double Jeopardy Clause protects against (1) a second prosecution for the same offense after acquittal, (2) a second prosecution for the same offense after conviction, and (3) multiple punishments for the same offense.” State v. Rahaman, 202 N.C.

2014Once jeopardy has attached, defendant is “protect[ed] against (1) a second prosecution for the same offense after acquittal, (2) a second prosecution for the same offense after conviction, and (3) multiple punishments for the same offense." State v. Rahaman, 202 N.C.

22014–2014
State v. Evans green
ncctapp · 2001
2 sentences

2013Stat. § 20-16.5 requiring a thirty-day revocation constituted a double jeopardy violation. 145 N.C.

2013App. at 325 , 550 S.E.2d at 855 .

22005–2013
Grady v. Corbin red
scotus · 1990
2 sentences

2012In that footnote, the plurality addressed a concern by the dissenting opinion that the plurality’s overruling of the “same conduct” Double Jeopardy test established by Grady v. Corbin, 495 U.S. 508 , 109 L.

2012In that footnote, the plurality addressed a concern by the dissenting opinion that the plurality’s overruling of the “same conduct” Double Jeopardy test established by Grady v. Corbin, 495 U.S. 508 , 109 L.

21992–2012
Oregon v. Kennedy green
scotus · 1982
21987–1987
Illinois v. Vitale green
scotus · 1980
21984–1986
Illinois v. Somerville green
scotus · 1973
21981–1985
State v. Campbell green
nc · 2017
12026–2026
State v. Davis green
nc · 2010
12024–2024
State v. Simpson green
nc · 1981
12019–2019
State v. Tyson. green
nc · 1905
12019–2019
State v. Artis green
ncctapp · 2005
12019–2019
State v. Jacobs green
ncctapp · 1998
12018–2018
State v. Strickland neutral
ncctapp · 1990
12018–2018
State v. Hice neutral
ncctapp · 1977
12018–2018
State v. Ripley green
nc · 2006
12016–2016
State v. Wilson green
ncctapp · 1998
12016–2016
Shank v. Virginia green
scotus · 2005
12014–2014
Hammond v. Administrative Office of the Illinois Courts green
scotus · 2005
12014–2014
State v. Mintz neutral
nc · 2008
12011–2011
State v. Newman neutral
nc · 2008
12011–2011
State v. Davis green
ncctapp · 2009
12010–2010
State v. Hughes green
nc · 2000
12009–2009
Menna v. New York green
scotus · 1975
12008–2008
State v. Petty green
ncctapp · 1999
12007–2007
State v. Massey green
ncctapp · 2006
12007–2007
State v. Vardiman green
ncctapp · 2001
12007–2007

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 8C-1 (10) NC § N.C. Gen. Stat. § 14-17 (9) NC § N.C. Gen. Stat. § 14-39 (9) NC § N.C. Gen. Stat. § 14-33 (8) NC § N.C. Gen. Stat. § 20-138.1 (8) NC § N.C. Gen. Stat. § 14-32 (7) NC § N.C. Gen. Stat. § 14-72 (7) NC § N.C. Gen. Stat. § 15A-1443 (7) NC § N.C. Gen. Stat. § 7A-27 (7) NC § N.C. Gen. Stat. § 14-32.4 (6) NC § N.C. Gen. Stat. § 15A-1445 (6) NC § N.C. Gen. Stat. § 90-95 (6)

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

TX 1301 (1962–2026) FL 756 (1965–2026) IN 635 (1971–2026) WA 625 (1945–2026) IL 593 (1958–2026) PA 564 (1967–2026) CA 507 (1953–2026) NM 488 (1973–2026) OH 424 (1971–2025) CT 395 (1974–2026) MO 319 (1956–2025) MI 281 (1970–2026) MA 225 (1970–2026) TN 224 (1975–2026) AZ 205 (1960–2026) VA 199 (1970–2026) MS 192 (1977–2026) LA 179 (1974–2025) NY 175 (1960–2026) MD 169 (1956–2026) NJ 148 (1951–2025) KY 145 (1971–2026) GA 142 (1972–2026) WI 139 (1949–2026) AL 131 (1978–2026) KS 117 (1970–2026) CO 115 (1972–2026) AR 111 (1983–2026) NC 104 (1972–2026) WV 101 (1978–2025) DC 100 (1959–2026) HI 96 (1970–2026) AK 85 (1967–2025) IA 82 (1973–2026) MN 75 (1967–2026) WY 67 (1975–2024) NH 66 (1960–2025) OR 65 (1969–2025) MT 62 (1977–2025) ID 61 (1963–2025) NE 59 (1970–2025) SC 57 (1970–2025) ND 56 (1971–2025) RI 54 (1973–2023) OK 52 (1972–2020) UT 48 (1979–2026) ME 48 (1969–2026) DE 48 (1974–2025) NV 47 (1983–2024) SD 35 (1975–2025) VT 22 (1980–2024) VI 15 (1979–2024) GU 4 (2022–2025)

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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