claim of cumulative error (California) · Go Syfert
← California issues

claim of cumulative error in California

103 California opinions name it 2 courts 2012–2026 67 in the last five years

The cases below were cited by California 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 (14)

CaseFollowedCited
In Re Avenagreen
cal · 1996 · cited in 28 California opinions naming this issue, 2016–2026
2 sentences

2026“Under the ‘cumulative error’ doctrine, errors that are individually harmless may nevertheless have a cumulative effect that is prejudicial.” (In re Avena (1996) 12 Cal.4th 694, 772, fn. 32 .) A claim of cumulative error is essentially a due process claim.

2025“Under the ‘cumulative error’ doctrine, errors that are individually harmless may nevertheless have a cumulative effect that is prejudicial.” (In re Avena (1996) 12 Cal.4th 694, 772, fn. 32 .) A claim of cumulative error is essentially a due process claim.

2828
People v. Rivasgreen
calctapp · 2013 · cited in 40 California opinions naming this issue, 2013–2026
2 sentences

2025Cumulative Error Defendant claims cumulative error, which “is present when the combined effect of the trial court’s errors is prejudicial or harmful to the defendant.” (People v. Capers (2019) 7 Cal.5th 989, 1017 ; accord, People v. Winbush (2017) 2 Cal.5th 402, 487 ; People v. Hinton (2006) 37 Cal.4th 839, 897 .) “A claim of cumulative error is in essence a due process claim and is often presented as such (see, e.g., People v. Rogers (2006) 39 Cal.4th 826, 911 ). ‘The “litmus test” for cumulative error “is whether defendant received due process and a fair trial.”’” (People v. Rivas (2013) 214

2025Cumulative error “[A] series of trial errors, though independently harmless, may in some circumstances rise by accretion to the level of reversible and prejudicial error.” (People v. Hill (1998) 17 Cal.4th 800, 844 .) “A claim of cumulative error is in essence a due process claim . . . .” (People v. Rivas (2013) 214 Cal.App.4th 1410, 1436 .) “ ‘The “litmus test” for cumulative error “is whether defendant received due process and a fair trial.” ’ ” (Ibid.) “[T]he reviewing court must ‘review each allegation and assess the cumulative effect of any errors to see if it is reasonably probable the j

740
People v. Elizaldegreen
cal · 2015 · cited in 7 California opinions naming this issue, 2019–2022
2 sentences

2022(People v. Williams (2013) 56 Cal.4th 165, 201 , disapproved on another ground by People v. Elizalde (2015) 61 Cal.4th 523, 538, fn. 9 ; People v. Leeds (2015) 240 Cal.App.4th 822, 837 .) III.

2021(People v. Williams (2013) 56 Cal.4th 165, 201 , disapproved on another ground by People v. Elizalde (2015) 61 Cal.4th 523, 538, fn. 9 ; People v. Sedillo, supra, at p. 1068 ; People v. Leeds (2015) 240 Cal.App.4th 822, 837 .) IV.

47
People v. Rogersgreen
cal · 2006 · cited in 6 California opinions naming this issue, 2012–2025
2 sentences

2025Cumulative Error Defendant claims cumulative error, which “is present when the combined effect of the trial court’s errors is prejudicial or harmful to the defendant.” (People v. Capers (2019) 7 Cal.5th 989, 1017 ; accord, People v. Winbush (2017) 2 Cal.5th 402, 487 ; People v. Hinton (2006) 37 Cal.4th 839, 897 .) “A claim of cumulative error is in essence a due process claim and is often presented as such (see, e.g., People v. Rogers (2006) 39 Cal.4th 826, 911 ). ‘The “litmus test” for cumulative error “is whether defendant received due process and a fair trial.”’” (People v. Rivas (2013) 214

2014A claim of cumulative error is in essence a due process claim and is often presented as such (see, e.g., People v. Rogers (2006) 39 Cal.4th 826, 911 ).

36
People v. Richiegreen
calctapp · 1994 · cited in 3 California opinions naming this issue, 2013–2014
2 sentences

2014“Because we identified only one harmless error, the claim of cumulative error is without merit.” (People v. Vieira (2005) 35 Cal.4th 264, 305 ; see also People v. Richie (1994) 28 Cal.App.4th 1347, 1364, fn. 6 [“Since we have found only one error properly preserved for appeal, we need not address appellant’s contention that cumulative error at trial requires reversal.”].) 22 DISPOSITION The judgment is affirmed.

2013However, “[b]ecause we identified only one harmless error [the trial court‟s failure to define 30 semiautomatic firearm], the claim of cumulative error is without merit.” (People v. Vieira (2005) 35 Cal.4th 264, 305 ; see also People v. Richie (1994) 28 Cal.App.4th 1347, 1364, fn. 6 [“Since we have found only one error properly preserved for appeal, we need not address appellant‟s contention that cumulative error at trial requires reversal.”].) 7.

33
People v. Cucciagreen
calctapp · 2002 · cited in 10 California opinions naming this issue, 2012–2025
2 sentences

2025Cumulative Error Defendant claims cumulative error, which “is present when the combined effect of the trial court’s errors is prejudicial or harmful to the defendant.” (People v. Capers (2019) 7 Cal.5th 989, 1017 ; accord, People v. Winbush (2017) 2 Cal.5th 402, 487 ; People v. Hinton (2006) 37 Cal.4th 839, 897 .) “A claim of cumulative error is in essence a due process claim and is often presented as such (see, e.g., People v. Rogers (2006) 39 Cal.4th 826, 911 ). ‘The “litmus test” for cumulative error “is whether defendant received due process and a fair trial.”’” (People v. Rivas (2013) 214

2020The “‘litmus test’ for cumulative error ‘is whether defendant received due process and a fair trial.’” (People v. Cuccia (2002) 97 Cal.App.4th 785, 795 .) Thus, “[a] predicate to a claim of cumulative error is a finding of error.” (People v. Sedillo (2015) 235 Cal.App.4th 1037, 1068 .) Here, there is no cumulative effect of multiple errors, the only situation in which the cumulative error doctrine applies.

210
People v. Williamsgreen
calctapp · 2009 · cited in 9 California opinions naming this issue, 2015–2025
2 sentences

2025“Under the cumulative error doctrine, the reviewing court must ‘review each allegation and assess the cumulative effect of any errors to see if it is reasonably probable the jury would have reached a result more favorable to [the] defendant in their absence.’ ” (People v. Williams (2009) 170 Cal.App.4th 587, 646 .) “ ‘In examining a claim of cumulative error, the critical question is whether [the] defendant received due process and a fair trial.’ ” (People v. Roberts (2021) 65 Cal.App.5th 469 , 482.) Here, there are only two alleged errors, both of which relate to the same evidentiary issue.

2025Cumulative error “[A] series of trial errors, though independently harmless, may in some circumstances rise by accretion to the level of reversible and prejudicial error.” (People v. Hill (1998) 17 Cal.4th 800, 844 .) “A claim of cumulative error is in essence a due process claim . . . .” (People v. Rivas (2013) 214 Cal.App.4th 1410, 1436 .) “ ‘The “litmus test” for cumulative error “is whether defendant received due process and a fair trial.” ’ ” (Ibid.) “[T]he reviewing court must ‘review each allegation and assess the cumulative effect of any errors to see if it is reasonably probable the j

19
People v. Caingreen
cal · 1995 · cited in 7 California opinions naming this issue, 2015–2026
2 sentences

2026(People v. Cain (1995) 10 Cal.4th 1, 82 .) A predicate to a claim of cumulative error is a finding of error.

2025(Cain, supra, 10 Cal.4th at p. 82 ).

17
In re Renogreen
cal · 2012 · cited in 3 California opinions naming this issue, 2020–2022
2 sentences

2021(See In re Reno (2012) 55 Cal.4th 428, 483 [“claims previously rejected on their substantive merits—i.e., this court found no legal error— cannot logically be used to support a cumulative error claim because we have already found there was no error to cumulate”].) And having found the error as to the first contention harmless, we reject the claim of cumulative error.

2020“In theory, the aggregate prejudice from several different errors occurring at trial could require reversal even if no single error was prejudicial by itself.” (In re Reno (2012) 55 Cal.4th 428, 483 .) However, “[a] predicate to a claim of cumulative error is a finding of error.

13
People v. Butlergreen
cal · 2009 · cited in 2 California opinions naming this issue, 2016–2016
2 sentences

2016(See People v. Butler (2009) 46 Cal.4th 847, 885 [claim of cumulative error failed where reviewing court “found no substantial error in any respect”].) “Defendant was entitled to a fair trial but not a perfect one.” (Cunningham, supra, 25 Cal.4th at p. 1009 .) We are satisfied that defendant received due process and a fair trial, and his claim of cumulative error fails.

2016(People v. Butler (2009) 46 Cal.4th 847, 885 .) V.

12
People v. Winbushgreen
cal · 2017 · cited in 1 California opinions naming this issue, 2025–2025
1 sentence

2025Cumulative Error Defendant claims cumulative error, which “is present when the combined effect of the trial court’s errors is prejudicial or harmful to the defendant.” (People v. Capers (2019) 7 Cal.5th 989, 1017 ; accord, People v. Winbush (2017) 2 Cal.5th 402, 487 ; People v. Hinton (2006) 37 Cal.4th 839, 897 .) “A claim of cumulative error is in essence a due process claim and is often presented as such (see, e.g., People v. Rogers (2006) 39 Cal.4th 826, 911 ). ‘The “litmus test” for cumulative error “is whether defendant received due process and a fair trial.”’” (People v. Rivas (2013) 214

11
People v. Lopezgreen
calctapp · 2011 · cited in 1 California opinions naming this issue, 2023–2023
11
People v. Duffgreen
cal · 2014 · cited in 1 California opinions naming this issue, 2023–2023
11
People v. Evansgreen
calctapp · 2011 · cited in 1 California opinions naming this issue, 2021–2021
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (35)

CaseCitedYears
People v. Sedillo green
calctapp · 2015
2 sentences

2026“In examining a claim of cumulative error, the critical question is whether defendant received due process and a fair trial.” (People v. Sedillo (2015) 235 Cal.App.4th 1037, 1068 .) We are satisfied that Waln received a trial that was fair and comported with due process.16 16 For the first time in his reply brief, Waln argues the trial court should have granted his motion for a new trial based on newly discovered evidence.

2025“Under the ‘cumulative error’ doctrine, errors that are individually harmless may nevertheless have a cumulative effect that is prejudicial.” (In re Avena (1996) 12 Cal.4th 694, 772, fn. 32 .) “In examining a claim of cumulative error, the critical question is whether defendant received due process and a fair trial.” (People v. Sedillo (2015) 235 Cal.App.4th 1037, 1068 .) Having examined the entire record, we are satisfied Gifford received a fair trial.

272018–2026
People v. Williams green
cal · 2013
2 sentences

2022(People v. Williams (2013) 56 Cal.4th 165, 201 , disapproved on another ground by People v. Elizalde (2015) 61 Cal.4th 523, 538, fn. 9 ; People v. Leeds (2015) 240 Cal.App.4th 822, 837 .) III.

2021(People v. Williams (2013) 56 Cal.4th 165, 201 , disapproved on another ground by People v. Elizalde (2015) 61 Cal.4th 523, 538, fn. 9 ; People v. Sedillo, supra, at p. 1068 ; People v. Leeds (2015) 240 Cal.App.4th 822, 837 .) IV.

72019–2022
People v. Hill green
calctapp · 1998
2 sentences

2025Cumulative error “[A] series of trial errors, though independently harmless, may in some circumstances rise by accretion to the level of reversible and prejudicial error.” (People v. Hill (1998) 17 Cal.4th 800, 844 .) “A claim of cumulative error is in essence a due process claim . . . .” (People v. Rivas (2013) 214 Cal.App.4th 1410, 1436 .) “ ‘The “litmus test” for cumulative error “is whether defendant received due process and a fair trial.” ’ ” (Ibid.) “[T]he reviewing court must ‘review each allegation and assess the cumulative effect of any errors to see if it is reasonably probable the j

2023Cumulative error “[A] series of trial errors, though independently harmless, may in some circumstances rise by accretion to the level of reversible and prejudicial error.” (People v. Hill (1998) 17 Cal.4th 800, 844 .) “A claim of cumulative error is in essence a due process claim . . . .” (People v. Rivas (2013) 214 Cal.App.4th 1410, 1436 .) “ ‘The “litmus test” for cumulative error “is whether defendant received due process and a fair trial.” ’ ” (Ibid.) “[T]he reviewing court must ‘review each allegation and assess the cumulative effect of any errors to see if it is reasonably probable the j

62013–2025
People v. Leeds green
calctapp · 2015
2 sentences

2022(People v. Williams (2013) 56 Cal.4th 165, 201 , disapproved on another ground by People v. Elizalde (2015) 61 Cal.4th 523, 538, fn. 9 ; People v. Leeds (2015) 240 Cal.App.4th 822, 837 .) III.

2021(People v. Williams (2013) 56 Cal.4th 165, 201 , disapproved on another ground by People v. Elizalde (2015) 61 Cal.4th 523, 538, fn. 9 ; People v. Sedillo, supra, at p. 1068 ; People v. Leeds (2015) 240 Cal.App.4th 822, 837 .) IV.

42020–2022
People v. Kronemyer green
calctapp · 1987
2 sentences

2016In assessing a claim of cumulative error, the critical question is “whether defendant received due process and a fair trial.” (People v. Kronemyer (1987) 189 Cal.App.3d 314, 349 , overruled on another point in People v. Whitmer (2014) 59 Cal.4th 733, 742 .) Here, we have found no substantial error that could have affected the jury’s verdict.

2015(See generally People v. Kronemyer (1987) 189 Cal.App.3d 314, 349 , disapproved on another point in People v. Whitmer (2014) 59 Cal.4th 733 [in assessing a claim of cumulative error, “the litmus test is whether defendant received due process and a fair trial”].) DISPOSITION The judgment is affirmed. 11 ______________________________________ RUSHING, P.J.

42014–2016
People v. Seaton green
cal · 2001
2 sentences

2015(See People v. Seaton (2001) 26 Cal.4th 598, 639 ; People v. Bolin (1998) 18 Cal.4th 297, 335 .) 9 Rios applied the Tewksbury rule to the admission of prior inconsistent statements: “Under this exception to the hearsay rule, a court may allow earlier statements of a witness in evidence to prove the truth of their content where they are inconsistent with matters to which the witness testifies at trial.

2014(See People v. Seaton (2001) 26 Cal.4th 598, 639 ; People v. Bolin (1998) 18 Cal.4th 297, 335 .) 17.

32014–2015
People v. Bolin green
cal · 1998
2 sentences

2015(See People v. Seaton (2001) 26 Cal.4th 598, 639 ; People v. Bolin (1998) 18 Cal.4th 297, 335 .) 9 Rios applied the Tewksbury rule to the admission of prior inconsistent statements: “Under this exception to the hearsay rule, a court may allow earlier statements of a witness in evidence to prove the truth of their content where they are inconsistent with matters to which the witness testifies at trial.

2014(See People v. Seaton (2001) 26 Cal.4th 598, 639 ; People v. Bolin (1998) 18 Cal.4th 297, 335 .) 17.

32014–2015
People v. Tully green
cal · 2012
2 sentences

2014(People v. Tully (2012) 54 Cal.4th 952, 1061 .) 16

2014(People v. Tully (2012) 54 Cal.4th 952, 1061 .) The $400 domestic violence fine is stricken.

32013–2014
People v. Vieira green
cal · 2005
2 sentences

2014“Because we identified only one harmless error, the claim of cumulative error is without merit.” (People v. Vieira (2005) 35 Cal.4th 264, 305 ; see also People v. Richie (1994) 28 Cal.App.4th 1347, 1364, fn. 6 [“Since we have found only one error properly preserved for appeal, we need not address appellant’s contention that cumulative error at trial requires reversal.”].) 22 DISPOSITION The judgment is affirmed.

2013However, “[b]ecause we identified only one harmless error [the trial court‟s failure to define 30 semiautomatic firearm], the claim of cumulative error is without merit.” (People v. Vieira (2005) 35 Cal.4th 264, 305 ; see also People v. Richie (1994) 28 Cal.App.4th 1347, 1364, fn. 6 [“Since we have found only one error properly preserved for appeal, we need not address appellant‟s contention that cumulative error at trial requires reversal.”].) 7.

32013–2014
People v. Hinton green
cal · 2006
2 sentences

2025Cumulative Error Defendant claims cumulative error, which “is present when the combined effect of the trial court’s errors is prejudicial or harmful to the defendant.” (People v. Capers (2019) 7 Cal.5th 989, 1017 ; accord, People v. Winbush (2017) 2 Cal.5th 402, 487 ; People v. Hinton (2006) 37 Cal.4th 839, 897 .) “A claim of cumulative error is in essence a due process claim and is often presented as such (see, e.g., People v. Rogers (2006) 39 Cal.4th 826, 911 ). ‘The “litmus test” for cumulative error “is whether defendant received due process and a fair trial.”’” (People v. Rivas (2013) 214

2015"Under the cumulative error doctrine, the reviewing court must 'review each allegation and assess the cumulative effect of any errors to see if it is reasonably probable the jury would have reached a result more favorable to defendant in their absence.' [Citation.] When the cumulative effect of errors deprives the defendant of a fair trial and due process, reversal is required." (People v. Williams, supra, 170 Cal.App.4th at p. 646 .) However, to prevail on a claim of cumulative error, the defendant must show the 42 "errors . . . undermine[d] the facts supporting [his] guilt" and "explain[] ho

22015–2025
People v. Bunyard green
cal · 1988
2 sentences

2021(People v. Bunyard (1988) 45 Cal.3d 1189, 1236-1237 , disapproved on another ground in People v. Diaz (2015) 60 Cal.4th 1176 .) “In examining a claim of cumulative error, the critical 47 question is whether defendant received due process and a fair trial.” (People v. Sedillo (2015) 235 Cal.App.4th 1037, 1068 ; accord, People v. Rivas (2013) 214 Cal.App.4th 1410, 1436 (Rivas).) Taking all of Brown’s contentions into account, we are satisfied that he received a fair trial as to the robbery counts.

2013(People v. Bunyard (1988) 45 Cal.3d 1189 , 1236–1237.) CONCLUSION The judgment in this case is affirmed. __________________________________ Dondero, J.

22013–2021
Miller v. Alabama green
scotus · 2012
2 sentences

2017As to his sentence, Suarez contends it constitutes cruel and unusual punishment under the Eighth Amendment to the United States Constitution, as interpreted by Miller v. Alabama (2012) 567 U.S. 460 , 132 S.Ct. 2455 , 183 L.Ed.2d 407 ( Miller ).

2017As to his sentence, Suarez contends it constitutes cruel and unusual punishment under the Eighth Amendment to the United States Constitution, as interpreted by Miller v. Alabama (2012) 567 U.S. 460 , 132 S.Ct. 2455 , 183 L.Ed.2d 407 ( Miller ).

22017–2017
People v. Cunningham green
cal · 2001
2 sentences

2016(See People v. Butler (2009) 46 Cal.4th 847, 885 [claim of cumulative error failed where reviewing court “found no substantial error in any respect”].) “Defendant was entitled to a fair trial but not a perfect one.” (Cunningham, supra, 25 Cal.4th at p. 1009 .) We are satisfied that defendant received due process and a fair trial, and his claim of cumulative error fails.

2015(People v. Cain (1995) 34 10 Cal.4th 1, 82 .) As the California Supreme Court has long held, “[a] [d]efendant [is] entitled to a fair trial but not a perfect one.” (People v. Cunningham (2001) 25 Cal.4th 926, 1009 ; People v. Mincey (1992) 2 Cal.4th 408, 454 .) Our review of the record assures us that defendants received due process and a fundamentally fair trial.

22015–2016
People v. Whitmer green
cal · 2014
2 sentences

2016In assessing a claim of cumulative error, the critical question is “whether defendant received due process and a fair trial.” (People v. Kronemyer (1987) 189 Cal.App.3d 314, 349 , overruled on another point in People v. Whitmer (2014) 59 Cal.4th 733, 742 .) Here, we have found no substantial error that could have affected the jury’s verdict.

2015(See generally People v. Kronemyer (1987) 189 Cal.App.3d 314, 349 , disapproved on another point in People v. Whitmer (2014) 59 Cal.4th 733 [in assessing a claim of cumulative error, “the litmus test is whether defendant received due process and a fair trial”].) DISPOSITION The judgment is affirmed. 11 ______________________________________ RUSHING, P.J.

22015–2016
California v. Trombetta green
scotus · 1984
12025–2025
People v. Garton green
cal · 2018
1 sentence

2025To the extent we assumed error to address prejudice, “[t]he instructional and evidentiary errors were minor, especially in light of . . . the significant evidence of guilt, and they did not have ‘negative synergistic effect[s].’ ” (People v. Garton (2018) 4 Cal.5th 485, 521 ; see also People v. Williams, supra, 170 Cal.App.4th at p. 646 .) We thus conclude these errors do not demonstrate Dolce was deprived of due process and a fair trial. 9 DISPOSITION The judgment is affirmed. /s/ FEINBERG, J.

12025–2025
Arizona v. Youngblood green
scotus · 1989
1 sentence

2025Trombetta (1984) 467 U.S. 479 (Trombetta); Arizona v. Youngblood (1988) 488 U.S. 51 (Youngblood).) 2 We shall refer to this motion as Garcia’s Pitchess motion, in reference to Pitchess v. Superior Court (1974) 11 Cal.3d 531 (Pitchess). 3 As a result, we need not address Garcia’s claim that the trial court also improperly instructed the jury on the union of act and intent for voluntary manslaughter. 4 All further statutory references are to the Penal Code unless otherwise noted. 5 By separate order, we deny Garcia’s petition for a writ of habeas corpus premised on the same alleged ineffective a

12025–2025
Pitchess v. Superior Court red
cal · 1974
1 sentence

2025Trombetta (1984) 467 U.S. 479 (Trombetta); Arizona v. Youngblood (1988) 488 U.S. 51 (Youngblood).) 2 We shall refer to this motion as Garcia’s Pitchess motion, in reference to Pitchess v. Superior Court (1974) 11 Cal.3d 531 (Pitchess). 3 As a result, we need not address Garcia’s claim that the trial court also improperly instructed the jury on the union of act and intent for voluntary manslaughter. 4 All further statutory references are to the Penal Code unless otherwise noted. 5 By separate order, we deny Garcia’s petition for a writ of habeas corpus premised on the same alleged ineffective a

12025–2025
People v. Heard green
cal · 2003
1 sentence

2025(People v. Bacon (2010) 50 Cal.4th 1082, 1129 ; People v. Heard (2003) 31 Cal.4th 946, 982 .) IV.

12025–2025
People v. Bacon green
cal · 2010
1 sentence

2025(People v. Bacon (2010) 50 Cal.4th 1082, 1129 ; People v. Heard (2003) 31 Cal.4th 946, 982 .) IV.

12025–2025
People v. Capers green
cal · 2019
12025–2025
People v. Paul C. green
calctapp · 1990
12023–2023
People v. Falck green
calctapp · 1997
12023–2023
People v. Abilez green
cal · 2007
12023–2023
People v. Mora & Rangel green
cal · 2018
12022–2022
People v. Neely green
calctapp · 2004
12022–2022
People v. Bradford green
cal · 1997
12022–2022
Chapman v. California red
scotus · 1967
12022–2022
People v. Woods green
calctapp · 2006
12022–2022
People v. Reed green
cal · 2018
12021–2021
Paulus v. Bob Lynch Ford, Inc. green
calctapp · 2006
12021–2021
Lassiter v. Department of Social Servs. of Durham Cty. green
scotus · 1981
12021–2021
People v. Diaz green
cal · 2015
12021–2021
People v. Sapp green
cal · 2003
12016–2016
People v. Mincey green
cal · 1992
12015–2015

Statutes the citing opinions construe

CA § Cal. Evidence Code § 352 (32) CA § Cal. Penal Code § 187 (30) CA § Cal. Evidence Code § 1101 (19) CA § Cal. Evidence Code § 801 (10) CA § Cal. Evidence Code § 210 (9) CA § Cal. Evidence Code § 350 (8) CA § Cal. Evidence Code § 1109 (7) CA § Cal. Penal Code § 288 (7) CA § Cal. Evidence Code § 353 (6) CA § Cal. Evidence Code § 1200 (5) CA § Cal. Penal Code § 186.22 (5) CA § Cal. Penal Code § 245 (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 103 (2012–2026) FL 88 (2004–2026) NV 46 (1998–2024) OH 28 (2007–2025) WY 22 (1990–2020) UT 19 (2001–2026) MI 16 (2016–2026) KS 14 (2016–2025) MS 11 (1997–2025) GA 10 (2020–2026) NM 8 (1974–2010) IL 6 (1999–2026) PA 6 (2018–2021) MN 4 (2018–2024) TX 4 (1993–2024) AR 3 (2003–2025) SD 3 (2019–2020) MO 3 (2007–2017) IA 3 (2014–2026) WA 2 (2018–2018) ME 2 (2019–2024)

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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