Teague analysis in Washington

15 Washington opinions name it 2 courts 2005–2019 0 in the last five years

The cases below were cited by Washington 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 (10)

Case	Followed	Cited
In re the Personal Restraint of Gentrygreen wash · 2014 · cited in 5 Washington opinions naming this issue, 2015–2016 2 sentences 2016As a new rule, we thus turn to the Teague framework to determine if the change in who bears the burden of proving consent in a second degree rape case warrants retroactivity. ¶15 Under the Teague analysis, a new rule warrants retroactive application under two circumstances: “It must either be a substantive rule that places certain behavior ‘beyond the power of the criminal law-making authority to proscribe’ or a watershed rule of criminal procedure ‘implicit in the concept of ordered liberty.’ ” Gentry, 179 Wn.2d at 628 (internal quotation marks omitted) (quoting Teague, 489 U.S. at 311 ). 2016As a new rule, we thus turn to the Teague framework to determine if the change in who bears the burden of proving consent in a second degree rape case warrants retroactivity. ¶15 Under the Teague analysis, a new rule warrants retroactive application under two circumstances: “It must either be a substantive rule that places certain behavior ‘beyond the power of the criminal law-making authority to proscribe’ or a watershed rule of criminal procedure ‘implicit in the concept of ordered liberty.’ ” Gentry, 179 Wn.2d at 628 (internal quotation marks omitted) (quoting Teague, 489 U.S. at 311 ).	2	5
United States v. Sean Lamar Sanders, A/K/A Sean Lamont Sandersgreen ca4 · 2001 · cited in 2 Washington opinions naming this issue, 2016–2016 2 sentences 2016E.g., United States v. Sanders, 247 F.3d 139, 148-49 (4th Cir. 2001) (distinguishing rule adopted in Sullivan v. Louisiana, 508 U.S. 275 , 113 S. Ct. 2078 , 124 L. 2016E.g., United States v. Sanders, 247 F.3d 139, 148-49 (4th Cir. 2001) (distinguishing rule adopted in Sullivan v. Louisiana, 508 U.S. 275 , 113 S. Ct. 2078 , 124 L.	2	2
Danforth v. Minnesotagreen scotus · 2008 · cited in 2 Washington opinions naming this issue, 2013–2013 2 sentences 2013In fact, Teague “was intended to limit the authority of federal courts to overturn state convictions — not to limit a state court’s authority.” Danforth v. Minnesota, 552 U.S. 264, 280 , 128 S. Ct. 1029 , 169 L. 2013In fact, Teague “was intended to limit the authority of federal courts to overturn state convictions — not to limit a state court’s authority.” Danforth v. Minnesota, 552 U.S. 264, 280 , 128 S. Ct. 1029 , 169 L.	2	2
Marcus Mungo v. George Duncangreen ca2 · 2004 · cited in 2 Washington opinions naming this issue, 2005–2005 2 sentences 2005See Mungo, 393 F.3d at 336 . 2005See Mungo, 393 F.3d at 336 .	2	2
Teague v. Lanegreen scotus · 1989 · cited in 6 Washington opinions naming this issue, 2005–2016 2 sentences 2016As a new rule, we thus turn to the Teague framework to determine if the change in who bears the burden of proving consent in a second degree rape case warrants retroactivity. ¶15 Under the Teague analysis, a new rule warrants retroactive application under two circumstances: “It must either be a substantive rule that places certain behavior ‘beyond the power of the criminal law-making authority to proscribe’ or a watershed rule of criminal procedure ‘implicit in the concept of ordered liberty.’ ” Gentry, 179 Wn.2d at 628 (internal quotation marks omitted) (quoting Teague, 489 U.S. at 311 ). 2016As a new rule, we thus turn to the Teague framework to determine if the change in who bears the burden of proving consent in a second degree rape case warrants retroactivity. ¶15 Under the Teague analysis, a new rule warrants retroactive application under two circumstances: “It must either be a substantive rule that places certain behavior ‘beyond the power of the criminal law-making authority to proscribe’ or a watershed rule of criminal procedure ‘implicit in the concept of ordered liberty.’ ” Gentry, 179 Wn.2d at 628 (internal quotation marks omitted) (quoting Teague, 489 U.S. at 311 ).	1	6
Saffle v. Parksgreen scotus · 1990 · cited in 3 Washington opinions naming this issue, 2005–2016 2 sentences 2016Saffle, 494 U.S. at 495 (holding Teague exceptions not met based on Gideon, 372 U.S. 335 ). ¶17 The second Teague exception, involving “watershed” procedural rules, is limited to new procedures considered essential for an accurate conviction. 2005Thus, the question presented is whether Crawford is a "new rule" of procedure "implicit *252 in the concept of ordered liberty" under the so-called Teague analysis. ¶ 12 The United States Supreme Court has recently described the Teague analysis as "giv[ing] retroactive effect to only a small set of `"watershed rules of criminal procedure" implicating the fundamental fairness and accuracy of the criminal proceeding.'" Schriro v. Summerlin, ___ U.S. ___, 124 S.Ct. 2519, 2523 , 159 L.Ed.2d 442 (2004) (quoting Saffle v. Parks, 494 U.S. 484, 495 , 110 S.Ct. 1257 , 108 L.Ed.2d 415 (1990) (quoting Te	1	3
In re the Personal Restraint of Markelgreen wash · 2005 · cited in 3 Washington opinions naming this issue, 2013–2016 2 sentences 2013Rev. 51 , 65-66 (2012) (noting that the Court "has shifted its terminology somewhat" in describing the first Teague exception as substantive). 10 No. 68168-1-1/11 Wn.2d at 666; see ajso Market 154 Wn.2d at 269 (exception includes "rule[s] of substantive law" and not "a change in the procedures required under the Sixth Amendment[]"). 2013Here, unlike in Penry , the rule in Jones is procedural, not substantive, does not decriminalize any conduct, and does not categorically prohibit the assertion of a plea of not guilty by reason of insanity. (2) Watershed Rule Exception ¶33 The second Teague exception applies only to “a small set of ‘watershed rules of criminal procedure implicating the fundamental fairness and accuracy of the criminal proceeding.’ ” Market, 154 Wn.2d at 269 5 (quoting Schriro, 542 U.S. at 352 ). “ ‘That a new procedural rule is fundamental in some abstract sense is not enough; the rule must be one without whic	1	3
Samaniego v. Stategreen indctapp · 1997 · cited in 1 Washington opinions naming this issue, 2014–2014	1	1
State v. Cabreragreen minn · 2005 · cited in 1 Washington opinions naming this issue, 2014–2014	1	1
Beard v. Banksgreen scotus · 2004 · cited in 1 Washington opinions naming this issue, 2013–2013	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (34)

Case	Cited	Years
Schriro v. Summerlin green scotus · 2004 2 sentences 2013Here, unlike in Penry , the rule in Jones is procedural, not substantive, does not decriminalize any conduct, and does not categorically prohibit the assertion of a plea of not guilty by reason of insanity. (2) Watershed Rule Exception ¶33 The second Teague exception applies only to “a small set of ‘watershed rules of criminal procedure implicating the fundamental fairness and accuracy of the criminal proceeding.’ ” Market, 154 Wn.2d at 269 5 (quoting Schriro, 542 U.S. at 352 ). “ ‘That a new procedural rule is fundamental in some abstract sense is not enough; the rule must be one without whic 2013Here, unlike in Penry , the rule in Jones is procedural, not substantive, does not decriminalize any conduct, and does not categorically prohibit the assertion of a plea of not guilty by reason of insanity. (2) Watershed Rule Exception ¶33 The second Teague exception applies only to “a small set of ‘watershed rules of criminal procedure implicating the fundamental fairness and accuracy of the criminal proceeding.’ ” Market, 154 Wn.2d at 269 5 (quoting Schriro, 542 U.S. at 352 ). “ ‘That a new procedural rule is fundamental in some abstract sense is not enough; the rule must be one without whic	5	2005–2016
Graham v. Collins green scotus · 1993 2 sentences 2016Graham, 506 U.S. at 478 (quoting Teague, 489 U.S. at 313 ). "'[T]his class of rules is extremely narrow, and it is unlikely that any ... ha[s] yet to emerge."' Markel, 154 Wn.2d at 269 (quoting Schriro[8l). 8 Schriro v. Summerlin, 542 U.S. 348, 352 , 124 S. Ct. 2519 , 159 L. 2016Graham, 506 U.S. at 478 (quoting Teague, 489 U.S. at 313 ). “ ‘[T]his class of rules is extremely narrow, and it is unlikely that any . . . ha[s] yet to emerge.’" Markel, 154 Wn.2d at 269 (quoting Schriro[ 8 ]).	4	2013–2016
O'Dell v. Netherland green scotus · 1997 2 sentences 2016O'Dell v. Netherland, 521 U.S. 151, 157 , 117 S. Ct. 1969 , 138 L. 2016O'Dell v. Netherland, 521 U.S. 151, 157 , 117 S. Ct. 1969 , 138 L.	4	2013–2016
In Re the Personal Restraint of Rhome green wash · 2011 2 sentences 2016Restraint of Rhome, 172 Wn.2d 654, 666-67 , 260 P.3d 874 (2011) (applying Teague analysis to petitioner's proposed due process rule); State v. Kilgore, 167 Wn.2d 28, 35 , 216 P.3d 393 (2009) (under Teague analysis, constitutional rule announced in Blakely v. Washington, 542 U.S. 296 , 124 S. Ct. 2531 , 159 L. 2016Restraint of Rhome, 172 Wn.2d 654, 666-67 , 260 P.3d 874 (2011) (applying Teague analysis to petitioner's proposed due process rule); State v. Kilgore, 167 Wn.2d 28, 35 , 216 P.3d 393 (2009) (under Teague analysis, constitutional rule announced in Blakely v. Washington, 542 U.S. 296 , 124 S. Ct. 2531 , 159 L.	3	2013–2016
Commonwealth v. Sylvain green mass · 2013 2 sentences 2015Gentry, 179 Wn.2d at 625 ; cf Commonwealth v. Sylvain, 466 Mass. 422, 433-34 , 995 N.E.2d 760 (2013) (retaining the general Teague framework but declining to adopt the expanded definition of a "new" rule that was articulated after Teague). (b) Padilla significantly changed Washington law It is true that in most cases simply applying the ordinary Strickland test to new facts will announce neither new rules nor significant changes in the law. 2015Gentry, 179 Wn.2d at 625 ; cf Commonwealth v. Sylvain, 466 Mass. 422, 433-34 , 995 N.E.2d 760 (2013) (retaining the general Teague framework but declining to adopt the expanded definition of a "new" rule that was articulated after Teague). (b) Padilla significantly changed Washington law It is true that in most cases simply applying the ordinary Strickland test to new facts will announce neither new rules nor significant changes in the law.	3	2015–2015
Crawford v. Washington green scotus · 2004 2 sentences 2016Restraint ofMarkel, ! 54 Wn.2d 262, 270-71 , Ill P .3d 249 (2005) (rule announced in Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 , 158 L. 2016Restraint ofMarkel, ! 54 Wn.2d 262, 270-71 , Ill P .3d 249 (2005) (rule announced in Crawford v. Washington, 541 U.S. 36 , 124 S. Ct. 1354 , 158 L.	2	2016–2016
State v. Williams-Walker green wash · 2010 2 sentences 2016Restraint of Eastmond, 173 Wn.2d 632, 639-40 , 272 P.3d 188 (2012) (applying Teague analysis to rule announced in State v. Williams-Walker, 167 Wn.2d 889, 897-900 , 225 P.3d 913 (2010), that constitutional jury trial right applies to the imposition of a sentence enhancement); In re Pers. 2016Restraint of Eastmond, 173 Wn.2d 632, 639-40 , 272 P.3d 188 (2012) (applying Teague analysis to rule announced in State v. Williams-Walker, 167 Wn.2d 889, 897-900 , 225 P.3d 913 (2010), that constitutional jury trial right applies to the imposition of a sentence enhancement); In re Pers.	2	2016–2016
Blakely v. Washington green scotus · 2004 2 sentences 2016Restraint of Rhome, 172 Wn.2d 654, 666-67 , 260 P.3d 874 (2011) (applying Teague analysis to petitioner's proposed due process rule); State v. Kilgore, 167 Wn.2d 28, 35 , 216 P.3d 393 (2009) (under Teague analysis, constitutional rule announced in Blakely v. Washington, 542 U.S. 296 , 124 S. Ct. 2531 , 159 L. 2016Restraint of Rhome, 172 Wn.2d 654, 666-67 , 260 P.3d 874 (2011) (applying Teague analysis to petitioner's proposed due process rule); State v. Kilgore, 167 Wn.2d 28, 35 , 216 P.3d 393 (2009) (under Teague analysis, constitutional rule announced in Blakely v. Washington, 542 U.S. 296 , 124 S. Ct. 2531 , 159 L.	2	2016–2016
Sullivan v. Louisiana green scotus · 1993 2 sentences 2016E.g., United States v. Sanders, 247 F.3d 139, 148-49 (4th Cir. 2001) (distinguishing rule adopted in Sullivan v. Louisiana, 508 U.S. 275 , 113 S. Ct. 2078 , 124 L. 2016E.g., United States v. Sanders, 247 F.3d 139, 148-49 (4th Cir. 2001) (distinguishing rule adopted in Sullivan v. Louisiana, 508 U.S. 275 , 113 S. Ct. 2078 , 124 L.	2	2016–2016
Bousley v. United States green scotus · 1998 2 sentences 2016First, W.R. rests in part on statutory as opposed to constitutional interpretation and Teague is "inapplicable to the situation in which [the] Court decides the meaning of a criminal statute," 5 Bousley v. United States, 523 U.S. 614, 620 , 118 S. Ct. 1604 , 140 L. 2016First, W.R. rests in part on statutory as opposed to constitutional interpretation and Teague is "inapplicable to the situation in which [the] Court decides the meaning of a criminal statute," 5 Bousley v. United States, 523 U.S. 614, 620 , 118 S. Ct. 1604 , 140 L.	2	2016–2016
Gideon v. Wainwright green scotus · 1963 2 sentences 2016Saffle, 494 U.S. at 495 (holding Teague exceptions not met based on Gideon, 372 U.S. 335 ). ¶17 The second Teague exception, involving “watershed” procedural rules, is limited to new procedures considered essential for an accurate conviction. 2016Saffle, 494 U.S. at 495 (holding Teague exceptions not met based on Gideon, 372 U.S. 335 ). ¶17 The second Teague exception, involving “watershed” procedural rules, is limited to new procedures considered essential for an accurate conviction.	2	2013–2016
In re the Personal Restraint of Eastmond green wash · 2012 2 sentences 2016Restraint of Eastmond, 173 Wn.2d 632, 639-40 , 272 P.3d 188 (2012) (applying Teague analysis to rule announced in State v. Williams-Walker, 167 Wn.2d 889, 897-900 , 225 P.3d 913 (2010), that constitutional jury trial right applies to the imposition of a sentence enhancement); In re Pers. 2016Restraint of Eastmond, 173 Wn.2d 632, 639-40 , 272 P.3d 188 (2012) (applying Teague analysis to rule announced in State v. Williams-Walker, 167 Wn.2d 889, 897-900 , 225 P.3d 913 (2010), that constitutional jury trial right applies to the imposition of a sentence enhancement); In re Pers.	2	2016–2016
State v. Abrams green wash · 2008 2 sentences 2016Ed. 2d 403 (2004 ), applies only to cases pending on direct review or not yet final); State v. Abrams, 163 Wn.2d 277,290-91 , 178 P.3d 1021 (2008) (applying Teague analysis to new rule based in constitutional jury trial right); In re Pers. 2016Ed. 2d 403 (2004), applies only to cases pending on direct review or not yet final); State v. Abrams, 163 Wn.2d 277, 290-91 , 178 P.3d 1021 (2008) (applying Teague analysis to new rule based in constitutional jury trial right); In re Pers.	2	2016–2016
State v. Williams-Walker green wash · 2010 2 sentences 2016Restraint of Eastmond, 173 Wn.2d 632, 639-40 , 272 P.3d 188 (2012) (applying Teague analysis to rule announced in State v. Williams-Walker, 167 Wn.2d 889, 897-900 , 225 P.3d 913 (2010), that constitutional jury trial right applies to the imposition of a sentence enhancement); In re Pers. 2016Restraint of Eastmond, 173 Wn.2d 632, 639-40 , 272 P.3d 188 (2012) (applying Teague analysis to rule announced in State v. Williams-Walker, 167 Wn.2d 889, 897-900 , 225 P.3d 913 (2010), that constitutional jury trial right applies to the imposition of a sentence enhancement); In re Pers.	2	2016–2016
State v. Kilgore green wash · 2009 2 sentences 2016Restraint of Rhome, 172 Wn.2d 654, 666-67 , 260 P.3d 874 (2011) (applying Teague analysis to petitioner's proposed due process rule); State v. Kilgore, 167 Wn.2d 28, 35 , 216 P.3d 393 (2009) (under Teague analysis, constitutional rule announced in Blakely v. Washington, 542 U.S. 296 , 124 S. Ct. 2531 , 159 L. 2016Restraint of Rhome, 172 Wn.2d 654, 666-67 , 260 P.3d 874 (2011) (applying Teague analysis to petitioner’s proposed due process rule); State v. Kilgore, 167 Wn.2d 28, 35 , 216 P.3d 393 (2009) (under Teague analysis, constitutional rule announced in Blakely v. Washington, 542 U.S. 296 , 124 S. Ct. 2531 , 159 L.	2	2016–2016
State v. Kilgore green wash · 2009 2 sentences 2016Restraint of Rhome, 172 Wn.2d 654, 666-67 , 260 P.3d 874 (2011) (applying Teague analysis to petitioner's proposed due process rule); State v. Kilgore, 167 Wn.2d 28, 35 , 216 P.3d 393 (2009) (under Teague analysis, constitutional rule announced in Blakely v. Washington, 542 U.S. 296 , 124 S. Ct. 2531 , 159 L. 2016Restraint of Rhome, 172 Wn.2d 654, 666-67 , 260 P.3d 874 (2011) (applying Teague analysis to petitioner’s proposed due process rule); State v. Kilgore, 167 Wn.2d 28, 35 , 216 P.3d 393 (2009) (under Teague analysis, constitutional rule announced in Blakely v. Washington, 542 U.S. 296 , 124 S. Ct. 2531 , 159 L.	2	2016–2016
State v. Abrams green wash · 2008 2 sentences 2016Ed. 2d 403 (2004 ), applies only to cases pending on direct review or not yet final); State v. Abrams, 163 Wn.2d 277,290-91 , 178 P.3d 1021 (2008) (applying Teague analysis to new rule based in constitutional jury trial right); In re Pers. 2016Ed. 2d 403 (2004), applies only to cases pending on direct review or not yet final); State v. Abrams, 163 Wn.2d 277, 290-91 , 178 P.3d 1021 (2008) (applying Teague analysis to new rule based in constitutional jury trial right); In re Pers.	2	2016–2016
Matter of Personal Restraint of St. Pierre green wash · 1992 2 sentences 2014Pierre, 118 Wn.2d 321, 327 , 823 P.2d 492 (1992) . 2014Pierre, 118 Wn.2d 321, 327 , 823 P.2d 492 (1992) .	2	2014–2014
Graham v. Florida green scotus · 2010 2 sentences 2013Here, unlike in Penrv, the rule in Jones is procedural, not substantive, does not decriminalize any conduct, and does not categorically prohibit the assertion of a plea of not guilty by reason of insanity. (2) Watershed Rule Exception The second Teague exception applies only to "a small set of 'watershed rules of criminal procedure implicating the fundamental fairness and accuracy of the criminal proceeding.'" Markel, 154 Wn.2d at 2696 (quoting Schriro. 542 U.S. at 352 ). " 'That a new procedural rule is fundamental in some abstract sense is not enough; the rule must 5 Carnev also cites Graham 2013Here, unlike in Penrv, the rule in Jones is procedural, not substantive, does not decriminalize any conduct, and does not categorically prohibit the assertion of a plea of not guilty by reason of insanity. (2) Watershed Rule Exception The second Teague exception applies only to "a small set of 'watershed rules of criminal procedure implicating the fundamental fairness and accuracy of the criminal proceeding.'" Markel, 154 Wn.2d at 2696 (quoting Schriro. 542 U.S. at 352 ). " 'That a new procedural rule is fundamental in some abstract sense is not enough; the rule must 5 Carnev also cites Graham	2	2013–2013
Whorton v. Bockting green scotus · 2007 2 sentences 2013In applying the second Teague exception, the Court has “looked to the example of Gideon, and ‘we have not hesitated to hold that less sweeping and fundamental rules’ do not qualify.” Whorton v. Bockting, 549 U.S. 406, 421 , 127 S. Ct. 1173 , 167 L. 2013In applying the second Teague exception, the Court has “looked to the example of Gideon, and ‘we have not hesitated to hold that less sweeping and fundamental rules’ do not qualify.” Whorton v. Bockting, 549 U.S. 406, 421 , 127 S. Ct. 1173 , 167 L.	2	2013–2013
Penry v. Lynaugh red scotus · 1989 2 sentences 2013The Court also applied the first Teague exception to “rules prohibiting a certain category of punishment for a class of defendants because of their status or offense.” Penry v. Lynaugh, 492 U.S. 302, 330 , 109 S. Ct. 2934 , 106 L. 2013The Court also applied the first Teague exception to “rules prohibiting a certain category of punishment for a class of defendants because of their status or offense.” Penry v. Lynaugh, 492 U.S. 302, 330 , 109 S. Ct. 2934 , 106 L.	2	2013–2013
Atkins v. Virginia green scotus · 2002 2 sentences 2013Ed. 2d 256 (1989), abrogated on other grounds by Atkins v. Virginia, 536 U.S. 304 , 122 S. Ct. 2242 , 153 L. 2013Ed. 2d 256 (1989), abrogated on other grounds by Atkins v. Virginia, 536 U.S. 304 , 122 S. Ct. 2242 , 153 L.	2	2013–2013
Berger v. California green scotus · 1969 2 sentences 2005In contrast, Berger was not a case before the Court on collateral review and would not, therefore, be subject to the Teague analysis if decided today. 393 U.S. 314 . 2005In contrast, Berger was not a case before the Court on collateral review and would not, therefore, be subject to the Teague analysis if decided today. 393 U.S. 314 .	2	2005–2005
In re the Personal Restraint of Colbert green wash · 2016	1	2019–2019
Montgomery v. Louisiana green · 2016	1	2019–2019
In Re Markel green wash · 2005	1	2016–2016
State v. W.R. green wash · 2014	1	2016–2016
Chaidez v. United States green scotus · 2013	1	2015–2015
Commonwealth v. Tirado green pa · 1977	1	2014–2014
State v. Winterstein green wash · 2009	1	2013–2013
Desist v. United States green scotus · 1969	1	2013–2013
State v. Winterstein green wash · 2009	1	2013–2013
State v. Evans green wash · 2005	1	2013–2013
State v. Evans green wash · 2005	1	2013–2013

Statutes the citing opinions construe

WA § Wash. Rev. Code § 10.73.100 (15) WA § Wash. Rev. Code § 10.73.090 (13) WA § Wash. Rev. Code § 10.40.200 (5) USC § 28u.s.c.2255 (3)

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

IL 82 (1975–2023) PA 39 (2004–2025) TX 33 (1951–2017) MN 19 (2003–2025) WA 15 (2005–2019) CA 15 (2005–2024) CO 14 (2002–2026) NY 14 (2002–2025) NM 14 (2005–2023) TN 13 (1984–2022) CT 12 (2002–2024) MI 11 (2005–2024) FL 11 (1995–2025) MS 9 (1992–2023) IN 9 (1990–2023) LA 8 (1992–2022) MA 8 (2005–2013) ID 7 (2010–2023) MT 5 (2001–2006) DE 5 (1993–2026) OR 5 (2002–2022) AL 5 (2002–2015) NJ 4 (1999–2026) NC 4 (1994–2026) WI 4 (1995–2004) HI 4 (2008–2021) AZ 4 (2001–2005) IA 3 (2012–2020) MD 3 (2006–2012) ND 3 (2001–2018) SD 3 (1990–2014) SC 3 (2003–2015) KS 3 (2001–2016) MO 3 (2003–2015) AK 3 (2006–2012) WY 2 (2014–2014) OH 2 (2014–2016) NH 2 (2003–2014) KY 2 (2009–2023) ME 2 (1993–2007) AR 2 (1949–2015) NE 2 (1994–2003) NV 2 (2002–2006)

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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