ex post facto clause (Maine) · Go Syfert
← Maine issues

ex post facto clause in Maine

14 Maine opinions name it 2 courts 1984–2026 2 in the last five years

The cases below were cited by Maine 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 (16)

CaseFollowedCited
State v. Letaliengreen
me · 2009 · cited in 6 Maine opinions naming this issue, 2006–2026
2 sentences

2020In light of this and other provisions of SORNA of 1999, we have held that the intent of SORNA of 1999, as amended, is 10 civil and regulatory in nature.7 See Anderson, 2015 ME 3, ¶ 6 , 108 A.3d 378 ; Letalien, 2009 ME 130, ¶ 30 , 985 A.2d 4 . [¶17] We have previously addressed the “effects” component of the ex post facto analysis of SORNA of 1999.

2020In light of this and other provisions of SORNA of 1999, we have held that the intent of SORNA of 1999, as amended, is 10 civil and regulatory in nature.7 See Anderson, 2015 ME 3, ¶ 6 , 108 A.3d 378 ; Letalien, 2009 ME 130, ¶ 30 , 985 A.2d 4 . [¶17] We have previously addressed the “effects” component of the ex post facto analysis of SORNA of 1999.

36
Doe v. District Attorneygreen
me · 2007 · cited in 5 Maine opinions naming this issue, 2006–2013
2 sentences

2010See Doe v. District Allorney, 2007 ME 139 , ~ 28, 932 A,2d 552, 561 , overruled in part by Letalien, 2009 ME 130 , 985 A,2d 4 ("We conclude that Haskell does not declare for all time that SORNA is immune from an ex post facto challenge.

2010See Doe v. District Allorney, 2007 ME 139 , ~ 28, 932 A,2d 552, 561 , overruled in part by Letalien, 2009 ME 130 , 985 A,2d 4 ("We conclude that Haskell does not declare for all time that SORNA is immune from an ex post facto challenge.

25
State v. Haskellgreen
me · 2001 · cited in 4 Maine opinions naming this issue, 2007–2009
2 sentences

2009The State contends, in part, that the retroactive application of the law to Letalien, involving, among other things, his inclusion in Maine’s Internet registry, does not violate ex post facto or due process protections under the Supreme Court’s decisions in Smith v. Doe, 538 U.S. 84 , 123 S.Ct. 1140 , 155 L.Ed.2d 164 (2003), and Connecticut Department of Public Safety v. Doe, 538 U.S. 1 , 123 S.Ct. 1160 , 155 L.Ed.2d 98 (2003); that the retroactive application of SORNA’s quarterly in-person verification requirement was previously determined constitutional by this Court in Haskell, 2001 ME 154

2009The State contends, in part, that the retroactive application of the law to Letalien, involving, among other things, his inclusion in Maine’s Internet registry, does not violate ex post facto or due process protections under the Supreme Court’s decisions in Smith v. Doe, 538 U.S. 84 , 123 S.Ct. 1140 , 155 L.Ed.2d 164 (2003), and Connecticut Department of Public Safety v. Doe, 538 U.S. 1 , 123 S.Ct. 1160 , 155 L.Ed.2d 98 (2003); that the retroactive application of SORNA’s quarterly in-person verification requirement was previously determined constitutional by this Court in Haskell, 2001 ME 154

24
John Doe XLVI v. Stephanie Andersongreen
me · 2015 · cited in 3 Maine opinions naming this issue, 2017–2026
2 sentences

2026See Anderson, 2015 ME 3, ¶¶ 1-6 , 108 A.3d 378 11 In Williams, we also noted that legislative amendments following Letalien alleviated some of SORNA’s obligations, which we had understood to create an “affirmative disability or restraint” that, in combination with the registration requirement’s role as part of the sentence, created the Ex Post Facto violation in Letalien. 2013 ME 24, ¶¶ 28-33, 46 , 61 A.3d 718 .

2026See Anderson, 2015 ME 3, ¶¶ 1-6 , 108 A.3d 378 11 In Williams, we also noted that legislative amendments following Letalien alleviated some of SORNA’s obligations, which we had understood to create an “affirmative disability or restraint” that, in combination with the registration requirement’s role as part of the sentence, created the Ex Post Facto violation in Letalien. 2013 ME 24, ¶¶ 28-33, 46 , 61 A.3d 718 .

23
Smith v. Doegreen
scotus · 2003 · cited in 3 Maine opinions naming this issue, 2007–2009
2 sentences

2009The State contends, in part, that the retroactive application of the law to Letalien, involving, among other things, his inclusion in Maine’s Internet registry, does not violate ex post facto or due process protections under the Supreme Court’s decisions in Smith v. Doe, 538 U.S. 84 , 123 S.Ct. 1140 , 155 L.Ed.2d 164 (2003), and Connecticut Department of Public Safety v. Doe, 538 U.S. 1 , 123 S.Ct. 1160 , 155 L.Ed.2d 98 (2003); that the retroactive application of SORNA’s quarterly in-person verification requirement was previously determined constitutional by this Court in Haskell, 2001 ME 154

2009The State contends, in part, that the retroactive application of the law to Letalien, involving, among other things, his inclusion in Maine’s Internet registry, does not violate ex post facto or due process protections under the Supreme Court’s decisions in Smith v. Doe, 538 U.S. 84 , 123 S.Ct. 1140 , 155 L.Ed.2d 164 (2003), and Connecticut Department of Public Safety v. Doe, 538 U.S. 1 , 123 S.Ct. 1160 , 155 L.Ed.2d 98 (2003); that the retroactive application of SORNA’s quarterly in-person verification requirement was previously determined constitutional by this Court in Haskell, 2001 ME 154

13
John Doe I v. Robert Williamsgreen
me · 2013 · cited in 2 Maine opinions naming this issue, 2020–2026
2 sentences

2026See Anderson, 2015 ME 3, ¶¶ 1-6 , 108 A.3d 378 11 In Williams, we also noted that legislative amendments following Letalien alleviated some of SORNA’s obligations, which we had understood to create an “affirmative disability or restraint” that, in combination with the registration requirement’s role as part of the sentence, created the Ex Post Facto violation in Letalien. 2013 ME 24, ¶¶ 28-33, 46 , 61 A.3d 718 .

2026See Anderson, 2015 ME 3, ¶¶ 1-6 , 108 A.3d 378 11 In Williams, we also noted that legislative amendments following Letalien alleviated some of SORNA’s obligations, which we had understood to create an “affirmative disability or restraint” that, in combination with the registration requirement’s role as part of the sentence, created the Ex Post Facto violation in Letalien. 2013 ME 24, ¶¶ 28-33, 46 , 61 A.3d 718 .

12
Collins v. Youngbloodgreen
scotus · 1990 · cited in 2 Maine opinions naming this issue, 1992–2009
2 sentences

2009The prohibition on ex post facto laws “applies only to penal statutes which disadvantage the offender affected by them.” Collins v. Youngblood, 497 U.S. 37, 41 , 110 S.Ct. 2715 , 111 L.Ed.2d 30 (1990). [¶ 17] In Collins , the United States Supreme Court comprehensively reviewed the history of interpretation of the ex post facto clause.

2009The prohibition on ex post facto laws “applies only to penal statutes which disadvantage the offender affected by them.” Collins v. Youngblood, 497 U.S. 37, 41 , 110 S.Ct. 2715 , 111 L.Ed.2d 30 (1990). [¶ 17] In Collins , the United States Supreme Court comprehensively reviewed the history of interpretation of the ex post facto clause.

12
State v. Johnsongreen
me · 2006 · cited in 1 Maine opinions naming this issue, 2026–2026
2 sentences

2026See State v. Letalien, 2009 ME 130, ¶ 11 , 894 A.2d 489 ; State v. Johnson, 2006 ME 35, ¶ 14 , 894 A.2d 489 .

2026See State v. Letalien, 2009 ME 130, ¶ 11 , 894 A.2d 489 ; State v. Johnson, 2006 ME 35, ¶ 14 , 894 A.2d 489 .

11
Eastern Enterprises v. Apfelgreen
scotus · 1998 · cited in 1 Maine opinions naming this issue, 2025–2025
1 sentence

2025Id. at 538-39 (Thomas, J., concurring).

11
Stogner v. Californiagreen
scotus · 2003 · cited in 1 Maine opinions naming this issue, 2018–2018
2 sentences

2018See Stogner v. California , 539 U.S. 607 , 611, 123 S.Ct. 2446 , 156 L.Ed.2d 544 (2003) (reasoning that an ex post facto violation occurs where a limitations period is extended " after the State has assured a man that he has become safe from its pursuit" (emphasis added) (quotation marks omitted) ).

2018See Stogner v. California , 539 U.S. 607 , 611, 123 S.Ct. 2446 , 156 L.Ed.2d 544 (2003) (reasoning that an ex post facto violation occurs where a limitations period is extended " after the State has assured a man that he has become safe from its pursuit" (emphasis added) (quotation marks omitted) ).

11
State v. Myrickgreen
me · 1981 · cited in 1 Maine opinions naming this issue, 2009–2009
2 sentences

2009In contrast to ten-year registrants, who must verify their information once annually, lifetime registrants must verify their registration information in person every ninety days and within five days of receipt of a verification request from the local law enforcement agency. 7 34-A M.R.S. § 11222(4)(C) (2008). [¶ 29] As we have already noted, the protection offered by the ex post facto clause of the Maine Constitution is coextensive with that of the United States Constitution. 8 See, e.g., Doe, 2007 ME 139 , ¶ 26 n. 6, 932 A.2d at 560 ; Haskell , 2001 ME 154 , ¶ 6 n. 5, 784 A.2d at 8 ; Chapman,

2009In contrast to ten-year registrants, who must verify their information once annually, lifetime registrants must verify their registration information in person every ninety days and within five days of receipt of a verification request from the local law enforcement agency. [7] 34-A M.R.S. § 11222(4)(C) (2008). *16 [¶ 29] As we have already noted, the protection offered by the ex post facto clause of the Maine Constitution is co-extensive with that of the United States Constitution. [8] See, e.g., Doe, 2007 ME 139 , ¶ 26 n. 6, 932 A.2d at 560 ; Haskell, 2001 ME 154 , ¶ 6 n. 5, 784 A.2d at 8 ;

11
State v. Vainiogreen
me · 1983 · cited in 1 Maine opinions naming this issue, 2009–2009
2 sentences

2009In contrast to ten-year registrants, who must verify their information once annually, lifetime registrants must verify their registration information in person every ninety days and within five days of receipt of a verification request from the local law enforcement agency. 7 34-A M.R.S. § 11222(4)(C) (2008). [¶ 29] As we have already noted, the protection offered by the ex post facto clause of the Maine Constitution is coextensive with that of the United States Constitution. 8 See, e.g., Doe, 2007 ME 139 , ¶ 26 n. 6, 932 A.2d at 560 ; Haskell , 2001 ME 154 , ¶ 6 n. 5, 784 A.2d at 8 ; Chapman,

2009In contrast to ten-year registrants, who must verify their information once annually, lifetime registrants must verify their registration information in person every ninety days and within five days of receipt of a verification request from the local law enforcement agency. [7] 34-A M.R.S. § 11222(4)(C) (2008). *16 [¶ 29] As we have already noted, the protection offered by the ex post facto clause of the Maine Constitution is co-extensive with that of the United States Constitution. [8] See, e.g., Doe, 2007 ME 139 , ¶ 26 n. 6, 932 A.2d at 560 ; Haskell, 2001 ME 154 , ¶ 6 n. 5, 784 A.2d at 8 ;

11
Doe v. Millergreen
ca8 · 2005 · cited in 1 Maine opinions naming this issue, 2007–2007
1 sentence

2007See, e.g., Doe v. Miller, 405 F.3d 700 , 706, 723 (8th Cir.2005) (finding that the evidence after a two-day trial did not demonstrate that residency requirements for sex offenders made the law ex post facto). .

11
People v. Carmonygreen
calctapp · 2005 · cited in 1 Maine opinions naming this issue, 2006–2006
1 sentence

2006See State v. TD (In re TD), 2011 Mich. App. LEXIS 954 at* 18 ("We note that the majority of the binding precedent holds that the SORA does not cause punishment, and the Dipiazza Court's holding to the contrary appears confined to the specific facts of that case."). 2 And explicitly did not address the defendant's ex post facto claim, Carmony, 26 Cal. Rptr. 3d at 370 n.6. 22 The court also analyzed the proportionality of the registration requirements in its determination that SORNA of 1999, as amended, did not constitute punishment, see ll(7), supra. 56 "We have traditionally exercised great re

11
Bagley v. Raymond School Departmentgreen
me · 1999 · cited in 1 Maine opinions naming this issue, 2006–2006
2 sentences

2006Dep 't, 1999 ME 60 , ,-r 13, 728 A.2d 127, 132 (quoting State v. Buzzell, 617 A.2d 1016 , 1018 n.4 (Me. 1992)).

2006Dep 't, 1999 ME 60 , ,-r 13, 728 A.2d 127, 132 (quoting State v. Buzzell, 617 A.2d 1016 , 1018 n.4 (Me. 1992)).

11
Dobbert v. Floridagreen
scotus · 1977 · cited in 1 Maine opinions naming this issue, 1984–1984
2 sentences

1984See e.g., Dobbert v. Florida, 432 U.S. 282, 292-93 , 97 S.Ct. 2290, 2298 , 53 L.Ed.2d 344 (1977); Weaver v. Graham, 450 U.S. 24 , 29 n. 12, 101 S.Ct. 960 , 964 n. 12, 67 L.Ed.2d 17 (1981).

1984See e.g., Dobbert v. Florida, 432 U.S. 282, 292-93 , 97 S.Ct. 2290, 2298 , 53 L.Ed.2d 344 (1977); Weaver v. Graham, 450 U.S. 24 , 29 n. 12, 101 S.Ct. 960 , 964 n. 12, 67 L.Ed.2d 17 (1981).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
Beazell v. Ohio green
scotus · 1925
2 sentences

2009Id. at 42 , 110 S.Ct. 2715 (quoting Beazell v. Ohio, 269 U.S. 167, 169-70 , 46 S.Ct. 68 , 70 L.Ed. 216 (1925)). [¶ 18] The Collins criteria are stated in the alternative; violation of any one prohibition renders a law a violation of the ex post facto clause.

2009Id. at 42 , 110 S.Ct. 2715 (quoting Beazell v. Ohio, 269 U.S. 167, 169-70 , 46 S.Ct. 68 , 70 L.Ed. 216 (1925)). [¶ 18] The Collins criteria are stated in the alternative; violation of any one prohibition renders a law a violation of the ex post facto clause.

21992–2009
Hudson v. United States green
scotus · 1997
2 sentences

2009In both Haskell, 2001 ME 154, ¶¶ 8-22 , 784 A.2d at 8-16 , and Doe, 2007 ME 139, ¶¶ 22-28 , 932 A.2d at 559-61 , we analyzed SORNA of 1999 following the two-step “intent/effects” test employed by the United States Supreme Court in Smith, 538 U.S. at 92 , 123 S.Ct. 1140 , and Hudson v. United States, 522 U.S. 93, 99 , 118 S.Ct. 488 , 139 L.Ed.2d 450 (1997).

2009In both Haskell, 2001 ME 154, ¶¶ 8-22 , 784 A.2d at 8-16 , and Doe, 2007 ME 139, ¶¶ 22-28 , 932 A.2d at 559-61 , we analyzed SORNA of 1999 following the two-step “intent/effects” test employed by the United States Supreme Court in Smith, 538 U.S. at 92 , 123 S.Ct. 1140 , and Hudson v. United States, 522 U.S. 93, 99 , 118 S.Ct. 488 , 139 L.Ed.2d 450 (1997).

22008–2009
Levesque v. Androscoggin County green
me · 2012
2 sentences

2013Summary judgment is properly granted when “the plaintiff fails to establish a prima facie case for each element of [his] cause of action.” Id. (quotation marks omitted). [¶11] The Does’ arguments based on procedural and substantive due process, equal protection, and the Ex Post Facto Clause challenge the constitutionality of SORNA of 1999.

2013Summary judgment is properly granted when “the plaintiff fails to establish a prima facie case for each element of [his] cause of action.” Id. (quotation marks omitted). [¶ 11] The Does’ arguments based on procedural and substantive due process, equal protection, and the Ex Post Facto Clause challenge the constitutionality of SORNA of 1999.

12013–2013
Pharmaceutical Research and Manufacturers of America v. Walsh, Acting Commissioner, Maine Department of Human Services green
scotus · 2003
2 sentences

2009The State contends, in part, that the retroactive application of the law to Letalien, involving, among other things, his inclusion in Maine’s Internet registry, does not violate ex post facto or due process protections under the Supreme Court’s decisions in Smith v. Doe, 538 U.S. 84 , 123 S.Ct. 1140 , 155 L.Ed.2d 164 (2003), and Connecticut Department of Public Safety v. Doe, 538 U.S. 1 , 123 S.Ct. 1160 , 155 L.Ed.2d 98 (2003); that the retroactive application of SORNA’s quarterly in-person verification requirement was previously determined constitutional by this Court in Haskell, 2001 ME 154

2009The State contends, in part, that the retroactive application of the law to Letalien, involving, among other things, his inclusion in Maine's Internet registry, does not violate ex post facto or due process protections under the Supreme Court's decisions in Smith v. Doe, 538 U.S. 84 , 123 S.Ct. 1140 , 155 L.Ed.2d 164 (2003), and Connecticut Department of Public Safety v. Doe, 538 U.S. 1 , 123 S.Ct. 1160 , 155 L.Ed.2d 98 (2003); that the retroactive application of SORNA's quarterly in-person verification requirement was previously determined constitutional by this Court in Haskell, 2001 ME 154

12009–2009
Connecticut Department of Public Safety v. Doe green
scotus · 2003
2 sentences

2009The State contends, in part, that the retroactive application of the law to Letalien, involving, among other things, his inclusion in Maine’s Internet registry, does not violate ex post facto or due process protections under the Supreme Court’s decisions in Smith v. Doe, 538 U.S. 84 , 123 S.Ct. 1140 , 155 L.Ed.2d 164 (2003), and Connecticut Department of Public Safety v. Doe, 538 U.S. 1 , 123 S.Ct. 1160 , 155 L.Ed.2d 98 (2003); that the retroactive application of SORNA’s quarterly in-person verification requirement was previously determined constitutional by this Court in Haskell, 2001 ME 154

2009The State contends, in part, that the retroactive application of the law to Letalien, involving, among other things, his inclusion in Maine’s Internet registry, does not violate ex post facto or due process protections under the Supreme Court’s decisions in Smith v. Doe, 538 U.S. 84 , 123 S.Ct. 1140 , 155 L.Ed.2d 164 (2003), and Connecticut Department of Public Safety v. Doe, 538 U.S. 1 , 123 S.Ct. 1160 , 155 L.Ed.2d 98 (2003); that the retroactive application of SORNA’s quarterly in-person verification requirement was previously determined constitutional by this Court in Haskell, 2001 ME 154

12009–2009
Fletcher v. Peck green
· 1810
2 sentences

2009Writing in Fletcher v. Peck, 10 U.S. (6 Cranch) 87, 137-38 , 3 L.Ed. 162 (1810), Chief Justice John Marshall explained that the framers intended the ex post facto clause to limit legislative power to guard against "violent acts which might grow out of the feeling of the moment.” .

2009Writing in Fletcher v. Peck, 10 U.S. (6 Cranch) 87, 137-38 , 3 L.Ed. 162 (1810), Chief Justice John Marshall explained that the framers intended the ex post facto clause to limit legislative power to guard against "violent acts which might grow out of the feeling of the moment.” .

12009–2009
State v. Chapman green
me · 1996
1 sentence

2009In contrast to ten-year registrants, who must verify their information once annually, lifetime registrants must verify their registration information in person every ninety days and within five days of receipt of a verification request from the local law enforcement agency. [7] 34-A M.R.S. § 11222(4)(C) (2008). *16 [¶ 29] As we have already noted, the protection offered by the ex post facto clause of the Maine Constitution is co-extensive with that of the United States Constitution. [8] See, e.g., Doe, 2007 ME 139 , ¶ 26 n. 6, 932 A.2d at 560 ; Haskell, 2001 ME 154 , ¶ 6 n. 5, 784 A.2d at 8 ;

12009–2009
State v. Joubert green
me · 1992
2 sentences

2009In contrast to ten-year registrants, who must verify their information once annually, lifetime registrants must verify their registration information in person every ninety days and within five days of receipt of a verification request from the local law enforcement agency. 7 34-A M.R.S. § 11222(4)(C) (2008). [¶ 29] As we have already noted, the protection offered by the ex post facto clause of the Maine Constitution is coextensive with that of the United States Constitution. 8 See, e.g., Doe, 2007 ME 139 , ¶ 26 n. 6, 932 A.2d at 560 ; Haskell , 2001 ME 154 , ¶ 6 n. 5, 784 A.2d at 8 ; Chapman,

2009In contrast to ten-year registrants, who must verify their information once annually, lifetime registrants must verify their registration information in person every ninety days and within five days of receipt of a verification request from the local law enforcement agency. [7] 34-A M.R.S. § 11222(4)(C) (2008). *16 [¶ 29] As we have already noted, the protection offered by the ex post facto clause of the Maine Constitution is co-extensive with that of the United States Constitution. [8] See, e.g., Doe, 2007 ME 139 , ¶ 26 n. 6, 932 A.2d at 560 ; Haskell, 2001 ME 154 , ¶ 6 n. 5, 784 A.2d at 8 ;

12009–2009
State v. Buzzell green
me · 1992
1 sentence

2006Dep 't, 1999 ME 60 , ,-r 13, 728 A.2d 127, 132 (quoting State v. Buzzell, 617 A.2d 1016 , 1018 n.4 (Me. 1992)).

12006–2006
Weaver v. Graham green
scotus · 1981
2 sentences

1984See e.g., Dobbert v. Florida, 432 U.S. 282, 292-93 , 97 S.Ct. 2290, 2298 , 53 L.Ed.2d 344 (1977); Weaver v. Graham, 450 U.S. 24 , 29 n. 12, 101 S.Ct. 960 , 964 n. 12, 67 L.Ed.2d 17 (1981).

1984See e.g., Dobbert v. Florida, 432 U.S. 282, 292-93 , 97 S.Ct. 2290, 2298 , 53 L.Ed.2d 344 (1977); Weaver v. Graham, 450 U.S. 24 , 29 n. 12, 101 S.Ct. 960 , 964 n. 12, 67 L.Ed.2d 17 (1981).

11984–1984

Statutes the citing opinions construe

ME § Me. Rev. Stat. tit. 34-A, § 11121 (6) ME § Me. Rev. Stat. tit. 34-A, § 11201 (6) ME § Me. Rev. Stat. tit. 34-A, § 11221 (6) ME § Me. Rev. Stat. tit. 34-A, § 11222 (6) ME § Me. Rev. Stat. tit. 34-A, § 11227 (6) ME § Me. Rev. Stat. tit. 34-A, § 11202 (5) ME § Me. Rev. Stat. tit. 34-A, § 11202-A (5) ME § Me. Rev. Stat. tit. 34-A, § 11203 (5) ME § Me. Rev. Stat. tit. 17-A, § 1152 (4) ME § Me. Rev. Stat. tit. 17-A, § 253 (3) ME § Me. Rev. Stat. tit. 17-A, § 255-A (3) ME § Me. Rev. Stat. tit. 34-A, § 11003 (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

CA 372 (1958–2025) PA 355 (1950–2026) FL 245 (1982–2026) OH 219 (1993–2024) TX 166 (1971–2026) IL 135 (1974–2025) WA 112 (1989–2024) IN 107 (1974–2026) CT 91 (1981–2025) LA 70 (1978–2025) MO 61 (1988–2024) NY 61 (1939–2023) OR 60 (1980–2026) MS 58 (1976–2023) NJ 56 (1978–2026) TN 54 (1993–2025) KS 50 (1987–2026) MI 46 (1942–2026) SC 46 (1989–2023) AZ 43 (1976–2025) NC 42 (1980–2020) IA 40 (1979–2025) KY 29 (1983–2024) AR 29 (1987–2026) MA 29 (1980–2025) WV 27 (1980–2025) WI 27 (1994–2023) RI 26 (1917–2022) MD 25 (1980–2023) DE 23 (1985–2023) OK 23 (1980–2025) CO 22 (1990–2025) GA 22 (1972–2018) AL 21 (1981–2025) AK 21 (1986–2026) MT 20 (1979–2026) NE 17 (1983–2026) VT 17 (2008–2024) ID 17 (1979–2022) DC 17 (1972–2023) NV 16 (1977–2018) MN 15 (1985–2026) HI 15 (1994–2025) VA 14 (1984–2025) ME 14 (1984–2026) SD 11 (1993–2022) ND 10 (1980–2010) UT 10 (1983–2024) NM 9 (2004–2016) WY 7 (1895–2021) NH 6 (1974–2008) PR 4 (1949–1961)

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.

← Caselaw search · G Cite Topics · Brief Check