first prong test (Pennsylvania) · Go Syfert
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first prong test in Pennsylvania

91 Pennsylvania opinions name it 6 courts 1975–2026 22 in the last five years

The cases below were cited by Pennsylvania 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 (43)

CaseFollowedCited
Bogdan, D. v. American Legion Post 153green
pasuperct · 2021 · cited in 3 Pennsylvania opinions naming this issue, 2022–2025
2 sentences

2025“For the first prong of the analysis under Pa.R.A.P. 313(b), a court must determine whether the issue(s) raised in the order are separable from the central issue of the ongoing litigation.” Bogdan v. American Legion Post 153 Home Ass’n, 257 A.3d 751, 755 (Pa. Super. 2021) (citation omitted). “[I]f the resolution of an issue concerning a challenged trial court order can be achieved independent from an analysis of the merits of the underlying dispute, then the order is separable for purposes of determining whether the order is a collateral order pursuant to Rule 313.” Commonwealth v. Kennedy, 87

2023Separable Claim “For the first prong of the analysis under Pa.R.A.P. 313(b), a court must determine whether the issue(s) raised in the order are separable from the central issue of the ongoing litigation.” Bogdan v. American Legion Post 153 Home Assoc., 257 A.3d 751, 755 (Pa. Super. 2021) (citation omitted). “[I]f the resolution of an issue concerning a challenged trial court order can be achieved independent from an analysis of the merits of the underlying dispute, then the order is separable for purposes of determining whether the order is a collateral order pursuant to Rule 313.” Commonweal

33
ABG Promotions v. Parkway Publishing, Inc.green
pasuperct · 2003 · cited in 3 Pennsylvania opinions naming this issue, 2017–2023
2 sentences

2023See - 14 - J-A12020-23 ABG Promotions, 834 A.2d at 616 .

2023See - 14 - J-A12020-23 ABG Promotions, 834 A.2d at 616 .

33
In Re Jsgreen
pasuperct · 2009 · cited in 3 Pennsylvania opinions naming this issue, 2011–2015
2 sentences

2015Namely, the dependency proceeding involves “substantive decisions affecting the child’s best interests, which is the polestar of all dependency proceedings.” In re J.S., 980 A.2d 117, 121 (Pa. Super. 2009).

2012In re J.S., 980 A.2d 117, 121 (Pa. Super.

33
Resource Staffing, Inc. v. Unemployment Compensation Board of Reviewgreen
pacommwct · 2008 · cited in 3 Pennsylvania opinions naming this issue, 2019–2023
2 sentences

2023Res[.] Staffing, Inc. v. Unemployment Comp[.] [Bd.] of Rev[.], 961 A.2d 261, 264 (Pa. Cmwlth. 2008). 9 Begovic v. Unemployment Comp.

2020Resource Staffing, Inc. v. Unemployment Compensation Board of Review, 961 A.2d 261, 264 (Pa. Cmwlth. 2008).

23
Epler v. North American Rockwell Corp.green
pa · 1978 · cited in 3 Pennsylvania opinions naming this issue, 2018–2021
2 sentences

2021The first prong of the test requires us to assess whether the site of the accident was “so connected with the [employer’s] business or operating premises as to form an integral part thereof.” US Airways, Inc. v. Workers’ Compensation Appeal Board (Bockelman), 221 A.3d 171 , 177 (Pa. 2019) (Bockelman II) (citing 7 Epler v. North American Rockwell Corporation, 393 A.2d 1163, 1165 (Pa. 1978)).4 “[T]he critical factor is not the employer’s title to or control over the area, but rather the fact that [the employer] had caused the area to be used by [employees] in performance of their assigned tasks.

2021Our evaluation of the first prong of the test requires us to assess whether the site of the fall is “so connected to [Employer’s] business . . . as to form an integral part thereof.” Epler, 393 A.2d at 1165 (citation omitted).

23
Commonwealth v. Kennedygreen
pa · 2005 · cited in 2 Pennsylvania opinions naming this issue, 2023–2025
2 sentences

2025“For the first prong of the analysis under Pa.R.A.P. 313(b), a court must determine whether the issue(s) raised in the order are separable from the central issue of the ongoing litigation.” Bogdan v. American Legion Post 153 Home Ass’n, 257 A.3d 751, 755 (Pa. Super. 2021) (citation omitted). “[I]f the resolution of an issue concerning a challenged trial court order can be achieved independent from an analysis of the merits of the underlying dispute, then the order is separable for purposes of determining whether the order is a collateral order pursuant to Rule 313.” Commonwealth v. Kennedy, 87

2023Separable Claim “For the first prong of the analysis under Pa.R.A.P. 313(b), a court must determine whether the issue(s) raised in the order are separable from the central issue of the ongoing litigation.” Bogdan v. American Legion Post 153 Home Assoc., 257 A.3d 751, 755 (Pa. Super. 2021) (citation omitted). “[I]f the resolution of an issue concerning a challenged trial court order can be achieved independent from an analysis of the merits of the underlying dispute, then the order is separable for purposes of determining whether the order is a collateral order pursuant to Rule 313.” Commonweal

22
In re L.M.green
pasuperct · 2007 · cited in 2 Pennsylvania opinions naming this issue, 2021–2023
2 sentences

2023See In re L.M., 923 A.2d at 511 ; 23 Pa.C.S.A. § 2511(b). - 10 - J-S28002-23 Here, regarding the first prong of the analysis, the orphans' court found Mother had proven by clear and convincing evidence that Father’s conduct met the grounds for termination of her parental rights to I.W. under Section 2511(a)(1), which provides that parental rights may involuntarily be terminated on the grounds that: The parent by conduct continuing for a period of at least six months immediately preceding the filing of the petition either has evidenced a settled purpose of relinquishing parental claim to a chil

2021See In re L.M., 923 A.2d at 511 ; 23 Pa.C.S.A. § 2511(b). -8- J-A10014-21 Here, regarding the first prong of the analysis, the trial court found that DHS had proven by clear and convincing evidence that Father’s conduct met the grounds for termination of his parental rights under Sections 2511 (a)(1), (a)(2), (a)(5) and (a)(8).

22
Commonwealth v. Chestergreen
pa · 2006 · cited in 2 Pennsylvania opinions naming this issue, 2019–2019
2 sentences

2019See Commonwealth v. Chester, 895 A.2d 520, 523 (Pa. 2006).

2019See Commonwealth v. Chester, 895 A.2d 520, 523 (Pa. 2006).

22
McCoy v. Threshgreen
pasuperct · 2004 · cited in 2 Pennsylvania opinions naming this issue, 2005–2018
2 sentences

2018See 23 Pa.C.S.A. § 5421(a)(2); see also McCoy v. Thresh, 862 A.2d 109, 112 (Pa. Super. 2004) (Pennsylvania courts will not assume jurisdiction under “significant connections” principle unless it appears that no other state can assume jurisdiction under statutory prerequisites substantially similar to Pennsylvania law).

2005See 23 Pa.C.S.A. § 5421(a)(2); see also McCoy v. Thresh, 862 A.2d 109, 112 (Pa.Super.2004) (Pennsylvania courts will not assume jurisdiction under “significant connections” principle unless it appears that no other state can assume jurisdiction under statutory prerequisites substantially similar to Pennsylvania law). ¶ 21 Mother, although a resident of Pennsylvania during her period of military service in this Commonwealth, was born and raised in Florida.

22
Commonwealth v. Burkettgreen
pasuperct · 2010 · cited in 2 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016Id., 5 A.3d at 1279 (holding that “although there is no procedural rule requiring a court to determine a petition within a certain time frame after conducting a hearing in a non-death penalty case, presumptively it should not require more than [the] 120 days [allotted to death penalty cases under Pa.R.Crim.P. 909] to render a decision.”).

2016Id., 5 A.3d at 1279 (holding that “although there is no procedural rule requiring a court to determine a petition within a certain time frame after conducting a hearing in a non-death penalty case, presumptively it should not require more than [the] 120 days [allotted to death penalty cases under Pa.R.Crim.P. 909] to render a decision.”).

22
Scarpitti v. Weborggreen
pa · 1992 · cited in 2 Pennsylvania opinions naming this issue, 1994–2003
2 sentences

2003Restatement (Second) of Contracts § 302 (1979); see also Scarpitti v. Weborg, 530 Pa. 366 , 609 A.2d 147 (1992). ¶ 9 Consequently, the Guy court concluded: There is thus a two part test for determining whether one is an intended third party beneficiary: (1) the recognition of the beneficiary's right must be `appropriate to effectuate the intention of the parties,' and (2) the performance must `satisfy an obligation of the promisee to pay money to the beneficiary' or `the circumstances indicate that the promisee intends to give the beneficiary the benefit of the promised performance.' Id. at 60

2003Restatement (Second) of Contracts § 302 (1979); see also Scarpitti v. Weborg, 530 Pa. 366 , 609 A.2d 147 (1992). ¶ 9 Consequently, the Guy court concluded: There is thus a two part test for determining whether one is an intended third party beneficiary: (1) the recognition of the beneficiary's right must be `appropriate to effectuate the intention of the parties,' and (2) the performance must `satisfy an obligation of the promisee to pay money to the beneficiary' or `the circumstances indicate that the promisee intends to give the beneficiary the benefit of the promised performance.' Id. at 60

12
Chilutti, S. v. Uber Technologies, Inc.green
pasuperct · 2023 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026An en banc panel of this Court held in that case that a browsewrap agreement, like the one used by Empower, may only be enforced if it is “explicitly” stated on the application screens that, by agreeing to the company’s terms and conditions, the “consumer is waiving a right to a jury trial.” Chilutti I, 300 A.3d at 450.

11
In Re:The Estate of McAleer, W. Appeal of: McAleergreen
pasuperct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025See McAleer I, 194 A.3d at 594 .

11
Brown v. Pa. Department of Correctionsgreen
pa · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025This Court can address the issue of whether the trial court erred in modifying the terms of the Consent Order without reviewing the main causes of action, namely Taxpayers’ assessment appeal and constitutional claim. 4 The Township and BPAAR have been precluded from filing briefs or participating in oral argument due to their failure to comply with this Court’s orders. 4 As for the second prong, “a right is important if ‘the interests that would go unprotected without immediate appeal are significant relative to the efficiency interests served by the final order rule.’” K.C., 128 A.3d at 779 [

11
Jones v. North Carolina Prisoners' Labor Union, Inc.green
scotus · 1977 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Regarding the first prong of this test, [t]hough “confinement and the needs of the penal institution impose limitations on constitutional rights, including those derived from the First Amendment,” Jones v. North Carolina Prisoners’ Labor Union, Inc., 433 U.S. 119, 125 (1977), it is equally true that “incarceration does not divest prisoners of all constitutional protections.” Shaw v. Murphy, 532 U.S. 223, 228 (2001).

11
Pell v. Procuniergreen
scotus · 1974 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Accordingly, “a prison inmate retains those First Amendment rights that are not inconsistent with his status as a prisoner or with the legitimate penological objectives of the corrections system.” Pell v. Procunier, 417 U.S. 817, 822 (1974).

11
Shaw v. Murphygreen
scotus · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Regarding the first prong of this test, [t]hough “confinement and the needs of the penal institution impose limitations on constitutional rights, including those derived from the First Amendment,” Jones v. North Carolina Prisoners’ Labor Union, Inc., 433 U.S. 119, 125 (1977), it is equally true that “incarceration does not divest prisoners of all constitutional protections.” Shaw v. Murphy, 532 U.S. 223, 228 (2001).

11
Digital Communication v. Allen Investmentsgreen
pasuperct · 2019 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Trial Ct. Op. at 20-21. -9- J-A27019-22 Regarding the first prong of the test for opening a default judgment, “[t]he timeliness of a petition to open a judgment is measured from the date that notice of the entry of the default judgment is received.” Digital Communications Warehouse, Inc. v. Allen Investments, LLC, 223 A.3d 278, 285 (Pa.Super. 2019) (citation omitted).

11
Sullivan v. Belmont Center for Comprehensive Treatmentgreen
pasuperct · 2004 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See, e.g., Sullivan v. Belmont Ctr. for Comprehensive Treatment, 848 A.2d 994, 996 (Pa. Super. 2004) (affirming an order denying petition to open judgment of non pros, because plaintiff failed to satisfy the first prong of the test). -8- J-S07018-23 Here, the trial court denied Ms. Atuahene’s petition, because it found she failed to satisfy the second and third prongs.

11
Vignola v. Vignolagreen
pasuperct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See Vignola, supra at 393 (emphasis added).

11
Commonwealth v. Maddreygreen
pasuperct · 2019 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022See Commonwealth v. Maddrey, 205 A.3d 323, 328 (Pa.Super. 2019) (“It is well settled that there is no absolute right to an evidentiary hearing on a PCRA petition, and if the PCRA court can determine from the record that no genuine issues of material fact exist, then a hearing is not necessary.” (cleaned up)).

11
Commonwealth v. Postiegreen
pasuperct · 2018 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020See Sepulveda, 55 A.3d at 1117 - 18. -5- J-A11007-20 As to the first prong of the test, “[a] claim has arguable merit where the factual averments, if accurate, could establish cause for relief.” Commonwealth v. Postie, 200 A.3d 1015, 1023 (Pa. Super. 2018) (citation omitted).

11
Commonwealth v. Sepulvedagreen
pa · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020See Sepulveda, 55 A.3d at 1117 - 18. -5- J-A11007-20 As to the first prong of the test, “[a] claim has arguable merit where the factual averments, if accurate, could establish cause for relief.” Commonwealth v. Postie, 200 A.3d 1015, 1023 (Pa. Super. 2018) (citation omitted).

11
Commonwealth v. Champneygreen
pa · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
11
Commonwealth v. Wilsongreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Commonwealth v. Snydergreen
pa · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Commonwealth v. Devlingreen
pa · 1975 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Stauffer v. Unemployment Compensation Board of Reviewgreen
pacommwct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
11
Terletsky v. Prudential Property & Casualty Insurancegreen
pasuperct · 1994 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11
Nordi v. Keystone Health Plan West Inc.green
pasuperct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11
Greene v. United Services Automobile Ass'ngreen
pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11
Ferrick v. Bianchinigreen
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11
Commonwealth v. Smithgreen
pasuperct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
11
Commonwealth v. Hoovergreen
pa · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
11
Commonwealth v. Williamsgreen
pa · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2009–2009
11
Commonwealth v. Jonesgreen
pa · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
11
Consolidated Gas Supply Corp. v. County of Clintongreen
pacommwct · 1984 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
11
Jordan v. Fayette County Board of Assessment Appealsgreen
pacommwct · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2006–2006
11
Geniviva v. Friskgreen
pa · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11
Hoffman v. Knightgreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2005–2005
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (37)

CaseCitedYears
Blockburger v. United States green
scotus · 1931
2 sentences

1995Appellants contend that the proper inquiry was established by the United States Supreme Court in Grady v. Corbin, 495 U.S. 508 , 110 S.Ct. 2084 , 109 L.Ed.2d 548 (1990), and adopted by this Court for purposes of state double jeopardy analysis in Commonwealth v. Labelle, 397 Pa.Super. 179 , 579 A.2d 1315 (1990) (en banc), rev’d. on other grounds, 531 Pa. 256 , 612 A.2d 418 (1990). 2 This Court has analyzed the Grady double jeopardy test and stated: To determine whether a prosecution is barred by double jeopardy, the first prong of the inquiry requires the application of the Blockburger [v. U.S.

1995Appellants contend that the proper inquiry was established by the United States Supreme Court in Grady v. Corbin, 495 U.S. 508 , 110 S.Ct. 2084 , 109 L.Ed.2d 548 (1990), and adopted by this Court for purposes of state double jeopardy analysis in Commonwealth v. Labelle, 397 Pa.Super. 179 , 579 A.2d 1315 (1990) (en banc), rev’d. on other grounds, 531 Pa. 256 , 612 A.2d 418 (1990). 2 This Court has analyzed the Grady double jeopardy test and stated: To determine whether a prosecution is barred by double jeopardy, the first prong of the inquiry requires the application of the Blockburger [v. U.S.

41992–1995
Commonwealth, Aplt. v. Carrasquillo, J. green
pa · 2015
2 sentences

2026The trial court noted that Appellant having failed to establish fair and just reasons for permitting withdrawal of his guilty plea, the “Commonwealth . . . need not demonstrate, and [the trial court] need not analyze prejudice, as Appellant has failed to meet the first prong of the analysis under [Carrasquillo, 115 A.3d at 1291-92 ].” Trial Court Opinion, 3/7/25, at 8.

2018Our Supreme Court narrowed the first prong of that test in 2015, in the companion cases of Carrasquillo, supra, and Commonwealth v. Hvizda, 116 A.3d 1103 (Pa. 2015).1 In Carrasquillo, the court acknowledged that requiring any claim of innocence to serve as a basis for a pre-sentence withdrawal of a guilty plea was unsatisfactory because it did not allow the court to consider the underlying facts of the case.

22018–2026
New York State Rifle & Pistol Assn., Inc. v. Bruen green
scotus · 2022
2 sentences

2025Id. at 32-33 , 142 S.Ct. at 2134-35 .

2025Id. at 32-33 , 142 S.Ct. at 2134-35 .

22025–2025
Hospital & Healthsystem Ass'n v. Department of Public Welfare green
pa · 2005
2 sentences

2006“The first prong of the test requires that the questioned provision be germane to the appropriation.” HAP, 585 Pa. at 121, 888 A.2d at 610 .

2006"The first prong of the test requires that the questioned provision be germane to the appropriation." HAP, 585 Pa. at 121, 888 A.2d at 610 .

22006–2006
K.C. and V.C. v. L.A. Appeal of: D.M and L.N. green
pa · 2015
1 sentence

2025This Court can address the issue of whether the trial court erred in modifying the terms of the Consent Order without reviewing the main causes of action, namely Taxpayers’ assessment appeal and constitutional claim. 4 The Township and BPAAR have been precluded from filing briefs or participating in oral argument due to their failure to comply with this Court’s orders. 4 As for the second prong, “a right is important if ‘the interests that would go unprotected without immediate appeal are significant relative to the efficiency interests served by the final order rule.’” K.C., 128 A.3d at 779 [

12025–2025
South Dakota v. Wayfair, Inc. green
scotus · 2018
1 sentence

2022Id. at 2099 .

12022–2022
Commonwealth v. Shults green
pacommwct · 1976
12019–2019
Commonwealth v. Conte green
pasuperct · 2018
12019–2019
Elwyn v. DeLuca green
pasuperct · 2012
1 sentence

2019The Mancusos have not satisfied the first prong of the test in Elwyn, supra, because they failed to establish that there was an arbitration agreement between Ms. Gallagher and themselves.

12019–2019
Com. v. White neutral
pasuperct · 2016
12019–2019
Kurbatov v. Department of Labor & Industry green
pacommwct · 2011
12018–2018
Branton, K. v. Nicholas Meat, LLC green
pasuperct · 2017
12018–2018
Commonwealth v. Sinclair green
pasuperct · 2006
12018–2018
ICT Group v. Workers' Compensation Appeal Board green
pacommwct · 2010
12018–2018
Graziano v. Pennsylvania Department of Corrections green
pa · 2015
12018–2018
Commonwealth v. Ogontz Area Neighbors Ass'n green
pa · 1984
12017–2017
Dorsey v. Beard green
pa · 2009
12017–2017
Commonwealth v. Walsh green
pasuperct · 2012
12016–2016
Commonwealth v. Miller green
pa · 2005
12014–2014
Lehman v. Pennsylvania State Police green
pa · 2003
12014–2014
C E Credits Online v. Unemployment Compensation Board of Review green
pacommwct · 2008
12011–2011
Buchanan v. Unemployment Compensation Board of Review green
pacommwct · 1990
12011–2011
Resource Staffing, Inc. v. Unemployment Compensation Board of Review green
pacommwct · 2010
12011–2011
Easter Seal Society for Handicapped Children & Adults v. Unemployment Compensation Board of Review green
pacommwct · 1998
12010–2010
Charlton v. Toyota Industrial Equipment green
pasuperct · 1998
12010–2010
Montgomery v. UNEM. COMP. BD. OF REV. green
pacommwct · 2007
12010–2010
Lockwood v. City of Pittsburgh green
pa · 2000
12010–2010
Commonwealth v. Pierce green
pa · 2001
12009–2009
Commonwealth v. Pierce green
pa · 1987
12008–2008
Commonwealth v. Williams green
pa · 2003
12006–2006
Flemming v. Nestor green
scotus · 1960
12006–2006
Kennedy v. Mendoza-Martinez green
scotus · 1963
12006–2006
Abraxas Foundation, Inc. v. Workers' Compensation Appeal Board green
pacommwct · 2000
12005–2005
Venneri v. County of Allegheny green
pacommwct · 1974
12005–2005
Robinson v. Robinson green
pa · 1994
12003–2003
Guy v. Liederbach green
pa · 1983
12003–2003
Gruber v. Gruber green
pa · 1990
12003–2003

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 9543 (4)

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 450 (1982–2026) OH 227 (1980–2026) CA 162 (1982–2026) IL 137 (1983–2026) NY 127 (1969–2026) GA 105 (1975–2026) WA 100 (1982–2026) NJ 95 (1985–2026) CT 93 (1981–2025) PA 91 (1975–2026) FL 71 (1981–2025) IA 65 (1983–2024) MI 57 (1977–2026) TN 49 (1991–2025) NM 48 (1988–2026) AL 46 (1985–2024) MA 41 (1982–2023) IN 41 (1988–2024) MO 38 (1984–2016) RI 36 (1987–2017) NC 35 (1984–2024) NH 35 (1988–2025) UT 35 (1983–2025) MS 31 (1992–2024) WI 31 (1978–2025) KS 30 (1978–2024) MT 29 (1985–2023) KY 28 (1993–2026) VA 26 (1986–2026) VT 26 (1988–2025) CO 25 (1973–2026) HI 23 (1981–2024) LA 21 (1991–2025) MD 18 (1988–2024) SD 18 (1976–2025) MN 16 (1977–2024) OR 16 (1996–2021) AZ 14 (1983–2020) ME 14 (1984–2023) DC 13 (1978–2025) ND 12 (1980–2024) NE 12 (1985–2018) SC 12 (1992–2015) AK 11 (1975–2023) OK 9 (1986–2021) WV 9 (1991–2018) ID 7 (1989–2020) WY 7 (1991–2025) NV 6 (1996–2021) AR 5 (2003–2024) DE 5 (2018–2025) VI 4 (2007–2023)

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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