penalty hearing (Utah) · Go Syfert
← Utah issues

penalty hearing in Utah

13 Utah opinions name it 2 courts 1936–2015 0 in the last five years

The cases below were cited by Utah 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 (23)

CaseFollowedCited
Gardner v. Holdengreen
utah · 1994 · cited in 2 Utah opinions naming this issue, 2004–2005
2 sentences

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

2004Gardner II, 888 P.2d at 611, 623 . ¶ 5 In January 1997, Gardner filed a petition for writ of habeas corpus in the United States District Court for the District of Utah.

22
Reliance Insurance Co. v. Utah Department of Transportationgreen
utah · 1993 · cited in 1 Utah opinions naming this issue, 2012–2012
1 sentence

2012Co. v. Utah Dep't of Transp., 858 P.2d 1363, 1367 (Utah 1993) (internal quotation marks omitted), abrogated by Commercial Real Estate Inv., 2012 UT 49 , 285 P.3d 1193 .

11
Margaret H. Wayne Trust v. Lipskygreen
idaho · 1993 · cited in 1 Utah opinions naming this issue, 2012–2012
2 sentences

2012Wayne Trust v. Lipsky, 123 Idaho 253 , 846 P.2d 904, 910 (1993).) However, in reaching its decision, the district court did not conduct a penalty analysis but instead examined the enforceability of the liquidated damages provision under section 389 of the Restatement (First) of Contracts, which provides that an "agreement, made in advance of breach fixing the damages therefor, is not enforceable as a contract and does not affect the damages recoverable for the breach, unless ... the amount so fixed is a reasonable forecast of just compensation for the harm that is eaused by the breach, and ...

2012Wayne Trust v. Lipsky, 123 Idaho 253 , 846 P.2d 904, 910 (1993).) However, in reaching its decision, the district court did not conduct a penalty analysis but instead examined the enforceability of the liquidated damages provision under section 389 of the Restatement (First) of Contracts, which provides that an "agreement, made in advance of breach fixing the damages therefor, is not enforceable as a contract and does not affect the damages recoverable for the breach, unless ... the amount so fixed is a reasonable forecast of just compensation for the harm that is eaused by the breach, and ...

11
Croft v. Jensengreen
utah · 1935 · cited in 1 Utah opinions naming this issue, 2012–2012
1 sentence

2012See, e.g., Croft, 40 P.2d at 202 (concluding that a penalty would be "clearly unconscionable"). 35 The "shock the conscience" standard similarly is problematic for a number of reasons.

11
Shayesteh v. City of South Salt Lakegreen
ca10 · 2000 · cited in 1 Utah opinions naming this issue, 2005–2005
1 sentence

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

11
City of Billings v. Smithgreen
mont · 1997 · cited in 1 Utah opinions naming this issue, 2005–2005
2 sentences

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

11
Provo City v. Hansengreen
utah · 1979 · cited in 1 Utah opinions naming this issue, 2005–2005
1 sentence

2005Furthermore, subsection (8)(a), the penalty clause of this section, specifically provides that if the candidate fails to file an interim report, “the city recorder shall, after making a reasonable attempt to discover if the report was timely mailed, inform the appropriate election officials who: shall, if practicable, remove the name of the candidate by blacking [it] out” or “inform the voters by any practicable method that the candidate has been disqualified.” Id. § 10-3-208(8)(a)(i)-(ii). ¶ 13 The statute repeatedly uses the word “shall,” which is “usually presumed mandatory and has been int

11
State v. Nealgreen
utah · 1953 · cited in 1 Utah opinions naming this issue, 2005–2005
2 sentences

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

11
Kuehnert v. Turnergreen
utah · 1972 · cited in 1 Utah opinions naming this issue, 2005–2005
2 sentences

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

11
Board of Education of the Granite School District v. Salt Lake Countygreen
utah · 1983 · cited in 1 Utah opinions naming this issue, 2005–2005
1 sentence

2005Furthermore, subsection (8)(a), the penalty clause of this section, specifically provides that if the candidate fails to file an interim report, “the city recorder shall, after making a reasonable attempt to discover if the report was timely mailed, inform the appropriate election officials who: shall, if practicable, remove the name of the candidate by blacking [it] out” or “inform the voters by any practicable method that the candidate has been disqualified.” Id. § 10-3-208(8)(a)(i)-(ii). ¶ 13 The statute repeatedly uses the word “shall,” which is “usually presumed mandatory and has been int

11
State v. Gardnergreen
utah · 1989 · cited in 1 Utah opinions naming this issue, 2004–2004
1 sentence

2004In State v. Gardner, this court affirmed his conviction and death sentence. 789 P.2d 273, 288 (Utah 1989) (Gardner I).

11
Action Electric Co. v. Industrial Commissiongreen
utah · 1981 · cited in 1 Utah opinions naming this issue, 1997–1997
1 sentence

1997Co. v. Industrial Comm’n, 636 P.2d 474, 477 (Utah 1981). 3 Defendant contends that the second paragraph of section 34-28-5(1) (“the penalty clause”) applies not only when the employer terminates or discharges an employee but also when an employee such as he quits voluntarily (subsection (2)) or when employees go on strike (subsection (3)).

11
Kevin Winston Osborn v. Duane Shillinger, Warden of the Wyoming State Penitentiary A.G. McClintock the Attorney General of the State of Wyominggreen
ca10 · 1988 · cited in 1 Utah opinions naming this issue, 1994–1994
1 sentence

1994As the Tenth Circuit stated in Osborn v. Shillinger, the “process by which he [the defendant] pled and was sentenced to death was not adversarial, and therefore not reliable.” 861 F.2d 612, 629 (10th Cir.1988).

11
Van Hook v. United Statesgreen
scotus · 1961 · cited in 1 Utah opinions naming this issue, 1993–1993
1 sentence

1993See Van Hook, 365 U.S. at 609 , 81 S.Ct. at 823 ; Mohn, 584 P.2d at 44 ; Emig, 493 P.2d at 369-70 ; Tomlinson, 647 P.2d at 417 ; Nicoletti, 471 A.2d at 618 ; see also Ashe v. State, 586 F.2d 334, 336 (4th Cir.1978), cert. denied, 441 U.S. 966 , 99 S.Ct. 2416 , 60 L.Ed.2d 1072 (1979).

11
Hitchcock v. Arizonagreen
scotus · 1961 · cited in 1 Utah opinions naming this issue, 1993–1993
11
State v. Mitchellgreen
utah · 1989 · cited in 1 Utah opinions naming this issue, 1993–1993
1 sentence

1993NOTES [1] State v. Tillman, 750 P.2d 546 (Utah 1987). [2] Id. [3] Fernandez v. Cook, 783 P.2d 547, 549 (Utah 1989); State v. Mitchell, 779 P.2d 1116, 1118 (Utah 1989). [4] Utah Code Ann. § 76-5-202 (1) provides in pertinent part: (1) Criminal homicide constitutes murder in the first degree if the actor intentionally or knowingly causes the death of another under any of the following circumstances: .... (q) The homicide was committed in an especially heinous, atrocious, cruel, or exceptionally depraved manner, any of which must be demonstrated by physical torture, serious physical abuse, or ser

11
State v. Cartergreen
utah · 1989 · cited in 1 Utah opinions naming this issue, 1993–1993
2 sentences

1993See State v. Carter, 776 P.2d 886 (Utah 1989).

1993See State v. Carter, 776 P.2d 886 (Utah 1989).

11
People v. Emiggreen
colo · 1972 · cited in 1 Utah opinions naming this issue, 1993–1993
2 sentences

1993For example, the Colorado Supreme Court concluded that failure to grant allocution "renders [the sentence] invalid" and explained that the defendant had a "right of allocution" prior to sentencing "which cannot be withheld from him." People v. Emig, 177 Colo. 174 , 493 P.2d 368, 369-70 (1972).

1993For example, the Colorado Supreme Court concluded that failure to grant allocution "renders [the sentence] invalid" and explained that the defendant had a "right of allocution" prior to sentencing "which cannot be withheld from him." People v. Emig, 177 Colo. 174 , 493 P.2d 368, 369-70 (1972).

11
Fernandez v. Cookgreen
utah · 1989 · cited in 1 Utah opinions naming this issue, 1993–1993
1 sentence

1993NOTES [1] State v. Tillman, 750 P.2d 546 (Utah 1987). [2] Id. [3] Fernandez v. Cook, 783 P.2d 547, 549 (Utah 1989); State v. Mitchell, 779 P.2d 1116, 1118 (Utah 1989). [4] Utah Code Ann. § 76-5-202 (1) provides in pertinent part: (1) Criminal homicide constitutes murder in the first degree if the actor intentionally or knowingly causes the death of another under any of the following circumstances: .... (q) The homicide was committed in an especially heinous, atrocious, cruel, or exceptionally depraved manner, any of which must be demonstrated by physical torture, serious physical abuse, or ser

11
Lloyd C. Ashe and Hilliard P. Ashe v. State of North Carolina, and Cherokee County, Murphy, North Carolinagreen
ca4 · 1978 · cited in 1 Utah opinions naming this issue, 1993–1993
1 sentence

1993See Van Hook, 365 U.S. at 609 , 81 S.Ct. at 823 ; Mohn, 584 P.2d at 44 ; Emig, 493 P.2d at 369-70 ; Tomlinson, 647 P.2d at 417 ; Nicoletti, 471 A.2d at 618 ; see also Ashe v. State, 586 F.2d 334, 336 (4th Cir.1978), cert. denied, 441 U.S. 966 , 99 S.Ct. 2416 , 60 L.Ed.2d 1072 (1979).

11
Tormey v. De La Cruzgreen
scotus · 1979 · cited in 1 Utah opinions naming this issue, 1993–1993
11
Croatan Books, Inc. v. Virginiagreen
scotus · 1979 · cited in 1 Utah opinions naming this issue, 1993–1993
1 sentence

1993See Van Hook, 365 U.S. at 609 , 81 S.Ct. at 823 ; Mohn, 584 P.2d at 44 ; Emig, 493 P.2d at 369-70 ; Tomlinson, 647 P.2d at 417 ; Nicoletti, 471 A.2d at 618 ; see also Ashe v. State, 586 F.2d 334, 336 (4th Cir.1978), cert. denied, 441 U.S. 966 , 99 S.Ct. 2416 , 60 L.Ed.2d 1072 (1979).

11
California v. Browngreen
scotus · 1987 · cited in 1 Utah opinions naming this issue, 1993–1993
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (15)

CaseCitedYears
State v. Norton green
utah · 1983
1 sentence

2015Specifically, the defendant argued that the standard of persuasion at the penalty hearing in his capital case should have been the hlgher standard announced 'in State v. Wood-" 'beyond a reasonable doubt' both as to the fact that total aggravation outweighs total mitigation and as to the conclusion that the imposition of the death penalty is justified and appropriate," Id. at 583 .

12015–2015
Commercial Real Estate Investment, L.C. v. Comcast of Utah II, Inc. green
utah · 2012
2 sentences

2012Co. v. Utah Dep't of Transp., 858 P.2d 1363, 1367 (Utah 1993) (internal quotation marks omitted), abrogated by Commercial Real Estate Inv., 2012 UT 49 , 285 P.3d 1193 .

2012Co. v. Utah Dep't of Transp., 858 P.2d 1363, 1367 (Utah 1993) (internal quotation marks omitted), abrogated by Commercial Real Estate Inv., 2012 UT 49 , 285 P.3d 1193 .

12012–2012
Western Macaroni Mfg. Co. v. Fiore green
utah · 1915
1 sentence

2012Second, the penalty inquiry is motivated by "the interest of justice and fairness," id.

12012–2012
Alabama v. Shelton green
scotus · 2002
2 sentences

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

2005For example, a court may vacate the sentence and order a new trial, Billings v. Smith, 281 Mont. 133 , 932 P.2d 1058, 1063 (1997) (vacating sentence and granting new trial to remedy denial of effective assistance of counsel); modify the defendant’s sentence with or without a new penalty hearing, see Gardner v. Holden, 888 P.2d 608, 611 (Utah 1994) (discussing correctness of trial court’s decision to grant defendant a new penalty hearing and appeal to remedy the alleged denial of effective assistance of counsel); Kuehnert v. Turner, 28 Utah 2d 150 , 499 P.2d 839, 840-41 (1972) (remanding for re

12005–2005
Sjostrom v. Bishop green
utah · 1964
2 sentences

2005Ms. Pugh, however, argues that the language of the statute is not mandatory, but only directory, citing Sjostrom v. Bishop, 15 Utah 2d 373 , 393 P.2d 472 (1964).

2005Ms. Pugh, however, argues that the language of the statute is not mandatory, but only directory, citing Sjostrom v. Bishop, 15 Utah 2d 373 , 393 P.2d 472 (1964).

12005–2005
Mohn v. State green
alaska · 1978
11993–1993
Tomlinson v. State green
nm · 1982
1 sentence

1993See Van Hook, 365 U.S. at 609 , 81 S.Ct. at 823 ; Mohn, 584 P.2d at 44 ; Emig, 493 P.2d at 369-70 ; Tomlinson, 647 P.2d at 417 ; Nicoletti, 471 A.2d at 618 ; see also Ashe v. State, 586 F.2d 334, 336 (4th Cir.1978), cert. denied, 441 U.S. 966 , 99 S.Ct. 2416 , 60 L.Ed.2d 1072 (1979).

11993–1993
State v. Nicoletti green
ri · 1984
1 sentence

1993See Van Hook, 365 U.S. at 609 , 81 S.Ct. at 823 ; Mohn, 584 P.2d at 44 ; Emig, 493 P.2d at 369-70 ; Tomlinson, 647 P.2d at 417 ; Nicoletti, 471 A.2d at 618 ; see also Ashe v. State, 586 F.2d 334, 336 (4th Cir.1978), cert. denied, 441 U.S. 966 , 99 S.Ct. 2416 , 60 L.Ed.2d 1072 (1979).

11993–1993
Woodson v. North Carolina green
scotus · 1976
2 sentences

1993Eddings v. Oklahoma, 455 U.S. 104, 113-15 , 102 S.Ct. 869, 876-77 , 71 L.Ed.2d 1 (1982); Lockett v. Ohio, 438 U.S. 586, 604-09 , 98 S.Ct. 2954, 2964-67 , 57 L.Ed.2d 973 (1978) (plurality opinion); Woodson v. North Carolina, 428 U.S. 280, 303-04 , 96 S.Ct. 2978, 2990-91 , 49 L.Ed.2d 944 (1976) (plurality opinion); see also California v. Brown, 479 U.S. 538, 541 , 107 S.Ct. 837, 839 , 93 L.Ed.2d 934 (1987).

1993Eddings v. Oklahoma, 455 U.S. 104, 113-15 , 102 S.Ct. 869, 876-77 , 71 L.Ed.2d 1 (1982); Lockett v. Ohio, 438 U.S. 586, 604-09 , 98 S.Ct. 2954, 2964-67 , 57 L.Ed.2d 973 (1978) (plurality opinion); Woodson v. North Carolina, 428 U.S. 280, 303-04 , 96 S.Ct. 2978, 2990-91 , 49 L.Ed.2d 944 (1976) (plurality opinion); see also California v. Brown, 479 U.S. 538, 541 , 107 S.Ct. 837, 839 , 93 L.Ed.2d 934 (1987).

11993–1993
Lockett v. Ohio green
scotus · 1978
11993–1993
State v. Tillman green
utah · 1987
2 sentences

1993NOTES [1] State v. Tillman, 750 P.2d 546 (Utah 1987). [2] Id. [3] Fernandez v. Cook, 783 P.2d 547, 549 (Utah 1989); State v. Mitchell, 779 P.2d 1116, 1118 (Utah 1989). [4] Utah Code Ann. § 76-5-202 (1) provides in pertinent part: (1) Criminal homicide constitutes murder in the first degree if the actor intentionally or knowingly causes the death of another under any of the following circumstances: .... (q) The homicide was committed in an especially heinous, atrocious, cruel, or exceptionally depraved manner, any of which must be demonstrated by physical torture, serious physical abuse, or ser

1993NOTES [1] State v. Tillman, 750 P.2d 546 (Utah 1987). [2] Id. [3] Fernandez v. Cook, 783 P.2d 547, 549 (Utah 1989); State v. Mitchell, 779 P.2d 1116, 1118 (Utah 1989). [4] Utah Code Ann. § 76-5-202 (1) provides in pertinent part: (1) Criminal homicide constitutes murder in the first degree if the actor intentionally or knowingly causes the death of another under any of the following circumstances: .... (q) The homicide was committed in an especially heinous, atrocious, cruel, or exceptionally depraved manner, any of which must be demonstrated by physical torture, serious physical abuse, or ser

11993–1993
Eddings v. Oklahoma green
scotus · 1982
2 sentences

1993Eddings v. Oklahoma, 455 U.S. 104, 113-15 , 102 S.Ct. 869, 876-77 , 71 L.Ed.2d 1 (1982); Lockett v. Ohio, 438 U.S. 586, 604-09 , 98 S.Ct. 2954, 2964-67 , 57 L.Ed.2d 973 (1978) (plurality opinion); Woodson v. North Carolina, 428 U.S. 280, 303-04 , 96 S.Ct. 2978, 2990-91 , 49 L.Ed.2d 944 (1976) (plurality opinion); see also California v. Brown, 479 U.S. 538, 541 , 107 S.Ct. 837, 839 , 93 L.Ed.2d 934 (1987).

1993Eddings v. Oklahoma, 455 U.S. 104, 113-15 , 102 S.Ct. 869, 876-77 , 71 L.Ed.2d 1 (1982); Lockett v. Ohio, 438 U.S. 586, 604-09 , 98 S.Ct. 2954, 2964-67 , 57 L.Ed.2d 973 (1978) (plurality opinion); Woodson v. North Carolina, 428 U.S. 280, 303-04 , 96 S.Ct. 2978, 2990-91 , 49 L.Ed.2d 944 (1976) (plurality opinion); see also California v. Brown, 479 U.S. 538, 541 , 107 S.Ct. 837, 839 , 93 L.Ed.2d 934 (1987).

11993–1993
State v. Wood green
utah · 1982
11983–1983
In Re WINSHIP green
scotus · 1970
11980–1980
Moorehouse v. Hammond neutral
utah · 1922
11936–1936

Statutes the citing opinions construe

UT § Utah Code § 76-3-207 (4) UT § Utah Code § 76-5-202 (4) UT § Utah Code § 76-5-203 (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

PA 193 (1890–2024) IL 160 (1873–2026) CA 151 (1884–2026) NV 136 (1950–2022) LA 75 (1910–2025) OH 73 (1891–2026) NY 67 (1824–2023) MO 64 (1878–2022) TX 64 (1911–2020) FL 61 (1917–2023) DE 45 (1981–2025) NJ 37 (1905–2025) GA 34 (1868–2025) WI 32 (1882–2020) OR 24 (1877–2024) CT 24 (1880–2022) OK 23 (1896–1989) WA 22 (1949–2020) MD 21 (1893–2024) KY 20 (1908–2024) IN 19 (1877–2018) CO 19 (1899–2026) NC 18 (1886–2013) MI 16 (1892–2015) KS 16 (1905–2024) IA 16 (1907–2016) MT 15 (1888–1999) MN 15 (1895–2007) NE 13 (1897–2015) ID 13 (1922–2021) UT 13 (1936–2015) VA 12 (1867–2013) AZ 12 (1915–2020) AL 12 (1872–1993) AR 11 (1869–1995) TN 11 (1923–2015) MA 10 (1918–2025) WV 8 (1903–2025) NM 7 (1916–2022) WY 6 (1952–2020) HI 6 (1911–2017) MS 6 (1905–1990) AK 5 (1983–2001) DC 5 (2011–2019) ND 4 (1916–2021) SD 4 (1928–2006) VT 3 (1975–2011) ME 3 (1949–2012) RI 3 (1981–2016) PR 2 (1971–1994) NH 2 (2010–2013)

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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