aggravating and mitigating factors (Florida) · Go Syfert
← Florida issues

aggravating and mitigating factors in Florida

89 Florida opinions name it 3 courts 1979–2025 3 in the last five years

The cases below were cited by Florida 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 (31)

CaseFollowedCited
Hayward v. Stategreen
fla · 2009 · cited in 10 Florida opinions naming this issue, 2010–2020
2 sentences

2020We also “accept the weight assigned by the trial court to the aggravating and mitigating factors.” Covington, 228 So. 3d at 68 (quoting Hayward v. State, 24 So. 3d 17, 46 (Fla. 2009)). -9- In Doty’s first direct appeal, we found that his death sentence was proportionate in comparison to other capital cases, reasoning as follows: Comparing the death sentence in this case to other capital cases, we recognize that this case is exceedingly similar to the facts and circumstances of [Gill], a case in which the defendant was convicted of murder after he strangled his cellmate.

2020We also “accept the weight assigned by the trial court to the aggravating and mitigating factors.” Covington, 228 So. 3d at 68 (quoting Hayward v. State, 24 So. 3d 17, 46 (Fla. 2009)). -9- In Doty’s first direct appeal, we found that his death sentence was proportionate in comparison to other capital cases, reasoning as follows: Comparing the death sentence in this case to other capital cases, we recognize that this case is exceedingly similar to the facts and circumstances of [Gill], a case in which the defendant was convicted of murder after he strangled his cellmate.

710
Bobby Marion Francis v. Richard L. Dugger, Secretary, Florida Department of Correctionsgreen
ca11 · 1990 · cited in 5 Florida opinions naming this issue, 1996–2013
2 sentences

2013Thus, our proportionality review requires that we discretely analyze the nature and weight of the underlying facts; we do not engage in a “ ‘mere tabulation’ of the aggravating and mitigating factors.” Terry v. State, 668 So.2d 954, 965 (Fla.1996) (quoting Francis v. Dugger, 908 F.2d 696, 705 (11th Cir.1990)).

2012Thus, our proportionality review requires that we discretely analyze the nature and weight of the underlying facts; we do not engage in a “ ‘mere tabulation’ of the aggravating and mitigating factors.” Terry v. State, 668 So.2d 954, 965 (Fla.1996) (quoting Francis v. Dugger, 908 F.2d 696, 705 (11th Cir.1990)).

55
Urbin v. Stategreen
fla · 1998 · cited in 10 Florida opinions naming this issue, 2013–2019
2 sentences

2017“In reviewing the sentence for proportionality, this Court will accept the jury’s recommendation and the weight assigned by the trial judge to the aggravating and mitigating factors.” Id.

2014“In reviewing the sentence for proportionality, this Court will accept the jury’s recommendation and the weight assigned by the trial judge to the aggravating and mitigating factors.” Id.

410
Terry v. Stategreen
fla · 1996 · cited in 4 Florida opinions naming this issue, 2011–2013
2 sentences

2013Thus, our proportionality review requires that we discretely analyze the nature and weight of the underlying facts; we do not engage in a “ ‘mere tabulation’ of the aggravating and mitigating factors.” Terry v. State, 668 So.2d 954, 965 (Fla.1996) (quoting Francis v. Dugger, 908 F.2d 696, 705 (11th Cir.1990)).

2012Thus, our proportionality review requires that we discretely analyze the nature and weight of the underlying facts; we do not engage in a “ ‘mere tabulation’ of the aggravating and mitigating factors.” Terry v. State, 668 So.2d 954, 965 (Fla.1996) (quoting Francis v. Dugger, 908 F.2d 696, 705 (11th Cir.1990)).

44
Grossman v. Stategreen
fla · 1988 · cited in 4 Florida opinions naming this issue, 1993–2001
2 sentences

2001We have also made clear that "[n]otwithstanding the jury's recommendation, whether it be for life imprisonment or death, the judge is required to make an independent determination, based on the aggravating and mitigating factors." Grossman v. State, 525 So.2d 833, 840 (Fla.1988); see King v. State, 623 So.2d 486, 489 (Fla.1993).

1993As we have stated previously: “Notwithstanding the jury recommendation ... the judge is required to make an independent determination, based on the aggravating and mitigating factors.” Grossman v. State, 525 So.2d 833, 840 (Fla.1988), cert. denied, 489 U.S. 1071 , 109 S.Ct. 1354 , 103 L.Ed.2d 822 (1989).

44
Bates v. Stategreen
fla · 1999 · cited in 3 Florida opinions naming this issue, 2009–2011
2 sentences

2011See Bates v. State, 750 So.2d 6, 12 (Fla.1999).

2009See Bates v. State, 750 So.2d 6, 12 (Fla.1999).

33
Morton v. Stategreen
fla · 2001 · cited in 3 Florida opinions naming this issue, 2003–2008
2 sentences

2008Morton v. State, 789 So.2d 324, 328-29 (Fla.2001). [3] Morton asserted that (1) the prosecutor made several improper comments during penalty-phase closing arguments that entitled Morton to a new penalty phase; (2) the trial court failed to find, consider, and weigh mitigating evidence that Morton suffered from antisocial personality disorder; (3) the trial court did not properly weigh the mitigating circumstances of Morton's age and history as an abused child; and (4) the resentencing judge erred by adopting the original sentencing judge's findings of fact regarding the aggravating and mitigat

2008Id. at 329 . [4] Morton alleged as follows: (1) he was deprived of a reliable adversarial testing due to ineffective assistance of counsel at the guilt and penalty phases; (2) he was deprived of his right to develop mitigating factors because the court-appointed psychiatrist failed to conduct appropriate tests for organic brain damage and mental illness; (3) the State violated the constitutional requirements under Brady v. Maryland, 373 U.S. 83 , 83 S.Ct. 1194 , 10 L.Ed.2d 215 (1963), and its progeny, and such actions and omissions by the State rendered defense counsel ineffective and prevente

33
Bryant v. Stategreen
fla · 1995 · cited in 3 Florida opinions naming this issue, 2001–2005
2 sentences

2005See id.

2001See Bryant v. State, 656 So.2d 426, 428 (Fla.1995) (concluding that the trial court did not err in denying cause challenges where five jurors who expressed a predisposition to impose the death penalty if the defendant was convicted of first-degree murder later stated that they would follow the court's instructions and weigh the aggravating and mitigating factors to determine whether death was the appropriate sentence). b.

33
Scott v. Stategreen
fla · 2011 · cited in 2 Florida opinions naming this issue, 2012–2013
2 sentences

2013Scott v. State, 66 So.3d 923, 934-35 (Fla.2011).

2012Scott v. State, 66 So.3d 923, 934-35 (Fla.2011).

22
Cox v. Stategreen
fla · 2002 · cited in 2 Florida opinions naming this issue, 2003–2012
2 sentences

2012For example, in Cox v. State, 819 So.2d 705, 723-24 (Fla.2002), we upheld the death penalty where the trial court found and gave great weight to HAC, CCP, prior violent felony, and under sentence of imprisonment, while giving little or moderate weight to several nonstatutory mitigators.

2003See, e.g., Cox v. State, 819 So.2d 705 (Fla.2002) (finding death sentence proportionate where court found three aggravating factors, including HAC and CCP, measured against nineteen nonstatutory mitigating factors accorded slight to some weight), cert. denied, 537 U.S. 1120 , 123 S.Ct. 889 , 154 L.Ed.2d 799 (2003); Connor v. State, 803 So.2d 598 (Fla.2001) (finding death sentence proportionate where court found three aggravating factors, including HAC and CCP, measured against four nonstatutory mitigators); Hauser v. State, 701 So.2d 329 (Fla.1997) (finding death sentence proportionate where v

22
Rodgers v. Stategreen
fla · 2006 · cited in 2 Florida opinions naming this issue, 2007–2012
2 sentences

2012We defer to the trial court’s determination ‘unless no reasonable person would have assigned the weight the trial court did.’ ” (quoting Rodgers v. State, 948 So.2d 655, 669 (Fla.2006))).

2007We defer to the trial court's determination "unless no reasonable person would have assigned the weight the trial court did." Rodgers v. State, 948 So.2d 655, 669 (Fla.2006), cert. denied, ___ U.S. ___, 128 S.Ct. 59 , 169 L.Ed.2d 50 (2007) (No. 06-10961).

22
Gaskin v. Stategreen
fla · 1999 · cited in 2 Florida opinions naming this issue, 2009–2011
2 sentences

2011See Gaskin v. State, 737 So.2d at 516 n. 14.

2009See Jones v. State, 998 So.2d 573, 585 (Fla.2008) (“ ‘Prejudice ... is shown where, absent the errors, there is a reasonable probability that the balance of aggravating and mitigating circumstances would have been different or the deficiencies substantially impair confidence in the outcome of the proceedings.’ ” (quoting Gaskin v. State, 737 So.2d 509 , 516 n. 14 (Fla.1999))).

22
Porter v. Stategreen
fla · 1990 · cited in 2 Florida opinions naming this issue, 1998–1998
2 sentences

1998Further, based on our review of all of the aggravating and mitigating factors, including their nature and quality according to the specific facts of this case, we find that the totality of the circumstances justifies the imposition of the death sentence, see Porter, 564 So.2d at 1064 , and that this case is proportionate to other cases where we have upheld the imposition of a death sentence.

1998See Porter, 564 So.2d at 1064 .

12
Rogers v. Stategreen
fla · 1987 · cited in 2 Florida opinions naming this issue, 1991–1993
2 sentences

1993We remind the judge that, even though a jury determination is entitled to great weight, "the judge is required to make an independent determination, based on the aggravating and mitigating factors." [2] Grossman v. State, 525 So.2d 833, 840 (Fla. 1988), cert. denied, 489 U.S. 1071 , 109 S.Ct. 1354 , 103 L.Ed.2d 822 (1989); Rogers v. State, 511 So.2d 526 (Fla. 1987), cert. denied, 484 U.S. 1020 , 108 S.Ct. 733 , 98 L.Ed.2d 681 (1988).

1991See Rogers, 511 So.2d at 535 .

12
Taylor v. Stategreen
fla · 2006 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019Taylor v. State, 937 So. 2d 590, 601 (Fla. 2006). - 16 - “Further, in a proportionality analysis, this Court will accept the weight assigned by the trial court to the aggravating and mitigating factors.” Hayward v. State, 24 So. 3d 17, 46 (Fla. 2009).

11
Kevin G. Jeffries, Jr. v. State of Floridagreen
fla · 2017 · cited in 1 Florida opinions naming this issue, 2018–2018
11
Brooks v. Stategreen
fla · 2005 · cited in 1 Florida opinions naming this issue, 2017–2017
11
State v. Sturdivantgreen
fla · 2012 · cited in 1 Florida opinions naming this issue, 2017–2017
11
Knight v. Stategreen
fla · 2005 · cited in 1 Florida opinions naming this issue, 2013–2013
11
McLean v. Stategreen
fla · 2010 · cited in 1 Florida opinions naming this issue, 2012–2012
11
Smith v. Wisconsingreen
scotus · 2010 · cited in 1 Florida opinions naming this issue, 2012–2012
11
McLean v. Floridagreen
scotus · 2010 · cited in 1 Florida opinions naming this issue, 2012–2012
11
Merck v. Stategreen
fla · 2007 · cited in 1 Florida opinions naming this issue, 2012–2012
11
Davis v. Stategreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2011–2011
11
Jones v. Stategreen
fla · 2008 · cited in 1 Florida opinions naming this issue, 2009–2009
11
Johnston v. Stategreen
fla · 2002 · cited in 1 Florida opinions naming this issue, 2009–2009
11
Franqui v. Stategreen
fla · 2001 · cited in 1 Florida opinions naming this issue, 2007–2007
11
Dufour v. Stategreen
fla · 2005 · cited in 1 Florida opinions naming this issue, 2007–2007
11
Alston v. Stategreen
fla · 1998 · cited in 1 Florida opinions naming this issue, 2006–2006
11
Blackwelder v. Stategreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2006–2006
11
Johnson v. Stategreen
fla · 1995 · cited in 1 Florida opinions naming this issue, 2005–2005
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (49)

CaseCitedYears
Green v. United States green
scotus · 1989
2 sentences

1993As we have stated previously: “Notwithstanding the jury recommendation ... the judge is required to make an independent determination, based on the aggravating and mitigating factors.” Grossman v. State, 525 So.2d 833, 840 (Fla.1988), cert. denied, 489 U.S. 1071 , 109 S.Ct. 1354 , 103 L.Ed.2d 822 (1989).

1993As we have stated previously: "Notwithstanding the jury recommendation ... the judge is required to make an independent determination, based on the aggravating and mitigating factors." Grossman v. State, 525 So.2d 833, 840 (Fla. 1988), cert. denied, 489 U.S. 1071 , 109 S.Ct. 1354 , 103 L.Ed.2d 822 (1989).

31993–1993
Cooper v. United States green
scotus · 1989
2 sentences

1993As we have stated previously: “Notwithstanding the jury recommendation ... the judge is required to make an independent determination, based on the aggravating and mitigating factors.” Grossman v. State, 525 So.2d 833, 840 (Fla.1988), cert. denied, 489 U.S. 1071 , 109 S.Ct. 1354 , 103 L.Ed.2d 822 (1989).

1993As we have stated previously: "Notwithstanding the jury recommendation ... the judge is required to make an independent determination, based on the aggravating and mitigating factors." Grossman v. State, 525 So.2d 833, 840 (Fla. 1988), cert. denied, 489 U.S. 1071 , 109 S.Ct. 1354 , 103 L.Ed.2d 822 (1989).

31993–1993
Edward Allen Covington v. State of Florida green
fla · 2017
2 sentences

2020We also “accept the weight assigned by the trial court to the aggravating and mitigating factors.” Covington, 228 So. 3d at 68 (quoting Hayward v. State, 24 So. 3d 17, 46 (Fla. 2009)). -9- In Doty’s first direct appeal, we found that his death sentence was proportionate in comparison to other capital cases, reasoning as follows: Comparing the death sentence in this case to other capital cases, we recognize that this case is exceedingly similar to the facts and circumstances of [Gill], a case in which the defendant was convicted of murder after he strangled his cellmate.

2020We also “accept the weight assigned by the trial court to the aggravating and mitigating factors.” Covington, 228 So. 3d at 68 (quoting Hayward v. State, 24 So. 3d 17, 46 (Fla. 2009)). -9- In Doty’s first direct appeal, we found that his death sentence was proportionate in comparison to other capital cases, reasoning as follows: Comparing the death sentence in this case to other capital cases, we recognize that this case is exceedingly similar to the facts and circumstances of [Gill], a case in which the defendant was convicted of murder after he strangled his cellmate.

22020–2020
The Florida Bar v. Ticktin green
fla · 2009
2 sentences

2018Moreover, "[a] referee's findings in aggravation carry a presumption of correctness that should be upheld unless clearly erroneous or without support in the record." Fla. Bar v. Ticktin , 14 So.3d 928 , 937 (Fla. 2009).

2018Moreover, "[a] referee's findings in aggravation carry a presumption of correctness that should be upheld unless clearly erroneous or without support in the record." Fla. Bar v. Ticktin , 14 So.3d 928 , 937 (Fla. 2009).

22018–2018
Silvia v. State green
fla · 2011
2 sentences

2017Id.

2014“In reviewing the sentence for proportionality, this Court will accept the jury’s recommendation and the weight assigned by the trial judge to the aggravating and mitigating factors.” Silvia, 60 So.3d at 973 .

22014–2017
Kilgore v. State green
fla · 1996
2 sentences

2015Id. at 900 .

2015Id. at 900 .

22015–2015
Shellito v. State green
fla · 1997
2 sentences

2012See, e.g., McLean v. State, 29 So.3d 1045 (Fla.2010) (in a robbery with multiple gunshot victims, death sentence proportionate with prior violent felony • aggravator and committed during a robbery aggravator, both statutory mental health mitigators, and nonstatutory mitigators of substance abuse, family problems, mild brain injury, and miscellaneous factors) cert. denied, - U.S. -, 131 S.Ct. 153 , 178 L.Ed.2d 92 (2010); Hayward v. State, 24 So.3d 17 (Fla.2009) (death sentence proportionate with prior violent felony aggra-vator and merged committed during a robbery/committed for pecuniary gain

2010See, e.g., Hayward v. State, 24 So.3d 17 (Fla.2009) (death sentence proportionate with prior violent felony ag-gravator and merged committed during a robbery/committed for pecuniary gain ag-gravator and nonstatutory mitigators including academic problems, an absent father, some capacity for rehabilitation, and financial stress at the time of the crime); LaMarca v. State, 785 So.2d 1209 (Fla.2001) (death sentence proportionate with prior violent felony aggravator and non-statutory mitigators of good behavior at trial, substance abuse issues, and mental disorders); Shellito v. State, 701 So.2d 8

22010–2012
Pope v. State green
fla · 1996
2 sentences

2012See, e.g., McLean v. State, 29 So.3d 1045 (Fla.2010) (in a robbery with multiple gunshot victims, death sentence proportionate with prior violent felony • aggravator and committed during a robbery aggravator, both statutory mental health mitigators, and nonstatutory mitigators of substance abuse, family problems, mild brain injury, and miscellaneous factors) cert. denied, - U.S. -, 131 S.Ct. 153 , 178 L.Ed.2d 92 (2010); Hayward v. State, 24 So.3d 17 (Fla.2009) (death sentence proportionate with prior violent felony aggra-vator and merged committed during a robbery/committed for pecuniary gain

2010See, e.g., Hayward v. State, 24 So.3d 17 (Fla.2009) (death sentence proportionate with prior violent felony ag-gravator and merged committed during a robbery/committed for pecuniary gain ag-gravator and nonstatutory mitigators including academic problems, an absent father, some capacity for rehabilitation, and financial stress at the time of the crime); LaMarca v. State, 785 So.2d 1209 (Fla.2001) (death sentence proportionate with prior violent felony aggravator and non-statutory mitigators of good behavior at trial, substance abuse issues, and mental disorders); Shellito v. State, 701 So.2d 8

22010–2012
Brady v. Maryland green
scotus · 1963
2 sentences

2008Id. at 329 . [4] Morton alleged as follows: (1) he was deprived of a reliable adversarial testing due to ineffective assistance of counsel at the guilt and penalty phases; (2) he was deprived of his right to develop mitigating factors because the court-appointed psychiatrist failed to conduct appropriate tests for organic brain damage and mental illness; (3) the State violated the constitutional requirements under Brady v. Maryland, 373 U.S. 83 , 83 S.Ct. 1194 , 10 L.Ed.2d 215 (1963), and its progeny, and such actions and omissions by the State rendered defense counsel ineffective and prevente

2008Id. at 329 . [4] Morton alleged as follows: (1) he was deprived of a reliable adversarial testing due to ineffective assistance of counsel at the guilt and penalty phases; (2) he was deprived of his right to develop mitigating factors because the court-appointed psychiatrist failed to conduct appropriate tests for organic brain damage and mental illness; (3) the State violated the constitutional requirements under Brady v. Maryland, 373 U.S. 83 , 83 S.Ct. 1194 , 10 L.Ed.2d 215 (1963), and its progeny, and such actions and omissions by the State rendered defense counsel ineffective and prevente

22007–2008
Lockett v. Ohio green
scotus · 1978
2 sentences

1989Lockett v Ohio, 438 U.S. 586 (1978), deliberated and by a vote of 11 to 1 returned an advisory sentence recommending imposition of the death penalty.

1988Lockett v Ohio, 438 U.S. 586 (1978), deliberated; and by votes of 10 to 2 as to Count II, 8 to 4 as to Count XIV, 10 to 2 as to Count XV returned an advisory sentence recommencing imposition of the death penalty.

21988–1989
The Florida Bar v. Committe green
fla · 2005
1 sentence

2025“A private reprimand is now termed an admonishment . . . .” Fla. Bar v. Committe, 916 So. 2d 741 , 748 n.3 (Fla. 2005). - 10 - The Standards for Imposing Lawyer Sanctions discuss the presumptive sanctions in relation to the misconduct established and are subject to aggravating and mitigating factors and this Court’s case law.

12025–2025
Bates v. State green
fla · 1985
1 sentence

2024Bates v. State, 465 So. 2d at 493 .

12024–2024
Spencer v. State green
fla · 1993
1 sentence

2024Spencer v. State, 615 So. 2d 688 (Fla. 1993). -4- court contemporaneously issued a written sentencing order detailing its consideration of both the aggravating and mitigating factors at issue.

12024–2024
Gary Czajkowski v. State of Florida red
fla · 2016
1 sentence

2020By requiring unanimity in a recommendation of death in order for death to be considered and imposed, Florida will achieve the important goal of bringing its capital sentencing laws into harmony with the direction of society reflected in all these states and with federal law. 202 So. 3d at 61 .

12020–2020
The Florida Bar v. Ratiner green
fla · 2010
1 sentence

2018The referee found the following mitigating factors under Florida Standard for Imposing Lawyer Sanctions 9.32: (b) (absence of a dishonest or selfish motive); *121 (g) (character or reputation); and (h) (physical or mental disability or impairment ). 3 In addition to the above-cited aggravating and mitigating factors, the referee considered the following cases prior to recommending discipline: Fla. Bar v. Kelner , 670 So.2d 62 (Fla. 1996) ; Fla. Bar v. Wasserman , 675 So.2d 103 (Fla. 1996) ; Fla. Bar v. Morgan , 938 So.2d 496 (Fla. 2006) ; Fla. Bar v. Abramson , 3 So.3d 964 (Fla. 2009) ; Fla. B

12018–2018
The Florida Bar v. Wasserman green
fla · 1996
12018–2018
& SC13-2480 The Florida Bar v. Jeffrey Alan Norkin green
fla · 2015
12018–2018
The Florida Bar v. Abramson green
fla · 2009
12018–2018
The Florida Bar v. Vining green
fla · 2000
12018–2018
Florida Bar v. Chosid green
fla · 1987
12018–2018
Florida Bar v. Walkden green
fla · 2007
12018–2018
Florida Bar v. Rotstein green
fla · 2002
12018–2018
The Florida Bar v. Kelner green
fla · 1996
12018–2018
Florida Bar v. Morgan green
fla · 2006
12018–2018
The Florida Bar v. Simring green
fla · 1993
12018–2018
Florida Bar v. Norkin green
fla · 2013
12018–2018
Tison v. Arizona green
scotus · 1987
12017–2017
Wickham v. State green
fla · 1991
12013–2013
Henyard v. State green
fla · 1996
12012–2012
Apprendi v. New Jersey green
scotus · 2000
12012–2012
Ring v. Arizona green
scotus · 2002
12012–2012
Singleton v. State green
fla · 2001
12012–2012
Walker v. State green
fla · 2007
12012–2012
Coleman v. State green
fla · 2011
12012–2012
LaMarca v. State green
fla · 2001
12010–2010
Heath v. State green
fla · 1994
12010–2010
Nelson v. State green
fladistctapp · 1973
12010–2010
Mansfield v. State green
fla · 2000
12009–2009
Taylor v. State green
fla · 1993
12009–2009
Roper v. Simmons green
scotus · 2005
12008–2008

Statutes the citing opinions construe

FL § 921.141 (49) FL § 775.082 (9) FL § 782.04 (4) FL § 90.403 (4) FL § 90.804 (4) FL § 90.402 (3) FL § 90.404 (3) FL § 90.803 (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

NJ 700 (1980–2026) OH 274 (1990–2026) IL 137 (1981–2026) CA 120 (1976–2026) FL 89 (1979–2025) LA 86 (1984–2019) IN 84 (1980–2026) NY 81 (1988–2026) AZ 48 (1978–2026) NC 46 (1981–2026) WA 45 (1984–2026) TN 26 (1993–2018) KS 19 (1993–2021) ME 18 (1994–2026) AK 18 (1982–2025) MD 15 (1983–2024) CO 13 (1990–2012) UT 12 (1994–2020) MS 11 (1993–2023) AL 10 (1994–2016) PA 10 (1998–2024) GA 9 (2014–2025) NV 9 (1990–2019) DE 7 (1985–2023) CT 6 (1994–2025) IA 6 (2010–2023) OR 6 (1992–2022) OK 5 (1994–2017) AR 4 (2009–2025) NH 4 (2010–2015) MT 3 (1993–1996) MN 3 (2007–2014) MI 3 (2000–2009) NE 3 (1993–2023) WY 2 (2003–2017) TX 2 (1996–2020) WI 2 (2020–2026) VT 2 (2019–2022)

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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