minimum contacts doctrine in Connecticut

85 Connecticut opinions name it 3 courts 1983–2021 3 in the last five years

The cases below were cited by Connecticut 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 (17)

Case	Followed	Cited
Kulko v. Superior Court of Cal., City and County of San Franciscogreen scotus · 1978 · cited in 10 Connecticut opinions naming this issue, 1985–2007 2 sentences 2007“Like any standard that requires a determination of reasonableness, the minimum contacts test of International Shoe Co. is not susceptible of mechanical application; rather the facts of each case must be weighed to determine whether the requisite affiliating circumstances are present.” (Internal quotation marks omitted.) Kulko v. Superior Court of California, 436 U.S. 84, 92 , 98 S. Ct. 1690 , 56 L. 2007“Like any standard that requires a determination of reasonableness, the minimum contacts test of International Shoe Co. is not susceptible of mechanical application; rather the facts of each case must be weighed to determine whether the requisite affiliating circumstances are present.” (Internal quotation marks omitted.) Kulko v. Superior Court of California, 436 U.S. 84, 92 , 98 S. Ct. 1690 , 56 L.	4	10
United States Trust Co. v. Bohartgreen conn · 1985 · cited in 51 Connecticut opinions naming this issue, 1991–2008 2 sentences 2008“The twin touchstones of due process analysis under the minimum contacts doctrine are foreseeability and fairness. ‘[T]he foreseeability that is critical to due process analysis ... is that the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.’ ” United States Trust Co. v. Bohart, 197 Conn. 34, 41 , 495 A.2d 1034 (1985), quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 , 100 225 S. Ct. 559, 62 L. 2008“The twin touchstones of due process analysis under the minimum contacts doctrine are foreseeability and fairness. ‘[T]he foreseeability that is critical to due process analysis ... is that the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.’ ” United States Trust Co. v. Bohart, 197 Conn. 34, 41 , 495 A.2d 1034 (1985), quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 , 100 225 S. Ct. 559, 62 L.	3	51
Scott v. United Statesgreen scotus · 1978 · cited in 3 Connecticut opinions naming this issue, 1997–2000 2 sentences 2000See Kulko v. California Superior Court , 436 U.S. 84 , 92 , 98 S.Ct. 1690 , 56 L.Ed.2d 132 , reh. denied, 438 U.S. 908 , 98 S.Ct. 3127 , 57 L.Ed.2d 1150 (1978)." United States Trust Co. v. Bohart, 197 Conn. 34 , 41-42 , 495 A.2d 1034 (1985). 2000See Kulko v. California Superior Court , 436 U.S. 84 , 92 , 98 S.Ct. 1690 , 56 L.Ed.2d 132 , reh. denied, 438 U.S. 908 , 98 S.Ct. 3127 , 57 L.Ed.2d 1150 (1978)." United States Trust Co. v. Bohart, 197 Conn. 34 , 41-42 , 495 A.2d 1034 (1985).	3	3
Burger King Corp. v. Rudzewiczgreen scotus · 1985 · cited in 15 Connecticut opinions naming this issue, 1997–2008 2 sentences 2002"The specific facts of each case necessarily determine the outcome of a minimum contacts analysis." United States Trust Co. v. Bohart , supra, 197 Conn. 42 . "[I]t is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws." Burger King Corp. v. Rudzewicz , 471 U.S. 462 , 475 , 105 S.Ct. 559 , 62 L.Ed.2d 528 (1985). 1997The minimum contacts rule is satisfied when a party "purposefully avails itself of the privilege of conducting activities within the forum state." Id. at 475 .	2	15
Frazer v. McGowangreen conn · 1986 · cited in 5 Connecticut opinions naming this issue, 1993–2001 2 sentences 2001See also Frazer v. McGowan , 198 Conn. 243 , 249 (1986). 2000In determining foreseeability, "it is the totality of the defendant's conduct and connection with this state that must be considered, on a case by case basis, to determine whether the defendant could reasonably have anticipated being haled into court here." Framer v. McGowan , 198 Conn. 243 , 249 , 502 A.2d 905 (1986).	2	5
Phoenix Leasing, Inc. v. Kosinskigreen connappct · 1998 · cited in 4 Connecticut opinions naming this issue, 1998–2019 2 sentences 2019Conn. 2013) ; see Phoenix Leasing, Inc. v. Kosinski , 47 Conn. App. 650 , 653, 707 A.2d 314 (1998) ("forum selection clauses have generally been found to satisfy the due process concerns targeted by the minimum contacts analysis"). 2019Conn. 2013) ; see Phoenix Leasing, Inc. v. Kosinski , 47 Conn. App. 650 , 653, 707 A.2d 314 (1998) ("forum selection clauses have generally been found to satisfy the due process concerns targeted by the minimum contacts analysis").	1	4
Lombard Brothers, Inc. v. General Asset Management Co.green conn · 1983 · cited in 2 Connecticut opinions naming this issue, 1984–1993 2 sentences 1984Ed. 95 (1945); Lombard Bros., Inc. v. General Asset Management Co., 190 Conn. 245 , 460 A.2d 481 (1983). 17 Under the minimum contacts test, a foreign defendant’s contact with the forum state must be such that it is reasonable to require the defendant to defend there. 1984Ed. 95 (1945); Lombard Bros., Inc. v. General Asset Management Co., 190 Conn. 245 , 460 A.2d 481 (1983). 17 Under the minimum contacts test, a foreign defendant’s contact with the forum state must be such that it is reasonable to require the defendant to defend there.	1	2
Bruce Kriegman v. 1127477 Alberta Ltd.green ca9 · 2017 · cited in 1 Connecticut opinions naming this issue, 2021–2021 1 sentence 2021See, e.g., In re LLS America, LLC, 701 Fed.	1	1
Northrup King Co. v. Compania Productora Semillas Algodoneras Selectas, S.A., Also Known as C.O.P.S.A., a Spanish Corporationgreen ca8 · 1995 · cited in 1 Connecticut opinions naming this issue, 2021–2021 1 sentence 2021Ed. 2d 896 (2015); Chloé v. Queen Bee of Beverly Hills, LLC, 616 F.3d 158, 164 (2d Cir. 2010) (court must consider totality of defendant’s contacts rather than look at factors in isolation); Mid-America Tablewares, Inc. v. Mogi Trad- ing Co., Ltd., 100 F.3d 1353, 1361 (7th Cir. 1996) (‘‘by discussing its contacts with Wisconsin in isolation and suggesting that none alone establishes the requisite min- imum contacts, [the defendant] fails to appreciate that the minimum contacts inquiry is one that examines the totality of the circumstances’’); Northrup King Co. v. Compania Productora Semillas	1	1
No. 96-1843green ca7 · 1996 · cited in 1 Connecticut opinions naming this issue, 2021–2021 1 sentence 2021Ed. 2d 896 (2015); Chloé v. Queen Bee of Beverly Hills, LLC, 616 F.3d 158, 164 (2d Cir. 2010) (court must consider totality of defendant’s contacts rather than look at factors in isolation); Mid-America Tablewares, Inc. v. Mogi Trad- ing Co., Ltd., 100 F.3d 1353, 1361 (7th Cir. 1996) (‘‘by discussing its contacts with Wisconsin in isolation and suggesting that none alone establishes the requisite min- imum contacts, [the defendant] fails to appreciate that the minimum contacts inquiry is one that examines the totality of the circumstances’’); Northrup King Co. v. Compania Productora Semillas	1	1
Chloé v. Queen Bee of Beverly Hills, LLCgreen ca2 · 2010 · cited in 1 Connecticut opinions naming this issue, 2021–2021 1 sentence 2021Ed. 2d 896 (2015); Chloé v. Queen Bee of Beverly Hills, LLC, 616 F.3d 158, 164 (2d Cir. 2010) (court must consider totality of defendant’s contacts rather than look at factors in isolation); Mid-America Tablewares, Inc. v. Mogi Trad- ing Co., Ltd., 100 F.3d 1353, 1361 (7th Cir. 1996) (‘‘by discussing its contacts with Wisconsin in isolation and suggesting that none alone establishes the requisite min- imum contacts, [the defendant] fails to appreciate that the minimum contacts inquiry is one that examines the totality of the circumstances’’); Northrup King Co. v. Compania Productora Semillas	1	1
Gerardi v. City of Bridgeportgreen conn · 2010 · cited in 1 Connecticut opinions naming this issue, 2021–2021 2 sentences 2021See, e.g., Gerardi v. Bridgeport, 294 Conn. 461, 466 , 985 A.2d 328 (2010) (reviewing alternative ground for affirmance, even though defendants did not file notice under § 63-4 (a) (1), because there was no prejudice to the plaintiffs given that ‘‘the defendants . . . raised the claim in their briefs . . . and the plaintiffs had an adequate opportunity to respond, and did so, in their reply briefs’’). 14 The concurring and dissenting opinion is concerned that ‘‘we might be going beyond the confines of our adversarial system in our discovery of an additional doctrine that supports the plaintiff 2021See, e.g., Gerardi v. Bridgeport, 294 Conn. 461, 466 , 985 A.2d 328 (2010) (reviewing alternative ground for affirmance, even though defendants did not file notice under § 63-4 (a) (1), because there was no prejudice to the plaintiffs given that ‘‘the defendants . . . raised the claim in their briefs . . . and the plaintiffs had an adequate opportunity to respond, and did so, in their reply briefs’’). 14 The concurring and dissenting opinion is concerned that ‘‘we might be going beyond the confines of our adversarial system in our discovery of an additional doctrine that supports the plaintiff	1	1
Creative Calling Solutions, Inc. v. LF Beauty Ltd.green ca8 · 2015 · cited in 1 Connecticut opinions naming this issue, 2021–2021 1 sentence 2021See, e.g., Cre- ative Calling Solutions, Inc. v. LF Beauty Ltd., 799 F.3d 975, 980 (8th Cir. 2015) (after defendant initiated contact with plaintiff, parties e-mailed and phoned each other for close to two years); Johnson Worldwide Asso- ciates, Inc. v. Brunton Co., 12 F. Supp. 2d 901, 907 (E.D.	1	1
Johnson Worldwide Associates, Inc. v. Brunton Co.green wied · 1998 · cited in 1 Connecticut opinions naming this issue, 2021–2021 1 sentence 2021See, e.g., Cre- ative Calling Solutions, Inc. v. LF Beauty Ltd., 799 F.3d 975, 980 (8th Cir. 2015) (after defendant initiated contact with plaintiff, parties e-mailed and phoned each other for close to two years); Johnson Worldwide Asso- ciates, Inc. v. Brunton Co., 12 F. Supp. 2d 901, 907 (E.D.	1	1
Kulick v. Department of Revenuegreen or · 1981 · cited in 1 Connecticut opinions naming this issue, 1991–1991	1	1
Garlitz v. Rozargreen arizctapp · 1972 · cited in 1 Connecticut opinions naming this issue, 1990–1990	1	1
Pennoyer v. Neffred · 1878 · cited in 1 Connecticut opinions naming this issue, 1983–1983	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (21)

Case	Cited	Years
World-Wide Volkswagen Corp. v. Woodson green scotus · 1980 2 sentences 2008“The twin touchstones of due process analysis under the minimum contacts doctrine are foreseeability and fairness. ‘[T]he foreseeability that is critical to due process analysis ... is that the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.’ ” United States Trust Co. v. Bohart, 197 Conn. 34, 41 , 495 A.2d 1034 (1985), quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 , 100 225 S. Ct. 559, 62 L. 2008“The twin touchstones of due process analysis under the minimum contacts doctrine are foreseeability and fairness. ‘[T]he foreseeability that is critical to due process analysis ... is that the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.’ ” United States Trust Co. v. Bohart, 197 Conn. 34, 41 , 495 A.2d 1034 (1985), quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 , 100 225 S. Ct. 559, 62 L.	19	1985–2008
International Shoe Co. v. Washington green scotus · 1945 2 sentences 2017"The standard for determining whether an exercise of jurisdiction over the interests of persons is consistent with the Due Process Clause is the minimum-contacts standard elucidated in International Shoe [ Co. v. Washington , 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945) ]." Shaffer v. Heitner , 433 U.S. 186 , 207, 97 S.Ct. 2569 , 53 L.Ed.2d 683 (1977). "[I]f [a defendant] be not present within the territory of the forum, he [must] have certain minimum contacts with it such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice." (Internal 2017"The standard for determining whether an exercise of jurisdiction over the interests of persons is consistent with the Due Process Clause is the minimum-contacts standard elucidated in International Shoe [ Co. v. Washington , 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945) ]." Shaffer v. Heitner , 433 U.S. 186 , 207, 97 S.Ct. 2569 , 53 L.Ed.2d 683 (1977). "[I]f [a defendant] be not present within the territory of the forum, he [must] have certain minimum contacts with it such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice." (Internal	7	1985–2017
Hanson v. Denckla green scotus · 1958 2 sentences 2002The foreseeability that is critical to due process analysis . . . is that the defendant's conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there." (Citations omitted; internal quotation marks omitted.) United States Trust Co. v. Bohart , 197 Conn. 34 , 41 , 495 A.2d 1034 (1985). "[I]t is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws." Hanson v. Denckla , 357 U.S. 2002The foreseeability that is critical to due process analysis . . . is that the defendant's conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there." (Citations omitted; internal quotation marks omitted.) United States Trust Co. v. Bohart , 197 Conn. 34 , 41 , 495 A.2d 1034 (1985). "[I]t is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws." Hanson v. Denckla , 357 U.S.	6	1993–2002
Shaffer v. Heitner green scotus · 1977 2 sentences 2017"The standard for determining whether an exercise of jurisdiction over the interests of persons is consistent with the Due Process Clause is the minimum-contacts standard elucidated in International Shoe [ Co. v. Washington , 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945) ]." Shaffer v. Heitner , 433 U.S. 186 , 207, 97 S.Ct. 2569 , 53 L.Ed.2d 683 (1977). "[I]f [a defendant] be not present within the territory of the forum, he [must] have certain minimum contacts with it such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice." (Internal 2017"The standard for determining whether an exercise of jurisdiction over the interests of persons is consistent with the Due Process Clause is the minimum-contacts standard elucidated in International Shoe [ Co. v. Washington , 326 U.S. 310 , 66 S.Ct. 154 , 90 L.Ed. 95 (1945) ]." Shaffer v. Heitner , 433 U.S. 186 , 207, 97 S.Ct. 2569 , 53 L.Ed.2d 683 (1977). "[I]f [a defendant] be not present within the territory of the forum, he [must] have certain minimum contacts with it such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice." (Internal	4	1983–2017
Standard Tallow Corp. v. Jowdy green conn · 1983 2 sentences 2000The defendant also argues that it does not meet the minimum contacts standard as set out in Standard Tallow Corp. v. Jowdy, 190 Conn. 48 , 459 A.2d 803 (1983), and requests a hearing thereon. 1998"AIl assertions of state court jurisdiction must be evaluated according to the minimum contacts test." Standard Tallow Corp. v. Jowdy, 190 Conn. 48 , 51 , 459 A.2d 503 (1983).	4	1992–2000
McGee v. International Life Insurance green scotus · 1957 2 sentences 1996The defendants have such minimum contacts. since "[a] single act having impact in and connection with the forum state can satisfy the minimum contacts test . . ." McGee v. International Life Insurance, 355 U.S. 220 , 224 , 78 S.Ct. 199 , 2 L.Ed.2d 199 (1957). 1996The defendants have such minimum contacts. since "[a] single act having impact in and connection with the forum state can satisfy the minimum contacts test . . ." McGee v. International Life Insurance, 355 U.S. 220 , 224 , 78 S.Ct. 199 , 2 L.Ed.2d 199 (1957).	4	1991–1996
Thomason v. Chemical Bank green conn · 1995 2 sentences 2001In determining foreseeability, "it is the totality of the defendants conduct and connection with this state that must be considered, on a case by case basis, to determine whether the defendant could reasonably have anticipated being haled into court here." (Internal quotation marks omitted.) Thomason v. Chemical Bank, 234 Conn. 281 , 291 , 661 A.2d 595 (1995). "[I]t is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws." (Internal 2001In determining foreseeability, "it is the totality of the defendants conduct and connection with this state that must be considered, on a case by case basis, to determine whether the defendant could reasonably have anticipated being haled into court here." (Internal quotation marks omitted.) Thomason v. Chemical Bank, 234 Conn. 281 , 291 , 661 A.2d 595 (1995). "[I]t is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws." (Internal	2	1997–2001
Green v. United States green scotus · 1957 2 sentences 1996The defendants have such minimum contacts. since "[a] single act having impact in and connection with the forum state can satisfy the minimum contacts test . . ." McGee v. International Life Insurance, 355 U.S. 220 , 224 , 78 S.Ct. 199 , 2 L.Ed.2d 199 (1957). 1995The defendants argue that they lack minimum contacts with the State of Connecticut such that they can be held subject to the jurisdiction of this court because their "sporadic trips to the State, even combined with a number of telephone calls or fax transmissions, does not raise the level of contact such that jurisdiction can be inferred." However, "[a] single act having impact in and connection with the forum state can satisfy the minimum contacts test. . . ." McGee v. International Life Insurance, 355 U.S. 220 , 224 , 78 S.Ct. 199 , 2 L.Ed.2d 199 (1957).	2	1995–1996
Kenny v. Banks green conn · 2008 1 sentence 2018Id., at 529 , 958 A.2d 750 .	1	2018–2018
Cogswell v. American Transit Insurance green conn · 2007 2 sentences 2018Co. , supra, 282 Conn. 505 , 923 A.2d 638 , to argue that the minimum contacts requirement is not satisfied in the present case. 2018Co. , supra, 282 Conn. 505 , 923 A.2d 638 , to argue that the minimum contacts requirement is not satisfied in the present case.	1	2018–2018
NOBEL FARMS, INC. v. Pasero green calctapp · 2003 2 sentences 2016Consent is [a] traditional basis of jurisdiction, existing independently of long-arm statutes...." (Citations omitted; emphasis added; internal quotation marks omitted.) Nobel Farms, Inc. v. Pasero, 106 Cal.App.4th 654 , 658, 130 Cal.Rptr.2d 881 (2003). 2016Consent is [a] traditional basis of jurisdiction, existing independently of long-arm statutes...." (Citations omitted; emphasis added; internal quotation marks omitted.) Nobel Farms, Inc. v. Pasero, 106 Cal.App.4th 654 , 658, 130 Cal.Rptr.2d 881 (2003).	1	2016–2016
Global Packaging, Inc. v. Superior Court green calctapp · 2011 2 sentences 2016Finally, a party can consent to personal jurisdiction, when it would not otherwise be available." (Citations omitted; internal quotation marks omitted.) Global Packaging, Inc. v. Superior Court, 196 Cal.App.4th 1623 , 1629, 127 Cal.Rptr.3d 813 (2011). " Consent is considered as one of four traditional bases for the exercise of personal jurisdiction over a nonresident defendant and it is separate from the minimum contacts analysis .... 2016Finally, a party can consent to personal jurisdiction, when it would not otherwise be available." (Citations omitted; internal quotation marks omitted.) Global Packaging, Inc. v. Superior Court, 196 Cal.App.4th 1623 , 1629, 127 Cal.Rptr.3d 813 (2011). " Consent is considered as one of four traditional bases for the exercise of personal jurisdiction over a nonresident defendant and it is separate from the minimum contacts analysis ....	1	2016–2016
Leonard v. TALBERT green sc · 1954 1 sentence 2008“The twin touchstones of due process analysis under the minimum contacts doctrine are foreseeability and fairness. ‘[T]he foreseeability that is critical to due process analysis ... is that the defendant’s conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.’ ” United States Trust Co. v. Bohart, 197 Conn. 34, 41 , 495 A.2d 1034 (1985), quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 , 100 *225 S. Ct. 559, 62 L.	1	2008–2008
Zauderer v. Office of Disciplinary Counsel of the Supreme Court of Ohio neutral scotus · 1984 1 sentence 2002"The specific facts of each case necessarily determine the outcome of a minimum contacts analysis." United States Trust Co. v. Bohart , supra, 197 Conn. 42 . "[I]t is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws." Burger King Corp. v. Rudzewicz , 471 U.S. 462 , 475 , 105 S.Ct. 559 , 62 L.Ed.2d 528 (1985).	1	2002–2002
Hodge v. Hodge green conn · 1979 1 sentence 2001The standard for determining whether an exercise of jurisdiction over the interests of persons is consistent with the Due Process Clause is the minimum-contacts standard elucidated in International Shoe ." (Internal quotation marks omitted.) Id., 319 ; see also United States Trust Co. v. Bohart , 197 Conn. 34 , 42 n. 9, 495 A.2d 1034 (1985).	1	2001–2001
National Equipment Rental, Ltd. v. Szukhent green scotus · 1964 2 sentences 1996This basic tenet of foreseeability has given rise to the specific corollary that `parties to a contract may agree in advance to submit to the jurisdiction of a given court. . . .' National Rental v. Szukhent, 375 U.S. 311 , 315-16 , 84 S.Ct. 411 11 L.Ed.2d 354 (1964). 1996This basic tenet of foreseeability has given rise to the specific corollary that `parties to a contract may agree in advance to submit to the jurisdiction of a given court. . . .' National Rental v. Szukhent, 375 U.S. 311 , 315-16 , 84 S.Ct. 411 11 L.Ed.2d 354 (1964).	1	1996–1996
Liberty Life Insurance v. United States green scotus · 1979	1	1996–1996
Hart, Nininger & Campbell Associates v. Rogers green connappct · 1988	1	1994–1994
Hill v. W. R. Grace & Co. neutral connsuperct · 1991	1	1994–1994
cluster 258228 green ca3 · 1962	1	1991–1991
Rush v. Savchuk green scotus · 1980	1	1983–1983

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 52-59b (6) CT § Conn. Gen. Stat. § 51-199 (4) CT § Conn. Gen. Stat. § 1-2z (3) CT § Conn. Gen. Stat. § 42-110a (3) CT § Conn. Gen. Stat. § 52-604 (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

TX 629 (1975–2026) CT 85 (1983–2021) CA 77 (1958–2026) IL 74 (1975–2026) FL 55 (1962–2026) NC 53 (1978–2025) NJ 48 (1964–2025) OH 42 (1982–2026) NY 36 (1964–2024) PA 32 (1979–2026) DE 30 (1978–2026) MN 26 (1976–2026) CO 26 (1975–2022) IA 26 (1983–2023) WA 21 (1971–2026) AZ 21 (1981–2024) AL 21 (1986–2024) TN 20 (1981–2023) MO 18 (1982–2023) MD 18 (1978–2024) ME 15 (1995–2022) VT 15 (1979–2026) OK 13 (1973–2014) GA 13 (1980–2025) OR 13 (1982–2025) MI 12 (1974–2025) SC 11 (1985–2022) MA 10 (1983–2024) RI 9 (1981–2016) NM 9 (1986–2020) WI 9 (1997–2020) LA 8 (1971–2009) UT 7 (1990–2019) IN 7 (1982–2017) KS 7 (1980–2022) SD 6 (2005–2025) WV 6 (1981–2015) VA 6 (1977–2015) NE 6 (2005–2025) MS 6 (1984–2022) NV 5 (1998–2022) ID 5 (1977–2021) MT 4 (1982–2009) DC 4 (1968–2001) NH 4 (1987–2025) AR 3 (1994–2013) AK 3 (2018–2024) HI 3 (1996–2024) ND 3 (1980–1991) KY 2 (1980–2002)

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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