ineffective waiver (Texas) · Go Syfert
← Texas issues

ineffective waiver in Texas

12 Texas opinions name it 2 courts 2001–2015 0 in the last five years

The cases below were cited by Texas 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 (12)

CaseFollowedCited
Seamster v. Stategreen
texapp · 2011 · cited in 4 Texas opinions naming this issue, 2014–2015
2 sentences

2015See Seamster v. State, 344 S.W.3d 592, 594 (Tex.App.-- Houston [14th Dist.] 2011, pet. ref’d); My Thi Tieu v. State, 299 S.W.3d 216, 225 (Tex.App.-- Houston [14th Dist.] 2009, pet. ref’d)(it is unnecessary to determine whether trial counsel’s representation was deficient if appellant cannot satisfy the second Strickland prong), citing Strickland, 466 U.S. at 697 , 104 S.Ct. at 2069-70 .

2015See Seamster v. State, 344 S.W.3d 592, 594 (Tex.App.-- Houston [14th Dist.] 2011, pet. ref’d); My Thi Tieu v. State, 299 S.W.3d 216, 225 (Tex.App.-- Houston [14th Dist.] 2009, pet. ref’d)(it is unnecessary to determine whether trial counsel’s representation was deficient if appellant cannot satisfy the second Strickland prong), citing Strickland, 466 U.S. at 697 , 104 S.Ct. at 2069-70 .

44
My Thi Tieu v. Stategreen
texapp · 2009 · cited in 4 Texas opinions naming this issue, 2014–2015
2 sentences

2015See Seamster v. State, 344 S.W.3d 592, 594 (Tex.App.-- Houston [14th Dist.] 2011, pet. ref’d); My Thi Tieu v. State, 299 S.W.3d 216, 225 (Tex.App.-- Houston [14th Dist.] 2009, pet. ref’d)(it is unnecessary to determine whether trial counsel’s representation was deficient if appellant cannot satisfy the second Strickland prong), citing Strickland, 466 U.S. at 697 , 104 S.Ct. at 2069-70 .

2015See Seamster v. State, 344 S.W.3d 592, 594 (Tex.App.-- Houston [14th Dist.] 2011, pet. ref’d); My Thi Tieu v. State, 299 S.W.3d 216, 225 (Tex.App.-- Houston [14th Dist.] 2009, pet. ref’d)(it is unnecessary to determine whether trial counsel’s representation was deficient if appellant cannot satisfy the second Strickland prong), citing Strickland, 466 U.S. at 697 , 104 S.Ct. at 2069-70 .

44
Alabama v. Sheltongreen
scotus · 2002 · cited in 3 Texas opinions naming this issue, 2008–2008
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

33
Cordova v. Bacagreen
ca9 · 2003 · cited in 3 Texas opinions naming this issue, 2008–2008
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing that a defective waiver colloquy, as opposed to a defective waiver, may be subject to a harmless error analysis). 39 .See Alabama v. Shelton, 535 U.S. 654, 658 , 122 S.Ct. 1764 , 152 L.Ed.2d 888 (2002). 40 .

33
United States v. Virgilgreen
ca5 · 2006 · cited in 3 Texas opinions naming this issue, 2008–2008
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing that a defective waiver colloquy, as opposed to a defective waiver, may be subject to a harmless error analysis). 39 .See Alabama v. Shelton, 535 U.S. 654, 658 , 122 S.Ct. 1764 , 152 L.Ed.2d 888 (2002). 40 .

33
Johnson v. Zerbstgreen
scotus · 1938 · cited in 3 Texas opinions naming this issue, 2008–2008
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

23
Gideon v. Wainwrightgreen
scotus · 1963 · cited in 2 Texas opinions naming this issue, 2008–2008
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

22
Oliver v. Stategreen
texcrimapp · 1994 · cited in 2 Texas opinions naming this issue, 2008–2008
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008Gideon, 372 U.S. at 340, 83 S.Ct. 792 (citing Zerbst, 304 U.S. at 465 , 58 S.Ct. 1019 ); Oliver v. State, 872 S.W.2d 713, 715-16 (Tex.Crim.App.1994). 41 .

22
Miranda v. Arizonagreen
scotus · 1966 · cited in 2 Texas opinions naming this issue, 2008–2008
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

12
Ayiba Queendalyn Chinyere & Suleman Nelson Ilodigwe and All Other Occupants of 13523 Bonilla Lane, Houston Texas 77083 v. Wells Fargo Bankgreen
texapp · 2012 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015See 440 S.W.3d 80, 85 (Tex. App.—Houston [1st Dist.] 2012, no pet.).

11
Fulbright v. Stategreen
texapp · 2001 · cited in 1 Texas opinions naming this issue, 2008–2008
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

11
Penson v. Ohiogreen
scotus · 1988 · cited in 1 Texas opinions naming this issue, 2008–2008
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Strickland v. Washington green
scotus · 1984
2 sentences

2001“Failure to make the required showing of either deficient performance or sufficient prejudice defeats the ineffective claim.” Id. at 700 .

2001"Failure to make the required showing of either deficient performance or sufficient prejudice defeats the ineffective claim." Id. at 700 .

62001–2015
Thompson v. State green
texcrimapp · 1999
2 sentences

2015Thompson, 9 S.W.3d at 813-14 . 4.

2015Thompson, 9 S.W.3d at 813-14 . 4.

22015–2015
Iowa v. Tovar green
scotus · 2004
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

22008–2008
Patterson v. Illinois green
scotus · 1988
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

22008–2008
Arizona v. Fulminante green
scotus · 1991
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

12008–2008
Williams v. State green
texapp · 2006
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

12008–2008
Satterwhite v. Texas green
scotus · 1988
2 sentences

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

2008P. 44.2(a). [29] 41 S.W.3d 228, 235-36 (Tex.App.-Fort Worth 2001, pet. ref'd). [30] Id. at 234 . [31] Id. at 235 . [32] Id. [33] Id. [34] Id. at 236 . [35] Id. [36] Id. [37] Williams, 194 S.W.3d at 578-79 . [38] See Cordova v. Baca, 346 F.3d 924, 926-27 (9th Cir.2003) (discussing the difference between a defective Faretta colloquy and an ineffective waiver of the right to trial counsel and noting the potential application of a harmless error analysis to a defective Faretta colloquy to find an effective waiver); see also United States v. Virgil, 444 F.3d 447, 456-47 (5th Cir.2006) (recognizing

12008–2008

Statutes the citing opinions construe

TX § Tex. Penal Code § 12.42 (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 12 (1976–2026) TX 12 (2001–2015) NY 9 (1992–2014) CA 8 (1961–2024) MI 7 (1982–2026) FL 6 (1996–2024) OH 4 (2006–2020) DE 3 (2015–2022) MO 2 (1913–1994) CT 2 (1988–2019) ID 2 (1992–2021)

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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