fair and impartial hearing (Illinois) · Go Syfert
← Illinois issues

fair and impartial hearing in Illinois

83 Illinois opinions name it 2 courts 1942–2026 6 in the last five years

The cases below were cited by Illinois 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 (25)

CaseFollowedCited
The PEOPLE v. Robinsongreen
ill · 1970 · cited in 12 Illinois opinions naming this issue, 1973–2026
2 sentences

2026Lakes cited published opinions for support: People v. Robinson, 46 Ill. 2d 229, 231-32 (1970) (“there is no question that a defendant has a right to a fair and impartial hearing to determine whether” an eyewitness identification was the product of suggestive police procedures); People v. Stiles, 95 Ill.

2025See, e.g., People v. Robinson, 46 Ill. 2d 229, 231-32 (1970) (“there is no question that a defendant has a right to a fair and impartial hearing to determine whether” an eyewitness identification was the product of suggestive police procedures); People v. Stiles, 95 Ill.

612
Abrahamson v. Illinois Department of Professional Regulationgreen
ill · 1992 · cited in 5 Illinois opinions naming this issue, 2010–2016
2 sentences

2016See Abrahamson, 153 Ill. 2d at 95 (“A fair hearing before an administrative agency includes the opportunity to be heard, the right to cross-examine adverse witnesses, and impartiality in ruling on the evidence.”). ¶ 77 We conclude that petitioner received a fair and impartial hearing in this case and was not denied procedural due process. ¶ 78 2.

2016See Abramson, 153 Ill. 2d at 95 (“A fair hearing before an administrative agency includes the opportunity to be heard, the right to cross-examine adverse witnesses, and impartiality in ruling on the evidence.”). ¶ 77 We conclude that petitioner received a fair and impartial hearing in this case and was not denied procedural due process. ¶ 78 2.

45
Kaemmerer v. St. Clair County Electoral Boardgreen
illappct · 2002 · cited in 3 Illinois opinions naming this issue, 2014–2015
2 sentences

2015Clair County Electoral Board, 333 Ill.

2014Clair County Electoral Board, 333 Ill.

33
Golden Egg Club, Inc. v. Illinois Liquor Control Commissiongreen
illappct · 1970 · cited in 6 Illinois opinions naming this issue, 1980–2016
2 sentences

2016Moreover, “[a] basic tenet of our jurisprudence is that a person should receive a fair and impartial hearing, with an opportunity to offer evidence and cross-examine witnesses.” Golden Egg Club, Inc. v. Illinois Liquor Control Comm’n, 124 Ill.

2016Moreover, “[a] basic tenet of our jurisprudence is that a person should receive a fair and impartial hearing, with an opportunity to offer evidence and cross- examine witnesses.” Golden Egg Club, Inc. v. Illinois Liquor Control Comm’n, 124 Ill.

26
Gigger v. Board of Fire & Police Commissionersgreen
illappct · 1960 · cited in 4 Illinois opinions naming this issue, 1998–2016
2 sentences

2016App. 2d 241, 244 (1970); Gigger v. Board of Fire & Police Commissioners, 23 Ill.

2016App. 2d 241, 244 (1970); Gigger v. Board of Fire & Police Commissioners, 23 Ill.

24
People v. Stilesgreen
illappct · 1981 · cited in 3 Illinois opinions naming this issue, 1998–2026
2 sentences

2026Lakes cited published opinions for support: People v. Robinson, 46 Ill. 2d 229, 231-32 (1970) (“there is no question that a defendant has a right to a fair and impartial hearing to determine whether” an eyewitness identification was the product of suggestive police procedures); People v. Stiles, 95 Ill.

2025See, e.g., People v. Robinson, 46 Ill. 2d 229, 231-32 (1970) (“there is no question that a defendant has a right to a fair and impartial hearing to determine whether” an eyewitness identification was the product of suggestive police procedures); People v. Stiles, 95 Ill.

23
People v. Fultzgreen
illappct · 1975 · cited in 2 Illinois opinions naming this issue, 2025–2026
2 sentences

2026App. 3d 959, 964-65 (1981) (“It is fundamental that a defendant is entitled to a full and fair hearing -6- 1-25-0023 on [a] motion to suppress.”); People v. Fultz, 32 Ill.

2025App. 3d 959, 964-65 (1981) (“It is fundamental that a defendant is entitled to a full and fair hearing on [a] motion to suppress.”); People v. Fultz, 32 Ill.

22
Carrigan v. Board of Fire & Police Commissionersgreen
illappct · 1984 · cited in 2 Illinois opinions naming this issue, 2016–2016
2 sentences

2016The hearing shall be as hereinafter provided ***. *** *** The board of fire and police commissioners shall conduct a fair and impartial hearing of the charges, to be commenced within 30 days of the filing thereof, which hearing may be continued from time to time.” 65 ILCS 5/10-2.1-17 (West 2014). ¶ 10 “The statutory 30-day time limit to commence a hearing as provided in section 10-2.1-17 of the Illinois Municipal Code is mandatory, and a failure of the Board to commence a hearing within that time period causes the Board to lose jurisdiction of the case.” Carrigan v. Board of Fire & Police Comm

2016The hearing shall be as hereinafter provided ***. *** *** The board of fire and police commissioners shall conduct a fair and impartial hearing of the charges, to be commenced within 30 days of the filing thereof, which hearing may be continued from time to time.” 65 ILCS 5/10-2.1-17 (West 2014). ¶ 10 “The statutory 30-day time limit to commence a hearing as provided in section 10-2.1-17 of the Illinois Municipal Code is mandatory, and a failure of the Board to commence a hearing within that time period causes the Board to lose jurisdiction of the case.” Carrigan v. Board of -2- Fire & Police

22
Turcol v. Pension Board of Trustees of Matteson Police Pension Fundgreen
illappct · 2005 · cited in 2 Illinois opinions naming this issue, 2010–2010
2 sentences

2010“An individual challenging the impartiality of an administrative tribunal must overcome a presumption that those serving in such tribunals are fair and honest.” Turcol v. Pension Board of Trustees of Matteson 19 1-08-1212 Police Pension Fund, 359 Ill.

2010“An individual challenging the impartiality of an administrative tribunal must overcome a presumption that those serving in such tribunals are fair and honest.” Turcol v. Pension Board of Trustees of Matteson Police Pension Fund, 359 Ill.

22
Anderson v. Human Rights Commissiongreen
illappct · 2000 · cited in 2 Illinois opinions naming this issue, 2005–2005
2 sentences

2005Anderson v. Human Rights Comm’n , 314 Ill.

2005Anderson v. Human Rights Comm'n, 314 Ill.

22
In Re Abandonment of Wells Located in Illinoisgreen
illappct · 2003 · cited in 3 Illinois opinions naming this issue, 2005–2012
2 sentences

2005"In a proceeding where a person's right or interest in life, liberty, or property is affected, due process requires that the person be served with adequate notice, be apprised of a definite charge, and be afforded an opportunity to defend that interest in a fair and impartial hearing that is appropriate to the nature of the case." In re Abandonment of Wells located in Illinois by Eva Lovene Leavell , 343 Ill.

2005“In a proceeding where a person’s right or interest in life, liberty, or property is affected, due process requires that the person be served with adequate notice, be apprised of a definite charge, and be afforded an opportunity to defend that interest in a fair and impartial hearing that is appropriate to the nature of the case.” In re Abandonment of Wells located in Illinois by Eva Lovene Leavell, 343 Ill.

13
People v. Robinsongreen
illappct · 1974 · cited in 2 Illinois opinions naming this issue, 1979–2011
2 sentences

2011See Robinson, 18 Ill.App.3d at 807 , 310 N.E.2d 652 ("it is universally held that a judge who, before hearing a criminal case expresses conviction that the accused is guilty, cannot give that accused a fair and impartial hearing, and is thereby disqualified to sit as a trial judge"). ¶ 24 Next, we lack jurisdiction to review the portion of the court's October 21, 2008, order denying defendants' motion for summary judgment as to count II.

2011See Robinson, 18 Ill.App.3d at 807 , 310 N.E.2d 652 ("it is universally held that a judge who, before hearing a criminal case expresses conviction that the accused is guilty, cannot give that accused a fair and impartial hearing, and is thereby disqualified to sit as a trial judge"). ¶ 24 Next, we lack jurisdiction to review the portion of the court's October 21, 2008, order denying defendants' motion for summary judgment as to count II.

12
Black Hawk Motor Transit Co. v. Illinois Commerce Commissiongreen
ill · 1943 · cited in 2 Illinois opinions naming this issue, 2003–2003
2 sentences

2003If an abuse of discretion is found, the reviewing court must then determine “whether the result was injurious or prejudicial to appellant’s right to a fair and impartial hearing.” Black Hawk Motor Transit Co., 383 Ill. at 66 , 48 N.E.2d at 346 .

2003If an abuse of discretion is found, the reviewing court must then determine “whether the result was injurious or prejudicial to appellant’s right to a fair and impartial hearing.” Black Hawk Motor Transit Co., 383 Ill. at 66 , 48 N.E.2d at 346 .

12
First National Bank v. Kascsakgreen
illappct · 1978 · cited in 2 Illinois opinions naming this issue, 2003–2003
2 sentences

2003In re Estate of Hecht, 63 Ill.App.3d 539, 540 , 20 Ill.Dec. 254 , 379 N.E.2d 1322, 1324 (1978).

2003In re Estate of Hecht, 63 Ill.App.3d 539, 540 , 20 Ill.Dec. 254 , 379 N.E.2d 1322, 1324 (1978).

12
Mank v. BD. OF FIRE AND POLICE COMMRS.green
illappct · 1972 · cited in 2 Illinois opinions naming this issue, 1977–1979
2 sentences

1979Because of the closeness of the relationship between the charging party and one of the members of the commission and because of the judgmental factors involved, this court does not believe that the requirements for a fair and impartial hearing before a disinterested board were satisfied by the Board when one of the commissioners was closely related to the person bringing the charges.” 7 Ill.

1977(Stryker v. Village of Oak Park, 62 Ill. 2d 523, 533 (1976); Mank v. Board of Fire & Police Commissioners, 7 Ill.

12
Arvia v. Madigangreen
ill · 2004 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025As for his suggestion that he was deprived of a fair and impartial hearing before the Commission, Gibson fails to provide any legal or evidentiary support to overcome the presumption that the Commission was “objective and capable of judging the controversy fairly.” Cannici v. Village of Melrose Park, 2019 IL App (1st) 181422, ¶ 57 ; see Arvia 209 Ill. 2d at 541 (“[W]ithout a showing to the contrary, state administrators are assumed to be individuals of conscience and intellectual discipline, capable of judging a particular controversy fairly on the basis of its own circumstances.” (Internal qu

11
People v. Smithgreen
illappct · 2005 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023It is well settled that if a suppression hearing is held, a defendant has “a right to a fair and impartial hearing to determine whether an eyewitness's identification was the product of undue or suggestive police procedures.” - 25 - No. 1-18-1821 People v. Smith, 362 Ill.

11
Williams v. Board of Trustees of the Morton Grove Firefighters' Pension Fundgreen
illappct · 2010 · cited in 1 Illinois opinions naming this issue, 2012–2012
1 sentence

2012App. 3d 563, 571 (2007); see Williams v. Board of Trustees of the Morton Grove Firefighters’ Pension Fund, 398 Ill.

11
SMRJ, INC. v. Russellgreen
illappct · 2007 · cited in 1 Illinois opinions naming this issue, 2012–2012
1 sentence

2012Bias ¶ 32 Next, plaintiff contends that he was not provided a fair and impartial hearing because Dr. Rose was biased against plaintiff’s “style of medicine,” thereby infecting the actions of the entire Disciplinary Board and the Director. ¶ 33 In order to demonstrate bias or prejudice, a claimant must “show[ ] in the record that the administrative proceedings were either tainted by dishonesty or contained an unacceptable risk of bias.” (Internal quotation marks omitted.) SMRJ, Inc. v. Russell, 378 Ill.

11
People v. DeJesusgreen
illappct · 1987 · cited in 1 Illinois opinions naming this issue, 1998–1998
11
Shango v. Jurichgreen
ca7 · 1982 · cited in 1 Illinois opinions naming this issue, 1992–1992
11
Rouse v. Judges of Circuit Court of Cook Countygreen
ilnd · 1985 · cited in 1 Illinois opinions naming this issue, 1992–1992
11
Yadro v. Bowlinggreen
illappct · 1980 · cited in 1 Illinois opinions naming this issue, 1984–1984
11
Stryker v. Village of Oak Parkgreen
ill · 1976 · cited in 1 Illinois opinions naming this issue, 1977–1977
11
Stamp v. Commonwealthgreen
kyctapp · 1922 · cited in 1 Illinois opinions naming this issue, 1974–1974
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (55)

CaseCitedYears
People v. Carroll green
illappct · 1992
2 sentences

2005See People v. Robinson, 46 Ill. 2d 229, 231-32 , 263 N.E.2d 57 (1970); People v. Carroll, 260 Ill.

2005See People v. Robinson, 46 Ill. 2d 229, 231-32 , 263 N.E.2d 57 (1970); People v. Carroll, 260 Ill.

42005–2005
Smith v. Department of Registration & Education green
ill · 1952
2 sentences

1976It is beyond dispute that “[a] dministrative as well as judicial proceedings are governed by the fundamental principles and requirements of due process of law.” (Brown v. Air Pollution Control Board, 37 Ill. 2d 450, 454 ; Ellis v. Illinois Commerce Com., 44 Ill. 2d 438 .) In such proceedings, “[t] he object of this constitutional safeguard is to preserve the personal and property rights of a person against the arbitrary action of public officials.” (People v. Belcastro, 356 Ill. 144, 147 .) “Due process of law presupposes a fair and impartial hearing before a fair and impartial tribunal.” (Smi

1976It is beyond dispute that "[a]dministrative as well as judicial proceedings are governed by the fundamental principles and requirements of due process of law." ( Brown v. Air Pollution Control Board, 37 Ill.2d 450, 454 ; Ellis v. Illinois Commerce Com., 44 Ill.2d 438 .) In such proceedings, "[t]he object of this constitutional safeguard is to preserve the personal and property rights of a person against the arbitrary action of public officials." ( People v. Belcastro, 356 Ill. 144, 147 .) "Due process of law presupposes a fair and impartial hearing before a fair and impartial tribunal." ( Smit

41960–1990
Brown v. Air Pollution Control Board green
ill · 1967
2 sentences

1992Ed. 2d 18, 33 , 96 S. Ct. 893, 902 .) Despite the flexibility built into this concept, it is clear that certain minimal guarantees must always be provided. “ ‘Among the guarantees without which there would be an absence of procedural due process are reasonable notice, the right to examine witnesses, to testify, to present witnesses, and to be represented by counsel.’ ” (Brown v. Air Pollution Control Board (1967), 37 Ill. 2d 450, 454 , quoting Yiannopoulos v. Robinson (7th Cir. 1957), 247 F.2d 655, 657 .) These protections ensure that a fair trial is provided to its participants, for due proce

1976It is beyond dispute that “[a] dministrative as well as judicial proceedings are governed by the fundamental principles and requirements of due process of law.” (Brown v. Air Pollution Control Board, 37 Ill. 2d 450, 454 ; Ellis v. Illinois Commerce Com., 44 Ill. 2d 438 .) In such proceedings, “[t] he object of this constitutional safeguard is to preserve the personal and property rights of a person against the arbitrary action of public officials.” (People v. Belcastro, 356 Ill. 144, 147 .) “Due process of law presupposes a fair and impartial hearing before a fair and impartial tribunal.” (Smi

31976–1992
Knolls Condominium Ass'n v. Harms green
ill · 2002
2 sentences

2011Because specific provisions control over more general provisions in the interpretation of legislative intent ( Knolls, 202 Ill.2d at 459 , 269 Ill.Dec. 464 , 781 N.E.2d 261 ), we conclude that the only reasonable interpretation of section 10-2.1-17 is that (1) the village president and corporate authorities discharge a police chief who is appointed by ordinance and (2) the Commissioners discharge rank-and-file police officers. ¶56 Our interpretation of section 10-2.1-17 is consistent with the automatic reversion provision of section 10-2.1-4.

2011Because specific provisions control over more general provisions in the interpretation of legislative intent ( Knolls, 202 Ill.2d at 459 , 269 Ill.Dec. 464 , 781 N.E.2d 261 ), we conclude that the only reasonable interpretation of section 10-2.1-17 is that (1) the village president and corporate authorities discharge a police chief who is appointed by ordinance and (2) the Commissioners discharge rank-and-file police officers. ¶56 Our interpretation of section 10-2.1-17 is consistent with the automatic reversion provision of section 10-2.1-4.

22011–2011
Balmoral Racing Club, Inc. v. Illinois Racing Board green
ill · 1992
2 sentences

2010Balmoral Racing Club, Inc., 151 Ill. 2d at 408 .

2010Balmoral Racing Club, Inc., 151 Ill. 2d at 408 .

22010–2010
The PEOPLE v. Smith green
ill · 1963
2 sentences

2001Construing section 114 — 5(d) liberally to protect defendant’s right to a fair and impartial hearing (see Smith, 28 Ill. 2d at 447 ), we find that the trial judge erred by failing to transfer defendant’s substitution motion to another judge, as the statute requires.

2001Construing section 114–5(d) liberally to protect defendant’s right to a fair and impartial hearing (see Smith , 28 Ill. 2d at 447 ), we find that the trial judge erred by failing to transfer defendant’s substitution motion to another judge, as the statute requires.

22001–2001
The People v. Blumenshine green
ill · 1969
2 sentences

1973Although in a similar situation the conviction has been vacated (People v. Blumenshine, 42 Ill.2d 508 , 250 N.E.2d 152 ) “and its reinstatement made dependent upon the results of a new hearing on the identification question we find that in view of all the circumstances of this case justice would be better served if the cause were reversed and remanded for a complete new trial.” People v. Robinson, 46 Ill.2d 229, 233-234 , 263 N.E.2d 57, 59 .

1973Although in a similar situation the conviction has been vacated (People v. Blumenshine, 42 Ill.2d 508 , 250 N.E.2d 152 ) “and its reinstatement made dependent upon the results of a new hearing on the identification question we find that in view of all the circumstances of this case justice would be better served if the cause were reversed and remanded for a complete new trial.” People v. Robinson, 46 Ill.2d 229, 233-234 , 263 N.E.2d 57, 59 .

21970–1973
Dombrowski v. City of Chicago green
illappct · 2005
1 sentence

2025We have “a duty to examine the procedural methods that were employed at [the] administrative hearing to ensure that it was a fair and impartial hearing.” Id.

12025–2025
Barron v. City of Chicago green
illappct · 2025
1 sentence

2025The statute further provides that the Board “shall conduct a fair and impartial hearing of the charges, to be commenced within 30 days of the filing thereof, which hearing may be continued from time to time.” Id.

12025–2025
Cannici v. The Village of Melrose Park green
illappct · 2019
1 sentence

2025As for his suggestion that he was deprived of a fair and impartial hearing before the Commission, Gibson fails to provide any legal or evidentiary support to overcome the presumption that the Commission was “objective and capable of judging the controversy fairly.” Cannici v. Village of Melrose Park, 2019 IL App (1st) 181422, ¶ 57 ; see Arvia 209 Ill. 2d at 541 (“[W]ithout a showing to the contrary, state administrators are assumed to be individuals of conscience and intellectual discipline, capable of judging a particular controversy fairly on the basis of its own circumstances.” (Internal qu

12025–2025
Alcantar v. Peoples Gas Light and Coke Co. green
illappct · 1997
2 sentences

2009Williams responded in relevant part by citing In re Estate of Hoellen, 367 Ill.App.3d 240 , 305 Ill.Dec. 182 , 854 N.E.2d 774 (2006), Alcantar v. Peoples Gas, Light & Coke Co., 288 Ill.App.3d 644 , 224 Ill.Dec. 372 , 681 N.E.2d 993 (1997), and People v. Damnitz, 269 Ill.App.3d 51 , 206 Ill.Dec. 460 , 645 N.E.2d 465 (1994), for the proposition that a motion for substitution of judge for cause must make a threshold showing of prejudice to warrant transfer to another judge for hearing.

2009Williams responded in relevant part by citing In re Estate of Hoellen, 367 Ill.App.3d 240 , 305 Ill.Dec. 182 , 854 N.E.2d 774 (2006), Alcantar v. Peoples Gas, Light & Coke Co., 288 Ill.App.3d 644 , 224 Ill.Dec. 372 , 681 N.E.2d 993 (1997), and People v. Damnitz, 269 Ill.App.3d 51 , 206 Ill.Dec. 460 , 645 N.E.2d 465 (1994), for the proposition that a motion for substitution of judge for cause must make a threshold showing of prejudice to warrant transfer to another judge for hearing.

12009–2009
People v. Damnitz green
illappct · 1994
12009–2009
In Re Estate of Hoellen green
illappct · 2006
12009–2009
People v. Colon neutral
illappct · 1993
11994–1994
Westby v. Board of Fire & Police Commissioners green
illappct · 1977
11994–1994
Easter House v. Department of Children & Family Services green
illappct · 1990
11993–1993
The People v. Dennis green
ill · 1970
11992–1992
Andrew Peter Yiannopoulos v. Robert H. Robinson, District Director of Immigration, U. S. Immigration and Naturalization Service green
ca7 · 1957
11992–1992
People v. Seets green
illappct · 1976
11992–1992
Mathews v. Eldridge green
scotus · 1976
11992–1992
Stanley M. Pariser, M.D. v. Christian Health Care Systems, Inc. green
ca8 · 1987
11989–1989
Hortonville Joint School District No. 1 v. Hortonville Education Ass'n green
scotus · 1976
11988–1988
Grissom v. Board of Education green
ill · 1979
11988–1988
Head-On Collision Line, Inc. v. Kirk green
illappct · 1976
11987–1987
Chambers v. Industrial Commission green
illappct · 1985
11987–1987
Interstate Contractors v. Industrial Commission green
ill · 1980
11987–1987
Piotrowski v. State Police Merit Board green
illappct · 1980
11984–1984
Presbyterian Church of Carlyle v. St. Louis Union Trust Co. green
illappct · 1974
11980–1980
American Home Assurance Co. v. Northwest Industries, Inc. green
illappct · 1977
11980–1980
Marut v. Costello green
ill · 1966
11980–1980
Anderson v. City of Wheaton green
illappct · 1975
11979–1979
Rosewood Corp. v. Transamerica Insurance green
ill · 1974
11979–1979
Gilliland v. Board of Education red
ill · 1977
11979–1979
Ellis v. Illinois Commerce Commission green
ill · 1970
11976–1976
The People v. Belcastro green
ill · 1934
11976–1976
People v. Jashunsky green
ill · 1972
11976–1976
Fish v. McGann green
ill · 1903
11975–1975
People v. Bickham green
illappct · 1968
11974–1974
Rutledge v. Department of Registration & Education green
illappct · 1966
11974–1974
State Ex Rel. Conley v. Parks neutral
oklacrimapp · 1925
11974–1974

Statutes the citing opinions construe

IL § 735 ILCS 5/3-101 (6) IL § 65 ILCS 5/10-2.1-17 (4) IL § 720 ILCS 5/8-4 (4) IL § 720 ILCS 5/9-1 (4) IL § 725 ILCS 220/3 (4) IL § 730 ILCS 5/5-5-3.2 (4) IL § 730 ILCS 5/5-8-1 (4) IL § 730 ILCS 5/5-8-2 (4) IL § 735 ILCS 5/3-110 (4) IL § 10 ILCS 5/1-1 (3) IL § 10 ILCS 5/28-4 (3) IL § 725 ILCS 5/114-12 (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

NY 95 (1914–2020) IL 83 (1942–2026) CA 41 (1933–2024) FL 28 (1989–2023) AZ 19 (1922–2022) PA 18 (1952–2025) OH 18 (1953–2025) NJ 17 (1949–2024) NM 16 (1982–2020) TX 15 (1885–2025) OK 14 (1926–2023) SD 13 (1980–2018) WI 11 (1940–2023) WA 9 (1912–2024) MO 9 (1942–2007) RI 9 (1963–2021) GA 9 (1935–2004) CT 7 (1970–2002) NC 7 (1986–2025) MS 7 (1977–2012) AL 6 (1937–1987) ND 6 (1988–2019) SC 6 (1961–2015) IN 6 (1972–2003) MD 6 (1973–2001) KS 6 (1973–2015) LA 6 (1999–2021) ID 6 (1923–1993) MI 6 (1968–2003) VT 5 (1988–2025) MA 5 (1918–2003) CO 5 (1953–1987) WY 4 (1976–2022) MN 4 (1947–2005) AK 4 (1983–2024) HI 4 (1980–2011) IA 4 (1944–2012) NH 3 (1995–2000) NE 3 (1930–1974) MT 3 (1956–1980) ME 3 (1970–2026) OR 3 (1977–1992) TN 2 (1969–2022) NV 2 (1970–1986) AR 2 (2003–2012) DE 2 (2023–2024)

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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