83 New York opinions name it 3 courts 1884–2025 5 in the last five years
The cases below were cited by New York 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.
| Case | Followed | Cited |
|---|---|---|
People v. Riveragreen2 sentences2015This contention is unpreserved for appellate review, as the defendant failed to raise this specific contention before the hearing court ( see CPL 470.05[2]; People v Vann , 92 AD3d 702 ; People v Inge , 90 AD3d 675, 676 ; People v Muriello , 71 AD3d 1050, 1051 ; People v Rivera , 27 AD3d 489, 490 ). 2015This contention is unpreserved for appellate review, as the defendant failed to raise this specific contention before the hearing court (see CPL 470.05 [2]; People v Vann, 92 AD3d 702 [2012]; People v Inge, 90 AD3d 675, 676 [2011]; People v Muriello, 71 AD3d 1050, 1051 [2010]; People v Rivera, 27 AD3d 489, 490 [2006]). | 3 | 3 |
People v. Ingegreen2 sentences2015This contention is unpreserved for appellate review, as the defendant failed to raise this specific contention before the hearing court (see CPL 470.05 [2]; People v Vann, 92 AD3d 702 [2012]; People v Inge, 90 AD3d 675, 676 [2011]; People v Muriello, 71 AD3d 1050, 1051 [2010]; People v Rivera, 27 AD3d 489, 490 [2006]). 2015Contrary to the People’s contention, the defendant preserved this argument for appellate review by, inter alia, specifically challenging the testimony of the police officers and arguing at the hearing that the testimony of the respective police officers was irreconcilable and inconsistent, and conflicted with testimony given before the grand jury (cf. People v Taylor, 120 AD3d 519, 520 [2014]; People v Inge, 90 AD3d 675 [2011]). | 2 | 3 |
People v. Seaberggreen2 sentences2016As the defendant’s challenge to the voluntariness of his plea survives even a valid waiver of the right to appeal (see People v Seaberg, 74 NY2d 1, 10 [1989]; People v Innocent, 132 AD3d 696, 696 [2015]), we need not determine whether the defendant’s waiver of the right to appeal was invalid (see People v Harvey, 137 AD3d 1162, 1163 [2016]). 2016As the defendant’s challenge to the voluntariness of his plea of guilty survives even a valid waiver of the right to appeal (see People v Seaberg, 74 NY2d 1, 10 [1989]; People v Innocent, 132 AD3d 696, 696 [2015]; People v Borges, 103 AD3d 747, 748 [2013]), we need not determine whether the defendant’s waiver of the right to appeal was invalid. | 2 | 2 |
People v. Herbgreen2 sentences2016As the defendant’s challenge to the voluntariness of his plea survives even a valid waiver of the right to appeal (see People v Seaberg, 74 NY2d 1, 10 [1989]; People v Innocent, 132 AD3d 696, 696 [2015]), we need not determine whether the defendant’s waiver of the right to appeal was invalid (see People v Harvey, 137 AD3d 1162, 1163 [2016]). 2016As the defendant’s challenge to the voluntariness of his plea of guilty survives even a valid waiver of the right to appeal (see People v Seaberg, 74 NY2d 1, 10 [1989]; People v Innocent, 132 AD3d 696, 696 [2015]; People v Borges, 103 AD3d 747, 748 [2013]), we need not determine whether the defendant’s waiver of the right to appeal was invalid. | 2 | 2 |
People v. McGeegreen2 sentences2016Defense counsel’s conduct at the hearing was reasonably competent under the circumstances (see People v Benevento, 91 NY2d at 712-713 ), and, while the defendant contends that defense counsel failed to make certain arguments in support of suppression, those arguments cannot be fairly characterized as clear-cut and dispositive in the defendant’s favor (see People v McGee, 20 NY3d 513, 518 [2013]; cf. People v Clermont, 22 NY3d 931 [2013]) so as to render defense counsel ineffective for failing to make them. 2016Defense counsel’s conduct at the hearing was reasonably competent under the circumstances (see People v Benevento, 91 NY2d at 712-713 ), and, while the defendant contends that defense counsel failed to make certain arguments in support of suppression, those arguments cannot be fairly characterized as clear-cut and dispositive in the defendant’s favor (see People v McGee, 20 NY3d 513, 518 [2013]; cf. People v Clermont, 22 NY3d 931 [2013]) so as to render defense counsel ineffective for failing to make them. | 2 | 2 |
People v. Taylorgreen2 sentences2016“The credibility determinations of a hearing court are entitled to great deference on appeal, and will not be disturbed unless clearly unsupported by the record” (People v Taylor, 120 AD3d 519, 520 [2014] [internal quotation marks omitted]; see People v Wheeler, 2 NY3d 370, 374 [2004]; People v Prochilo, 41 NY2d 759 , 761 [1977]). 2015Contrary to the People’s contention, the defendant preserved this argument for appellate review by, inter alia, specifically challenging the testimony of the police officers and arguing at the hearing that the testimony of the respective police officers was irreconcilable and inconsistent, and conflicted with testimony given before the grand jury (cf. People v Taylor, 120 AD3d 519, 520 [2014]; People v Inge, 90 AD3d 675 [2011]). | 2 | 2 |
People v. Adamsgreen2 sentences2007The defendant contends that the hearing court erred in denying suppression of physical evidence seized from his house when the police conducted an illegal search. “[W]here the searching officers rely in good faith on the apparent capability of an individual to consent to a search and the circumstances reasonably indicate that that individual does, in fact, have the authority to consent, evidence obtained as the result of such a search should not be suppressed” (People v Adams, 53 NY2d 1, 9 [1981]). 2007Here, the police officer reasonably relied in good faith upon the defendant’s wife’s apparent authority to consent to the search of the bedroom closet and the unlocked case which contained the seized weapon (see People v Adams, supra; People v Fontaine, 27 AD3d 1144 [2006]; People v Miloro, 22 AD3d 768, 769 [2005]). | 2 | 2 |
People v. Crimminsgreen2 sentences2008Even if the hearing court erred in failing to suppress the defendant’s videotaped statement, under the circumstances of this case, any error was harmless beyond a reasonable doubt (see People v Wood, 40 AD3d 663, 664 [2007]; People v Sacha, 177 AD2d 523 [1991]; see generally People v Crimmins, 36 NY2d 230, 241-242 [1975]). 1995We find that these contentions are unpreserved for appellate review (see, CPL 470.05 [2]), without merit, or harmless in light of the overwhelming evidence of the defendant’s guilt (see, People v Crimmins, 36 NY2d 230 ). | 1 | 3 |
People v. Thomasgreen2 sentences2025However, even if the defendant did not validly waive his right to appeal, "it would not render his guilty plea involuntary so as to require that we invalidate the plea or entitle him to withdraw his guilty plea" ( People v Thomas , 190 AD3d 1157, 1159 ). 2025However, even if the defendant did not validly waive his right to appeal, "it would not render his guilty plea involuntary so as to require that we invalidate the plea or entitle him to withdraw his guilty plea" ( People v Thomas , 190 AD3d 1157, 1159). | 1 | 2 |
People v. Chapplegreen2 sentences2015On appeal, the defendant contends that the hearing court erred in refusing to suppress the second videotaped statement because that statement was tainted by the pre-9 a.m. questioning. “[W]here an improper, unwarned statement gives rise to a subsequent Mirandized statement as part of a ‘single continuous chain of events,’ there is inadequate assurance that the Miranda warnings were effective in protecting a defendant’s rights, and the warned statement must also be suppressed” *783 (People v Paulman, 5 NY3d 122, 130 [2005], quoting People v Chapple, 38 NY2d 112, 114 [1975]). 1999However, it is well settled that, notwithstanding that a defendant made an earlier statement without the benefit of Miranda warnings, a later statement is admissible provided it follows a definite, pronounced break in questioning sufficient to return the defendant to the status of one who is not under the influence of questioning (see, People v Chapple, 38 NY2d 112, 115 ). | 1 | 2 |
Strickland v. Washingtongreen2 sentences2025To prevail on a claim of ineffective assistance of counsel under the federal constitution, "the defendant must show that counsel's representation fell below an objective standard of reasonableness" and "that the deficient performance prejudiced the defense" ( Strickland v Washington , 466 US 668, 687-688 ; see People v Ramroop , _____ AD3d _____, _____, 2025 NY [*2]Slip Op 01647, *1). 2025To prevail on a claim of ineffective assistance of counsel under the federal constitution, "the defendant must show that counsel's representation fell below an objective standard of reasonableness" and "that the deficient performance prejudiced the defense" ( Strickland v Washington , 466 US 668, 687-688; see People v Ramroop , _____ AD3d _____, _____, 2025 NY [*2]Slip Op 01647, *1). | 1 | 1 |
The People v. Louis Speaksgreen1 sentence2023Overall, the prosecutor's alleged improper comments during summation, to which the defendant contends defense counsel ought to have objected, but failed to do so, "were within the broad bounds of permissible rhetorical comment, a fair response to the defendant's summation, or fair comment on the evidence and the reasonable inferences to be drawn therefrom" ( People v Ramirez , 146 AD3d at 988 ; see People v Speak , 28 NY3d 990, 992 ; cf. People v Day , 178 AD3d 845 , 846). | 1 | 1 |
People v. Stonegreen1 sentence2022However, the defendant elected to proceed pro se after the Supreme Court engaged in a "searching inquiry" ( People v Stone , 22 NY3d 520, 525 [internal quotation marks omitted]) to clarify that he understood the ramifications of proceeding without counsel ( see People v Providence , 2 NY3d 579 ; People v James , 200 AD3d 711, 712 ). | 1 | 1 |
| People v. Baggettgreen | 1 | 1 |
| People v. Lopergreen | 1 | 1 |
| People v. Lugggreen | 1 | 1 |
| People v. Avenigreen | 1 | 1 |
| People v. Thompsongreen | 1 | 1 |
| People v. Borgesgreen | 1 | 1 |
| People v. Wheelergreen | 1 | 1 |
| People v. Santosgreen | 1 | 1 |
| People v. Ortizgreen | 1 | 1 |
| People v. Harveygreen | 1 | 1 |
| People v. Crumblegreen | 1 | 1 |
| Fare v. Michael C.green | 1 | 1 |
| People v. Rodneygreen | 1 | 1 |
| People v. Howardgreen | 1 | 1 |
| People v. Williamsgreen | 1 | 1 |
| People v. Muriellogreen | 1 | 1 |
| People v. Maxwellgreen | 1 | 1 |
| People v. Paulmangreen | 1 | 1 |
| People v. Borgesgreen | 1 | 1 |
| People v. Dunbargreen | 1 | 1 |
| People v. Woodgreen | 1 | 1 |
| People v. Milorogreen | 1 | 1 |
| People v. Bashergreen | 1 | 1 |
| People v. Samuelsgreen | 1 | 1 |
| People v. Kinchengreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Miranda v. Arizona
green
2 sentences2017The defendant contends that the hearing court should have suppressed his statements to law enforcement officials as the product of custodial interrogation conducted without the benefit of Miranda warnings (see Miranda v Arizona, 384 US 436 [1966]). 2016The defendant contends that the hearing court erred in denying that branch of his omnibus motion which was to suppress his statements to law enforcement officials because his waiver of Miranda rights (see Miranda v Arizona, 384 US 436 [1966]) was not voluntary, knowing, and intelligent due to his mental disability and extremely limited language and comprehension skills. “[F]or a statement to be admissible, the People must prove a voluntary, knowing, and intelligent waiver of the privilege against self-incrimination” (People v Aveni, 100 AD3d 228, 236 [2012] [citation omitted]; see People v Rod | 8 | 1988–2017 |
Payton v. New York
green
2 sentences2017The defendant contends that the hearing court erred in denying that branch of his omnibus motion which was to suppress his statements to law enforcement officials because there was insufficient attenuation between his statements and police conduct found by the hearing court to violate Payton v New York ( 445 US 573 [1980]). 2003The defendant contends that the hearing court erred in denying that branch of his omnibus motion which was to suppress his confession after his arrest because the police violated his rights under Payton v New York ( 445 US 573 [1980]) by arresting him inside his home without a warrant. | 4 | 1989–2017 |
People v. Bishop
neutral
2 sentences1996Further, while the defendant contends that the hearing court should not have credited the officer’s testimony, resolution of issues of credibility are primarily for the hearing court, which had the advantage of seeing and hearing the witnesses, and its determination should be accorded weight on appeal, and should not be set aside unless clearly unsupported by the record (see, People v Prochilo, 41 NY2d 759 ; People v Bishop, 199 AD2d 518 ). 1994Moreover, while the defendant contends that the hearing court should have credited his testimony that he committed no traffic violations, resolution of issues of credibility are primarily for the hearing court, which had the advantage of seeing and hearing the witnesses, and its determination should be accorded great weight on appeal, and should not be set aside unless clearly unsupported by the record (see, People v Prochilo, 41 NY2d 759 ; People v Bishop, supra; People v Overton, 188 AD2d 491 ; People v Gonzalez, 184 AD2d 525 ). | 3 | 1994–1996 |
People v. Lopez
green
2 sentences2019The defendant's valid waiver of the right to appeal forecloses appellate review of his challenges to the hearing court's adverse suppression rulings ( see People v Kemp , 94 NY2d 831 ; People v Kates , 162 AD3d 1627 , 1628; People v Anlyan , 142 AD3d 670, 671 ), as well as his contention that the sentence imposed was excessive ( see People v Bradshaw , 18 NY3d at 264-265 ; People v Lopez , 6 NY3d at 255 ; People v Vecchio , 168 AD3d 1000 ). 2010Although the Court of Appeals has determined that a waiver of the right to appeal, when knowingly and voluntarily entered into, precludes any challenge to the severity of the sentence (see People v Lopez, 6 NY3d 248 [2006]), the basis for that policy is “that the public interest concerns underlying plea bargains generally are served by enforcing waivers of the right to appeal. | 2 | 2010–2019 |
United States v. Wade
green
2 sentences2016The People established at a Wade hearing (see United States v Wade, 388 US 218 [1967]) that the showup identification of the defendant was properly conducted within close spatial and temporal proximity to the crime (see People v Ortiz, 90 NY2d 533, 537 [1997]; People v Crumble, 43 AD3d 953, 953 [2007]; see also People v Howard, 22 NY3d 388, 402 [2013]; People v Thompson, 129 AD2d 655, 656-657 [1987]). 1988We find merit in this contention, based upon our analysis infra. The Court of Appeals in People v Blake ( 35 NY2d 331, 335 [1974]) stated "Prior to United States v. Wade ( 388 U.S. 218 ), Gilbert v. California ( 388 U.S. 263 ), and Stovall v. Denno ( 388 U.S. 293 ), counsel were not required at pretrial corporeal viewings of a defendant by identification witnesses. | 2 | 1988–2016 |
People v. Benevento
green
2 sentences2016Defense counsel’s conduct at the hearing was reasonably competent under the circumstances (see People v Benevento, 91 NY2d at 712-713 ), and, while the defendant contends that defense counsel failed to make certain arguments in support of suppression, those arguments cannot be fairly characterized as clear-cut and dispositive in the defendant’s favor (see People v McGee, 20 NY3d 513, 518 [2013]; cf. People v Clermont, 22 NY3d 931 [2013]) so as to render defense counsel ineffective for failing to make them. 2016Defense counsel’s conduct at the hearing was reasonably competent under the circumstances (see People v Benevento, 91 NY2d at 712-713 ), and, while the defendant contends that defense counsel failed to make certain arguments in support of suppression, those arguments cannot be fairly characterized as clear-cut and dispositive in the defendant’s favor (see People v McGee, 20 NY3d 513, 518 [2013]; cf. People v Clermont, 22 NY3d 931 [2013]) so as to render defense counsel ineffective for failing to make them. | 2 | 2016–2016 |
People v. Clermont
green
2 sentences2016Defense counsel’s conduct at the hearing was reasonably competent under the circumstances (see People v Benevento, 91 NY2d at 712-713 ), and, while the defendant contends that defense counsel failed to make certain arguments in support of suppression, those arguments cannot be fairly characterized as clear-cut and dispositive in the defendant’s favor (see People v McGee, 20 NY3d 513, 518 [2013]; cf. People v Clermont, 22 NY3d 931 [2013]) so as to render defense counsel ineffective for failing to make them. 2016Defense counsel’s conduct at the hearing was reasonably competent under the circumstances (see People v Benevento, 91 NY2d at 712-713 ), and, while the defendant contends that defense counsel failed to make certain arguments in support of suppression, those arguments cannot be fairly characterized as clear-cut and dispositive in the defendant’s favor (see People v McGee, 20 NY3d 513, 518 [2013]; cf. People v Clermont, 22 NY3d 931 [2013]) so as to render defense counsel ineffective for failing to make them. | 2 | 2016–2016 |
People v. Bartlett
green
2 sentences2006The contention is unpreserved for appellate review, as the defendant failed to raise that specific claim before the hearing court (see CPL 470.05 [2]; People v Martinez, 287 AD2d 654 [2001]; People v Martinez, 267 AD2d 332 [1999]; People v Jackson, 241 AD2d 526 [1997]; People v Bartlett, 191 AD2d 574 [1993]). 2001The contention is unpreserved for appellate review, as the defendant failed to raise that specific claim before the hearing court (see, CPL 470.05 [2]; People v Martinez, 267 AD2d 332 ; People v Jackson, 241 AD2d 526 , cert denied 523 US 1061 ; People v Bartlett, 191 AD2d 574 ). | 2 | 2001–2006 |
People v. Jackson
neutral
2 sentences2006The contention is unpreserved for appellate review, as the defendant failed to raise that specific claim before the hearing court (see CPL 470.05 [2]; People v Martinez, 287 AD2d 654 [2001]; People v Martinez, 267 AD2d 332 [1999]; People v Jackson, 241 AD2d 526 [1997]; People v Bartlett, 191 AD2d 574 [1993]). 2001The contention is unpreserved for appellate review, as the defendant failed to raise that specific claim before the hearing court (see, CPL 470.05 [2]; People v Martinez, 267 AD2d 332 ; People v Jackson, 241 AD2d 526 , cert denied 523 US 1061 ; People v Bartlett, 191 AD2d 574 ). | 2 | 2001–2006 |
People v. Lloyd
neutral
2 sentences2006The contention is unpreserved for appellate review, as the defendant failed to raise that specific claim before the hearing court (see CPL 470.05 [2]; People v Martinez, 287 AD2d 654 [2001]; People v Martinez, 267 AD2d 332 [1999]; People v Jackson, 241 AD2d 526 [1997]; People v Bartlett, 191 AD2d 574 [1993]). 2001The contention is unpreserved for appellate review, as the defendant failed to raise that specific claim before the hearing court (see, CPL 470.05 [2]; People v Martinez, 267 AD2d 332 ; People v Jackson, 241 AD2d 526 , cert denied 523 US 1061 ; People v Bartlett, 191 AD2d 574 ). | 2 | 2001–2006 |
People v. Sandoval
green
2 sentences1998The defendant contends that the defense counsel’s elicitation of the underlying facts of a prior conviction after achieving its exclusion following the Sandoval hearing (see, People v Sandoval, 34 NY2d 371 ), constituted ineffective assistance of counsel requiring reversal of his conviction (see, e.g., People v Ofunniyin, 114 AD2d 1045, 1046-1047 ). 1987His past criminal acts demonstrate his willingness to place his interest ahead of that of society and we cannot say that the court’s ruling was an abuse of its discretion (see, People v Sandoval, 34 NY2d 371 ). | 2 | 1987–1998 |
People v. Munno
green
2 sentences1996However, the record is insufficient to afford meaningful appellate review of this issue (see, People v Morgan, 224 AD2d 720 , supra [decided herewith]; People v Jupiter, 210 AD2d 431 ; People v Neal, 205 AD2d 711 ). 1996However, because no transcript of the conversation between the court and Samuels was made and because defense counsel did not move to have the conversation reconstructed in any manner when he registered an untimely and pro forma objection thereto (cf., People v Anderson, 223 AD2d 547 ), the record is insufficient to afford meaningful appellate review of this issue (see, People v Jupiter, 210 AD2d 431 ; People v Neal, 205 AD2d 711 ). | 2 | 1996–1996 |
People v. Jupiter
green
2 sentences1996However, the record is insufficient to afford meaningful appellate review of this issue (see, People v Morgan, 224 AD2d 720 , supra [decided herewith]; People v Jupiter, 210 AD2d 431 ; People v Neal, 205 AD2d 711 ). 1996However, because no transcript of the conversation between the court and Samuels was made and because defense counsel did not move to have the conversation reconstructed in any manner when he registered an untimely and pro forma objection thereto (cf., People v Anderson, 223 AD2d 547 ), the record is insufficient to afford meaningful appellate review of this issue (see, People v Jupiter, 210 AD2d 431 ; People v Neal, 205 AD2d 711 ). | 2 | 1996–1996 |
People v. Stith
green
2 sentences1992The inevitable discovery exception to the exclusionary rule requires the People to establish "a very high degree of probability that the evidence in question would have been obtained independently of the tainted source” (People v Payton, 45 NY2d 300, 313 , revd 445 US 573 , on remand 51 NY2d 169 ; People v Fitzpatrick, 32 NY2d 499, 506 , cert denied 414 US 1033 , 1050; People v Stith, 69 NY2d 313, 318 ; People v Knapp, 52 NY2d 689, 697-698 ; People v Ruffin, 133 AD2d 425, 429 ; People v Buffardi, 92 AD2d 899, 901 ). "[TJhe inevitable discovery exception is based on the perception that in certa 1992The inevitable discovery exception to the exclusionary rule requires the People to establish "a very high degree of probability that the evidence in question would have been obtained independently of the tainted source” (People v Payton, 45 NY2d 300, 313 , revd 445 US 573 , on remand 51 NY2d 169 ; People v Fitzpatrick, 32 NY2d 499, 506 , cert denied 414 US 1033 , 1050; People v Stith, 69 NY2d 313, 318 ; People v Knapp, 52 NY2d 689, 697-698 ; People v Ruffin, 133 AD2d 425, 429 ; People v Buffardi, 92 AD2d 899, 901 ). "[TJhe inevitable discovery exception is based on the perception that in certa | 2 | 1988–1992 |
People v. Ramirez
green
1 sentence2023Overall, the prosecutor's alleged improper comments during summation, to which the defendant contends defense counsel ought to have objected, but failed to do so, "were within the broad bounds of permissible rhetorical comment, a fair response to the defendant's summation, or fair comment on the evidence and the reasonable inferences to be drawn therefrom" ( People v Ramirez , 146 AD3d at 988 ; see People v Speak , 28 NY3d 990, 992 ; cf. People v Day , 178 AD3d 845 , 846). | 1 | 2023–2023 |
People v. James
green
1 sentence2022However, the defendant elected to proceed pro se after the Supreme Court engaged in a "searching inquiry" ( People v Stone , 22 NY3d 520, 525 [internal quotation marks omitted]) to clarify that he understood the ramifications of proceeding without counsel ( see People v Providence , 2 NY3d 579 ; People v James , 200 AD3d 711, 712 ). | 1 | 2022–2022 |
People v. Providence
green
1 sentence2022However, the defendant elected to proceed pro se after the Supreme Court engaged in a "searching inquiry" ( People v Stone , 22 NY3d 520, 525 [internal quotation marks omitted]) to clarify that he understood the ramifications of proceeding without counsel ( see People v Providence , 2 NY3d 579 ; People v James , 200 AD3d 711, 712 ). | 1 | 2022–2022 |
| People v. Dunbar green | 1 | 2020–2020 |
| People v. Jarvis neutral | 1 | 2020–2020 |
| People v. Hidalgo green | 1 | 2019–2019 |
| People v. Kemp green | 1 | 2019–2019 |
| People v. Johnson green | 1 | 2019–2019 |
| People v. Brown green | 1 | 2019–2019 |
| People v. Lococo green | 1 | 2019–2019 |
| People v. Anlyan green | 1 | 2019–2019 |
| People v. Bradshaw green | 1 | 2019–2019 |
| People v. Grant green | 1 | 2019–2019 |
| Deck v. Missouri green | 1 | 2016–2016 |
| People v. Morgan neutral | 1 | 2016–2016 |
| People v. Campbell green | 1 | 2016–2016 |
| People v. Ashline green | 1 | 2016–2016 |
| People v. Best green | 1 | 2016–2016 |
| People v. Goldston green | 1 | 2016–2016 |
| People v. Vann green | 1 | 2015–2015 |
| People v. Brown green | 1 | 2015–2015 |
| People v. Crump green | 1 | 2015–2015 |
| People v. Parker green | 1 | 2011–2011 |
| People v. Sorrells neutral | 1 | 2008–2008 |
| People v. Cruz green | 1 | 2007–2007 |
| People v. Espala neutral | 1 | 2007–2007 |
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.