long-held rule (California) · Go Syfert
← California issues

long-held rule in California

11 California opinions name it 2 courts 1981–2020 0 in the last five years

The cases below were cited by California 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 (10)

CaseFollowedCited
Theodor v. Superior Courtgreen
cal · 1972 · cited in 2 California opinions naming this issue, 1981–1985
2 sentences

1985Furthermore, “a long-held rule of statutory construction is that ‘it is not to be presumed that the legislature in the enactment of statutes intends to overthrow long-established principles of law unless such intention is made clearly to appear either by express declaration or by necessary implication.’” (People v. Edwards (1981) 117 Cal.App.3d 436 [ 172 Cal.Rptr. 652 ], affirmed in People v. Cardenas (1982) 31 Cal.3d 897 [ 184 Cal.Rptr. 165 , 647 P.2d 569 ], quoting County of Los Angeles v. Frisbie (1942) 19 Cal.2d 634, 644 [ 122 P.2d 526 ]; Theodor v. Superior Court (1972) 8 Cal.3d 77, 92 [

1985Furthermore, “a long-held rule of statutory construction is that ‘it is not to be presumed that the legislature in the enactment of statutes intends to overthrow long-established principles of law unless such intention is made clearly to appear either by express declaration or by necessary implication.’” (People v. Edwards (1981) 117 Cal.App.3d 436 [ 172 Cal.Rptr. 652 ], affirmed in People v. Cardenas (1982) 31 Cal.3d 897 [ 184 Cal.Rptr. 165 , 647 P.2d 569 ], quoting County of Los Angeles v. Frisbie (1942) 19 Cal.2d 634, 644 [ 122 P.2d 526 ]; Theodor v. Superior Court (1972) 8 Cal.3d 77, 92 [

22
County of Los Angeles v. Frisbiegreen
cal · 1942 · cited in 2 California opinions naming this issue, 1981–1985
2 sentences

1985Furthermore, “a long-held rule of statutory construction is that ‘it is not to be presumed that the legislature in the enactment of statutes intends to overthrow long-established principles of law unless such intention is made clearly to appear either by express declaration or by necessary implication.’” (People v. Edwards (1981) 117 Cal.App.3d 436 [ 172 Cal.Rptr. 652 ], affirmed in People v. Cardenas (1982) 31 Cal.3d 897 [ 184 Cal.Rptr. 165 , 647 P.2d 569 ], quoting County of Los Angeles v. Frisbie (1942) 19 Cal.2d 634, 644 [ 122 P.2d 526 ]; Theodor v. Superior Court (1972) 8 Cal.3d 77, 92 [

1985Furthermore, “a long-held rule of statutory construction is that ‘it is not to be presumed that the legislature in the enactment of statutes intends to overthrow long-established principles of law unless such intention is made clearly to appear either by express declaration or by necessary implication.’” (People v. Edwards (1981) 117 Cal.App.3d 436 [ 172 Cal.Rptr. 652 ], affirmed in People v. Cardenas (1982) 31 Cal.3d 897 [ 184 Cal.Rptr. 165 , 647 P.2d 569 ], quoting County of Los Angeles v. Frisbie (1942) 19 Cal.2d 634, 644 [ 122 P.2d 526 ]; Theodor v. Superior Court (1972) 8 Cal.3d 77, 92 [

22
Miller v. State of Californiagreen
cal · 1977 · cited in 1 California opinions naming this issue, 2020–2020
1 sentence

2020However, Alameda County did acknowledge the long-held rule that even where an employee’s vested pension rights are at stake, the “‘employee does not have a right to any fixed or definite benefits,’” and “‘the amount, terms, and conditions of the benefits may be altered.’” (Alameda County, supra, 9 Cal.5th at p. 1100, quoting Kern, supra, 29 Cal.2d at p. 855 ; see also Miller v. State of California (1977) 18 Cal.3d 808, 816 (Miller), quoting Kern, supra, 29 Cal.2d at pp. 854– 855 [“Although vested prior to the time when the obligation to pay matures, pension rights are not immutable. . . . [T]h

11
Kern v. City of Long Beachgreen
cal · 1947 · cited in 1 California opinions naming this issue, 2020–2020
2 sentences

2020However, Alameda County did acknowledge the long-held rule that even where an employee’s vested pension rights are at stake, the “‘employee does not have a right to any fixed or definite benefits,’” and “‘the amount, terms, and conditions of the benefits may be altered.’” (Alameda County, supra, 9 Cal.5th at p. 1100, quoting Kern, supra, 29 Cal.2d at p. 855 ; see also Miller v. State of California (1977) 18 Cal.3d 808, 816 (Miller), quoting Kern, supra, 29 Cal.2d at pp. 854– 855 [“Although vested prior to the time when the obligation to pay matures, pension rights are not immutable. . . . [T]h

2020However, Alameda County did acknowledge the long-held rule that even where an employee’s vested pension rights are at stake, the “‘employee does not have a right to any fixed or definite benefits,’” and “‘the amount, terms, and conditions of the benefits may be altered.’” (Alameda County, supra, 9 Cal.5th at p. 1100, quoting Kern, supra, 29 Cal.2d at p. 855 ; see also Miller v. State of California (1977) 18 Cal.3d 808, 816 (Miller), quoting Kern, supra, 29 Cal.2d at pp. 854– 855 [“Although vested prior to the time when the obligation to pay matures, pension rights are not immutable. . . . [T]h

11
Mattco Forge, Inc. v. Arthur Young & Co.green
calctapp · 1997 · cited in 1 California opinions naming this issue, 2007–2007
2 sentences

2007(Mattco Forge, Inc. v. Arthur Young & Co. (1997) 52 Cal.App.4th 820, 847 [ 60 Cal.Rptr.2d 780 ].) Although there is a recognized exception to this rule for pure questions of law on uncontroverted records that require no factual determinations (ibid.), it is manifest that this issue does not qualify.

2007(Mattco Forge, Inc. v. Arthur Young & Co. (1997) 52 Cal.App.4th 820, 847 [ 60 Cal.Rptr.2d 780 ].) Although there is a recognized exception to this rule for pure questions of law on uncontroverted records that require no factual determinations (ibid.), it is manifest that this issue does not qualify.

11
Bardis v. Oatesgreen
calctapp · 2004 · cited in 1 California opinions naming this issue, 2007–2007
2 sentences

2007(Bardis v. Oates (2004) 119 Cal.App.4th 1, 13 [ 14 Cal.Rptr.3d 89 ].) This long-held rule is based upon fairness, more specifically the recognition that it would be unfair to both the opposing litigant and the trial court to allow a party to adopt a new theory not explored below.

2007(Bardis v. Oates (2004) 119 Cal.App.4th 1, 13 [ 14 Cal.Rptr.3d 89 ].) This long-held rule is based upon fairness, more specifically the recognition that it would be unfair to both the opposing litigant and the trial court to allow a party to adopt a new theory not explored below.

11
People v. Hernandezgreen
calctapp · 1979 · cited in 1 California opinions naming this issue, 1988–1988
2 sentences

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

11
People v. Watsongreen
cal · 1956 · cited in 1 California opinions naming this issue, 1988–1988
2 sentences

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

11
People v. Winthropgreen
· 1897 · cited in 1 California opinions naming this issue, 1988–1988
2 sentences

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

11
People v. Estorgagreen
cal · 1928 · cited in 1 California opinions naming this issue, 1988–1988
2 sentences

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

CaseCitedYears
Monge v. California green
scotus · 1998
2 sentences

2000Indeed, were we to apply double jeopardy here, we might create disincentives that would diminish these important procedural protections.” (Id. at p. 734 [ 118 S.Ct. at p. 2253 ].) Justice Stevens noted in his dissent in Monge II, supra, 524 U.S. 721 , that this case was the first in which the court had departed from the long-held rule that a retrial or resentencing is not permitted when the evidence at the first proceeding is insufficient as compared to there being legal error which infects the first proceeding.

2000Indeed, were we to apply double jeopardy here, we might create disincentives that would diminish these important procedural protections.” (Id. at p. 734 [ 118 S.Ct. at p. 2253 ].) Justice Stevens noted in his dissent in Monge II, supra, 524 U.S. 721 , that this case was the first in which the court had departed from the long-held rule that a retrial or resentencing is not permitted when the evidence at the first proceeding is insufficient as compared to there being legal error which infects the first proceeding.

22000–2000
People v. Hernandez green
cal · 1998
2 sentences

2000Indeed, were we to apply double jeopardy here, we might create disincentives that would diminish these important procedural protections." ( Id. at p. 734, 118 S.Ct. 2246 .) Justice Stevens noted in his dissent in Monge II, supra, 524 U.S. 721 , 118 S.Ct. 2246 , 141 L.Ed.2d 615 , that this case was the first in which the court had departed from the long-held rule that a retrial or resentencing is not permitted when the evidence at the first proceeding is insufficient as compared to there being legal error which infects the first proceeding. ( Id. at pp. 735-737, 118 S.Ct. 2246 , dis. opn. of St

2000Indeed, were we to apply double jeopardy here, we might create disincentives that would diminish these important procedural protections." ( Id. at p. 734, 118 S.Ct. 2246 .) Justice Stevens noted in his dissent in Monge II, supra, 524 U.S. 721 , 118 S.Ct. 2246 , 141 L.Ed.2d 615 , that this case was the first in which the court had departed from the long-held rule that a retrial or resentencing is not permitted when the evidence at the first proceeding is insufficient as compared to there being legal error which infects the first proceeding. ( Id. at pp. 735-737, 118 S.Ct. 2246 , dis. opn. of St

22000–2000
People v. Edwards green
calctapp · 1981
2 sentences

1985Furthermore, “a long-held rule of statutory construction is that ‘it is not to be presumed that the legislature in the enactment of statutes intends to overthrow long-established principles of law unless such intention is made clearly to appear either by express declaration or by necessary implication.’” (People v. Edwards (1981) 117 Cal.App.3d 436 [ 172 Cal.Rptr. 652 ], affirmed in People v. Cardenas (1982) 31 Cal.3d 897 [ 184 Cal.Rptr. 165 , 647 P.2d 569 ], quoting County of Los Angeles v. Frisbie (1942) 19 Cal.2d 634, 644 [ 122 P.2d 526 ]; Theodor v. Superior Court (1972) 8 Cal.3d 77, 92 [

1985Furthermore, “a long-held rule of statutory construction is that ‘it is not to be presumed that the legislature in the enactment of statutes intends to overthrow long-established principles of law unless such intention is made clearly to appear either by express declaration or by necessary implication.’” (People v. Edwards (1981) 117 Cal.App.3d 436 [ 172 Cal.Rptr. 652 ], affirmed in People v. Cardenas (1982) 31 Cal.3d 897 [ 184 Cal.Rptr. 165 , 647 P.2d 569 ], quoting County of Los Angeles v. Frisbie (1942) 19 Cal.2d 634, 644 [ 122 P.2d 526 ]; Theodor v. Superior Court (1972) 8 Cal.3d 77, 92 [

21984–1985
People v. Cardenas green
cal · 1982
2 sentences

1985Furthermore, “a long-held rule of statutory construction is that ‘it is not to be presumed that the legislature in the enactment of statutes intends to overthrow long-established principles of law unless such intention is made clearly to appear either by express declaration or by necessary implication.’” (People v. Edwards (1981) 117 Cal.App.3d 436 [ 172 Cal.Rptr. 652 ], affirmed in People v. Cardenas (1982) 31 Cal.3d 897 [ 184 Cal.Rptr. 165 , 647 P.2d 569 ], quoting County of Los Angeles v. Frisbie (1942) 19 Cal.2d 634, 644 [ 122 P.2d 526 ]; Theodor v. Superior Court (1972) 8 Cal.3d 77, 92 [

1985Furthermore, “a long-held rule of statutory construction is that ‘it is not to be presumed that the legislature in the enactment of statutes intends to overthrow long-established principles of law unless such intention is made clearly to appear either by express declaration or by necessary implication.’” (People v. Edwards (1981) 117 Cal.App.3d 436 [ 172 Cal.Rptr. 652 ], affirmed in People v. Cardenas (1982) 31 Cal.3d 897 [ 184 Cal.Rptr. 165 , 647 P.2d 569 ], quoting County of Los Angeles v. Frisbie (1942) 19 Cal.2d 634, 644 [ 122 P.2d 526 ]; Theodor v. Superior Court (1972) 8 Cal.3d 77, 92 [

21984–1985
Riley v. Fitzgerald green
calctapp · 1986
1 sentence

2013(Riley, supra, at pp. 875-877 .) Addressing that latter question, the court first cited case law from both California and Texas standing for the proposition that “the effect of corporate dissolution or expiration depends upon the law of [the corporation’s] domicile.” (Riley, supra, 178 Cal.App.3d at p. 876 .) 8 The court found that “[n]othing in the California Corporations Code indicates that this long-held principle has been overruled or superseded by statute.” (Riley, at p. 876.) In reaching its conclusion the court relied substantially on section 2115, located in chapter 21 (foreign corpora

12013–2013
Committee on Children's Television, Inc. v. General Foods Corp. red
cal · 1983
1 sentence

2013"The pleading of fraud . . . is . . . the last remaining habitat of the common law notion that a complaint should be sufficiently specific that the court can weed out nonmeritorious actions on the basis of the pleadings." (Committee On Children's Television, supra, 35 Cal.3d at pp. 216–217.) Under these circumstances, we will not dispense with the long-held principle of law in California requiring heightened pleading for fraud.

12013–2013
Small v. Fritz Companies, Inc. green
cal · 2003
1 sentence

2013And, as these pleading requirements have been at least impliedly applied to the tort of negligent misrepresentation (see Small v. Fritz Companies, Inc. (2003) 30 Cal.4th 167, 184 ), we conclude the deficient pleading defeats plaintiffs' cause of action for negligent misrepresentation.

12013–2013
Almendarez-Torres v. United States red
scotus · 1998
2 sentences

2000Indeed, were we to apply double jeopardy here, we might create disincentives that would diminish these important procedural protections." ( Id. at p. 734, 118 S.Ct. 2246 .) Justice Stevens noted in his dissent in Monge II, supra, 524 U.S. 721 , 118 S.Ct. 2246 , 141 L.Ed.2d 615 , that this case was the first in which the court had departed from the long-held rule that a retrial or resentencing is not permitted when the evidence at the first proceeding is insufficient as compared to there being legal error which infects the first proceeding. ( Id. at pp. 735-737, 118 S.Ct. 2246 , dis. opn. of St

2000Indeed, were we to apply double jeopardy here, we might create disincentives that would diminish these important procedural protections." ( Id. at p. 734, 118 S.Ct. 2246 .) Justice Stevens noted in his dissent in Monge II, supra, 524 U.S. 721 , 118 S.Ct. 2246 , 141 L.Ed.2d 615 , that this case was the first in which the court had departed from the long-held rule that a retrial or resentencing is not permitted when the evidence at the first proceeding is insufficient as compared to there being legal error which infects the first proceeding. ( Id. at pp. 735-737, 118 S.Ct. 2246 , dis. opn. of St

12000–2000
People v. Monge green
cal · 1997
2 sentences

2000Beyond Monge I and II, and Hernandez In remanding the case in Monge I, supra, 16 Cal.4th 826 , 66 Cal.Rptr.2d 853 , 941 P.2d 1121 , the court concluded only that retrial was not barred by double jeopardy, specifically leaving open for determination the question of whether other constitutional or statutory grounds prevented retrial. ( Id. at p. 845, 66 Cal.Rptr.2d 853 , 941 P.2d 1121 .) The court in Monge I noted its conclusion raised "numerous secondary issues": "For example, the Court of Appeal's determination that the evidence was insufficient to prove defendant's prior conviction was of a s

2000Beyond Monge I and II, and Hernandez In remanding the case in Monge I, supra, 16 Cal.4th 826 , 66 Cal.Rptr.2d 853 , 941 P.2d 1121 , the court concluded only that retrial was not barred by double jeopardy, specifically leaving open for determination the question of whether other constitutional or statutory grounds prevented retrial. ( Id. at p. 845, 66 Cal.Rptr.2d 853 , 941 P.2d 1121 .) The court in Monge I noted its conclusion raised "numerous secondary issues": "For example, the Court of Appeal's determination that the evidence was insufficient to prove defendant's prior conviction was of a s

12000–2000
People v. Shirley green
cal · 1982
2 sentences

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

1988(People v. Winthrop (1897) 118 Cal. 85, 88 [ 50 P. 390 ]; People v. Estorga (1928) 206 Cal. 81, 85-87 [ 273 P. 575 ]; People v. Hernandez (1979) 94 Cal.App.3d 715, 719 [ 156 Cal.Rptr. 572 ].) 4 In People v. Shirley (1982) 31 Cal.3d 18 [ 181 Cal.Rptr. 243 , 641 P.2d 775 ], this court ruled inadmissible the testimony of any nondefendant witness who has been hypnotized for the purpose of restoring his or her memory of the events in issue, and that the prejudicial effect of erroneous admission of such testimony is to be judged under the “reasonable probability” test of People v. Watson (1956) 46 C

11988–1988
Ferguson-McKinney Dry Goods Co. v. Garrett green
texcommnapp · 1923
1 sentence

1986App. 1978) 570 S.W.2d 70, 72 , citing Ferguson-McKinney Dry Goods Co. v. Garrett (Tex.Com.App. 1923) 252 S.W. 738 .) Nothing in the California Corporations Code indicates that this long-held principle has been overruled or superseded by statute.

11986–1986
Country Cupboard, Inc. v. Texstar Corp. green
texapp · 1978
1 sentence

1986App. 1978) 570 S.W.2d 70, 72 , citing Ferguson-McKinney Dry Goods Co. v. Garrett (Tex.Com.App. 1923) 252 S.W. 738 .) Nothing in the California Corporations Code indicates that this long-held principle has been overruled or superseded by statute.

11986–1986

Where else courts name it

MI 17 (1981–2022) TX 12 (2000–2015) IL 11 (1993–2025) CA 11 (1981–2020) PA 10 (1984–2021) MD 10 (2000–2025) OH 7 (2002–2023) WA 7 (1968–2004) NC 6 (1988–2023) TN 6 (2010–2025) NY 5 (1988–2025) VA 4 (1994–1998) WI 4 (1988–2016) MS 4 (2008–2017) GA 4 (2006–2020) MO 4 (1983–2020) MN 4 (1985–2014) AL 3 (1987–2011) MT 3 (1988–2026) KS 3 (1974–2013) AR 3 (2003–2020) DC 3 (2011–2012) KY 3 (2021–2026) RI 3 (2006–2011) IN 2 (1993–2009) NJ 2 (1987–2025) UT 2 (2012–2022) FL 2 (2015–2020)

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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