discussion waiver (New York) · Go Syfert
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discussion waiver in New York

81 New York opinions name it 16 courts 1891–2026 21 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.

Followed or applied (33)

CaseFollowedCited
People v. Bryantgreen
ny · 2016 · cited in 4 New York opinions naming this issue, 2025–2025
2 sentences

2025Thus, it cannot be said that the defendant "received no material benefit from his appeal waiver," or that the appeal waiver "was a gratuitous, after-the-fact additional demand asserted after the bargain had already been struck" ( People v Sutton, 184 AD3d 236, 245 ; see People v Bryant , 28 NY3d 1094, 1095-1096 ; People v Williams , 227 AD3d 480 , 481).

2025Thus, it cannot be said that the defendant "received no material benefit from his appeal waiver," or that the appeal waiver "was a gratuitous, after-the-fact additional demand asserted after the bargain had already been struck" ( People v Sutton, 184 AD3d 236, 245 ; see People v Bryant , 28 NY3d 1094, 1095-1096 ; People v Williams , 227 AD3d 480 , 481).

44
Leon v. Martinezgreen
ny · 1994 · cited in 3 New York opinions naming this issue, 2011–2025
2 sentences

2024DISCUSSION On motion to dismiss brought under CPLR § 3211 (a) (7), “the pleading is to be afforded a liberal construction” (Leon v Martinez, 84 NY2d 83, 87 [1994]).

2011(CPLR 3211 [c], [e]; Rovello v Orofino Realty Co., 40 NY2d 633 [1976].) When the plaintiff offers such proof in response to a motion to dismiss, the standard “is whether the proponent of the pleading has a cause of action, not whether he has stated one.” {Leon v Martinez, 84 NY2d 83, 88 [1994].) Discussion The defendants contend that federal law preempts the causes of action alleged in the present class action complaint, because defendant U.S. Bank is federally regulated under the National Bank Act and any liability by defendant Simon Property Group is contingent upon U.S. Bank’s liability.

33
Radloff v. Adlergreen
nyappdiv · 1994 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013Plaintiffs related claim — that Supreme Court erred in failing to marshal the evidence — is unpreserved for our review (see Radloff v Adler, 205 AD2d 973, 974 [1994], lv dismissed and denied 84 NY2d 988 [1994]) and, in any event, is lacking in merit given that this was a relatively simple trial of short duration.

2013Plaintiffs related claim — that Supreme Court erred in failing to marshal the evidence — is unpreserved for our review (see Radloff v Adler, 205 AD2d 973, 974 [1994], lv dismissed and denied 84 NY2d 988 [1994]) and, in any event, is lacking in merit given that this was a relatively simple trial of short duration.

22
Pell v. Board of Educationgreen
ny · 1974 · cited in 2 New York opinions naming this issue, 1997–2024
2 sentences

2024DISCUSSION The standard for judicial review of an administrative determination pursuant to CPLR Article 78 is limited to determining whether the agency acted arbitrarily or capriciously, i.e., without any sound basis in reason or regard to the facts (See Matter of Pell v Board of Educ., 34 NY2d 222 , 231-232 [1974]).

1997The " 'judicial function is exhausted when there is found to be a rational basis for the conclusions approved by the administrative body.’ ” (Ostrer v Schenck, 41 NY2d 782 , 786 [1977]; see also, Pell v Board of Educ., 34 NY2d 222 , 231 [1974].) The Court of Appeals has ruled that section 1127 is not a tax, but an enforceable term and condition of employment with the City acting in its capacity as an employer, stating that it "is clear beyond cavil that the payments due to the City of New York are owed as a result of the contract entered into by the petitioner with the city and not as a result

12
In Re the Estate of Findlaygreen
ny · 1930 · cited in 2 New York opinions naming this issue, 1994–2012
2 sentences

2012Discussion The presumption that a child born during marriage is the biological product of the marriage has been described as “one of the strongest and most persuasive known to the law” (Matter of Findlay, 253 NY 1, 7 [1930]).

1994DISCUSSION The presumption of legitimacy has been termed one of the strongest and most persuasive known to law (Matter of Findlay, 253 NY 1 [1930]).

12
Vega v. Restani Construction Corp.green
ny · 2012 · cited in 1 New York opinions naming this issue, 2026–2026
1 sentence

2026"Summary judgment is a drastic remedy, to be granted only where the moving party has tendered sufficient evidence to demonstrate the absence of any material issues of fact." (Vega v Restani Const. Corp., 18 NY3d 499, 503 [2012]).

11
JP Morgan Chase Bank, N.A. v. Whitegreen
nyappdiv · 2020 · cited in 1 New York opinions naming this issue, 2025–2025
1 sentence

2025Although appellant did not move to intervene, it had standing to oppose the foreclosure action as an "interested party" because it took title to the property pursuant to a referee's deed in connection with the Boatyard Condominium's lien foreclosure ( see MTGLQ Invs. , L.P. v Shay , 190 AD3d 527 , 528 [1st Dept 2021], lv denied 37 NY3d 908 [2021]; JP Morgan Chase Bank, N.A. v White , 182 AD3d 469, 470 [1st Dept 2020]).

11
MATTER OF BARNES v. LeFevregreen
ny · 1986 · cited in 1 New York opinions naming this issue, 2023–2023
1 sentence

2023Although there was a discussion at the hearing that the alleged victim would have to agree to testify, there is no indication that the alleged victim refused to testify or that the Hearing Officer made any effort to procure him as a witness. "[W]here the record does not reflect any reason for the witness' refusal to testify, or that any inquiry was made of him [or her] as to why he [or she] refused or that the [H]earing [O]fficer communicated with the witness to verify his [or her] refusal to testify, there has been a denial of the [incarcerated individual's] right to call witnesses as provide

11
The Matter of George Texeira v. Brian Fischergreen
ny · 2015 · cited in 1 New York opinions naming this issue, 2023–2023
1 sentence

2023As we view the unexplained outright denial of a witness commensurate to the denial of petitioner's constitutional right to call witnesses, expungement rather than remittal for a new hearing is the appropriate remedy ( see Matter of Texeira v Fischer , 26 NY3d 230, 234 [2016]; Matter of Doleman v Prack , 145 AD3d 1289, 1290-1291 [3d Dept 2016]).

11
Matter of Young v. Annuccigreen
nyappdiv · 2016 · cited in 1 New York opinions naming this issue, 2023–2023
1 sentence

2023As we view the unexplained outright denial of a witness commensurate to the denial of petitioner's constitutional right to call witnesses, expungement rather than remittal for a new hearing is the appropriate remedy ( see Matter of Texeira v Fischer , 26 NY3d 230, 234 [2016]; Matter of Doleman v Prack , 145 AD3d 1289, 1290-1291 [3d Dept 2016]).

11
People v. Kappgreen
nyappdiv · 2009 · cited in 1 New York opinions naming this issue, 2018–2018
11
People v. Turckgreen
nyappdiv · 2003 · cited in 1 New York opinions naming this issue, 2018–2018
1 sentence

2018Moreover, defendant failed to demonstrate the absence of a strategic or other legitimate explanation for defense counsel's discussion of the waiver inasmuch as the record establishes that the prosecutor had already prepared a written waiver prior to the proceeding and that defendant benefitted from the waiver [*2]insofar as it secured the court's sentencing commitment to a range far lower than the maximum sentence ( see People v Turck , 305 AD2d 1072, 1073 [4th Dept 2003], lv denied 100 NY2d 566 [2003]).

11
People v. Ariasgreen
nyappdiv · 2009 · cited in 1 New York opinions naming this issue, 2015–2015
11
National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc.green
nyappdiv · 2010 · cited in 1 New York opinions naming this issue, 2015–2015
11
People v. Hollmangreen
nyappdiv · 2012 · cited in 1 New York opinions naming this issue, 2015–2015
11
People v. Brummelgreen
nyappdiv · 2013 · cited in 1 New York opinions naming this issue, 2015–2015
11
People v. Hawkinsgreen
ny · 2008 · cited in 1 New York opinions naming this issue, 2015–2015
11
McAteer v. McAteergreen
nyappdiv · 2002 · cited in 1 New York opinions naming this issue, 2015–2015
11
People v. Alejandrogreen
ny · 1987 · cited in 1 New York opinions naming this issue, 2015–2015
11
Barbara S. v. Michael I.green
nyappdiv · 2005 · cited in 1 New York opinions naming this issue, 2012–2012
11
Fung v. Funggreen
nyappdiv · 1997 · cited in 1 New York opinions naming this issue, 2012–2012
11
Thomson-Csf, S.A. v. American Arbitration Association, Evans & Sutherland Computer Corporationgreen
ca2 · 1995 · cited in 1 New York opinions naming this issue, 2010–2010
11
Pennsylvania v. Finleygreen
scotus · 1987 · cited in 1 New York opinions naming this issue, 2010–2010
11
Denney v. BDO Seidman, L.L.P.green
ca2 · 2005 · cited in 1 New York opinions naming this issue, 2010–2010
11
Anderson v. Eli Lilly & Co.green
ny · 1991 · cited in 1 New York opinions naming this issue, 2010–2010
11
In re the Claim of Jonesgreen
nyappdiv · 2001 · cited in 1 New York opinions naming this issue, 2008–2008
11
State v. Insurance Co. of Pennsylvaniagreen
nyappdiv · 2003 · cited in 1 New York opinions naming this issue, 2007–2007
11
Legum v. Goldingreen
ny · 1982 · cited in 1 New York opinions naming this issue, 1997–1997
11
Anonymous v. Anonymousgreen
nyappdiv · 1956 · cited in 1 New York opinions naming this issue, 1994–1994
11
People v. Federated Radio Corporationgreen
ny · 1926 · cited in 1 New York opinions naming this issue, 1992–1992
11
People v. Essnergreen
nysupct · 1984 · cited in 1 New York opinions naming this issue, 1992–1992
11
State v. Rachmani Corp.green
ny · 1988 · cited in 1 New York opinions naming this issue, 1992–1992
11
John M. Thompson & Co. v. New Madison Square Garden Corp.green
nyappdiv · 1929 · cited in 1 New York opinions naming this issue, 1962–1962
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (47)

CaseCitedYears
People v. Sutton green
nyappdiv · 2020
2 sentences

2026Thus, it cannot be said that the defendant "received no material benefit from his appeal waiver," or that the appeal waiver "was a gratuitous, after-the-fact additional demand asserted after the bargain had already been struck" ( People v Sutton , 184 AD3d 236, 245 ; see People v Sobers , 235 AD3d 908 , 909; People v Victor , 235 AD3d 783 , 784; People v White , 234 AD3d 884 , 885).

2025Thus, it cannot be said that the defendant "received no material benefit from his appeal waiver," or that the appeal waiver "was a gratuitous, after-the-fact additional demand asserted after the bargain had already been struck" ( People v Sutton, 184 AD3d 236, 245 ; see People v Bryant , 28 NY3d 1094, 1095-1096 ; People v Williams , 227 AD3d 480 , 481).

62025–2026
Gilman v. New York State Division of Housing & Community Renewal green
ny · 2002
2 sentences

2026The Court must determine whether there is a rational basis for the administrative determination or whether it is arbitrary and capricious (Matter of Gilman v New York State Div. of Housing and Community Renewal, 99 NY2d 144 [2002]).

2025The Court must determine whether there is a rational basis for the agency determination or whether the determination is arbitrary and capricious (Matter of Gilman v New York State Div. of Housing and Community Renewal, 99 NY2d 144 [2002]).

22025–2026
People v. Bradshaw green
ny · 2011
2 sentences

2026Under the totality of the circumstances, including the exemplary explanation of the right to appeal provided to the defendant and the defendant's age, experience, and background, the appeal waiver was knowing, voluntary, and intelligent ( see People v Sanders , 25 NY3d 337, 340 ; People v Bradshaw , 18 NY3d 257, 264 ; People v Walcott , 238 AD3d 1177 ; People v Victor , 235 AD3d at 784; People v White , 234 AD3d at 885).

2025Under the totality of the circumstances, including the exemplary explanation of the right to appeal provided to the defendant and the defendant's age, experience, and background, the appeal waiver was knowing, voluntary, and intelligent ( see People v Sanders , 25 NY3d 337, 340 ; People v Bradshaw , 18 NY3d 257, 264 ; People v Victor , _____ AD3d _____, 2025 NY Slip Op 00887 ; People v White , 234 AD3d 884 ).

22025–2026
The People v. Rasaun Sanders green
ny · 2015
2 sentences

2026Under the totality of the circumstances, including the exemplary explanation of the right to appeal provided to the defendant and the defendant's age, experience, and background, the appeal waiver was knowing, voluntary, and intelligent ( see People v Sanders , 25 NY3d 337, 340 ; People v Bradshaw , 18 NY3d 257, 264 ; People v Walcott , 238 AD3d 1177 ; People v Victor , 235 AD3d at 784; People v White , 234 AD3d at 885).

2025Under the totality of the circumstances, including the exemplary explanation of the right to appeal provided to the defendant and the defendant's age, experience, and background, the appeal waiver was knowing, voluntary, and intelligent ( see People v Sanders , 25 NY3d 337, 340 ; People v Bradshaw , 18 NY3d 257, 264 ; People v Victor , _____ AD3d _____, 2025 NY Slip Op 00887 ; People v White , 234 AD3d 884 ).

22025–2026
People v. Victor neutral
nyappdiv · 2025
2 sentences

2025Although much of the discussion of the waiver of the right to appeal took place after the defendant had admitted his guilt, the Supreme Court advised the defendant prior to the defendant's plea of guilty and admission of guilt that the appeal waiver was part of the bargained-for benefit he received with his plea ( see People v Thomas , 34 NY3d 545 , 558; People v Victor , _____ AD3d _____, 2025 NY Slip Op 00887 ; People v White , _____ AD3d _____, 2025 NY Slip Op 00341 ).

2025Although much of the discussion of the waiver of the right to appeal took place after the defendant had admitted his guilt, the appeal waiver was mentioned as being a condition of the plea bargain prior to the defendant's pleas of guilty and admissions of guilt ( see People v Victor , _____ AD3d _____, 2025 NY Slip Op 00887 ; People v White , 234 AD3d 884 ).

22025–2025
Phillips v. Joseph Kantor & Co. green
ny · 1972
2 sentences

2024Summary judgment cannot be granted unless it clearly appears that no genuine triable issues of fact exist (see Phillips v Kantor & Co., 31 NY2d 307 [1972]).

2024Summary judgment cannot be granted unless it clearly appears that no genuine triable issues of fact exist (see Phillips v Kantor & Co., 31 NY2d 307 [1972]).

22024–2024
Wilkerson v. Buonomo & Thaler green
ny · 1994
2 sentences

2013Plaintiffs related claim — that Supreme Court erred in failing to marshal the evidence — is unpreserved for our review (see Radloff v Adler, 205 AD2d 973, 974 [1994], lv dismissed and denied 84 NY2d 988 [1994]) and, in any event, is lacking in merit given that this was a relatively simple trial of short duration.

2013Plaintiffs related claim — that Supreme Court erred in failing to marshal the evidence — is unpreserved for our review (see Radloff v Adler, 205 AD2d 973, 974 [1994], lv dismissed and denied 84 NY2d 988 [1994]) and, in any event, is lacking in merit given that this was a relatively simple trial of short duration.

22013–2013
Gerka v. Fidelity & Casualty Co. green
ny · 1929
2 sentences

2013Further, the Schiff Court cited to Gerka ( 251 NY at 51 ), in which, again, the insurer controlled the defense through trial.

2013Further, the Schiff Court cited to Gerka ( 251 NY at 51 ), in which, again, the insurer controlled the defense through trial.

22013–2013
Buchanan v. Kentucky green
scotus · 1987
2 sentences

2004In discussing the Fifth Amendment issue, the Court stated (at 684): “Language contained in Smith and in our later decision in Buchanan v Kentucky, 483 U. S. 402 (1987), provides some support for the Fifth Circuit’s discussion of waiver.

2004In [*6]discussing the Fifth Amendment issue, the Court stated (at 684): "Language contained in Smith and in our later decision in Buchanan v Kentucky , 483 U. S. 402 (1987), provides some support for the Fifth Circuit's discussion of waiver.

22004–2004
Estelle v. Smith green
scotus · 1981
2 sentences

2004In Smith we observed that [w]hen a defendant asserts the insanity defense and introduces supporting psychiatric testimony, his silence may deprive the State of the only effective means it has of controverting his proof on an issue that he has interjected into the case.’ 451 U. S., at 465 .

2004In Smith we observed that '[w]hen a defendant asserts the insanity defense and introduces supporting psychiatric testimony , his silence may deprive the State of the only effective means it has of controverting his proof on an issue that he has interjected into the case.' 451 U. S., at 465 .

22004–2004
Village of Euclid v. Ambler Realty Co. green
scotus · 1926
2 sentences

1997With the police power as the predicate for the State’s delegation of municipal zoning authority, a zoning ordinance will be struck down if it bears no substantial relation to the police power objective of promoting the public health, safety, morals or general welfare (Berenson v Town of New Castle, 38 NY2d 102,107 , quoting Village of Euclid v Ambler Realty Co., 272 US 365, 395 ; Cornell Univ. v Bagnardi, 68 NY2d 583 , supra).

1997With the police power as the predicate for the State's delegation of municipal zoning authority, a zoning ordinance will be struck down if it bears no substantial relation to the police power objective of promoting the public health, safety, morals or general welfare ( Berenson v Town of New Castle , 38 N.Y.2d 102, 107 , quoting Village of Euclid v Ambler Realty Co. , 272 US 365, 395 ; Cornell Univ. v Bagnardi , 68 N.Y.2d 583 , supra ).

21997–1997
Berenson v. Town of New Castle green
ny · 1975
2 sentences

1997With the police power as the predicate for the State’s delegation of municipal zoning authority, a zoning ordinance will be struck down if it bears no substantial relation to the police power objective of promoting the public health, safety, morals or general welfare (Berenson v Town of New Castle, 38 NY2d 102,107 , quoting Village of Euclid v Ambler Realty Co., 272 US 365, 395 ; Cornell Univ. v Bagnardi, 68 NY2d 583 , supra).

1997With the police power as the predicate for the State's delegation of municipal zoning authority, a zoning ordinance will be struck down if it bears no substantial relation to the police power objective of promoting the public health, safety, morals or general welfare ( Berenson v Town of New Castle , 38 N.Y.2d 102, 107 , quoting Village of Euclid v Ambler Realty Co. , 272 US 365, 395 ; Cornell Univ. v Bagnardi , 68 N.Y.2d 583 , supra ).

21997–1997
Cornell University v. Bagnardi green
ny · 1986
2 sentences

1997With the police power as the predicate for the State’s delegation of municipal zoning authority, a zoning ordinance will be struck down if it bears no substantial relation to the police power objective of promoting the public health, safety, morals or general welfare (Berenson v Town of New Castle, 38 NY2d 102,107 , quoting Village of Euclid v Ambler Realty Co., 272 US 365, 395 ; Cornell Univ. v Bagnardi, 68 NY2d 583 , supra).

1997With the police power as the predicate for the State's delegation of municipal zoning authority, a zoning ordinance will be struck down if it bears no substantial relation to the police power objective of promoting the public health, safety, morals or general welfare ( Berenson v Town of New Castle , 38 N.Y.2d 102, 107 , quoting Village of Euclid v Ambler Realty Co. , 272 US 365, 395 ; Cornell Univ. v Bagnardi , 68 N.Y.2d 583 , supra ).

21997–1997
Simons v. Northern Pacific Railway Co. green
mont · 1933
2 sentences

1981Co. ( 94 Mont. 355 ).

1963Co. ( 94 Mont. 355 ).

21963–1981
Majewski v. Broadalbin-Perth Central School District green
ny · 1998
1 sentence

2026Article 245 as it existed prior to the legislative changes which took effect on August 7, 2025, citing Majewski v Broadalbin-Perth Cent School Dist., 91 NY2d 577 [1998], among [*3]others.

12026–2026
People v. White neutral
nyappdiv · 2025
1 sentence

2025Although much of the discussion of the waiver of the right to appeal took place after the defendant had admitted his guilt, the Supreme Court advised the defendant prior to the defendant's plea of guilty and admission of guilt that the appeal waiver was part of the bargained-for benefit he received with his plea ( see People v Thomas , 34 NY3d 545 , 558; People v Victor , _____ AD3d _____, 2025 NY Slip Op 00887 ; People v White , _____ AD3d _____, 2025 NY Slip Op 00341 ).

12025–2025
Guzman v. Safir green
nyappdiv · 2002
1 sentence

2024An agency's decision must be upheld where there is any rational basis in the record before the agency to support the disputed determination (See Matter of Guzman v Safir, 293 AD2d 281 [1st Dept 2002]).

12024–2024
Mangione v. Jacobs green
nysupct · 2012
1 sentence

2023While the defendants acknowledge that "[s]poliation of evidence for failure to preserve the pre-surgical medical condition of a plaintiff in personal injury litigation is a newly emerging area of law," the defendants cite three cases where courts have concluded that spoliation sanctions may be imposed in such circumstances: Martinez v Nelson ( 64 Misc 3d 225 [Sup Ct, Bronx County 2019]), Mangione v Jacobs ( 37 Misc 3d 711 [Sup Ct, Queens County 2012], affd on other grounds 121 AD3d 953 [2d Dept 2014]), and Hoyeun Kang v Perri ( 2021 WL 5507987 , 2021 US Dist LEXIS 162769 [ED NY, Aug. 25, 2021,

12023–2023
Maharaj v. LaRoche green
nyappdiv · 2014
1 sentence

2023While the defendants acknowledge that "[s]poliation of evidence for failure to preserve the pre-surgical medical condition of a plaintiff in personal injury litigation is a newly emerging area of law," the defendants cite three cases where courts have concluded that spoliation sanctions may be imposed in such circumstances: Martinez v Nelson ( 64 Misc 3d 225 [Sup Ct, Bronx County 2019]), Mangione v Jacobs ( 37 Misc 3d 711 [Sup Ct, Queens County 2012], affd on other grounds 121 AD3d 953 [2d Dept 2014]), and Hoyeun Kang v Perri ( 2021 WL 5507987 , 2021 US Dist LEXIS 162769 [ED NY, Aug. 25, 2021,

12023–2023
People v. Kelley green
ny · 2009
12018–2018
People v. Tulip green
nyappdiv · 2017
12017–2017
People v. DeLuna green
nyappdiv · 2012
12015–2015
People v. Dumay green
ny · 2014
12015–2015
Arrocha v. Board of Education green
ny · 1999
12014–2014
People v. Sanford neutral
nysupct · 2004
12013–2013
Walker v. Covington green
nyappdiv · 2001
12012–2012
Rovello v. Orofino Realty Co. green
ny · 1976
12011–2011
Minnesota v. Murphy green
scotus · 1984
12009–2009
Hartog v. Hartog green
ny · 1995
12008–2008
Parker v. Executive Department, Board of Parole green
nyappdiv · 2000
12008–2008
People v. Baldi green
ny · 1981
12004–2004
Winnie v. Winnie green
nyappdiv · 1996
12002–2002
Messemer v. Messemer green
nyappdiv · 2000
12002–2002
People v. Wesley green
ny · 1994
12000–2000
Maddox v. City of New York green
ny · 1985
12000–2000
Reina v. Reina green
nyappdiv · 1989
11999–1999
O'Brien v. O'Brien green
ny · 1985
11999–1999
People v. Goodman green
ny · 1986
11988–1988
People v. Page green
ny · 1979
11983–1983
Webster v. Roe neutral
nysupct · 1926
11982–1982

Statutes the citing opinions construe

NY § N.Y. Domestic Relations Law § 236 (4)

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

CA 226 (1907–2026) LA 168 (1941–2025) TX 156 (1905–2021) PA 112 (1911–2026) NY 81 (1891–2026) TN 77 (1904–2026) IL 59 (1872–2024) CT 55 (1857–2021) MA 55 (1874–2024) MO 47 (1905–2020) FL 43 (1914–2019) AL 40 (1894–2024) MD 38 (1939–2025) WV 36 (1935–2020) IN 36 (1867–2019) WI 32 (1891–2025) KS 28 (1904–2024) GA 27 (1895–2018) MI 26 (1889–2022) WA 23 (1910–2024) OK 21 (1908–2009) NC 21 (1895–2022) OH 21 (1906–2026) MT 21 (1919–2022) KY 20 (1917–2022) DE 20 (1972–2025) RI 19 (1968–2022) ME 16 (1947–2024) SC 16 (1929–2022) AZ 16 (1916–2020) OR 15 (1922–2025) MS 15 (1956–2020) NE 15 (1884–2021) VA 14 (1927–2015) AR 14 (1941–2026) NJ 14 (1891–2019) WY 14 (1948–1999) NM 12 (1950–2025) AK 11 (1964–2001) UT 10 (1958–2021) IA 9 (1962–2025) DC 9 (1956–2016) MN 8 (1900–2006) CO 8 (1952–2008) NV 7 (1991–2009) VT 7 (1967–2026) NH 5 (1986–2021) ID 5 (1968–2012) HI 4 (1982–2017) ND 4 (1950–1991) SD 3 (1979–2010) VI 2 (1988–2010)

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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