hearing rule (Florida) · Go Syfert
← Florida issues

hearing rule in Florida

79 Florida opinions name it 3 courts 1955–2025 6 in the last five years

The cases below were cited by Florida 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 (42)

CaseFollowedCited
Hembd v. Dauriagreen
fladistctapp · 2003 · cited in 3 Florida opinions naming this issue, 2010–2021
2 sentences

2021The matter alleged must affect the outcome of the case and not merely be ‘de minimis.’ Thus, to obtain a hearing on a rule 1.540(b)(3) motion, the law requires a movant ‘to demonstrate a prima facie case of fraud, not just nibble at the edges of the concept.’ Hembd v. Dauria, 859 So. 2d 1238, 1240 (Fla. 4th DCA 2003)”) (citations and quotations omitted).

2011Thus, to obtain a hearing on a rule 1.540(b)(3) motion, the law requires a movant “to demonstrate a prima facie case of fraud, not just nibble at the edges of the concept.” Hembd v. Dauria, 859 So.2d 1238, 1240 (Fla. 4th DCA 2003).

33
Branton v. Stategreen
fladistctapp · 2016 · cited in 2 Florida opinions naming this issue, 2019–2019
2 sentences

2019See Branton v. State , 187 So.3d 382 (Fla. 5th DCA 2016).

2019See Branton v. State , 187 So.3d 382 (Fla. 5th DCA 2016).

22
Brown v. Stategreen
fla · 1971 · cited in 2 Florida opinions naming this issue, 1971–1975
2 sentences

1975In the recent case of Brown v. State, 245 So.2d 68, 70 (Fla. 1971), involving a similar situation, this Court, speaking through Justice Adkins, stated: `Defendant then requested further examination by experts.

1971In the recent case of Brown v. State, 245 So.2d 68, 70 (Fla. 1971), involving a similar situation, this Court, speaking through Justice Adkins, stated: "Defendant then requested further examination by experts.

22
Morton v. Stategreen
fla · 2008 · cited in 2 Florida opinions naming this issue, 2025–2025
2 sentences

2025But because Gudinas was indeed twenty years old “at the time of the murder[], it is impossible for him to demonstrate that he falls within the ages of exemption, rendering his claim facially insufficient and therefore properly summarily denied.” Ford, 402 So. 3d at 979 (citing Morton, 995 So. 2d at 245 ) (“Because it is impossible for Morton to demonstrate that he falls within the ages of exemption, his claim is facially insufficient and it was proper for the court to deny Morton a hearing on this claim.”)). - 20 - This claim also lacks merit because, as we have explained, this Court lacks the

2025See Morton v. State, 995 So. 2d 233, 245 (Fla. 2008) (“Because it is impossible for Morton to demonstrate that he falls within the ages of exemption, his claim is facially insufficient and it was proper for the court to deny Morton a hearing on this claim.”).

12
Steele v. Kehoegreen
fla · 1999 · cited in 2 Florida opinions naming this issue, 2004–2014
2 sentences

2014See Steele v. Kehoe, 747 So.2d 931, 934 (Fla.1999).

2004Steele v. Kehoe, 747 So.2d 931 (Fla.1999)(holding that a prisoner is entitled to a hearing on a claim that he or she missed the deadline to file a Rule 3.850 motion because his or her attorney had agreed to file the motion but failed to do so in a timely manner; if the prisoner prevails at the hearing he or she is authorized to file belatedly a Rule 3.850 motion). .

12
United States v. Olanogreen
scotus · 1993 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024Cf. § 948.06(b), (d), Fla. Stat. (authorizing revocation upon admission but requiring a hearing if the violation is not admitted); see generally United States v. Olano, 507 U.S. 725, 733 (1993) (explaining that “forfeiture is the failure to make the timely assertion of a right” but “waiver is the intentional relinquishment or abandonment of a known right” (internal quotation and citation omitted)).

11
Russell v. Stategreen
fla · 2008 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024An admission has the effect of waiving the probationer’s entitlement to “an opportunity to be fully heard on his or her behalf in person or by counsel.” § 948.06(2)(d), Fla. Stat. It also waives his right to require the State “establish by greater weight of the evidence that the violation of probation occurred.” Russell v. State, 982 So. 2d 642, 646 (Fla. 2008).

11
Valls v. Dept. of Healthgreen
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2022–2022
2 sentences

2022See Dougherty v. State, 149 So. 3d 672, 678 (Fla. 2014) (“[W]here the parties and the judge agree, the trial court may decide the issue of competency on the basis of the written reports alone.” (quoting Fowler v. State, 255 So. 2d 513, 515 (Fla. 1971))); Jones v. State, 125 So. 3d 982 , 984 (Fla. 2013) (holding Rule 3.212 was satisfied when trial court based finding of competence on defense’s two expert competency evaluations without conducting competency hearing); Fowler, 255 So. 3d at 515 (“Our decision [that the trial court erred by not setting a hearing to determine the 6 defendant’s compe

2022See Dougherty v. State, 149 So. 3d 672, 678 (Fla. 2014) (“[W]here the parties and the judge agree, the trial court may decide the issue of competency on the basis of the written reports alone.” (quoting Fowler v. State, 255 So. 2d 513, 515 (Fla. 1971))); Jones v. State, 125 So. 3d 982 , 984 (Fla. 2013) (holding Rule 3.212 was satisfied when trial court based finding of competence on defense’s two expert competency evaluations without conducting competency hearing); Fowler, 255 So. 3d at 515 (“Our decision [that the trial court erred by not setting a hearing to determine the 6 defendant’s compe

11
Fowler v. Stategreen
fla · 1971 · cited in 1 Florida opinions naming this issue, 2022–2022
2 sentences

2022See Dougherty v. State, 149 So. 3d 672, 678 (Fla. 2014) (“[W]here the parties and the judge agree, the trial court may decide the issue of competency on the basis of the written reports alone.” (quoting Fowler v. State, 255 So. 2d 513, 515 (Fla. 1971))); Jones v. State, 125 So. 3d 982 , 984 (Fla. 2013) (holding Rule 3.212 was satisfied when trial court based finding of competence on defense’s two expert competency evaluations without conducting competency hearing); Fowler, 255 So. 3d at 515 (“Our decision [that the trial court erred by not setting a hearing to determine the 6 defendant’s compe

2022See Dougherty v. State, 149 So. 3d 672, 678 (Fla. 2014) (“[W]here the parties and the judge agree, the trial court may decide the issue of competency on the basis of the written reports alone.” (quoting Fowler v. State, 255 So. 2d 513, 515 (Fla. 1971))); Jones v. State, 125 So. 3d 982 , 984 (Fla. 2013) (holding Rule 3.212 was satisfied when trial court based finding of competence on defense’s two expert competency evaluations without conducting competency hearing); Fowler, 255 So. 3d at 515 (“Our decision [that the trial court erred by not setting a hearing to determine the 6 defendant’s compe

11
Bernard J. Dougherty v. State of Floridagreen
fla · 2014 · cited in 1 Florida opinions naming this issue, 2022–2022
2 sentences

2022See Dougherty v. State, 149 So. 3d 672, 678 (Fla. 2014) (“[W]here the parties and the judge agree, the trial court may decide the issue of competency on the basis of the written reports alone.” (quoting Fowler v. State, 255 So. 2d 513, 515 (Fla. 1971))); Jones v. State, 125 So. 3d 982 , 984 (Fla. 2013) (holding Rule 3.212 was satisfied when trial court based finding of competence on defense’s two expert competency evaluations without conducting competency hearing); Fowler, 255 So. 3d at 515 (“Our decision [that the trial court erred by not setting a hearing to determine the 6 defendant’s compe

2022See Dougherty v. State, 149 So. 3d 672, 678 (Fla. 2014) (“[W]here the parties and the judge agree, the trial court may decide the issue of competency on the basis of the written reports alone.” (quoting Fowler v. State, 255 So. 2d 513, 515 (Fla. 1971))); Jones v. State, 125 So. 3d 982 , 984 (Fla. 2013) (holding Rule 3.212 was satisfied when trial court based finding of competence on defense’s two expert competency evaluations without conducting competency hearing); Fowler, 255 So. 3d at 515 (“Our decision [that the trial court erred by not setting a hearing to determine the 6 defendant’s compe

11
Rusniaczek v. Tableau Fine Art Group, Inc.green
fladistctapp · 2014 · cited in 1 Florida opinions naming this issue, 2021–2021
1 sentence

2021See also Rusniaczek v. Tableau Fine Art Grp., Inc., 139 So. 3d 355, 357-58 (Fla. 3d DCA 2014) (explaining that the “purpose of this specificity requirement is to permit the court ‘to determine whether the movant has made a prima facie showing which would justify relief from judgment,’ and is not merely rehashing matters explored at trial”) (quotation omitted). 2

11
JUNIO SAINVIL v. STATE OF FLORIDAgreen
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019See Sainvil v. State, 248 So. 3d 148, 149 (Fla. 4th DCA 2018) (“The imposition of restitution without notice or a hearing is error.”) (citation omitted).

11
Hamrick v. Stategreen
fladistctapp · 1995 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018Analysis “The imposition of restitution without notice or a hearing is error.” Hamrick v. State, 648 So. 2d 274, 276 (Fla. 4th DCA 1995); see also Manuel v. State, 152 So. 3d 1290, 1290 (Fla. 4th DCA 2015).

11
Kendrick Silver v. State of Floridagreen
fladistctapp · 2016 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018The State alleges that the motion did not provide reasonable belief to the court, and “the order for evaluation may have been entered in an abundance of caution, merely in response to the filing of the motion.” However, speculation on the trial court’s reasonable belief is unnecessary, because “a trial court’s appointing experts to evaluate a defendant’s competency suggests there were reasonable grounds to do so.” Silver v. State, 193 So. 3d 991, 993 (Fla. 4th DCA 2016).

11
Datavious Manuel v. Stategreen
fladistctapp · 2015 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018Analysis “The imposition of restitution without notice or a hearing is error.” Hamrick v. State, 648 So. 2d 274, 276 (Fla. 4th DCA 1995); see also Manuel v. State, 152 So. 3d 1290, 1290 (Fla. 4th DCA 2015).

11
Martin v. Stategreen
fladistctapp · 2006 · cited in 1 Florida opinions naming this issue, 2016–2016
1 sentence

2016See, e.g., Johnson v. State, 60 So.3d 1045, 1048 (Fla.2011) (“At the hearing, the State withdrew the allegation that Johnson had committed new substantive offenses.... ”); Martin v. State, 937 So.2d 714, 715 (Fla. 1st DCA 2006) (“At the hearing on the violation of probation, the prosecutor withdrew the allegation of violation of condition number 5 (the new law violation).”), disapproved on other grounds in Del Valle v. State, 80 So.3d 999 (Fla. 2011).

11
Johnson v. Stategreen
fla · 2011 · cited in 1 Florida opinions naming this issue, 2016–2016
1 sentence

2016See, e.g., Johnson v. State, 60 So.3d 1045, 1048 (Fla.2011) (“At the hearing, the State withdrew the allegation that Johnson had committed new substantive offenses.... ”); Martin v. State, 937 So.2d 714, 715 (Fla. 1st DCA 2006) (“At the hearing on the violation of probation, the prosecutor withdrew the allegation of violation of condition number 5 (the new law violation).”), disapproved on other grounds in Del Valle v. State, 80 So.3d 999 (Fla. 2011).

11
Foster v. Stategreen
fla · 2013 · cited in 1 Florida opinions naming this issue, 2015–2015
11
State v. Summersgreen
fla · 1994 · cited in 1 Florida opinions naming this issue, 2013–2013
11
Mederos v. Stategreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2013–2013
11
Joseph v. Stategreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2013–2013
11
Yoxsimer v. Yoxsimergreen
fladistctapp · 2006 · cited in 1 Florida opinions naming this issue, 2011–2011
11
Culbreath v. Stategreen
fladistctapp · 2005 · cited in 1 Florida opinions naming this issue, 2009–2009
11
Shaw v. Stategreen
fladistctapp · 1989 · cited in 1 Florida opinions naming this issue, 2009–2009
11
Evans v. Stategreen
fladistctapp · 2003 · cited in 1 Florida opinions naming this issue, 2008–2008
11
Johnson v. Stategreen
fladistctapp · 2006 · cited in 1 Florida opinions naming this issue, 2008–2008
11
McLin v. Stategreen
fla · 2002 · cited in 1 Florida opinions naming this issue, 2008–2008
11
Hering v. Stategreen
fladistctapp · 2008 · cited in 1 Florida opinions naming this issue, 2008–2008
11
Jackson v. Stategreen
fla · 1984 · cited in 1 Florida opinions naming this issue, 2008–2008
11
LPP Mortgage Ltd. v. Bank of America, NAgreen
fladistctapp · 2002 · cited in 1 Florida opinions naming this issue, 2005–2005
11
Stephens v. Stategreen
fladistctapp · 1993 · cited in 1 Florida opinions naming this issue, 2004–2004
11
Davenport v. Dimitrijevicgreen
fladistctapp · 2003 · cited in 1 Florida opinions naming this issue, 2003–2003
11
Salvatierra v. Stategreen
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2002–2002
11
State, Dept. of Transp. v. Finkelsteingreen
fladistctapp · 1993 · cited in 1 Florida opinions naming this issue, 2001–2001
11
STATE, DHRS v. Lemastergreen
fladistctapp · 1992 · cited in 1 Florida opinions naming this issue, 2000–2000
11
McGraw v. Stategreen
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2000–2000
11
Gordon v. Stategreen
fladistctapp · 1995 · cited in 1 Florida opinions naming this issue, 1999–1999
11
State Ex Rel. Dept. of General Serv. v. Willisgreen
fladistctapp · 1977 · cited in 1 Florida opinions naming this issue, 1999–1999
11
Hoffman v. Stategreen
fla · 1990 · cited in 1 Florida opinions naming this issue, 1998–1998
11
Whitmore Ex Rel. Simmons v. Arkansasgreen
scotus · 1990 · cited in 1 Florida opinions naming this issue, 1997–1997
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (38)

CaseCitedYears
Smith v. Smith green
fladistctapp · 2005
2 sentences

2019To be entitled to a hearing on a rule 1.540(b) motion, the allegations in the motion and accompanying affidavits must show a "colorable entitlement to relief." See Smith v. Smith , 903 So.2d 1044 , 1045 (Fla. 5th DCA 2005) ; Richards v. Crowder , 191 So.3d 524 , 525 (Fla. 4th DCA 2016).

2019To be entitled to a hearing on a rule 1.540(b) motion, the allegations in the motion and accompanying affidavits must show a "colorable entitlement to relief." See Smith v. Smith , 903 So.2d 1044 , 1045 (Fla. 5th DCA 2005) ; Richards v. Crowder , 191 So.3d 524 , 525 (Fla. 4th DCA 2016).

22019–2019
John Richards v. Ashley Dale Crowder green
fladistctapp · 2016
2 sentences

2019To be entitled to a hearing on a rule 1.540(b) motion, the allegations in the motion and accompanying affidavits must show a "colorable entitlement to relief." See Smith v. Smith , 903 So.2d 1044 , 1045 (Fla. 5th DCA 2005) ; Richards v. Crowder , 191 So.3d 524 , 525 (Fla. 4th DCA 2016).

2019To be entitled to a hearing on a rule 1.540(b) motion, the allegations in the motion and accompanying affidavits must show a "colorable entitlement to relief." See Smith v. Smith , 903 So.2d 1044 , 1045 (Fla. 5th DCA 2005) ; Richards v. Crowder , 191 So.3d 524 , 525 (Fla. 4th DCA 2016).

22019–2019
Connor v. State green
fla · 2008
2 sentences

2012We rejected this argument in Lawrence v. State, 969 So.2d 294 (Fla.2007), and Connor v. State, 979 So.2d 852 (Fla.2007).

2009We rejected this argument in Lawrence v. State, 969 So.2d 294 (Fla.2007), and Connor v. State, 979 So.2d 852 (Fla.2007).

22009–2012
Lawrence v. State green
fla · 2007
2 sentences

2012We rejected this argument in Lawrence v. State, 969 So.2d 294 (Fla.2007), and Connor v. State, 979 So.2d 852 (Fla.2007).

2009We rejected this argument in Lawrence v. State, 969 So.2d 294 (Fla.2007), and Connor v. State, 979 So.2d 852 (Fla.2007).

22009–2012
Mounds v. State green
fladistctapp · 1988
2 sentences

1995Dominique v. State, 590 So.2d 1059 (Fla. 4th DCA 1991); Mounds v. State, 526 So.2d 1084 (Fla. 4th DCA 1988).

1991As this court held in Mounds v. State, 526 So.2d 1084 (Fla. 4th DCA 1988), "the imposition of restitution without notice or a hearing was error." In the present case this rule was not honored and thus we find it necessary to remand for purposes of allowing appellant his opportunity to be heard on the matter.

21991–1995
Kirk v. Baumann neutral
fladistctapp · 1976
2 sentences

1991We therefore depart from our holding in Kirk v. Baumann, supra, and herein hold that an order of court need not precede the filing of a valid notice of lis pendens.

1982We therefore depart from our holding in Kirk v. Baumann, supra , and herein hold that an order of court need not precede the filing of a valid notice of lis pendens.

21982–1991
Preece v. Bethesda Memorial Hospital, Inc. green
fladistctapp · 2013
2 sentences

2022See Dougherty v. State, 149 So. 3d 672, 678 (Fla. 2014) (“[W]here the parties and the judge agree, the trial court may decide the issue of competency on the basis of the written reports alone.” (quoting Fowler v. State, 255 So. 2d 513, 515 (Fla. 1971))); Jones v. State, 125 So. 3d 982 , 984 (Fla. 2013) (holding Rule 3.212 was satisfied when trial court based finding of competence on defense’s two expert competency evaluations without conducting competency hearing); Fowler, 255 So. 3d at 515 (“Our decision [that the trial court erred by not setting a hearing to determine the 6 defendant’s compe

2022See Dougherty v. State, 149 So. 3d 672, 678 (Fla. 2014) (“[W]here the parties and the judge agree, the trial court may decide the issue of competency on the basis of the written reports alone.” (quoting Fowler v. State, 255 So. 2d 513, 515 (Fla. 1971))); Jones v. State, 125 So. 3d 982 , 984 (Fla. 2013) (holding Rule 3.212 was satisfied when trial court based finding of competence on defense’s two expert competency evaluations without conducting competency hearing); Fowler, 255 So. 3d at 515 (“Our decision [that the trial court erred by not setting a hearing to determine the 6 defendant’s compe

12022–2022
Mills v. State green
fladistctapp · 2015
1 sentence

2021Recognizing two contrary holdings, the Second District certified direct conflict with Mills v. State, 177 So. 3d 984 (Fla. 1st DCA 2015), and Alexis v. State, 211 So. 3d 81 (Fla. 4th DCA 2017).

12021–2021
Alexis v. State green
fladistctapp · 2017
1 sentence

2021Recognizing two contrary holdings, the Second District certified direct conflict with Mills v. State, 177 So. 3d 984 (Fla. 1st DCA 2015), and Alexis v. State, 211 So. 3d 81 (Fla. 4th DCA 2017).

12021–2021
State Farm Fire & Casualty Co. v. Lezcano green
fladistctapp · 2009
1 sentence

2018Because we find that the trial court committed fundamental error in entering final summary judgment in favor of Wells Fargo without conducting a hearing as provided by rule 1.510(c), the final summary judgment entered in favor of Wells Fargo is reversed, and the cause remanded for further proceedings.2 See Lezcano, 22 So. 3d at 634 ; Greene, 745 So. 2d at 411 ; Kozich, 609 So. 2d at 148 .

12018–2018
Kozich v. Hartford Ins. Co. green
fladistctapp · 1992
1 sentence

2018Because we find that the trial court committed fundamental error in entering final summary judgment in favor of Wells Fargo without conducting a hearing as provided by rule 1.510(c), the final summary judgment entered in favor of Wells Fargo is reversed, and the cause remanded for further proceedings.2 See Lezcano, 22 So. 3d at 634 ; Greene, 745 So. 2d at 411 ; Kozich, 609 So. 2d at 148 .

12018–2018
Greene v. Seigle green
fladistctapp · 1999
1 sentence

2018Because we find that the trial court committed fundamental error in entering final summary judgment in favor of Wells Fargo without conducting a hearing as provided by rule 1.510(c), the final summary judgment entered in favor of Wells Fargo is reversed, and the cause remanded for further proceedings.2 See Lezcano, 22 So. 3d at 634 ; Greene, 745 So. 2d at 411 ; Kozich, 609 So. 2d at 148 .

12018–2018
Del Valle v. State green
fla · 2011
1 sentence

2016See, e.g., Johnson v. State, 60 So.3d 1045, 1048 (Fla.2011) (“At the hearing, the State withdrew the allegation that Johnson had committed new substantive offenses.... ”); Martin v. State, 937 So.2d 714, 715 (Fla. 1st DCA 2006) (“At the hearing on the violation of probation, the prosecutor withdrew the allegation of violation of condition number 5 (the new law violation).”), disapproved on other grounds in Del Valle v. State, 80 So.3d 999 (Fla. 2011).

12016–2016
McDonald v. State green
fla · 2006
12015–2015
Nixon v. State green
fla · 2009
12012–2012
Knorr v. Knorr green
fladistctapp · 1999
12011–2011
Williams v. State green
fladistctapp · 2006
12010–2010
Wallace v. State green
fladistctapp · 2002
12003–2003
Huff v. State green
fla · 1993
12002–2002
Brady v. Maryland green
scotus · 1963
12002–2002
Bates v. State green
fladistctapp · 2002
12002–2002
Wincor v. Florida Bar green
fladistctapp · 2002
12002–2002
Narvaez v. State green
fladistctapp · 1996
12002–2002
Sireci v. State green
fla · 2000
12002–2002
Stansel v. State green
fladistctapp · 2002
12002–2002
Perriello v. State green
fladistctapp · 1996
12001–2001
Finkelstein v. Department of Transp. green
fla · 1995
12001–2001
STATE, DEPT. OF HRS v. Sandidge green
fladistctapp · 1995
12000–2000
State v. Boyd green
fla · 1998
11999–1999
Durocher v. Singletary green
fla · 1993
11997–1997
Hunter v. State green
fla · 1995
11997–1997
Gosby v. Third Judicial Circuit green
fla · 1991
11996–1996
City of Miami v. Perez green
fladistctapp · 1993
11996–1996
Brown v. Name Change green
fladistctapp · 1993
11996–1996
Casey v. State green
fladistctapp · 1992
11996–1996
In Re Keppro green
fladistctapp · 1991
11996–1996
Dominique v. State green
fladistctapp · 1991
11995–1995
Smith v. State green
fladistctapp · 1993
11994–1994

Statutes the citing opinions construe

FL § 775.089 (3) FL § 948.06 (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

LA 310 (1918–2025) NY 254 (1890–2026) OH 130 (1960–2026) TX 129 (1932–2026) PA 125 (1870–2026) CA 101 (1954–2026) IL 89 (1942–2026) FL 79 (1955–2025) GA 42 (1910–2024) MI 40 (1929–2025) MO 39 (1927–2025) IN 38 (1965–2025) AL 33 (1912–2018) WI 33 (1890–2025) CO 31 (1891–2026) MA 26 (1984–2026) MD 24 (1951–2024) CT 24 (1977–2025) NJ 23 (1958–2024) AZ 22 (1973–2025) WA 20 (1981–2025) OR 20 (1977–2026) DC 18 (1970–2023) NC 17 (1966–2023) MS 17 (1990–2021) NM 17 (1967–2022) IA 16 (1931–2023) MN 14 (1986–2024) KS 14 (1940–2024) MT 13 (1977–2026) UT 13 (1924–2026) TN 12 (1943–2026) OK 11 (1928–2016) RI 11 (1972–2025) AR 11 (1956–2021) WV 10 (1895–2026) NV 9 (1999–2020) ND 9 (1952–2025) VA 9 (1980–2025) KY 9 (1933–2020) ID 9 (1973–2022) HI 9 (1995–2025) DE 8 (1954–2025) SC 7 (1931–2026) AK 6 (1984–2020) NE 6 (1906–2021) WY 5 (1955–2007) NH 4 (1974–1989) ME 4 (2007–2012) VT 4 (1979–2014) VI 3 (2012–2016) SD 2 (1990–1990)

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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