Roth standard (Connecticut) · Go Syfert
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Roth standard in Connecticut

10 Connecticut opinions name it 3 courts 1963–2020 0 in the last five years

The cases below were cited by Connecticut 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 (7)

CaseFollowedCited
Roth v. Westongreen
conn · 2002 · cited in 4 Connecticut opinions naming this issue, 2008–2019
2 sentences

2019These two factors, commonly referred to as the Roth factors, "must be satisfied **134 in order for a court: (1) to have jurisdiction over a petition for visitation contrary to the wishes of a fit parent; and (2) to grant such a petition." Id., at 234 , 789 A.2d 431 .

2019These two factors, commonly referred to as the Roth factors, "must be satisfied **134 in order for a court: (1) to have jurisdiction over a petition for visitation contrary to the wishes of a fit parent; and (2) to grant such a petition." Id., at 234 , 789 A.2d 431 .

24
Mierzejewski v. Brownellgreen
conn · 2007 · cited in 1 Connecticut opinions naming this issue, 2020–2020
2 sentences

2020See Fennelly v. Norton, 103 Conn. App. 125, 142 , 931 A.2d 269 (petition must contain ‘‘specific, good faith allegations of both relationship and harm’’ [emphasis added]), cert. denied, 284 Conn. 918 , 931 A.2d 936 (2007). 6 The defendant passingly argues in her appellate brief that the court should not have considered the allegations contained in the plaintiffs’ affida- vit, which was attached to and referenced in the plaintiffs’ petition.

2020See Fennelly v. Norton, 103 Conn. App. 125, 142 , 931 A.2d 269 (petition must contain ‘‘specific, good faith allegations of both relationship and harm’’ [emphasis added]), cert. denied, 284 Conn. 918 , 931 A.2d 936 (2007). 6 The defendant passingly argues in her appellate brief that the court should not have considered the allegations contained in the plaintiffs’ affida- vit, which was attached to and referenced in the plaintiffs’ petition.

11
Fennelly v. Nortongreen
connappct · 2007 · cited in 1 Connecticut opinions naming this issue, 2020–2020
2 sentences

2020See Fennelly v. Norton, 103 Conn. App. 125, 142 , 931 A.2d 269 (petition must contain ‘‘specific, good faith allegations of both relationship and harm’’ [emphasis added]), cert. denied, 284 Conn. 918 , 931 A.2d 936 (2007). 6 The defendant passingly argues in her appellate brief that the court should not have considered the allegations contained in the plaintiffs’ affida- vit, which was attached to and referenced in the plaintiffs’ petition.

2020See Fennelly v. Norton, 103 Conn. App. 125, 142 , 931 A.2d 269 (petition must contain ‘‘specific, good faith allegations of both relationship and harm’’ [emphasis added]), cert. denied, 284 Conn. 918 , 931 A.2d 936 (2007). 6 The defendant passingly argues in her appellate brief that the court should not have considered the allegations contained in the plaintiffs’ affida- vit, which was attached to and referenced in the plaintiffs’ petition.

11
Poulin v. Commissioner of Correctiongreen
conn · 2007 · cited in 1 Connecticut opinions naming this issue, 2020–2020
2 sentences

2020See Fennelly v. Norton, 103 Conn. App. 125, 142 , 931 A.2d 269 (petition must contain ‘‘specific, good faith allegations of both relationship and harm’’ [emphasis added]), cert. denied, 284 Conn. 918 , 931 A.2d 936 (2007). 6 The defendant passingly argues in her appellate brief that the court should not have considered the allegations contained in the plaintiffs’ affida- vit, which was attached to and referenced in the plaintiffs’ petition.

2020See Fennelly v. Norton, 103 Conn. App. 125, 142 , 931 A.2d 269 (petition must contain ‘‘specific, good faith allegations of both relationship and harm’’ [emphasis added]), cert. denied, 284 Conn. 918 , 931 A.2d 936 (2007). 6 The defendant passingly argues in her appellate brief that the court should not have considered the allegations contained in the plaintiffs’ affida- vit, which was attached to and referenced in the plaintiffs’ petition.

11
Denardo v. Bergamogreen
conn · 2005 · cited in 1 Connecticut opinions naming this issue, 2019–2019
2 sentences

2019The defendant's argument is predicated on Denardo v. Bergamo , 272 Conn. 500 , 509, 863 A.2d 686 (2005), which he contends requires application of the Roth factors to a postjudgment motion to dismiss filed by a fit parent. 11 The defendant's *18 reliance on Denardo is **138 misplaced, however, because Denardo involved an award of third-party visitation that was not supported by the Roth factors in the first instance.

2019The defendant's argument is predicated on Denardo v. Bergamo , 272 Conn. 500 , 509, 863 A.2d 686 (2005), which he contends requires application of the Roth factors to a postjudgment motion to dismiss filed by a fit parent. 11 The defendant's *18 reliance on Denardo is **138 misplaced, however, because Denardo involved an award of third-party visitation that was not supported by the Roth factors in the first instance.

11
Lewis v. Connecticut Gaming Policy Boardgreen
conn · 1993 · cited in 1 Connecticut opinions naming this issue, 2014–2014
2 sentences

2014The plaintiff did not appeal that decision, and that decision stands as the law of the case.’’ This court, however, has stated that ‘‘when the jurisdiction of the trial court is implicated, an adjudica- tor is not bound by the law of the case doctrine, but should consider independently the issue of jurisdic- tion.’’ Pinchbeck v. Dept. of Public Health, 65 Conn. App. 201 , 207–208, 782 A.2d 242 , cert. denied, 258 Conn. 928 , 783 A.2d 1029 (2001); see also Lewis v. Gaming Policy Board, 224 Conn. 693 , 698–99, 620 A.2d 780 (1993).

2014The plaintiff did not appeal that decision, and that decision stands as the law of the case.’’ This court, however, has stated that ‘‘when the jurisdiction of the trial court is implicated, an adjudica- tor is not bound by the law of the case doctrine, but should consider independently the issue of jurisdic- tion.’’ Pinchbeck v. Dept. of Public Health, 65 Conn. App. 201 , 207–208, 782 A.2d 242 , cert. denied, 258 Conn. 928 , 783 A.2d 1029 (2001); see also Lewis v. Gaming Policy Board, 224 Conn. 693 , 698–99, 620 A.2d 780 (1993).

11
Fish v. Fishgreen
connappct · 2005 · cited in 1 Connecticut opinions naming this issue, 2008–2008
2 sentences

2008See id., at 756, 881 A.2d 342 .

2008See id., at 756, 881 A.2d 342 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (17)

CaseCitedYears
DiGiovanna v. St. George green
conn · 2011
2 sentences

2020In resolving that question, the court noted that it was ‘‘treat[ing] as uncontested the trial court’s findings that the plaintiff alleged and proved the Roth factors by clear and convincing evidence.’’ Id., 70 .

2020In resolving that question, the court noted that it was ‘‘treat[ing] as uncontested the trial court’s findings that the plaintiff alleged and proved the Roth factors by clear and convincing evidence.’’ Id., 70 .

32014–2020
Troxel v. Granville green
scotus · 2000
2 sentences

2008In Roth v. Weston, supra, 259 Conn. 209 -10, this court determined that, in light of the United States Supreme Court’s decision in Troxel v. Granville, 530 U.S. 57 , 120 S. Ct. 2054 , 147 L.

2008In Roth v. Weston, supra, 259 Conn. 209 -10, this court determined that, in light of the United States Supreme Court’s decision in Troxel v. Granville, 530 U.S. 57 , 120 S. Ct. 2054 , 147 L.

32002–2008
Fish v. Fish green
conn · 2008
2 sentences

2019A fit parent retains the "quintessential rights of parenthood," which "include the right to make medical, educational, religious and other decisions that affect the most fundamental aspects of the child's life ...." (Internal quotation marks omitted.) Fish v. Fish , 285 Conn. 24 , 58, 939 A.2d 1040 (2008).

2019A fit parent retains the "quintessential rights of parenthood," which "include the right to make medical, educational, religious and other decisions that affect the most fundamental aspects of the child's life ...." (Internal quotation marks omitted.) Fish v. Fish , 285 Conn. 24 , 58, 939 A.2d 1040 (2008).

22011–2019
Murray v. Taylor green
conn · 2001
2 sentences

2014The plaintiff did not appeal that decision, and that decision stands as the law of the case.’’ This court, however, has stated that ‘‘when the jurisdiction of the trial court is implicated, an adjudica- tor is not bound by the law of the case doctrine, but should consider independently the issue of jurisdic- tion.’’ Pinchbeck v. Dept. of Public Health, 65 Conn. App. 201 , 207–208, 782 A.2d 242 , cert. denied, 258 Conn. 928 , 783 A.2d 1029 (2001); see also Lewis v. Gaming Policy Board, 224 Conn. 693 , 698–99, 620 A.2d 780 (1993).

2014The plaintiff did not appeal that decision, and that decision stands as the law of the case.’’ This court, however, has stated that ‘‘when the jurisdiction of the trial court is implicated, an adjudica- tor is not bound by the law of the case doctrine, but should consider independently the issue of jurisdic- tion.’’ Pinchbeck v. Dept. of Public Health, 65 Conn. App. 201 , 207–208, 782 A.2d 242 , cert. denied, 258 Conn. 928 , 783 A.2d 1029 (2001); see also Lewis v. Gaming Policy Board, 224 Conn. 693 , 698–99, 620 A.2d 780 (1993).

12014–2014
Pinchbeck v. Department of Public Health green
conn · 2001
2 sentences

2014The plaintiff did not appeal that decision, and that decision stands as the law of the case.’’ This court, however, has stated that ‘‘when the jurisdiction of the trial court is implicated, an adjudica- tor is not bound by the law of the case doctrine, but should consider independently the issue of jurisdic- tion.’’ Pinchbeck v. Dept. of Public Health, 65 Conn. App. 201 , 207–208, 782 A.2d 242 , cert. denied, 258 Conn. 928 , 783 A.2d 1029 (2001); see also Lewis v. Gaming Policy Board, 224 Conn. 693 , 698–99, 620 A.2d 780 (1993).

2014The plaintiff did not appeal that decision, and that decision stands as the law of the case.’’ This court, however, has stated that ‘‘when the jurisdiction of the trial court is implicated, an adjudica- tor is not bound by the law of the case doctrine, but should consider independently the issue of jurisdic- tion.’’ Pinchbeck v. Dept. of Public Health, 65 Conn. App. 201 , 207–208, 782 A.2d 242 , cert. denied, 258 Conn. 928 , 783 A.2d 1029 (2001); see also Lewis v. Gaming Policy Board, 224 Conn. 693 , 698–99, 620 A.2d 780 (1993).

12014–2014
Pinchbeck v. Department of Public Health green
connappct · 2001
2 sentences

2014The plaintiff did not appeal that decision, and that decision stands as the law of the case.’’ This court, however, has stated that ‘‘when the jurisdiction of the trial court is implicated, an adjudica- tor is not bound by the law of the case doctrine, but should consider independently the issue of jurisdic- tion.’’ Pinchbeck v. Dept. of Public Health, 65 Conn. App. 201 , 207–208, 782 A.2d 242 , cert. denied, 258 Conn. 928 , 783 A.2d 1029 (2001); see also Lewis v. Gaming Policy Board, 224 Conn. 693 , 698–99, 620 A.2d 780 (1993).

2014The plaintiff did not appeal that decision, and that decision stands as the law of the case.’’ This court, however, has stated that ‘‘when the jurisdiction of the trial court is implicated, an adjudica- tor is not bound by the law of the case doctrine, but should consider independently the issue of jurisdic- tion.’’ Pinchbeck v. Dept. of Public Health, 65 Conn. App. 201 , 207–208, 782 A.2d 242 , cert. denied, 258 Conn. 928 , 783 A.2d 1029 (2001); see also Lewis v. Gaming Policy Board, 224 Conn. 693 , 698–99, 620 A.2d 780 (1993).

12014–2014
Monroe v. Monroe green
conn · 1979
2 sentences

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

12014–2014
Raitport v. Lyons green
scotus · 1979
2 sentences

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

12014–2014
Wolman v. Walter green
scotus · 1979
2 sentences

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

12014–2014
Carter v. Texas green
scotus · 1979
2 sentences

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

12014–2014
Devone v. Finley neutral
connappct · 2014
2 sentences

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

2014The decision focused on the defendants’ attempt to substitute their judgment as to the best medical treatment for the minor child. 8 See, e.g., Perry v. Perry, 312 Conn. 600 , 626, A.3d (2014); Devone v. Finley, 148 Conn. App. 647 , 651–52, 87 A.3d 1120 , cert. denied, 312 Conn. 912 , 93 A.3d 595 (2014). 9 Despite this broad language, there are, in fact, boundaries as to when challenges to the jurisdiction of the court may be brought. ‘‘The modern law of civil procedure suggests that even litigation about subject matter jurisdiction should take into account the importance of the principle of t

12014–2014
Castagno v. Wholean green
conn · 1996
2 sentences

2008In Roth v. Weston, supra, 259 Conn. at 209-10 , 789 A.2d 431 , this court determined that, in light of the United States Supreme Court's decision in Troxel v. Granville, 530 U.S. 57 , 120 S.Ct. 2054 , 147 L.Ed.2d 49 (2000), we must reconsider the constitutional gloss that we had placed on the third party visitation statute, General Statutes § 46b-59, just six years earlier in Castagno v. Wholean, 239 Conn. 336 , 684 A.2d 1181 (1996). [2] The court concluded *1081 that the jurisdictional requirements that we had added in Castagno "[did] not adequately acknowledge the status of parents' interest

2008In Roth v. Weston, supra, 259 Conn. at 209-10 , 789 A.2d 431 , this court determined that, in light of the United States Supreme Court's decision in Troxel v. Granville, 530 U.S. 57 , 120 S.Ct. 2054 , 147 L.Ed.2d 49 (2000), we must reconsider the constitutional gloss that we had placed on the third party visitation statute, General Statutes § 46b-59, just six years earlier in Castagno v. Wholean, 239 Conn. 336 , 684 A.2d 1181 (1996). [2] The court concluded *1081 that the jurisdictional requirements that we had added in Castagno "[did] not adequately acknowledge the status of parents' interest

12008–2008
In re Joshua S. green
conn · 2002
2 sentences

2008The majority engrafts onto the “detriment” standard the following gloss: “damaging, injurious or harmful to the child,” a definition of “detriment” previously cited by this cour t in In re Joshua S., 260 Conn. 182, 207 , 796 A.2d 1141 (2002); “exceptional circumstances”; not “temporary harm of the kind resulting from the stress of the dissolution proceeding itself, but significant harm arising from the pattern of dysfunctional behavior that has developed between the parent and the child over a period of time”; and a “qualitatively different [analysis] from that involving the ‘best interests of

2008The majority engrafts onto the “detriment” standard the following gloss: “damaging, injurious or harmful to the child,” a definition of “detriment” previously cited by this cour t in In re Joshua S., 260 Conn. 182, 207 , 796 A.2d 1141 (2002); “exceptional circumstances”; not “temporary harm of the kind resulting from the stress of the dissolution proceeding itself, but significant harm arising from the pattern of dysfunctional behavior that has developed between the parent and the child over a period of time”; and a “qualitatively different [analysis] from that involving the ‘best interests of

12008–2008
Foster v. Foster, No. Fa01-055 82 04 S (Aug. 19, 2002) neutral
connsuperct · 2002
2 sentences

2003The court thus agrees with the plaintiff regarding the interrelationship of the statutory scheme of these three statutes and would apply the Roth standard under General Statutes §§ 46b-56 and 46b-57 whether a non-parent seeks visitation or custody." (Foster v. Foster, 2002 Ct. Sup. 10460 , p. 10463-4).

2003The court thus agrees with the plaintiff regarding the interrelationship of the statutory scheme of these three statutes and would apply the Roth standard under General Statutes §§ 46b-56 and 46b-57 whether a non-parent seeks visitation or custody." (Foster v. Foster, 2002 Ct. Sup. 10460 , p. 10463-4).

12003–2003
Yale Auto Parts, Inc. v. Johnson green
ca2 · 1985
2 sentences

1992The Second Circuit applied the Roth standard in Yale Auto Parts, Inc. v. Johnson, 758 F.2d 54 (2d Cir. 1985), a case factually similar to the one at bar.

1992The Second Circuit applied the Roth standard in Yale Auto Parts, Inc. v. Johnson, 758 F.2d 54 (2d Cir. 1985), a case factually similar to the one at bar.

11992–1992
Rri Realty Corp. v. Village Of Southampton green
ca2 · 1989
2 sentences

1992The Second Circuit has adhered to the “property interest analysis” and “Yale Auto Parts and its progeny have committed [the Second] Circuit to the ‘entitlement’ inquiry in land use regulation cases.” RRI, supra, 917-18 . 5 “Many post-1972 land regulation decisions, however, have not pursued the Roth analysis in land regulation cases.

1992The Second Circuit has adhered to the “property interest analysis” and “Yale Auto Parts and its progeny have committed [the Second] Circuit to the ‘entitlement’ inquiry in land use regulation cases.” RRI, supra, 917-18 . 5 “Many post-1972 land regulation decisions, however, have not pursued the Roth analysis in land regulation cases.

11992–1992
State v. Sul green
conn · 1958
2 sentences

1963“In defining, in State v. Sul . . . [146 Conn. 78, 85 ], what constitutes obscenity under § 53-243, we took our text from the opinion of Mr. Justice Brennan, speaking for a majority of five of the United States Supreme Court, in Roth v. United States, supra. We held that § 53-243 ‘contemplates a publication, such as a book or pamphlet, which, considered as a whole, has a predominant appeal to the prurient interest, that is, a shameful or morbid interest in nudity, sex or excretion, and goes substantially beyond the customary limits of candor in describing or representing such matters.’ See Rot

1963“In defining, in State v. Sul . . . [146 Conn. 78, 85 ], what constitutes obscenity under § 53-243, we took our text from the opinion of Mr. Justice Brennan, speaking for a majority of five of the United States Supreme Court, in Roth v. United States, supra. We held that § 53-243 ‘contemplates a publication, such as a book or pamphlet, which, considered as a whole, has a predominant appeal to the prurient interest, that is, a shameful or morbid interest in nudity, sex or excretion, and goes substantially beyond the customary limits of candor in describing or representing such matters.’ See Rot

11963–1963

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 46b-120 (5) CT § Conn. Gen. Stat. § 46b-59 (5) CT § Conn. Gen. Stat. § 46b-56 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 11 (1966–2016) WA 11 (1970–2017) MD 11 (1961–1981) CT 10 (1963–2020) CA 10 (1968–2016) IL 9 (1964–2020) MN 7 (1971–1972) WI 6 (1971–2017) TX 6 (1960–2015) FL 5 (1967–1971) OH 4 (1960–2014) NJ 3 (1964–1997) PA 3 (1967–1980) SC 3 (1970–1972) KS 3 (1966–1999) IA 2 (1987–1988) ND 2 (2006–2006) GA 2 (1974–1991) AK 2 (1970–2014) AZ 2 (1966–1986) AL 2 (2008–2013) NE 2 (1964–2006) MI 2 (1970–1972) IN 2 (1971–1984)

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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