enforcement claim (New York) · Go Syfert
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enforcement claim in New York

76 New York opinions name it 12 courts 1880–2025 4 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 (27)

CaseFollowedCited
Rodriguez v. Hangartnergreen
nyappdiv · 2009 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013The Family Court should have considered the mother’s enforcement claim on the merits (cf. Matter of Rodriguez v Hangartner, 59 AD3d 630, 631 [2009]; Matter of Danvers v Clarke, 29 AD3d 578, 579 [2006]).

2013The Family Court should have considered the mother’s enforcement claim on the merits (cf. Matter of Rodriguez v Hangartner, 59 AD3d 630, 631 [2009]; Matter of Danvers v Clarke, 29 AD3d 578, 579 [2006]).

22
Danvers v. Clarkegreen
nyappdiv · 2006 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013The Family Court should have considered the mother’s enforcement claim on the merits (cf. Matter of Rodriguez v Hangartner, 59 AD3d 630, 631 [2009]; Matter of Danvers v Clarke, 29 AD3d 578, 579 [2006]).

2013The Family Court should have considered the mother’s enforcement claim on the merits (cf. Matter of Rodriguez v Hangartner, 59 AD3d 630, 631 [2009]; Matter of Danvers v Clarke, 29 AD3d 578, 579 [2006]).

22
Candid Productions, Inc. v. International Skating Uniongreen
nysd · 1982 · cited in 2 New York opinions naming this issue, 1983–1988
2 sentences

1988However, even when called upon to construe a clause in a contract expressly providing that a party is to apply his best efforts, a clear set of guidelines against which to measure a party’s best efforts is essential to the enforcement of such a clause (see, Mocca Lounge v Misak, supra, at 763; accord, Candid Prods. v International Skating Union, 530 F Supp 1330 ; Pinnacle Books v Harlequin Enters., 519 F Supp 118 ).

1983However, even when called upon to construe a clause in a contract expressly providing that a party is to apply his best efforts, a clear set of guidelines against which to measure a party’s best efforts is essential to the enforcement of such a clause (see Cross Props, v Brook Realty Co., 76 AD2d 445 ; accord Candid Prods, v International Skating Union, 530 F Supp 1330 ; Pinnacle Books v Harlequin Enterprises, 519 F Supp 118 ).

22
Murphy v. Relaxation Plus Commodore, Ltd.green
nyappterm · 1975 · cited in 2 New York opinions naming this issue, 1997–2023
2 sentences

2023Any other construction would make it possible for a willing landlord, greedy for the high rent that can be obtained for illegal use, to repeal the statute or make it legally ineffective" ( Murphy , 83 Misc 2d at 840 ).

1997"Clearly, it is the legislative intent that the acceptance of rent by landlord or doing any act constituting waiver will have no effect in a proceeding for eviction based on illegal use * * * when the matter relates to a situation where the Legislature has established a public policy and the enforcement of such a waiver would violate the public policy” (Murphy v Relaxation Plus Commodore, 83 Misc 2d 838, 840 [App Term, 1st Dept]).

12
Hines v. Davidowitzgreen
scotus · 1941 · cited in 2 New York opinions naming this issue, 1988–2005
2 sentences

2005Perez v. Campbell, 402 U.S. 637, 649 (1971) (quoting Hines v. Davidowitz, 312 U.S. 52, 67 [1941]).

1988Perez v. Campbell, 402 U.S. 637, 649 , 91 S.Ct. 1704, 1711 , 29 L.Ed.2d 233 (1971) (quoting Hines v. Davidowitz, 312 U.S. 52, 67 , 61 S.Ct. 399, 404 , 85 L.Ed. 581 (1941)).

12
Perez. v. Campbellgreen
scotus · 1971 · cited in 2 New York opinions naming this issue, 1988–2005
2 sentences

2005Perez v. Campbell, 402 U.S. 637, 649 (1971) (quoting Hines v. Davidowitz, 312 U.S. 52, 67 [1941]).

1988Perez v. Campbell, 402 U.S. 637, 649 , 91 S.Ct. 1704, 1711 , 29 L.Ed.2d 233 (1971) (quoting Hines v. Davidowitz, 312 U.S. 52, 67 , 61 S.Ct. 399, 404 , 85 L.Ed. 581 (1941)).

12
Yalango v. Poppgreen
ny · 1994 · cited in 1 New York opinions naming this issue, 2025–2025
1 sentence

2025Accordingly, it is, 1 Although fees premised upon the schedule set forth in Judiciary Law§ 474-a(2) generally "are calculated on the net sum recovered by the plaintiff after deducting 'full expenses and disbursements for expert testimony and investigative or other services properly chargeable to the enforcement of the claim or prosecution of the action'" (Yalango v Popp, 84 NY2d 601,606 [1994], quoting Judiciary Law§ 474- a[3] [emphasis added]), after the Legislature amended Judiciary Law§ 488(2)(d) in 2006 (see L 2006, ch 635, § 1), "in an action in which an attorney's fee is payable in whole

11
Claim of Katz v. A. Kadans & Co.green
ny · 1922 · cited in 1 New York opinions naming this issue, 2024–2024
1 sentence

2024Less than a decade after enactment of WCL § 21 (1), we considered the case of a “dairyman’s chauffeur” who, while driving his employer’s car and delivering cheese, was randomly stabbed by an “insane man” who “stabbed any one near him” (Katz v Kadans & Co., 232 NY 420, 421 [1922]).

11
People v. Lopezgreen
ny · 2006 · cited in 1 New York opinions naming this issue, 2016–2016
2 sentences

2016A defendant who has validly waived his right of appeal may not invoke this Court’s interest-of-justice jurisdiction to reduce a bargained-for sentence (People v Lopez, 6 NY3d 248, 255-256 [2006]), particularly where the waiver is documented by a writing.

2016A defendant who has validly waived his right of appeal may not invoke this Court's interest-of-justice jurisdiction to reduce a bargained-for sentence ( People v Lopez , 6 NY3d 248, 255-256 [2006]), particularly where the waiver is documented by a writing.

11
Brunswick Smart Growth, Inc. v. Town of Brunswickgreen
nyappdiv · 2010 · cited in 1 New York opinions naming this issue, 2011–2011
1 sentence

2011“Potential general harm does not constitute direct harm” (Matter of Brunswick Smart Growth, Inc. v Town of Brunswick, 73 AD3d 1267, 1268 [3d Dept 2010]).

11
Spearin, Preston & Burrows, Inc. v. City of New Yorkgreen
nyappdiv · 1990 · cited in 1 New York opinions naming this issue, 2008–2008
1 sentence

2008Damages are recoverable for delays caused by a contractee’s bad faith or willful, malicious or grossly negligent conduct, as are damages for uncontemplated delays, irrespective of such a clause (Spearin, Preston & Burrows v City of New York, 160 AD2d 263, 264 [1990]).

11
Zuckerman v. City of New Yorkgreen
ny · 1980 · cited in 1 New York opinions naming this issue, 2008–2008
1 sentence

2008Pursuant to Rules of the Appellate Division, Fourth Department (22 NYCRR) § 1022.31 (c), the contingent fee in a personal injury action is a “percentage [that] shall be computed on the net sum recovered after deducting from the amount recovered expenses and disbursements for expert testimony and investigative or other services properly chargeable to the enforcement of the claim or prosecution of the action.” The retainer agreement between Goins-Henry and defendant stated that “[attorneys’ fees are to be . . . calculated after expenses associated with prosecuting the case have been deducted fro

11
Town of Parishville v. Contore Co.green
nyappdiv · 1995 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Here, petitioners’ bare assertion that they relied on the oral statements allegedly made by the Town that no relevant laws existed does not constitute support for an estoppel (see Matter of Twin Town Little League v Town of Poestenkill, 249 AD2d 811, 812 [1998], lv denied 92 NY2d 806 [1998]; Town of Parishville v Contore Co., 215 AD2d 932, 934 [1995], lv dismissed 87 NY2d 918 [1996]).

11
Twin Town Little League, Inc. v. Town of Poestenkillgreen
nyappdiv · 1998 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Here, petitioners’ bare assertion that they relied on the oral statements allegedly made by the Town that no relevant laws existed does not constitute support for an estoppel (see Matter of Twin Town Little League v Town of Poestenkill, 249 AD2d 811, 812 [1998], lv denied 92 NY2d 806 [1998]; Town of Parishville v Contore Co., 215 AD2d 932, 934 [1995], lv dismissed 87 NY2d 918 [1996]).

11
Waste Recovery Enterprises, LLC v. Town of Unadillagreen
nyappdiv · 2002 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Nor will estoppel be invoked where, as here, “reasonable diligence by a good-faith inquirer would have disclosed the existence of the statute” or where the Town’s correction of an enforcement error will result in a harsh result to petitioners (Waste Recovery Enters, v Town of Unadilla, supra at 769; see Matter of Parkview Assoc. v City of New York, 71 NY2d 274, 282 [1988], appeal dismissed, cert denied 488 US 801 [1988]).

11
Brackenridge v. Ametek, Inc.green
scotus · 1988 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Nor will estoppel be invoked where, as here, “reasonable diligence by a good-faith inquirer would have disclosed the existence of the statute” or where the Town’s correction of an enforcement error will result in a harsh result to petitioners (Waste Recovery Enters, v Town of Unadilla, supra at 769; see Matter of Parkview Assoc. v City of New York, 71 NY2d 274, 282 [1988], appeal dismissed, cert denied 488 US 801 [1988]).

11
Parkview Associates v. City of New Yorkgreen
ny · 1988 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Nor will estoppel be invoked where, as here, “reasonable diligence by a good-faith inquirer would have disclosed the existence of the statute” or where the Town’s correction of an enforcement error will result in a harsh result to petitioners (Waste Recovery Enters, v Town of Unadilla, supra at 769; see Matter of Parkview Assoc. v City of New York, 71 NY2d 274, 282 [1988], appeal dismissed, cert denied 488 US 801 [1988]).

11
Reid v. County of Nassaugreen
nysupct · 1993 · cited in 1 New York opinions naming this issue, 1994–1994
11
Adams v. Town of Lisbongreen
nyappdiv · 1991 · cited in 1 New York opinions naming this issue, 1994–1994
11
Walker v. Town of Hempsteadgreen
nyappdiv · 1993 · cited in 1 New York opinions naming this issue, 1994–1994
11
Gross v. Grossgreen
nyappdiv · 1983 · cited in 1 New York opinions naming this issue, 1988–1988
11
In Re the Arbitration Between Weinrott & Carpgreen
ny · 1973 · cited in 1 New York opinions naming this issue, 1985–1985
11
Scherk v. Alberto-Culver Co.green
scotus · 1974 · cited in 1 New York opinions naming this issue, 1985–1985
11
Scarpuzza v. Blumgreen
nyappdiv · 1980 · cited in 1 New York opinions naming this issue, 1980–1980
11
People v. Snydergreen
· 1904 · cited in 1 New York opinions naming this issue, 1976–1976
11
Laurencelle v. Laurencellegreen
nyappdiv · 1926 · cited in 1 New York opinions naming this issue, 1949–1949
11
In re the Estate of Browngreen
nysurct · 1908 · cited in 1 New York opinions naming this issue, 1945–1945
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 (53)

CaseCitedYears
Pinnacle Books, Inc. v. Harlequin Enterprises Ltd. green
nysd · 1981
2 sentences

1988However, even when called upon to construe a clause in a contract expressly providing that a party is to apply his best efforts, a clear set of guidelines against which to measure a party’s best efforts is essential to the enforcement of such a clause (see, Mocca Lounge v Misak, supra, at 763; accord, Candid Prods. v International Skating Union, 530 F Supp 1330 ; Pinnacle Books v Harlequin Enters., 519 F Supp 118 ).

1983However, even when called upon to construe a clause in a contract expressly providing that a party is to apply his best efforts, a clear set of guidelines against which to measure a party’s best efforts is essential to the enforcement of such a clause (see Cross Props, v Brook Realty Co., 76 AD2d 445 ; accord Candid Prods, v International Skating Union, 530 F Supp 1330 ; Pinnacle Books v Harlequin Enterprises, 519 F Supp 118 ).

21983–1988
Schell v. Mayor of New York green
ny · 1891
2 sentences

1979The following quote from Schell v Mayor of New York ( 128 NY 67, 68-69 ) clearly states the applicable legal guidelines: "The usual and ordinary remedy of a party, for the enforcement of a claim against another, is an action in a court of law or equity but, as between attorney and client, it has long been settled that a proceeding of this character, to compel the attorney to pay over money received by him and which belongs to the client, may be entertained and is within the power of the court.

1930As is said by the Court of Appeals in Schell v. Mayor, etc. ( 128 N. Y. 67, at p. 68 ): “ The usual and ordinary remedy of a party, for the enforcement of a claim against another, is an action in a court of law or equity but, as between attorney and client, it has long been settled that a proceeding of this character, to compel the attorney to pay over money received by him and which belongs to the client, may be entertained and is within the power of the court.

21930–1979
Tompkins v. State green
nyclaimsct · 1962
2 sentences

1973(Tompkins v. State of New York, 33 Misc 2d 828 ; Tomlinson Constr.

1972(Tompkins v. State of New York, 33 Misc 2d 828 ; Tomlinson Constr.

21972–1973
Sporn v. Hudson Transit Lines neutral
nyappdiv · 1942
2 sentences

1965Lines, 265 App. Div. 360, 362 .) The court notes that plaintiff has proffered nothing other than conclusory, naked assertions to militate against the relief requested by defendant.

1948Such a counterclaim, if permitted to remain, might prejudice the conduct of an orderly trial. “ The avoidance of a multiplicity of suits is much to be desired, but where, as here, the enforcement of such a rule might occasion prejudice to appellant’s substantial rights and might tend to confuse the jury, the divergent causes of action should be separately tried.” (Sporn v. Hudson Transit Lines, 265 App. Div. 360, 362 .) The order accordingly should be reversed, with $20 costs and disbursements to the appellant and the motion to dismiss the partial defense and counterclaim and the complete defe

21948–1965
King v. Ashley neutral
nyappdiv · 1904
2 sentences

1908The district attorney bases his contention upon the theory that, the object of the statute having been voluntarily defeated by the party for whose benefit it was enacted, there can be no reason for the enforcement of the rule which protects the confidential character of a communication between attorney and client, and cites these authorities: Hurlburt v. Hurlburt, 128 N. Y. 420 ; Matter of King v. Ashley, 96 App. Div. 143 ; Lecour v. Importers & Traders’ National Bank, 61 id. 163 ; McKinney v. Grand St., Prospect Pk. & F. R.

1908The district attorney bases his contention upon the theory that, the object of the statute having been voluntarily defeated by the party for whose benefit it was enacted, there can be no reason for the enforcement of the rule which protects the confidential character of a communication between attorney and client, and cites these authorities: Hurlburt v. Hurlburt, 128 N. Y. 420 ; Matter of King v. Ashley, 96 App. Div. 143 ; Lecour v. Importers & Traders’ National Bank, 61 id. 163 ; McKinney v. Grand St., Prospect Pk. & F. R.

21908–1908
McKinney v. Grand Street, Prospect Park & Flatbush Railroad green
ny · 1887
2 sentences

1908R., 104 N. Y. 352 ; Marx v. Manhattan R.

1908R., 104 N. Y. 352 ; Marx v. Manhattan R.

21908–1908
Hurlburt v. . Hurlburt green
ny · 1891
2 sentences

1908The district attorney bases his contention upon the theory that, the object of the statute having been voluntarily defeated by the party for whose benefit it was enacted, there can be no reason for the enforcement of the rule which protects the confidential character of a communication between attorney and client, and cites these authorities: Hurlburt v. Hurlburt, 128 N. Y. 420 ; Matter of King v. Ashley, 96 App. Div. 143 ; Lecour v. Importers & Traders’ National Bank, 61 id. 163 ; McKinney v. Grand St., Prospect Pk. & F. R.

1908The district attorney bases his contention upon the theory that, the object of the statute having been voluntarily defeated by the party for whose benefit it was enacted, there can be no reason for the enforcement of the rule which protects the confidential character of a communication between attorney and client, and cites these authorities: Hurlburt v. Hurlburt, 128 N. Y. 420 ; Matter of King v. Ashley, 96 App. Div. 143 ; Lecour v. Importers & Traders’ National Bank, 61 id. 163 ; McKinney v. Grand St., Prospect Pk. & F. R.

21908–1908
In Re the Probate of the Will of Smith green
ny · 1884
2 sentences

1902As was said by Judge Andrews in Matter of Smith (supra): “ The law is not so impracticable as to refuse to take notice of the influence of greed and selfishness upon human conduct, and in the case supposed it wisely interposes by adjusting the quality and measure of proof to the circumstances, to protect the weaker party and, as far as may be, to make it certain that trust and confidence have not been perverted or abused.” In cases where a testamentary disposition is made of which those interested in the decedent’s property have no knowledge until after his death, and when his lips are sealed

1902As was said by Judge Andrews in Re Smith, supra: “Tbe law Is not so impracticable as to refuse to take notice of tbe influence of greed and selfishness upon human conduct, and in tbe case supposed it wisely interposes by adjusting tbe quality and measure of proof to tbe circumstances, to protect tbe weaker party, and, as far as may be, to make it certain that trust and confidence have not been perverted or abused.” In cases where a testamentary disposition is made of which those interested in the decedent’s property have no knowledge until after his death, and when his lips are sealed, so that

21902–1902
Cheney v. . Troy Hospital Association neutral
ny · 1875
2 sentences

1898Here, however, the provision for the retention of the percentage was in the agreement also between the contractor and the sub-contractor, and it would be manifestly unjust to hold that it availed nothing to a materialman having a' claim against the sub-contractor for materials furnished, when he had .been induced by both parties to the sub-contract to postpone the enforcement of that claim by representations that such percentage would be retained.' The respondents also cite McMillan v. Seneca Lake Grape & Wine Co. ( 5 Hun, 12 ) and Cheney v. Troy Hospital Association ( 65 N. Y. 282 ) in suppor

1898The respondents also cite McMillan v. Wine Co., 5 Hun, 12 , and Cheney v. Association, 65 N. Y. 282 , in support of the proposition that where ■the contract has been abandoned, and the contractor (or, in a case like the present, the subcontractor) has been fully paid for all work done prior to the time the lien is filed, the lien must fail, because nothing can thereafter be due the contractor.

21898–1898
National Bank v. . Dillingham green
ny · 1895
2 sentences

1896The case of The National Bank v. Dillingham, supra, was decided upon a claim of liability under section 24 of the Stock Corporation Law (chapter 688, Laws of 1892), which in no manner provided for the enforcement of the claim against the corporation first, but declared that the directors creating or consenting to a debt increasing the total indebtedness of the corporation, not secured by mortgage, beyond its paid-up capital stock, should be personally liable therefor to the creditors of the corporation.

1896The case of The National Bank v. Dillingham, supra, was decided upon a claim of liability under section 24 of the Stock Corporation Law (chapter 688, Laws of 1892), which in no manner provided for the enforcement of the claim against the corporation first, but declared that the directors creating or consenting to a debt increasing the total indebtedness of the corporation, not secured by mortgage, beyond its paid-up capital stock, should be personally liable therefor to the creditors of the corporation.

21896–1896
Freeford Ltd. v. Pendleton green
nyappdiv · 2008
1 sentence

2024Freeford Ltd. , 53 AD3d at 39 .

12024–2024
Ferrara v. City of New York neutral
nynyccityct · 1946
1 sentence

1999(See generally, 10th Ann Report of NY Jud Council, at 270, 274, 275 [1944]; Ferrara v City of New York, 187 Misc 478 [NY City Ct, Bronx County 1946].) Indeed, General Municipal Law § 50-e (4) provides that: “No other or further notice, no other or further service, filing or delivery of the notice of claim, and no notice of intention to commence an action or special proceeding, shall be required as a condition to the commencement of an action or special proceeding for the enforcement of the claim.” Defendants also rely on Robles v City of New York ( 251 AD2d 485 [2d Dept 1998], lv granted 93 NY

11999–1999
Robles v. City of New York neutral
nyappdiv · 1998
1 sentence

1999(See generally, 10th Ann Report of NY Jud Council, at 270, 274, 275 [1944]; Ferrara v City of New York, 187 Misc 478 [NY City Ct, Bronx County 1946].) Indeed, General Municipal Law § 50-e (4) provides that: “No other or further notice, no other or further service, filing or delivery of the notice of claim, and no notice of intention to commence an action or special proceeding, shall be required as a condition to the commencement of an action or special proceeding for the enforcement of the claim.” Defendants also rely on Robles v City of New York ( 251 AD2d 485 [2d Dept 1998], lv granted 93 NY

11999–1999
Tyner v. City of Buffalo green
nyappdiv · 1989
11994–1994
Alwinseal, Inc. v. Travelers Indemnity Co. green
nyappdiv · 1978
11985–1985
Matter of Arbitration Between Schachter (Lester Witte & Co.) green
nyappdiv · 1976
11985–1985
Cross Properties, Inc. v. Brook Realty Co. green
nyappdiv · 1980
11983–1983
BLUM, COMMISSIONER OF NEW YORK STATE DEPARTMENT OF SOCIAL SERVICES v. CALDWELL Et Al. green
scotus · 1980
11980–1980
Zumbo v. Town of Farmington green
nyappdiv · 1978
11978–1978
Helvering v. Mitchell green
scotus · 1938
11976–1976
In Re the Accounting of Gruner green
ny · 1946
11976–1976
In re the Estate of Rubin neutral
nysurct · 1973
11976–1976
Shapiro v. Collins neutral
nyappterm · 1958
11975–1975
English-Speaking Union (New York), Inc. v. Payson neutral
nyappdiv · 1958
11975–1975
47 East 74th Street Corp. v. Simon neutral
nyappterm · 1947
11975–1975
Robin P. Allen v. The Cloisters Building Corporation neutral
scotus · 1936
11966–1966
In re Bernard green
ca2 · 1922
11966–1966
State v. Boyd neutral
sc · 1900
11966–1966
Teubert v. Kessler neutral
ca3 · 1924
11966–1966
Planert v. Cosmopolitan Bond & Mortgage Co. neutral
ca7 · 1935
11966–1966
Newburgh v. Clarendon Gardens, Inc. neutral
nysupct · 1962
11965–1965
Lyon v. . Hersey green
ny · 1886
11963–1963
Norman S. Riesenfeld, Inc. v. R-W Realty Co. green
nyappdiv · 1928
11963–1963
Burnee Corp. v. Uneeda Pure Orange Drink Co. green
nyappterm · 1928
11963–1963
Burns v. . McCormick green
ny · 1922
11961–1961
Schindler v. Royal Insurance Co. green
ny · 1932
11960–1960
Williams v. . Hays green
ny · 1894
11956–1956
National Surety Co. v. Ruffin green
ny · 1926
11949–1949
Hewlett v. Van Voorhis green
nyappdiv · 1921
11948–1948
Lobee v. Williams neutral
nyappdiv · 1929
11948–1948

Where else courts name it

TX 85 (1902–2025) NY 76 (1880–2025) IL 41 (1881–2023) PA 37 (1895–2026) AL 35 (1877–2026) CA 33 (1898–2025) MO 32 (1891–2018) OK 28 (1911–2020) MD 24 (1869–2026) AK 23 (1970–2018) NJ 21 (1951–2024) AR 20 (1909–2025) FL 18 (1889–2018) KS 17 (1895–2024) MS 17 (1895–2023) IN 16 (1894–2024) HI 16 (1969–2025) IA 15 (1871–2014) NC 14 (1903–2025) WA 13 (1905–2018) MI 13 (1878–2019) GA 13 (1936–2020) OH 13 (1910–2020) LA 13 (1906–2023) CT 12 (1926–2025) TN 11 (1897–2015) WI 11 (1899–2010) NE 10 (1891–2020) AZ 10 (1933–2022) OR 9 (1914–2005) MA 9 (1921–2026) KY 7 (1911–1970) DC 7 (1902–2017) SC 7 (1887–2011) MT 6 (1913–2006) MN 5 (1889–1982) ME 5 (1879–1993) VA 4 (1886–1952) NM 4 (1918–2003) CO 4 (1910–2007) WV 4 (1905–1992) DE 3 (1992–2025) ID 3 (1908–1963) WY 3 (1908–1964) UT 3 (1935–2009) VT 2 (1962–1988) VI 2 (2001–2006) SD 2 (1894–1909)

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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