circumstances challenge (Ohio) · Go Syfert
← Ohio issues

circumstances challenge in Ohio

76 Ohio opinions name it 4 courts 1902–2025 17 in the last five years

The cases below were cited by Ohio 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 (28)

CaseFollowedCited
Bertell Ollman v. Rowland Evans, Robert Novakgreen
cadc · 1984 · cited in 4 Ohio opinions naming this issue, 2001–2006
2 sentences

2006See, also, Ollman v. Evans (D.D.C.1984), 750 F.2d 970 , 979-984 .

2002See, also, Ollman v. Evans (D.D.C. 1984), 750 F.2d 970 , 979-984 . {¶ 39} The weight given to any one factor under this inquiry will vary depending on the circumstances of each case.

44
State v. Clarkgreen
ohio · 1988 · cited in 6 Ohio opinions naming this issue, 2002–2024
2 sentences

2016“Evidence of use by the interrogators of an inherently coercive tactic (e.g., physical abuse, threats, deprivation of food, medical treatment, or sleep) will trigger [a] totality of the circumstances analysis.” State v. Clark, 38 Ohio St.3d 252, 261 , 527 N.E.2d 844 (1988).

2016“Evidence of use by the interrogators of an inherently coercive tactic (e.g., physical abuse, threats, deprivation of food, medical treatment, or sleep) will trigger [a] totality of the circumstances analysis.” State v. Clark, 38 Ohio St.3d 252, 261 , 527 N.E.2d 844 (1988).

26
In re Burtongreen
ohio · 1984 · cited in 2 Ohio opinions naming this issue, 2018–2022
2 sentences

2022Importantly, when “assessing whether a defendant is a mentally ill person subject to court order,” a trial court is “to consider the totality of the circumstances.” Id. at ¶ 29, citing Williams, 126 Ohio St.3d 65 , 2010-Ohio-2453 , at ¶ 15 and In re Burton, 11 Ohio St.3d 147, 149-150 (1984) (outlining the factors for a trial court to consider when conducting its totality of the circumstances analysis). {¶48} Here, the trial court concluded that the State presented clear and convincing evidence that Sims is a mentally ill person subject to court order.

2018See also In re Burton at 149-150 (outlining a variety of factors for the court to consider in conducting its totality of the circumstances analysis). {¶30} If a trial court determines that the State has set forth clear and convincing evidence to satisfy the elements of R.C. 2945.39(A)(2)(a) and (b), “the court shall commit the 14 defendant.” R.C. 2945.39(D)(1).

22
Surace v. Wuligergreen
ohio · 1986 · cited in 2 Ohio opinions naming this issue, 2022–2022
2 sentences

2022See Surace v. Wuliger, 25 Ohio St.3d 229, 231-233 , 495 N.E.2d 939 (1986). {¶ 21} Early on, this court acknowledged that there were many views on the litigation privilege, ranging from absolute privilege for all statements made during judicial proceedings, to all relevant statements made during judicial proceedings, to all not false and malicious statements made during judicial proceedings.

2022In State v. Brown, __Ohio St.3d__, 2022-Ohio-4347 , the No. 22AP-242 8 court observed that while the privilege "is a deeply rooted common-law rule that protects individuals from defamation lawsuits," it described the "English rule" as "broad" and contrasted it with Ohio's version of the rule, which "limits the types of defamatory statements that are considered privileged and limits the circumstances in which the privilege applies." Id. at ¶ 20, citing Surace v. Wuliger, 25 Ohio St.3d 229, 231-233 (1986).

22
State v. Fraziergreen
ohio · 2007 · cited in 7 Ohio opinions naming this issue, 2015–2022
2 sentences

2021"The critical issue is whether discriminatory intent is inherent in counsel's explanation for use of the strike; intent is present if the explanation is merely a pretext for exclusion on the basis of race." Hicks at 98 , citing Hernandez at 363 . {¶ 27} "Finally, [under the third prong,] the court must decide, based on all the circumstances, whether the defendant has proved purposeful racial discrimination." State v. Johnson, 144 Ohio St.3d 518 , 2015-Ohio-4903, ¶ 21 , citing Batson at 98 . " 'In doing so, the court must consider the circumstances of the challenge and access [sic] the plausibi

2016"In doing so, the court No. 15AP-544 16 must consider the circumstances of the challenge and access the plausibility of the prosecutor's explanation in order to determine whether it is merely pretextual." Id., citing Miller-El I and State v. Frazier, 115 Ohio St.3d 139 , 2007-Ohi0-5048, ¶ 65.

17
Miller-El v. Cockrellgreen
scotus · 2003 · cited in 5 Ohio opinions naming this issue, 2015–2018
2 sentences

2016“In doing so, the court must consider the circumstances of the challenge and assess the plausibility of the prosecutor’s explanation in order to determine whether it is merely pretextual.” Johnson, 144 Ohio St.3d 518 , 2015-Ohio-4903 , --- N.E.3d ----, at ¶ 21, citing Miller-El v. Cockrell, 537 U.S. 322, 339 , 123 S.Ct. 1029 , 154 L.Ed.2d 931 (2003); State v. Frazier, 115 Ohio St.3d 139 , 2007-Ohio-5048 , 873 N.E.2d 1263 , ¶ 65.

2016“In doing so, the court must consider the circumstances of the challenge and assess the plausibility of the prosecutor’s explanation in order to determine whether it is merely pretextual.” Johnson, 144 Ohio St.3d 518 , 2015-Ohio-4903 , --- N.E.3d ----, at ¶ 21, citing Miller-El v. Cockrell, 537 U.S. 322, 339 , 123 S.Ct. 1029 , 154 L.Ed.2d 931 (2003); State v. Frazier, 115 Ohio St.3d 139 , 2007-Ohio-5048 , 873 N.E.2d 1263 , ¶ 65.

15
State ex rel. Massie v. Board of Education of Gahanna-Jefferson Public Schoolsgreen
ohio · 1996 · cited in 2 Ohio opinions naming this issue, 1998–1998
2 sentences

1998Massie, 76 Ohio St.3d at 589 , 669 N.E.2d at 843 .

1998Massie, 76 Ohio St.3d at 589 , 669 N.E.2d at 843 .

12
Maryland v. Wilsongreen
scotus · 1997 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025Maryland v. Wilson, 519 U.S. 408, 414 (1997); accord State v. Grubbs, 2017-Ohio-41, ¶ 29 (6th Dist.).

11
State v. Gurleygreen
ohioctapp · 2015 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025State v. Gurley, 2015-Ohio-5361, ¶ 16 (4th Dist.), citing State v. Roberts, 2006-Ohio-3665 , ¶ 100; State v. Jones, 2022-Ohio- 561, ¶ 15 (4th Dist.).

11
State v. Grubbsgreen
ohioctapp · 2017 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025Maryland v. Wilson, 519 U.S. 408, 414 (1997); accord State v. Grubbs, 2017-Ohio-41, ¶ 29 (6th Dist.).

11
State v. Campbellgreen
ohio · 2000 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024See State v. Osie, 2014- Ohio-2966, ¶ 179, citing State v. Campbell, 90 Ohio St.3d 320 (2000), [paragraph three of the syllabus].

11
R.H. v. J.H.green
ohioctapp · 2020 · cited in 1 Ohio opinions naming this issue, 2023–2023
1 sentence

2023R.H. v. J.H., 2020-Ohio-3402, ¶ 9-14 (trial court abused its discretion in denying respondent’s request for a continuance of the full hearing of a domestic violence civil protection order so that he could obtain counsel where, “[r]ather than engaging in any consideration of the particular circumstances and factors surrounding the request as set forth in Unger,” the magistrate denied the request based solely on a perceived need for expediency in the proceedings); cf. Slusser v. Klosterman, 3d Dist.

11
Arthur Theiss v. Gordon H. Scherergreen
ca6 · 1968 · cited in 1 Ohio opinions naming this issue, 2022–2022
1 sentence

2022The English rule, as explained above, is broad, see Theiss v. Scherer, 396 F.2d 646, 649 (6th Cir.1968); whereas the American rule, which was adopted by this court, limits the types of defamatory statements that are considered privileged and limits the circumstances in which the privilege applies.

11
Wampler v. Higginsgreen
ohio · 2001 · cited in 1 Ohio opinions naming this issue, 2021–2021
11
In re N.S.green
ohioctapp · 2017 · cited in 1 Ohio opinions naming this issue, 2021–2021
11
Miller-El v. Dretkegreen
scotus · 2005 · cited in 1 Ohio opinions naming this issue, 2016–2016
11
Upjohn Co. v. Ohio Department of Human Servicesgreen
ohioctapp · 1991 · cited in 1 Ohio opinions naming this issue, 2016–2016
11
State v. Johnson, 2006-Ca-04 (4-10-2007)green
ohioctapp · 2007 · cited in 1 Ohio opinions naming this issue, 2007–2007
11
Dunlop v. United Statesgreen
scotus · 1897 · cited in 1 Ohio opinions naming this issue, 2004–2004
11
State v. Treeshgreen
ohio · 2001 · cited in 1 Ohio opinions naming this issue, 2004–2004
11
State v. Maurergreen
ohio · 1984 · cited in 1 Ohio opinions naming this issue, 2004–2004
11
Archbold Truck Line, Inc. v. Pub. Util. Comm.green
ohio · 1994 · cited in 1 Ohio opinions naming this issue, 2004–2004
11
State v. Treeshgreen
ohio · 2001 · cited in 1 Ohio opinions naming this issue, 2004–2004
11
Texas v. Grangergreen
scotus · 1985 · cited in 1 Ohio opinions naming this issue, 2004–2004
11
In re Disbarment of Whittingtongreen
scotus · 1985 · cited in 1 Ohio opinions naming this issue, 2004–2004
11
In re Hollandgreen
scotus · 1985 · cited in 1 Ohio opinions naming this issue, 2004–2004
11
Wilson v. Trexlergreen
sc · 1916 · cited in 1 Ohio opinions naming this issue, 2004–2004
11
State v. Poolegreen
ohioctapp · 1996 · cited in 1 Ohio opinions naming this issue, 2004–2004
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (52)

CaseCitedYears
State v. Johnson (Slip Opinion) green
ohio · 2015
2 sentences

2021"The critical issue is whether discriminatory intent is inherent in counsel's explanation for use of the strike; intent is present if the explanation is merely a pretext for exclusion on the basis of race." Hicks at 98 , citing Hernandez at 363 . {¶ 27} "Finally, [under the third prong,] the court must decide, based on all the circumstances, whether the defendant has proved purposeful racial discrimination." State v. Johnson, 144 Ohio St.3d 518 , 2015-Ohio-4903, ¶ 21 , citing Batson at 98 . " 'In doing so, the court must consider the circumstances of the challenge and access [sic] the plausibi

2021"The critical issue is whether discriminatory intent is inherent in counsel's explanation for use of the strike; intent is present if the explanation is merely a pretext for exclusion on the basis of race." Hicks at 98 , citing Hernandez at 363 . {¶ 27} "Finally, [under the third prong,] the court must decide, based on all the circumstances, whether the defendant has proved purposeful racial discrimination." State v. Johnson, 144 Ohio St.3d 518 , 2015-Ohio-4903, ¶ 21 , citing Batson at 98 . " 'In doing so, the court must consider the circumstances of the challenge and access [sic] the plausibi

82016–2022
Scott v. News-Herald green
ohio · 1986
2 sentences

2006First is the specific language used, second is whether the statement is verifiable, third is the general context of the statement and fourth is the broader context in which the statement appeared.' Scott , 25 Ohio St.3d at 250 . 'This analysis is not a bright-line test[.]' Vail , 72 Ohio St.3d at 282 . '[T]he totality of the circumstances test * * * can only be used as a compass to show general direction and not a map to set rigid boundaries.' Id., quoting Scott , 25 Ohio St.3d at 250 .

2006First is the specific language used, second is whether the statement is verifiable, third is the general context of the statement and fourth is the broader context in which the statement appeared.' Scott , 25 Ohio St.3d at 250 . 'This analysis is not a bright-line test[.]' Vail , 72 Ohio St.3d at 282 . '[T]he totality of the circumstances test * * * can only be used as a compass to show general direction and not a map to set rigid boundaries.' Id., quoting Scott , 25 Ohio St.3d at 250 .

62001–2023
Vail v. Plain Dealer Publishing Co. green
ohio · 1995
2 sentences

2006First is the specific language used, second is whether the statement is verifiable, third is the general context of the statement and fourth is the broader context in which the statement appeared.' Scott , 25 Ohio St.3d at 250 . 'This analysis is not a bright-line test[.]' Vail , 72 Ohio St.3d at 282 . '[T]he totality of the circumstances test * * * can only be used as a compass to show general direction and not a map to set rigid boundaries.' Id., quoting Scott , 25 Ohio St.3d at 250 .

2006First is the specific language used, second is whether the statement is verifiable, third is the general context of the statement and fourth is the broader context in which the statement appeared.' Scott , 25 Ohio St.3d at 250 . 'This analysis is not a bright-line test[.]' Vail , 72 Ohio St.3d at 282 . '[T]he totality of the circumstances test * * * can only be used as a compass to show general direction and not a map to set rigid boundaries.' Id., quoting Scott , 25 Ohio St.3d at 250 .

62001–2021
Lepera v. Fuson green
ohioctapp · 1992
2 sentences

2007Lepera v. Fuson (1992), 83 Ohio App.3d 17, 26 , 613 N.E.2d 1060 .

2007Lepera v. Fuson (1992), 83 Ohio App.3d 17, 26 , 613 N.E.2d 1060 .

22007–2007
State v. Parker green
ohio · 1990
2 sentences

2006State v. Parker (1990), 53 Ohio St.3d 82 , 558 N.E.2d 1164 .

2006State v. Parker (1990), 53 Ohio St.3d 82 , 558 N.E.2d 1164 .

22006–2006
State v. Schoen green
ohio · 1990
2 sentences

2006State v. Parker (1990), 53 Ohio St.3d 82 , 558 N.E.2d 1164 .

2006State v. Parker (1990), 53 Ohio St.3d 82 , 558 N.E.2d 1164 .

22006–2006
Illinois v. Gates green
scotus · 1983
2 sentences

1995With regard to the first step, the court adopted the “totality of the circumstances test” of Illinois v. Gates (1983), 462 U.S. 213 , 103 S.Ct. 2317 , 76 L.Ed.2d 527 , and articulated that test as follows: “In determining the sufficiency of probable cause in an affidavit submitted in support of a search warrant, ‘[t]he task of the issuing magistrate is simply to make a practical, common-sense decision whether, given all the circumstances set forth in the affidavit before him, including the “veracity” and “basis of knowledge” of persons supplying hearsay information, there is a fair probability

1995With regard to the first step, the court adopted the “totality of the circumstances test” of Illinois v. Gates (1983), 462 U.S. 213 , 103 S.Ct. 2317 , 76 L.Ed.2d 527 , and articulated that test as follows: “In determining the sufficiency of probable cause in an affidavit submitted in support of a search warrant, ‘[t]he task of the issuing magistrate is simply to make a practical, common-sense decision whether, given all the circumstances set forth in the affidavit before him, including the “veracity” and “basis of knowledge” of persons supplying hearsay information, there is a fair probability

21995–2005
Lord v. Daugherty green
ohio · 1981
2 sentences

2004Appellant refers to Lord v. Daugherty (1981), 66 Ohio St.2d 441 , 20 O.O.3d 376 , 423 N.E.2d 96 ; and Hampton v. Trimble (1995), 101 Ohio App.3d 282 , 655 N.E.2d 432 , and argues that because the accident occurred on the street outside Adkins’s home, and because appellee (her employer) benefited by her being there, she should recover under this test.

1991Applying the principles of liberal construction, the totality of the circumstances and the factors set forth in Lord, supra, to the case sub judice, we find that decedent's injury arose out of and in the course of his employment and is, therefore, compensable under R.C. 4123.01(C).

21991–2004
In re Watson green
ohio · 1989
2 sentences

2003Fare v, Michael C. (1979), 442 U.S.707; In re Watson (1989), 47 Ohio St.3d 86 , 89-90 .

1998Fare v. Michael C. (1979), 442 U.S. 707 , 99 S.Ct. 2560 , 61 L.Ed.2d 197 ; In re Watson (1989), 47 Ohio St.3d 86, 89-90 , 548 N.E.2d 210, 213-215 .

21998–2003
State ex rel. Bossa v. Giles green
ohio · 1980
2 sentences

1995Bossa v. Giles (1980), 64 Ohio St.2d 273, 276 , 18 O.O.3d 461 , 462- 463, 415 N.E.2d 256, 258 . {¶ 13} Based on the foregoing, the availability of a breach of contract action does not bar the issuance of a writ of mandamus under the particular circumstances at bar.

1995Bossa v. Giles (1980), 64 Ohio St.2d 273, 276 , 18 O.O.3d 461 , 462- 463, 415 N.E.2d 256, 258 . {¶ 13} Based on the foregoing, the availability of a breach of contract action does not bar the issuance of a writ of mandamus under the particular circumstances at bar.

21995–1995
Batson v. Kentucky green
scotus · 1986
1 sentence

2022Id., citing Batson at 98 . {¶ 40} In reaching its determination, the trial court must consider the circumstances of the challenge and assess the plausibility of the prosecutor’s explanation for discriminatory pretext.

12022–2022
State v. Brown neutral
ohio · 2022
1 sentence

2022In State v. Brown, __Ohio St.3d__, 2022-Ohio-4347 , the No. 22AP-242 8 court observed that while the privilege "is a deeply rooted common-law rule that protects individuals from defamation lawsuits," it described the "English rule" as "broad" and contrasted it with Ohio's version of the rule, which "limits the types of defamatory statements that are considered privileged and limits the circumstances in which the privilege applies." Id. at ¶ 20, citing Surace v. Wuliger, 25 Ohio St.3d 229, 231-233 (1986).

12022–2022
Wyatt v. Autozone, Inc., Unpublished Decision (12-15-2003) green
ohioctapp · 2003
1 sentence

2022Van Wert No. 15-03-05, 2003-Ohio-6706 (totality of the circumstances exception applied when the injury occurred in the parking lot of the store where the employee was working at that time and the parking lot was under the control of the employer); Owens v. Giant Eagle, Inc., 8th Dist.

12022–2022
State v. Williams green
ohio · 2010
2 sentences

2022Importantly, when “assessing whether a defendant is a mentally ill person subject to court order,” a trial court is “to consider the totality of the circumstances.” Id. at ¶ 29, citing Williams, 126 Ohio St.3d 65 , 2010-Ohio-2453 , at ¶ 15 and In re Burton, 11 Ohio St.3d 147, 149-150 (1984) (outlining the factors for a trial court to consider when conducting its totality of the circumstances analysis). {¶48} Here, the trial court concluded that the State presented clear and convincing evidence that Sims is a mentally ill person subject to court order.

2022Importantly, when “assessing whether a defendant is a mentally ill person subject to court order,” a trial court is “to consider the totality of the circumstances.” Id. at ¶ 29, citing Williams, 126 Ohio St.3d 65 , 2010-Ohio-2453 , at ¶ 15 and In re Burton, 11 Ohio St.3d 147, 149-150 (1984) (outlining the factors for a trial court to consider when conducting its totality of the circumstances analysis). {¶48} Here, the trial court concluded that the State presented clear and convincing evidence that Sims is a mentally ill person subject to court order.

12022–2022
Stair v. Mid Ohio Home Health Ltd. neutral
ohioctapp · 2011
1 sentence

2022Richland No. 2010-CA-0114, 2011-Ohio-2351 (accident occurred on a sidewalk under the employer’s control, not on a public roadway). {¶36} Cases in which the totality of the circumstances exception applies are those where the accident occurs at a location where the employer physically controls the scene.

12022–2022
Metro Diplomat Healthcare green
ohioctapp · 2014
1 sentence

2022Cuyahoga No. 100799, 2014-Ohio-3146, ¶ 2 . 3 Civ.R. 10(D)(2)(c) details the circumstances and factors the court is to consider in determining whether good cause exists to grant the plaintiff an extension of time to file the affidavit of merit.

12022–2022
American Chemical Society v. Leadscope, Inc. green
ohio · 2012
12021–2021
State v. Darmond green
ohio · 2013
2 sentences

2021State v. Darmond, 135 Ohio St.3d 343 , 2013-Ohio-966 , 986 N.E.2d 971, ¶ 35 .

2021State v. Darmond, 135 Ohio St.3d 343 , 2013-Ohio-966 , 986 N.E.2d 971, ¶ 35 .

12021–2021
State v. Thompson (Slip Opinion) green
ohio · 2014
12021–2021
Maryland v. Pringle green
scotus · 2003
12018–2018
State v. Green green
ohioctapp · 2009
12017–2017
State v. Minton green
ohioctapp · 2016
12017–2017
In Re Wilson, Unpublished Decision (6-27-2005) green
ohioctapp · 2005
12017–2017
March v. Steed Ents., Inc. neutral
ohioctapp · 2013
12016–2016
United States v. James and Mallay green
ca2 · 2013
12014–2014
State v. Gumm green
ohio · 1995
12013–2013
State v. Gumm green
ohio · 1995
12013–2013
State v. Bodyke green
ohio · 2010
12011–2011
Von Moltke v. Gillies green
scotus · 1948
12010–2010
McClain v. McClain green
ohio · 1984
12007–2007
State v. Lafreniere green
ohioctapp · 1993
12007–2007
State v. Souel green
ohio · 1978
12006–2006
City of Lakewood v. Papadelis green
ohio · 1987
12006–2006
Swidler & Berlin v. United States green
scotus · 1998
12005–2005
Jorg v. Cincinnati Black United Front green
ohioctapp · 2003
12005–2005
Didier v. Johns green
ohioctapp · 1996
12005–2005
Still v. McLemore Warden green
scotus · 2003
12004–2004
State v. Retherford green
ohioctapp · 1994
12004–2004
Neil v. Biggers green
scotus · 1972
12004–2004
State v. Lynch green
ohio · 2003
12004–2004

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2903.11 (7) OH § Ohio Rev. Code § 2901.01 (5) OH § Ohio Rev. Code § 2901.22 (5) OH § Ohio Rev. Code § 2903.02 (5) OH § Ohio Rev. Code § 2903.13 (5) OH § Ohio Rev. Code § 2903.04 (4) OH § Ohio Rev. Code § 2905.01 (4) OH § Ohio Rev. Code § 2929.14 (4) OH § Ohio Rev. Code § 2903.01 (3) OH § Ohio Rev. Code § 2925.03 (3) OH § Ohio Rev. Code § 2925.11 (3) OH § Ohio Rev. Code § 2945.371 (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 214 (1885–2025) CA 182 (1900–2026) PA 125 (1903–2026) IL 121 (1856–2026) TX 115 (1908–2025) OH 76 (1902–2025) FL 62 (1933–2020) NJ 61 (1949–2026) WI 60 (1915–2026) MD 52 (1964–2025) MA 49 (1917–2020) VA 43 (1877–2023) NC 42 (1924–2026) GA 42 (1905–2025) LA 41 (1965–2020) TN 40 (1918–2026) MO 39 (1897–2021) IN 33 (1925–2020) CO 32 (1945–2026) AL 30 (1926–2024) WA 29 (1960–2026) MT 28 (1912–2020) OR 28 (1959–2026) NE 28 (1932–2026) MI 27 (1921–2026) CT 27 (1978–2026) WY 26 (1934–2026) KY 26 (1916–2023) MN 26 (1949–2024) KS 26 (1926–2025) AZ 26 (1963–2022) VT 26 (1913–2026) NM 22 (1990–2023) SD 18 (1940–2024) MS 16 (1921–2020) HI 16 (1925–2021) DC 16 (1973–2024) IA 16 (1915–2023) ND 13 (1974–2012) ID 12 (1925–2024) DE 12 (1977–2026) NV 11 (1948–2026) AR 11 (1956–2001) ME 11 (1965–2022) UT 11 (1985–2024) SC 10 (1925–2024) OK 9 (1910–2021) WV 8 (1940–2026) NH 8 (1973–2021) AK 7 (1976–1996) RI 6 (1971–2012) VI 3 (2006–2012)

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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