demand rule (Georgia) · Go Syfert
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demand rule in Georgia

10 Georgia opinions name it 2 courts 1907–2025 1 in the last five years

The cases below were cited by Georgia 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 (9)

CaseFollowedCited
Barker v. Wingogreen
scotus · 1972 · cited in 2 Georgia opinions naming this issue, 2008–2008
2 sentences

2008See Barker, supra, 407 U. S. at 529 (“We hardly need add that if delay is attributable to the defendant, then his waiver may he given effect under standard waiver doctrine, the demand rule aside.”).

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

12
Cox Enterprises, Inc. v. Nixgreen
ga · 2000 · cited in 1 Georgia opinions naming this issue, 2012–2012
2 sentences

2012Additionally, “[e]nforcing the statute according to its terms also serves the salutary function of eliminating the need for courts to evaluate, as this court is asked to do in this case, whether failing to make a demand was excusable.” Albers, 31 P3d at 829 (F) (1) (b) (¶ 33). 32 See OCGA § 14-11-801 (3) (requiring, before a member commences a derivative action, that “[90] days have expired from the date the demand was made unless the member has earlier been notified that the demand has been rejected by the limited liability company or unless irreparable injury to the limited liability company

2012Additionally, “[e]nforcing the statute according to its terms also serves the salutary function of eliminating the need for courts to evaluate, as this court is asked to do in this case, whether failing to make a demand was excusable.” Albers, 31 P3d at 829 (F) (1) (b) (¶ 33). 32 See OCGA § 14-11-801 (3) (requiring, before a member commences a derivative action, that “[90] days have expired from the date the demand was made unless the member has earlier been notified that the demand has been rejected by the limited liability company or unless irreparable injury to the limited liability company

11
Albers v. Edelson Technology Partners L.P.green
arizctapp · 2001 · cited in 1 Georgia opinions naming this issue, 2012–2012
1 sentence

2012Additionally, “[e]nforcing the statute according to its terms also serves the salutary function of eliminating the need for courts to evaluate, as this court is asked to do in this case, whether failing to make a demand was excusable.” Albers, 31 P3d at 829 (F) (1) (b) (¶ 33). 32 See OCGA § 14-11-801 (3) (requiring, before a member commences a derivative action, that “[90] days have expired from the date the demand was made unless the member has earlier been notified that the demand has been rejected by the limited liability company or unless irreparable injury to the limited liability company

11
Smith v. Hooeygreen
scotus · 1969 · cited in 1 Georgia opinions naming this issue, 2008–2008
2 sentences

2008See Hooey, supra, 393 U.S. at 380 n. 11, 89 S.Ct. 575 , 21 L.Ed.2d 607 ("[T]he short and perhaps the best answer to any objection based upon expense was given by the Supreme Court of Wisconsin in a case much like the present one: `We will not put a price tag upon constitutional rights.'") (citation omitted); Barker, supra, 407 U.S. at 538 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (White, J., concurring) ("[U]nreasonable delay in run-of-the-mill criminal cases cannot be justified by simply asserting that the public resources provided by the State's criminal-justice system are limited and that each case

2008See Hooey, supra, 393 U.S. at 380 n. 11, 89 S.Ct. 575 , 21 L.Ed.2d 607 ("[T]he short and perhaps the best answer to any objection based upon expense was given by the Supreme Court of Wisconsin in a case much like the present one: `We will not put a price tag upon constitutional rights.'") (citation omitted); Barker, supra, 407 U.S. at 538 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (White, J., concurring) ("[U]nreasonable delay in run-of-the-mill criminal cases cannot be justified by simply asserting that the public resources provided by the State's criminal-justice system are limited and that each case

11
Howell v. Southern Heritage Insurancegreen
gactapp · 1994 · cited in 1 Georgia opinions naming this issue, 2002–2002
2 sentences

2002Co., 214 Ga. App. 536, 537 (1) ( 448 SE2d 275 ) (1994).

2002Co., 214 Ga. App. 536, 537 (1) ( 448 SE2d 275 ) (1994).

11
Thrift v. Maxwellgreen
gactapp · 1982 · cited in 1 Georgia opinions naming this issue, 1997–1997
2 sentences

1997See Harris v. Eagle-Bridges Co., 212 Ga. 599 ( 94 SE2d 381 ) (1956); Thrift v. Maxwell, 162 Ga. App. 237, 239 (2) ( 290 SE2d 301 ) (1982).

1997See Harris v. Eagle-Bridges Co., 212 Ga. 599 ( 94 SE2d 381 ) (1956); Thrift v. Maxwell, 162 Ga. App. 237, 239 (2) ( 290 SE2d 301 ) (1982).

11
McKoon v. Jonesgreen
gactapp · 1994 · cited in 1 Georgia opinions naming this issue, 1997–1997
2 sentences

1997Furthermore, the comments to OCGA § 14-2-742, which are persuasive authority, see McKoon v. Jones, 214 Ga. App. 40, 41 ( 447 SE2d 50 ) (1994), state the provision requires that “the demand shall be in writing.” OCGA § 14-2-742, comment 1.

1997Furthermore, the comments to OCGA § 14-2-742, which are persuasive authority, see McKoon v. Jones, 214 Ga. App. 40, 41 ( 447 SE2d 50 ) (1994), state the provision requires that “the demand shall be in writing.” OCGA § 14-2-742, comment 1.

11
McGregor v. Stachelgreen
gactapp · 1991 · cited in 1 Georgia opinions naming this issue, 1997–1997
2 sentences

1997Although we have found no case precisely on point relating to either OCGA § 14-2-742 or § 14-3-742, we have observed that the demand requirement is a “procedural prerequisite for asserting [a derivative] claim [under OCGA § 14-2-742 (1)].” McGregor v. Stachel, 200 Ga. App. 324, 325 (1) ( 408 SE2d 118 ) (1991).

1997Although we have found no case precisely on point relating to either OCGA § 14-2-742 or § 14-3-742, we have observed that the demand requirement is a “procedural prerequisite for asserting [a derivative] claim [under OCGA § 14-2-742 (1)].” McGregor v. Stachel, 200 Ga. App. 324, 325 (1) ( 408 SE2d 118 ) (1991).

11
Harris v. EAGLE-BRIDGES CO., INC.green
ga · 1956 · cited in 1 Georgia opinions naming this issue, 1997–1997
2 sentences

1997See Harris v. Eagle-Bridges Co., 212 Ga. 599 ( 94 SE2d 381 ) (1956); Thrift v. Maxwell, 162 Ga. App. 237, 239 (2) ( 290 SE2d 301 ) (1982).

1997See Harris v. Eagle-Bridges Co., 212 Ga. 599 ( 94 SE2d 381 ) (1956); Thrift v. Maxwell, 162 Ga. App. 237, 239 (2) ( 290 SE2d 301 ) (1982).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (16)

CaseCitedYears
Doggett v. United States green
scotus · 1992
2 sentences

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

22008–2008
Francis v. Chavis. green
gactapp · 2018
1 sentence

2025Francis v. Chavis, 345 Ga. App. 641 , 642, n. 1 ( 814 SE2d 778 ) (2018).

12025–2025
United States v. Ewell green
scotus · 1966
2 sentences

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

12008–2008
Strunk v. United States green
scotus · 1973
2 sentences

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

12008–2008
Boseman v. State green
ga · 1994
2 sentences

2008See Hooey, supra, 393 U.S. at 380 n. 11, 89 S.Ct. 575 , 21 L.Ed.2d 607 ("[T]he short and perhaps the best answer to any objection based upon expense was given by the Supreme Court of Wisconsin in a case much like the present one: `We will not put a price tag upon constitutional rights.'") (citation omitted); Barker, supra, 407 U.S. at 538 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (White, J., concurring) ("[U]nreasonable delay in run-of-the-mill criminal cases cannot be justified by simply asserting that the public resources provided by the State's criminal-justice system are limited and that each case

2008See Hooey, supra, 393 U.S. at 380 n. 11, 89 S.Ct. 575 , 21 L.Ed.2d 607 ("[T]he short and perhaps the best answer to any objection based upon expense was given by the Supreme Court of Wisconsin in a case much like the present one: `We will not put a price tag upon constitutional rights.'") (citation omitted); Barker, supra, 407 U.S. at 538 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (White, J., concurring) ("[U]nreasonable delay in run-of-the-mill criminal cases cannot be justified by simply asserting that the public resources provided by the State's criminal-justice system are limited and that each case

12008–2008
Dickey v. Florida green
scotus · 1970
2 sentences

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

12008–2008
United States v. Loud Hawk green
scotus · 1986
2 sentences

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

2008A requirement of unreasonable speed would have a deleterious effect both upon the rights of the accused and upon the ability of society to protect itself."). [30] Loud Hawk, supra, 474 U.S. at 315 , 106 S.Ct. 648 . [31] Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 ; Ewell, supra, 383 U.S. at 120 , 86 S.Ct. 773 . [32] Doggett, supra, 505 U.S. at 656 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 ; Barker, supra, 407 U.S. at 531 & n. 32, 92 S.Ct. 2182 . [33] See Barker, supra, 407 U.S. at 529 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 ("We hardly need add that if delay is attributable to the defendant, then

12008–2008
Brannen v. State green
ga · 2001
2 sentences

2008See Hooey, supra, 393 U.S. at 380 n. 11, 89 S.Ct. 575 , 21 L.Ed.2d 607 ("[T]he short and perhaps the best answer to any objection based upon expense was given by the Supreme Court of Wisconsin in a case much like the present one: `We will not put a price tag upon constitutional rights.'") (citation omitted); Barker, supra, 407 U.S. at 538 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (White, J., concurring) ("[U]nreasonable delay in run-of-the-mill criminal cases cannot be justified by simply asserting that the public resources provided by the State's criminal-justice system are limited and that each case

2008See Hooey, supra, 393 U.S. at 380 n. 11, 89 S.Ct. 575 , 21 L.Ed.2d 607 ("[T]he short and perhaps the best answer to any objection based upon expense was given by the Supreme Court of Wisconsin in a case much like the present one: `We will not put a price tag upon constitutional rights.'") (citation omitted); Barker, supra, 407 U.S. at 538 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (White, J., concurring) ("[U]nreasonable delay in run-of-the-mill criminal cases cannot be justified by simply asserting that the public resources provided by the State's criminal-justice system are limited and that each case

12008–2008
City of Atlanta v. Frank red
gactapp · 1969
2 sentences

1978The only time the City of Smyrna came close to being named was in document two, which was addressed to "Smyrna Sanitation Department, West Spring Street, Smyrna, Georgia.” Chiles cites City of Atlanta v. Frank, 120 Ga. App. 273 ( 170 SE2d 265 ) (1969) as authority for the fact that the notice does not have to be received by the City of Smyrna as such.

1978The only time the City of Smyrna came close to being named was in document two, which was addressed to "Smyrna Sanitation Department, West Spring Street, Smyrna, Georgia.” Chiles cites City of Atlanta v. Frank, 120 Ga. App. 273 ( 170 SE2d 265 ) (1969) as authority for the fact that the notice does not have to be received by the City of Smyrna as such.

11978–1978
Wright v. State green
gactapp · 1936
2 sentences

1972In the light of these authorities (see particularly citation of 21 Georgia cases on p. 540 of Jones v. Mayor &c. of Savannah, 52 Ga. App. 537 ( 184 SE 353 )), substantial compliance with the requirements of Code Ann. §69-308 is all that is required.

1972In the light of these authorities (see particularly citation of 21 Georgia cases on p. 540 of Jones v. Mayor &c. of Savannah, 52 Ga. App. 537 ( 184 SE 353 )), substantial compliance with the requirements of Code Ann. § 69-308 is all that is required.

11972–1972
Jones v. Mayor of Savannah green
gactapp · 1936
2 sentences

1972In the light of these authorities (see particularly citation of 21 Georgia cases on p. 540 of Jones v. Mayor &c. of Savannah, 52 Ga. App. 537 ( 184 SE 353 )), substantial compliance with the requirements of Code Ann. §69-308 is all that is required.

1972In the light of these authorities (see particularly citation of 21 Georgia cases on p. 540 of Jones v. Mayor &c. of Savannah, 52 Ga. App. 537 ( 184 SE 353 )), substantial compliance with the requirements of Code Ann. § 69-308 is all that is required.

11972–1972
Mobley, Ward & Davis v. Pendergrast green
gactapp · 1911
2 sentences

1956The last sentence of Code § 3-707 provides that mere credits of partial payments will not suffice “to make a mutual account.” A case precisely' in point and controlling in the instant case is Mobley, Ward & Davis v. Pendergrast, 8 Ga. App. 565 (1) ( 70 S. E. 18 ), which holds, "The counter-claim in favor of the defendant which will relieve a plaintiff’s demand from the bar of the statute of limitations must be one dependent upon a demand based on the extension of credit by such debtor to the creditor whose claim is sued on.

1956The last sentence of Code § 3-707 provides that mere credits of partial payments will not suffice “to make a mutual account.” A case precisely' in point and controlling in the instant case is Mobley, Ward & Davis v. Pendergrast, 8 Ga. App. 565 (1) ( 70 S. E. 18 ), which holds, "The counter-claim in favor of the defendant which will relieve a plaintiff’s demand from the bar of the statute of limitations must be one dependent upon a demand based on the extension of credit by such debtor to the creditor whose claim is sued on.

11956–1956
Brazell v. Hearn green
gactapp · 1925
1 sentence

1956To constitute that mutuality of accounts which will relieve the bar of the statute of limitations there must be something more than the mere allowance of a credit item on behalf of the debtor; the debtor must extend credit to his creditor, or the creditor is some way become indebted to his debtor on his own account, and, in the face of his own credit and liability, promise to pay, or no mutuality of account exists.” A similar pronouncement is found in Brazell v. Hearn, 33 Ga. App. 490 ( 127 S. E. 479 ). • 2.

11956–1956
Heard v. State green
gactapp · 1925
1 sentence

1956To constitute that mutuality of accounts which will relieve the bar of the statute of limitations there must be something more than the mere allowance of a credit item on behalf of the debtor; the debtor must extend credit to his creditor, or the creditor is some way become indebted to his debtor on his own account, and, in the face of his own credit and liability, promise to pay, or no mutuality of account exists.” A similar pronouncement is found in Brazell v. Hearn, 33 Ga. App. 490 ( 127 S. E. 479 ). • 2.

11956–1956
Livingston & Stewart v. King green
gactapp · 1907
1 sentence

1907Taylor v. Chambers, 2 Ga. App. 178 ( 58 S. E. 369 ).

11907–1907
Taylor v. Chambers neutral
gactapp · 1907
1 sentence

1907Taylor v. Chambers, 2 Ga. App. 178 ( 58 S. E. 369 ).

11907–1907

Where else courts name it

DE 79 (1982–2026) TX 60 (1958–2025) NY 58 (1876–2026) CA 57 (1899–2025) IL 36 (1882–2024) NC 29 (1918–2026) LA 21 (1901–2025) MD 21 (1973–2025) MA 18 (1973–2025) MI 15 (1930–2018) IA 14 (1973–2026) AL 14 (1880–2011) PA 13 (1924–2025) FL 12 (1915–2022) OK 11 (1913–2026) OH 10 (1885–2017) GA 10 (1907–2025) ID 10 (1998–2026) NJ 9 (1935–2013) DC 9 (1979–2017) CT 8 (1895–2013) MO 8 (1910–2012) MS 8 (1947–2015) NV 7 (2006–2020) NM 7 (1922–1999) IN 7 (1867–2020) TN 7 (1926–2022) SC 6 (1978–2018) KS 6 (1900–1974) HI 6 (1953–2007) OR 5 (1938–2022) VA 5 (1834–2016) WY 5 (1935–2020) MT 4 (1894–1979) CO 4 (1971–2007) ND 4 (1974–2017) AZ 4 (1994–2015) RI 4 (1902–2005) AK 3 (1977–2003) WA 3 (1924–2018) NE 3 (1967–2014) AR 2 (2023–2024) WI 2 (1975–2021) MN 2 (1961–1984) UT 2 (2007–2022)

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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