plain view doctrine (Missouri) · Go Syfert
← Missouri issues

plain view doctrine in Missouri

73 Missouri opinions name it 2 courts 1972–2017 0 in the last five years

The cases below were cited by Missouri 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 (43)

CaseFollowedCited
State v. Collettgreen
mo · 1976 · cited in 5 Missouri opinions naming this issue, 1979–1987
2 sentences

1979The plain view doctrine was discussed at length in State v. Collett, 542 S.W.2d 783 (Mo. banc 1976), wherein this Court at 786 reviewing Coolidge v. New Hampshire, 403 U.S. 443 , 91 S.Ct. 2022 , 29 L.Ed.2d 564 (1971) stated: “[Coolidge ] is authority for the proposition that plain view alone is not enough to justify a warrantless seizure.

1979The plain view doctrine was discussed at length in State v. Collett, 542 S.W.2d 783 (Mo. banc 1976), wherein this Court at 786 reviewing Coolidge v. New Hampshire, 403 U.S. 443 , 91 S.Ct. 2022 , 29 L.Ed.2d 564 (1971) stated: "[ Coolidge ] is authority for the proposition that plain view alone is not enough to justify a warrantless seizure.

45
State v. Schneidergreen
mo · 1987 · cited in 4 Missouri opinions naming this issue, 1989–2014
2 sentences

2014State v. Schneider, 736 S.W.2d 392, 399 (Mo. banc 1987).

1996State v. Schneider, 736 S.W.2d 392, 399 (Mo. banc 1987).

44
State v. Blankenshipgreen
mo · 1992 · cited in 4 Missouri opinions naming this issue, 1993–2002
2 sentences

2002State v. Blankenship, 830 S.W.2d 1, 14 (Mo. banc 1992); 2 State v. Collins, 816 S.W.2d 257, 261 (Mo.App.1991); State v. Mitchell, 20 S.W.3d 546, 556 (Mo.App.2000).

1993Texas v. Brown, 460 U.S. 730, 737 , 103 S.Ct. 1535, 1540-41 , 75 L.Ed.2d 502 (1983); State v. Turner, 716 S.W.2d 462, 465 (Mo.App.1986); State v. Blankenship, 830 S.W.2d 1, 14 (Mo. banc 1992); see also, Arizona v. Hicks, 480 U.S. 321, 326 , 107 S.Ct. 1149, 1153 , 94 L.Ed.2d 347 (1987) (the plain view exception is a seizure doctrine).

44
Arizona v. Hicksgreen
scotus · 1987 · cited in 5 Missouri opinions naming this issue, 1992–2015
2 sentences

2015The plain view exception to the Fourth Amendment’s warrant requirement allows officers to seize evidence in plain view “when the evidence is in an area where the items described in the search warrant might be, and the incriminating character of the evidence is immediately apparent.” State v. Robinson, 379 S.W.3d 875, 881 (Mo. App. S.D. 2012) (citing Arizona v. Hicks, 480 U.S. 321, 326-27 , 107 S.Ct. 1149 , 94 L.Ed.2d 347 (1987)).

2015The plain view exception to the Fourth Amendment’s warrant requirement allows officers to seize evidence in plain view “when the evidence is in an area where the items described in the search warrant might be, and the incriminating character of the evidence is immediately apparent.” State v. Robinson, 379 S.W.3d 875, 881 (Mo. App. S.D. 2012) (citing Arizona v. Hicks, 480 U.S. 321, 326-27 , 107 S.Ct. 1149 , 94 L.Ed.2d 347 (1987)).

25
State v. Leavittgreen
moctapp · 1999 · cited in 3 Missouri opinions naming this issue, 2000–2016
2 sentences

2016State v. Leavitt, 993 S.W.2d 557, 561 (Mo.App.W.D. 1999).

2003A warrant is not required for: '(1) a search incident to a lawful arrest; (2) a seizure of items falling within the plain view doctrine; (3) a search of an automobile where probable cause exists to believe that it contains a substance which offends the law; or (4) a protective search by officers for weapons upon less than probable cause to arrest.’ ” Tackett, 12 S.W.3d at 337 (quoting State v. Leavitt, 993 S.W.2d 557, 560 (Mo.App.1999)).

23
State v. Holtgreen
moctapp · 1985 · cited in 3 Missouri opinions naming this issue, 1987–1989
2 sentences

1989The plain view exception permits an officer to seize items without a warrant if: ‘(1) the evidence is observed in plain view while the officer is in a place where he has a right to be; (2) the discovery of the evidence is inadvertent; and (3) it is apparent to the officer that he has evidence before him.’ State v. Holt, 695 S.W.2d 474, 477 (Mo.App.1985).

1987The plain view exception permits an officer to seize items without a warrant if: “(1) the evidence is observed in plain view while the officer is in a place where he has a right to be; (2) the discovery of the evidence is inadvertent; and (3) it is apparent to the officer that he has evidence before him.” State v. Holt, 695 S.W.2d 474, 477 (Mo.App.1985).

23
State v. Clarkgreen
mo · 1979 · cited in 3 Missouri opinions naming this issue, 1983–1987
2 sentences

1987State v. Clark, 592 S.W.2d 709, 715 (Mo. banc 1979); State v. Collett, 542 S.W.2d 783, 786 (Mo. banc 1976).

1987State v. Clark, 592 S.W.2d 709, 715 (Mo. banc 1979); State v. Collett, 542 S.W.2d 783, 786 (Mo. banc 1976).

23
State v. Edwardsgreen
moctapp · 2000 · cited in 2 Missouri opinions naming this issue, 2010–2017
2 sentences

2017Id.

2010“The plain view doctrine provides that anything an individual knowingly exposes to public view, even in his or her own home, involves no reasonable expectation of privacy and is not a subject of Fourth Amendment protection.” Kriley, 976 S.W.2d at 19 . “[I]t is altogether proper for police with legitimate business to enter the areas of curtilage open to the public.” State v. Edwards, 36 S.W.3d 22, 26 (Mo.App.2000).

22
Clampitt v. Nixongreen
mo · 2002 · cited in 2 Missouri opinions naming this issue, 2003–2005
2 sentences

2005See State v. Rutter, 93 S.W.3d 714, 724 (Mo. banc 2002); State v. Courtney, 102 S.W.3d 81, 87 (Mo.App.2003); Gantt, 87 S.W.3d at 333 .

2003State v. Rutter, 93 S.W.3d 714, 724 (Mo. banc 2002) (citing Washington v. Chrisman, 455 U.S. 1, 5-6 , 102 S.Ct. 812 , 70 L.Ed.2d 778 (1982)). [A] person’s reasonable expectation of privacy diminishes as to items that are readily visible in an otherwise private location into which police are invited or a public location to which all have access.

22
State v. Hallgreen
moctapp · 1974 · cited in 2 Missouri opinions naming this issue, 1977–1999
2 sentences

1999State v. Holman, 556 S.W.2d 499, 504-05 (Mo.App.1977) (citing, State v. Hall, 508 S.W.2d 200, 202-03 (Mo.App.1974)).

1977State v. Hall, 508 S.W.2d 200, 202-203 [1] (Mo.App.1974).

22
State v. Akersgreen
moctapp · 1986 · cited in 2 Missouri opinions naming this issue, 1996–1998
2 sentences

1998State v. Akers, 723 S.W.2d 9, 14 (Mo.App.1986) (citing Texas v. Brown, 460 U.S. 730, 741 , 103 S.Ct. 1535 , 75 L.Ed.2d 502 (1983); Katz v. United States, 389 U.S. 347, 351 , 88 S.Ct. 507 , 19 L.Ed.2d 576 (1967)).

1996State v. Akers, 723 S.W.2d 9, 14 (Mo.App.1986).

22
State v. Hollandgreen
moctapp · 1989 · cited in 2 Missouri opinions naming this issue, 1990–1993
2 sentences

1993See, State v. Holland, 781 S.W.2d 808, 815 [11, 12] (Mo. App.1989).

1990State v. Schneider, 736 S.W.2d 392, 399 (Mo. banc 1987), cert. denied, 484 U.S. 1047 , 108 S.Ct. 786 , 98 L.Ed.2d 871 (1988); State v. Holland, 781 S.W.2d 808, 815 (Mo.App.1989).

22
Texas v. Browngreen
scotus · 1983 · cited in 9 Missouri opinions naming this issue, 1984–2014
2 sentences

2000In Texas v. Brown, 460 U.S. 730 , 103 S.Ct. 1535 , 75 L.Ed.2d 502 (1983), the court applied the plain view doctrine to evidence observed within automobiles at a routine checkpoint established to check for driver’s licenses.

2000In Texas v. Brown, 460 U.S. 730 , 103 S.Ct. 1535 , 75 L.Ed.2d 502 (1983), the court applied the plain view doctrine to evidence observed within automobiles at a routine checkpoint established to check for driver’s licenses.

19
State v. Johnstongreen
mo · 1997 · cited in 3 Missouri opinions naming this issue, 2002–2005
2 sentences

2005State v. Johnston, 957 S.W.2d 734, 742 (Mo. banc 1997).

2003Under the plain-view exception, "an officer who is lawfully located in a place from which the object can plainly be seen may seize the object so long as there is probable cause to believe that the object is connected with the crime.” Johnston, 957 S.W.2d at 742 ; see also Arizona v. Hicks, 480 U.S. 321, 326 , 107 S.Ct. 1149, 1153 , 94 L.Ed.2d 347, 354 (1987); Rowland, 73 S.W.3d at 824 . 9 .

13
State v. Rowlandgreen
moctapp · 2002 · cited in 2 Missouri opinions naming this issue, 2003–2003
2 sentences

2003W.D.2000); See also State v. Rowland, 73 S.W.3d 818, 824 (Mo.App.

2003Under the plain-view exception, "an officer who is lawfully located in a place from which the object can plainly be seen may seize the object so long as there is probable cause to believe that the object is connected with the crime.” Johnston, 957 S.W.2d at 742 ; see also Arizona v. Hicks, 480 U.S. 321, 326 , 107 S.Ct. 1149, 1153 , 94 L.Ed.2d 347, 354 (1987); Rowland, 73 S.W.3d at 824 . 9 .

12
State v. Franklingreen
moctapp · 2004 · cited in 1 Missouri opinions naming this issue, 2016–2016
2 sentences

2016“The plain view doctrine is one of the recognized exceptions to the warrant requirement imposed by the Fourth Amendment to the United States Constitution.” State v. Franklin, 144 S.W.3d 355, 359 (Mo. App. S.D. 2004).

2016“This doctrine applies when: (1) the officer is lawfully located in a place from which the object can be plainly seen; (2) the officer has a lawful right of access to the object itself; and (3) the incriminating character of the object is immediately apparent to the seizing officer.” Id.

11
State v. Robinsongreen
moctapp · 2012 · cited in 1 Missouri opinions naming this issue, 2015–2015
1 sentence

2015The plain view exception to the Fourth Amendment’s warrant requirement allows officers to seize evidence in plain view “when the evidence is in an area where the items described in the search warrant might be, and the incriminating character of the evidence is immediately apparent.” State v. Robinson, 379 S.W.3d 875, 881 (Mo. App. S.D. 2012) (citing Arizona v. Hicks, 480 U.S. 321, 326-27 , 107 S.Ct. 1149 , 94 L.Ed.2d 347 (1987)).

11
State v. Olivergreen
mo · 2009 · cited in 1 Missouri opinions naming this issue, 2012–2012
1 sentence

2012The Fourth Amendment to the United States Constitution guarantees citizens the right to be free from “unreasonable searches and seizures.” “Article I, section 15 of the Missouri Constitution provides the same guarantees against unreasonable search and seizures; thus, the same analysis applies to cases under the Missouri Constitution as under the United States Constitution.” State v. Oliver, 293 S.W.3d 437, 442 (Mo. banc 2009).

11
State v. Courtneygreen
moctapp · 2003 · cited in 1 Missouri opinions naming this issue, 2005–2005
1 sentence

2005See State v. Rutter, 93 S.W.3d 714, 724 (Mo. banc 2002); State v. Courtney, 102 S.W.3d 81, 87 (Mo.App.2003); Gantt, 87 S.W.3d at 333 .

11
State v. Bibbgreen
moctapp · 1996 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
State v. Lingargreen
mo · 1987 · cited in 1 Missouri opinions naming this issue, 2003–2003
11
Wong Sun v. United Statesgreen
scotus · 1963 · cited in 1 Missouri opinions naming this issue, 2003–2003
11
State v. Millergreen
mo · 1995 · cited in 1 Missouri opinions naming this issue, 2003–2003
11
State v. Mitchellgreen
moctapp · 2000 · cited in 1 Missouri opinions naming this issue, 2002–2002
11
State v. Collinsgreen
moctapp · 1991 · cited in 1 Missouri opinions naming this issue, 2002–2002
11
State v. Hicksgreen
moctapp · 1993 · cited in 1 Missouri opinions naming this issue, 1999–1999
11
State v. Taylorgreen
moctapp · 1993 · cited in 1 Missouri opinions naming this issue, 1999–1999
11
State v. Holmangreen
moctapp · 1977 · cited in 1 Missouri opinions naming this issue, 1999–1999
11
United States v. George Martin Golaygreen
ca8 · 1974 · cited in 1 Missouri opinions naming this issue, 1997–1997
11
State v. Turnergreen
moctapp · 1986 · cited in 1 Missouri opinions naming this issue, 1993–1993
11
State v. Abbottgreen
moctapp · 1983 · cited in 1 Missouri opinions naming this issue, 1992–1992
11
State v. Gibbsgreen
moctapp · 1980 · cited in 1 Missouri opinions naming this issue, 1989–1989
11
State v. Stricklandgreen
mo · 1980 · cited in 1 Missouri opinions naming this issue, 1986–1986
11
State v. Johnsgreen
mo · 1984 · cited in 1 Missouri opinions naming this issue, 1986–1986
11
State v. Bellahgreen
moctapp · 1980 · cited in 1 Missouri opinions naming this issue, 1985–1985
11
State v. Giffingreen
mo · 1982 · cited in 1 Missouri opinions naming this issue, 1985–1985
11
United States v. Jerry Lee Wilsongreen
ca8 · 1975 · cited in 1 Missouri opinions naming this issue, 1983–1983
11
People v. Pakulagreen
illappct · 1980 · cited in 1 Missouri opinions naming this issue, 1982–1982
11
State v. Wilsongreen
md · 1977 · cited in 1 Missouri opinions naming this issue, 1979–1979
11
United States v. Michael C. Jackson, United States of America v. Salvatore (Sam) Pellitierigreen
ca8 · 1978 · cited in 1 Missouri opinions naming this issue, 1979–1979
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (37)

CaseCitedYears
Coolidge v. New Hampshire green
scotus · 1971
2 sentences

1991In Coolidge v. New Hampshire, 403 U.S. 443 , 91 S.Ct. 2022 , 29 L.Ed.2d 564 (1971), the Court explained the plain view doctrine by stating: What the “plain view” cases have in common is that the police officer in each of them had a prior justification for an intrusion in the course of which he came *261 inadvertently across a piece of evidence incriminating the accused.

1991In Coolidge v. New Hampshire, 403 U.S. 443 , 91 S.Ct. 2022 , 29 L.Ed.2d 564 (1971), the Court explained the plain view doctrine by stating: What the “plain view” cases have in common is that the police officer in each of them had a prior justification for an intrusion in the course of which he came *261 inadvertently across a piece of evidence incriminating the accused.

121976–2014
Horton v. California green
scotus · 1990
2 sentences

2002In Horton v. California, 496 U.S. 128, 136-37 , 110 S.Ct. 2301 , 110 L.Ed.2d 112 (1990), the United States Supreme Court has ruled that, for the state to justify its search under the plain view doctrine, it must prove that three conditions have been satisfied: (1) that police “did not violate the Fourth Amendment in arriving at the place from which the evidence could be plainly viewed,” id. at 136 , 110 S.Ct. 2301 ; (2) that the searching officer had a lawful right of access to the evidence itself, id. at 137 , 110 S.Ct. 2301 ; and (3) that the incriminating character of the evidence seized wa

2002In Horton v. California, 496 U.S. 128, 136-37 , 110 S.Ct. 2301 , 110 L.Ed.2d 112 (1990), the United States Supreme Court has ruled that, for the state to justify its search under the plain view doctrine, it must prove that three conditions have been satisfied: (1) that police “did not violate the Fourth Amendment in arriving at the place from which the evidence could be plainly viewed,” id. at 136 , 110 S.Ct. 2301 ; (2) that the searching officer had a lawful right of access to the evidence itself, id. at 137 , 110 S.Ct. 2301 ; and (3) that the incriminating character of the evidence seized wa

41992–2002
Harris v. United States green
scotus · 1968
2 sentences

1982Yet the officer may not enter the home without a warrant unless an exception to the warrant requirement applies.” On p. 820 Mr. Justice White quoted the following language from Harris v. United States, 390 U.S. 234 , 88 S.Ct. 992 , 19 L.Ed.2d 1067 (1968): “It has long been settled that objects falling in the plain view of an officer who has a right to be in the position to have that view are subject to seizure and may be introduced in evidence.” Mr. Justice White said: “The broad wording [of the quotation from Harris ] has apparently created some confusion regarding the plain view doctrine.

1982Yet the officer may not enter the home without a warrant unless an exception to the warrant requirement applies.” On p. 820 Mr. Justice White quoted the following language from Harris v. United States, 390 U.S. 234 , 88 S.Ct. 992 , 19 L.Ed.2d 1067 (1968): “It has long been settled that objects falling in the plain view of an officer who has a right to be in the position to have that view are subject to seizure and may be introduced in evidence.” Mr. Justice White said: “The broad wording [of the quotation from Harris ] has apparently created some confusion regarding the plain view doctrine.

41972–1983
Washington v. Chrisman green
scotus · 1982
2 sentences

2003State v. Rutter, 93 S.W.3d 714, 724 (Mo. banc 2002) (citing Washington v. Chrisman, 455 U.S. 1, 5-6 , 102 S.Ct. 812 , 70 L.Ed.2d 778 (1982)). [A] person’s reasonable expectation of privacy diminishes as to items that are readily visible in an otherwise private location into which police are invited or a public location to which all have access.

2003State v. Rutter, 93 S.W.3d 714, 724 (Mo. banc 2002) (citing Washington v. Chrisman, 455 U.S. 1, 5-6 , 102 S.Ct. 812 , 70 L.Ed.2d 778 (1982)). [A] person’s reasonable expectation of privacy diminishes as to items that are readily visible in an otherwise private location into which police are invited or a public location to which all have access.

21994–2003
In re Arlt green
scotus · 1988
2 sentences

1990State v. Schneider, 736 S.W.2d 392, 399 (Mo. banc 1987), cert. denied, 484 U.S. 1047 , 108 S.Ct. 786 , 98 L.Ed.2d 871 (1988); State v. Holland, 781 S.W.2d 808, 815 (Mo.App.1989).

1989State v. Schneider, 736 S.W.2d 392, 399 (Mo. banc 1987), cert. den. 484 U.S. 1047 , 108 S.Ct. 786 , 98 L.Ed.2d 871 (1988).

21989–1990
Mullins Coal Co. v. Director, Office of Workers' Compensation Programs green
scotus · 1988
2 sentences

1990State v. Schneider, 736 S.W.2d 392, 399 (Mo. banc 1987), cert. denied, 484 U.S. 1047 , 108 S.Ct. 786 , 98 L.Ed.2d 871 (1988); State v. Holland, 781 S.W.2d 808, 815 (Mo.App.1989).

1989State v. Schneider, 736 S.W.2d 392, 399 (Mo. banc 1987), cert. den. 484 U.S. 1047 , 108 S.Ct. 786 , 98 L.Ed.2d 871 (1988).

21989–1990
State v. Kruse green
moctapp · 2010
1 sentence

2017The doctrine “provides that anything an individual knowingly exposes to public view.. .involves no reasonable expectation of privacy and is not a subject of Fourth Amendment protection.” Kruse, 306 S.W.3d at 609 .

12017–2017
State v. Kelly green
moctapp · 2003
1 sentence

2017“The plain view exception to the Fourth Amendment warrant require ment permits a law enforcement officer to seize what clearly is incriminating evidence or contraband when it is discovered in a place where the officer has a right to be.” Kelly, 119 S.W.3d at 592 .

12017–2017
State v. Mitchell green
mo · 1981
1 sentence

2014If, on the other hand, the trial court determines that the search and seizure was justified by the plain view doctrine, then it “shall certify the transcript of the hearing and its determination and findings to this court to be made a part of the transcript in the cause for determination and disposition of the appeal upon the record as supplemented.” Id.

12014–2014
State v. Kriley green
moctapp · 1998
1 sentence

2010“The plain view doctrine provides that anything an individual knowingly exposes to public view, even in his or her own home, involves no reasonable expectation of privacy and is not a subject of Fourth Amendment protection.” Kriley, 976 S.W.2d at 19 . “[I]t is altogether proper for police with legitimate business to enter the areas of curtilage open to the public.” State v. Edwards, 36 S.W.3d 22, 26 (Mo.App.2000).

12010–2010
State v. Gantt green
moctapp · 2002
1 sentence

2005See State v. Rutter, 93 S.W.3d 714, 724 (Mo. banc 2002); State v. Courtney, 102 S.W.3d 81, 87 (Mo.App.2003); Gantt, 87 S.W.3d at 333 .

12005–2005
State v. David green
moctapp · 2000
12003–2003
State v. Tackett green
moctapp · 2000
12003–2003
State v. Neely green
moctapp · 1998
12003–2003
Minnesota v. Dickerson green
scotus · 1993
12001–2001
State v. Davis green
moctapp · 1998
12001–2001
State v. Hutchinson green
moctapp · 1990
12001–2001
Hargrove v. Tansy, Warden neutral
scotus · 1994
11999–1999
Hodgson v. Ylst, Warden green
scotus · 1994
11999–1999
Katz v. United States green
scotus · 1967
11998–1998
State v. Payano green
ri · 1987
11994–1994
State v. Griffin green
minn · 1983
11994–1994
State v. Burkhardt green
mo · 1990
11991–1991
State v. Mansfield green
moctapp · 1984
11985–1985
Chimel v. California red
scotus · 1969
11985–1985
New York v. Belton red
scotus · 1981
11985–1985
State v. Quinn green
moctapp · 1978
11983–1983
Qualls v. United States green
scotus · 1976
11983–1983
Hernandez-Rodriguez v. United States green
scotus · 1976
11983–1983
United States v. Tranquillo green
flmd · 1971
11979–1979
People v. Harris green
ill · 1979
11979–1979
People v. Hamilton green
ill · 1979
11979–1979
Johnson v. Royal Garden Estates, Inc. green
fladistctapp · 1979
11979–1979
Michigan v. Tyler green
scotus · 1978
11978–1978
Carroll v. United States green
scotus · 1925
11977–1977
Haefeli v. Chernoff green
ca5 · 1975
11977–1977
State v. Baines green
mo · 1965
11976–1976

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 542.296 (5) MO § Mo. Rev. Stat. § 195.010 (4) MO § Mo. Rev. Stat. § 571.015 (4) MO § Mo. Rev. Stat. § 547.200 (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

OH 323 (1973–2026) PA 276 (1970–2026) TX 266 (1972–2026) LA 207 (1975–2025) NJ 156 (1977–2026) IL 148 (1968–2025) NY 138 (1972–2026) WA 118 (1971–2026) GA 98 (1974–2024) MI 98 (1970–2026) IN 96 (1971–2023) VA 82 (1987–2026) FL 80 (1973–2026) MA 76 (1975–2026) CA 74 (1972–2026) MO 73 (1972–2017) TN 69 (1980–2025) NC 63 (1974–2025) CT 59 (1973–2025) AL 59 (1971–2018) CO 59 (1970–2026) KS 54 (1971–2022) MD 51 (1972–2026) OR 45 (1972–2026) MN 44 (1977–2024) ID 43 (1974–2026) NM 43 (1975–2025) WI 41 (1973–2025) MS 37 (1977–2025) DC 32 (1973–2025) MT 31 (1977–2025) IA 31 (1976–2026) SC 29 (1983–2023) KY 28 (1972–2025) AR 27 (1977–2021) OK 26 (1977–2015) ND 23 (1981–2026) AZ 22 (1973–2022) NE 21 (1976–2022) UT 19 (1981–2006) NH 19 (1976–2019) WY 18 (1979–2019) HI 17 (1975–2021) DE 17 (1971–2025) WV 17 (1980–2023) RI 16 (1974–2010) ME 16 (1971–2025) AK 16 (1974–2019) NV 15 (1981–2021) VT 12 (1976–2021) SD 11 (1973–2006) VI 8 (1984–2026)

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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