situation bar (Texas) · Go Syfert
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situation bar in Texas

73 Texas opinions name it 3 courts 1927–2024 6 in the last five years

The cases below were cited by Texas 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 (39)

CaseFollowedCited
City of Midland v. Goerlitzgreen
tex · 2006 · cited in 3 Texas opinions naming this issue, 2008–2018
2 sentences

2018See, e.g., Albert, 354 S.W.3d at 374 (“Although litigation actions of governmental entities underlay our decisions in Reata and similar cases, we did not hold that those actions effected waivers of immunity; rather, they were factors considered in defining the contours of immunity.”); City of Midland v. Goerlitz, 201 S.W.3d 689, 690 (Tex. 2006) (remanding to give plaintiff an “opportunity to argue . . . that the City’s immunity from suit either does not exist pursuant to our decision in Reata or that it has been waived by [Chapter 271]”); City of Houston v. United Water Servs., 201 S.W.3d 690,

2008It claims that "[i]n several cases, the supreme court has characterized the Reata rule as a situation in which immunity simply does not exist , rather than a situation in which governmental immunity is waived ." Id. (citing City of Midland v. Goerlitz , 201 S.W.3d 689, 690 (Tex. 2006); City of Houston v. United Water Servs. , 201 S.W.3d 690, 691 (Tex. 2006); Metro.

33
City of Houston v. United Water Services, Inc.green
tex · 2006 · cited in 3 Texas opinions naming this issue, 2008–2018
2 sentences

2018See, e.g., Albert, 354 S.W.3d at 374 (“Although litigation actions of governmental entities underlay our decisions in Reata and similar cases, we did not hold that those actions effected waivers of immunity; rather, they were factors considered in defining the contours of immunity.”); City of Midland v. Goerlitz, 201 S.W.3d 689, 690 (Tex. 2006) (remanding to give plaintiff an “opportunity to argue . . . that the City’s immunity from suit either does not exist pursuant to our decision in Reata or that it has been waived by [Chapter 271]”); City of Houston v. United Water Servs., 201 S.W.3d 690,

2008It claims that "[i]n several cases, the supreme court has characterized the Reata rule as a situation in which immunity simply does not exist , rather than a situation in which governmental immunity is waived ." Id. (citing City of Midland v. Goerlitz , 201 S.W.3d 689, 690 (Tex. 2006); City of Houston v. United Water Servs. , 201 S.W.3d 690, 691 (Tex. 2006); Metro.

33
Ex Parte McJunkinsgreen
texcrimapp · 1997 · cited in 3 Texas opinions naming this issue, 2014–2014
2 sentences

2014I note that this is not a situation where the challenge is to the procedures employed with respect to the cumulation order, which was the situation in Ex parte McJunkins, 954 S.W.2d 39, 39 (Tex.Crim.App.1997) (op. on reh'g).

2014Because it would grant relief only under circumstances in which no preservation of error is required and would deny relief when error has been preserved, the majority opinion’s reasoning to 2 I note that this is not a situation where the challenge is to the procedures employed with respect to the cumulation order, which was the situation in Ex parte McJunkins, 954 S.W.2d 39, 39 (Tex. Crim.

33
Tome v. United Statesgreen
scotus · 1995 · cited in 2 Texas opinions naming this issue, 2018–2018
2 sentences

2018See Tome, 513 U.S. at 158 , 115 S. Ct. at 701 ; Hammons, 239 S.W.3d at 804 ; see also Klein v. State, 273 S.W.3d 297 , 316–17 (Tex. Crim.

2018See Tome, 513 U.S. at 158 , 115 S. Ct. at 701 ; Hammons, 239 S.W.3d at 804 ; see also Klein v. State, 273 S.W.3d 297 , 316–17 (Tex. Crim.

22
Klein v. Stategreen
texcrimapp · 2008 · cited in 2 Texas opinions naming this issue, 2018–2018
2 sentences

2018See Tome, 513 U.S. at 158 , 115 S. Ct. at 701 ; Hammons, 239 S.W.3d at 804 ; see also Klein v. State, 273 S.W.3d 297 , 316–17 (Tex. Crim.

2018See Tome, 513 U.S. at 158 , 115 S. Ct. at 701 ; Hammons, 239 S.W.3d at 804 ; see also Klein v. State, 273 S.W.3d 297 , 316–17 (Tex. Crim.

22
In Re Department of Family & Protective Servicesgreen
tex · 2009 · cited in 2 Texas opinions naming this issue, 2015–2016
2 sentences

2016The Guerra court found significant the Legislature’s failure “to attach a consequence to a situation where a hearing is held outside the 40 days of the notice of [driver’s license] suspension” and noted that the Legislature “could have easily provided consequences for noncompliance.” Id. at 649 ; see also Crosstex Energy, 430 S.W.3d at 392-93 (“Although the plain meaning might suggest a jurisdictional bar, it does not meet the requisite level of clarity to establish the statute as jurisdictional.”); In re Dep’t of Family & Protective Servs., 273 S.W.3d 637, 642 (Tex.2009) (holding statute was

2015The Guerra court found significant the Legislature’s failure “to attach a consequence to a situation where a hearing is held outside the 40 days of the notice of [driver’s license] suspension” and noted that the Legislature “could have easily provided consequences for noncompliance.” Id. at 649 ; see also Crosstex Energy, 430 S.W.3d at 392–93 (“Although the plain meaning might suggest a jurisdictional bar, it does not meet 8 the requisite level of clarity to establish the statute as jurisdictional.”); In re Dep’t of Family & Protective Servs., 273 S.W.3d 637, 642 (Tex. 2009) (holding statute w

22
Texas a & M University-Kingsville v. Lawsongreen
tex · 2002 · cited in 2 Texas opinions naming this issue, 2011–2016
2 sentences

2016See Lawson, 87 S.W.3d at 522 (once the Legislature has decided to waive immunity for a class of claims, the inclusion of settlements within the waiver is consistent with that decision); Tex. A&M Univ.

2011It is important to note that the Lawson plurality expressly avowed this rule, id., and found a waiver of immunity in the situation at bar only because it concluded that the Legislature intended one.

22
Crosstex Energy Services, L.P. v. Pro Plus, Inc.green
tex · 2014 · cited in 2 Texas opinions naming this issue, 2015–2016
2 sentences

2016The Guerra court found significant the Legislature’s failure “to attach a consequence to a situation where a hearing is held outside the 40 days of the notice of [driver’s license] suspension” and noted that the Legislature “could have easily provided consequences for noncompliance.” Id. at 649 ; see also Crosstex Energy, 430 S.W.3d at 392-93 (“Although the plain meaning might suggest a jurisdictional bar, it does not meet the requisite level of clarity to establish the statute as jurisdictional.”); In re Dep’t of Family & Protective Servs., 273 S.W.3d 637, 642 (Tex.2009) (holding statute was

2015The Guerra court found significant the Legislature’s failure “to attach a consequence to a situation where a hearing is held outside the 40 days of the notice of [driver’s license] suspension” and noted that the Legislature “could have easily provided consequences for noncompliance.” Id. at 649 ; see also Crosstex Energy, 430 S.W.3d at 392–93 (“Although the plain meaning might suggest a jurisdictional bar, it does not meet 8 the requisite level of clarity to establish the statute as jurisdictional.”); In re Dep’t of Family & Protective Servs., 273 S.W.3d 637, 642 (Tex. 2009) (holding statute w

22
Virts v. Stategreen
texcrimapp · 1987 · cited in 2 Texas opinions naming this issue, 2003–2015
2 sentences

2015Virts v. State, 739 S.W.2d 25, 29 (Tex. Crim.

2003Virts v. State , 739 S.W.2d 25, 29 (Tex. Crim.

22
United States v. John W. Downinggreen
ca3 · 1985 · cited in 2 Texas opinions naming this issue, 2011–2011
2 sentences

2011United States v. Downing, 753 F.2d 1224, 1242 (3d Cir.1985).

2011United States v. Downing, 753 F.2d 1224, 1242 (3d Cir. 1985).

22
Caballero v. Stategreen
texapp · 1996 · cited in 2 Texas opinions naming this issue, 2011–2011
2 sentences

2011See Caballero v. State , 919 S.W.2d 919, 921 (Tex. App.--Houston [14th Dist.] 1996, pet. ref'd) (complainant's fear may be established by circumstantial evidence).

2011See Caballero v. State, 919 S.W.2d 919, 921 (Tex. App.—Houston [14th Dist.] 1996, pet. ref’d) (complainant’s fear may be established by circumstantial evidence).

22
Texas Department of Public Safety v. Guerragreen
texapp · 1998 · cited in 3 Texas opinions naming this issue, 2013–2016
2 sentences

2016The Guerra court found significant the Legislature’s failure “to attach a consequence to a situation where a hearing is held outside the 40 days of the notice of [driver’s license] suspension” and noted that the Legislature “could have easily provided consequences for noncompliance.” Id. at 649 ; see also Crosstex Energy, 430 S.W.3d at 392-93 (“Although the plain meaning might suggest a jurisdictional bar, it does not meet the requisite level of clarity to establish the statute as jurisdictional.”); In re Dep’t of Family & Protective Servs., 273 S.W.3d 637, 642 (Tex.2009) (holding statute was

2015The Guerra court found significant the Legislature’s failure “to attach a consequence to a situation where a hearing is held outside the 40 days of the notice of [driver’s license] suspension” and noted that the Legislature “could have easily provided consequences for noncompliance.” Id. at 649 ; see also Crosstex Energy, 430 S.W.3d at 392–93 (“Although the plain meaning might suggest a jurisdictional bar, it does not meet 8 the requisite level of clarity to establish the statute as jurisdictional.”); In re Dep’t of Family & Protective Servs., 273 S.W.3d 637, 642 (Tex. 2009) (holding statute w

13
Tooke v. City of Mexiagreen
tex · 2006 · cited in 2 Texas opinions naming this issue, 2008–2015
2 sentences

2015Reasoning that it was not the Court’s place to create a situation where immunity from suit would not apply, the Supreme Court further explained that is has “consistently deferred to the Legislature to waive sovereign immunity from suit, because this allows the Legislature to protect its policymaking function.” Tooke, 18 197 S.W.3d at 332; see also Gay, 457 S.W.3d at 505 (citing Tooke, 197 S.W.3d at 332 ); West Texas Mun.

2008It claims that "[i]n several cases, the supreme court has characterized the Reata rule as a situation in which immunity simply does not exist , rather than a situation in which governmental immunity is waived ." Id. (citing City of Midland v. Goerlitz , 201 S.W.3d 689, 690 (Tex. 2006); City of Houston v. United Water Servs. , 201 S.W.3d 690, 691 (Tex. 2006); Metro.

12
Moreno v. Stategreen
texapp · 2010 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024Alternatively, a waiver of the right to appeal may also be “valid, i.e., knowingly, voluntarily, and intelligently made, when the waiver is made . . . post-sentencing” because like the situation in which the waiver is made as part of a bargained exchange “the defendant, at the time of the waiver, knows the likely consequences of the waiver.” Moreno v. State, 327 S.W.3d 267, 268 (Tex. App.—San Antonio 2010, no pet.).

11
Moore v. Stategreen
texcrimapp · 1998 · cited in 1 Texas opinions naming this issue, 2023–2023
1 sentence

2023App. 1985), overruled on other grounds by Moore v. State, 969 S.W.2d 4, 10 (Tex. Crim.

11
Charles Brown, L.L.P. v. Lanier Worldwide, Inc.green
texapp · 2004 · cited in 1 Texas opinions naming this issue, 2022–2022
1 sentence

2022See 11 Lanier Worldwide, 124 S.W.3d at 829, 900 .

11
City of Dallas v. Albertgreen
tex · 2011 · cited in 1 Texas opinions naming this issue, 2018–2018
2 sentences

2018See, e.g., Albert, 354 S.W.3d at 374 (“Although litigation actions of governmental entities underlay our decisions in Reata and similar cases, we did not hold that those actions effected waivers of immunity; rather, they were factors considered in defining the contours of immunity.”); City of Midland v. Goerlitz, 201 S.W.3d 689, 690 (Tex. 2006) (remanding to give plaintiff an “opportunity to argue . . . that the City’s immunity from suit either does not exist pursuant to our decision in Reata or that it has been waived by [Chapter 271]”); City of Houston v. United Water Servs., 201 S.W.3d 690,

2018See, e.g., Albert, 354 S.W.3d at 374 (“Although litigation actions of governmental entities underlay our decisions in Reata and similar cases, we did not hold that those actions effected waivers of immunity; rather, they were factors considered in defining the contours of immunity.”); City of Midland v. Goerlitz, 201 S.W.3d 689, 690 (Tex. 2006) (remanding to give plaintiff an “opportunity to argue . . . that the City’s immunity from suit either does not exist pursuant to our decision in Reata or that it has been waived by [Chapter 271]”); City of Houston v. United Water Servs., 201 S.W.3d 690,

11
Wilkerson v. Stategreen
texcrimapp · 2005 · cited in 1 Texas opinions naming this issue, 2017–2017
1 sentence

2017See Wilkerson, 173 S.W.3d at 533 .

11
Otis Spunkmeyer, Inc. v. Blakelygreen
texapp · 2000 · cited in 1 Texas opinions naming this issue, 2015–2015
11
Cannon v. Stategreen
texcrimapp · 2008 · cited in 1 Texas opinions naming this issue, 2015–2015
11
Mitchell v. United Statesgreen
scotus · 1999 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015See id.

11
Christopher L. Gay and Steven L. Carroll v. the City of Wichita Falls, Texasgreen
texapp · 2014 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Reasoning that it was not the Court’s place to create a situation where immunity from suit would not apply, the Supreme Court further explained that is has “consistently deferred to the Legislature to waive sovereign immunity from suit, because this allows the Legislature to protect its policymaking function.” Tooke, 18 197 S.W.3d at 332; see also Gay, 457 S.W.3d at 505 (citing Tooke, 197 S.W.3d at 332 ); West Texas Mun.

11
City of DeSoto v. Whitegreen
tex · 2009 · cited in 1 Texas opinions naming this issue, 2013–2013
11
Helena Chemical Co. v. Wilkinsgreen
tex · 2001 · cited in 1 Texas opinions naming this issue, 2013–2013
11
Duhig v. Peavy-Moore Lumber Co.green
· 1940 · cited in 1 Texas opinions naming this issue, 2006–2006
11
Almanza v. Stategreen
texcrimapp · 1985 · cited in 1 Texas opinions naming this issue, 2000–2000
11
Gornick v. Stategreen
texapp · 1997 · cited in 1 Texas opinions naming this issue, 2000–2000
11
Landry v. Stategreen
texapp · 1994 · cited in 1 Texas opinions naming this issue, 1997–1997
11
Salazar v. Stategreen
texcrimapp · 1978 · cited in 1 Texas opinions naming this issue, 1997–1997
11
Adams v. Texas State Board of Chiropractic Examinersgreen
texapp · 1988 · cited in 1 Texas opinions naming this issue, 1992–1992
11
Equitable Trust Co. v. Rolandgreen
texapp · 1986 · cited in 1 Texas opinions naming this issue, 1988–1988
11
People v. Rogersgreen
ny · 1979 · cited in 1 Texas opinions naming this issue, 1985–1985
11
Hamilton v. Stategreen
texcrimapp · 1913 · cited in 1 Texas opinions naming this issue, 1985–1985
11
United States v. Martin Frankgreen
ca2 · 1975 · cited in 1 Texas opinions naming this issue, 1984–1984
11
Caldwell v. United Statesgreen
scotus · 1976 · cited in 1 Texas opinions naming this issue, 1984–1984
11
Adolph Coors Co. v. Commissionergreen
scotus · 1976 · cited in 1 Texas opinions naming this issue, 1984–1984
11
Milczanowski v. Stategreen
texcrimapp · 1983 · cited in 1 Texas opinions naming this issue, 1983–1983
11
In Re WINSHIPgreen
scotus · 1970 · cited in 1 Texas opinions naming this issue, 1982–1982
11
Serrato v. Stategreen
· 1914 · cited in 1 Texas opinions naming this issue, 1979–1979
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (41)

CaseCitedYears
Hammons v. State green
texcrimapp · 2007
2 sentences

2018See Tome, 513 U.S. at 158 , 115 S. Ct. at 701 ; Hammons, 239 S.W.3d at 804 ; see also Klein v. State, 273 S.W.3d 297 , 316–17 (Tex. Crim.

2018See Tome, 513 U.S. at 158 , 115 S. Ct. at 701 ; Hammons, 239 S.W.3d at 804 ; see also Klein v. State, 273 S.W.3d 297 , 316–17 (Tex. Crim.

22018–2018
Missouri v. McNeely green
scotus · 2013
2 sentences

2015Missouri v. McNeely, 133 S.Ct. 1552, 1562 , L.Ed. 2d 696 (2013). 14 In the situation at bar, probable cause was required in order for officers to secure a Blood Search Warrant.

2015Missouri v. McNeely, 133 S.Ct. 1552, 1562 , L.Ed. 2d 696 (2013). 14 In the situation at bar, probable cause was required in order for officers to secure a Blood Search Warrant.

22015–2015
Chaney v. State green
texapp · 2010
2 sentences

2012Per Curiam Do not publish. 1 Incidentally, we do not ignore appellant’s argument that the holding in Chaney v. State, 314 S.W.3d 561 (Tex. App.–Amarillo 2010, pet. ref’d) controls the situation at bar.

2012Incidentally, we do not ignore appellant’s argument that the holding in Chaney v. State, 314 S.W.3d 561 (Tex.App.-Amarillo 2010, pet. ref'd) controls the situation at bar.

22012–2012
Bogany v. State green
texcrimapp · 1983
2 sentences

1983Art. 44.24(b), V.A.C.C.P., provides: "(b) The courts of appeals and the Court of Criminal Appeals may affirm the judgment of the court below, or may reverse and remand for a new trial, or may reverse and dismiss the case, or may reform and correct the judgment or may enter any other appropriate order, as the law and nature of the case may require." In Bogany v. State, 661 S.W.2d 957 (Tex.Cr.App.1983), we held that the authority of a court on appeal to reform a judgment under Art. 44.24, supra, does not extend to the situation where the error involves punishment unauthorized by law.

1983Art. 44.24(b), V.A.C.C.P., provides: “(b) The courts of appeals and the Court of Criminal Appeals may affirm the judgment of the court below, or may reverse and remand for a new trial, or may reverse and dismiss the case, or may reform and correct the judgment or may enter any other appropriate order, as the law and nature of the case may require.” In Bogany v. State, 661 S.W.2d 957 (Tex.Cr.App.1983), we held that the authority of a court on appeal to reform a judgment under Art. 44.24, supra, does not extend to the situation where the error involves punishment unauthorized by law.

21983–1988
Lockhart v. Fretwell green
scotus · 1993
2 sentences

2024In Fretwell, the Supreme Court addressed a situation where the defense attorney failed to lodge an objection that would have been meritorious under a court decision that existed at the time of trial.7 The case that supported the objection was later overruled.8 An intermediate federal appellate court concluded that prejudice had been shown because the objection would have been sustained under the caselaw that existed at the 5 See id. 408. 6 See id. 403. 7 506 U.S. at 366 . 8 Id.

2024In Fretwell, the Supreme Court addressed a situation where the defense attorney failed to lodge an objection that would have been meritorious under a court decision that existed at the time of trial.7 The case that supported the objection was later overruled.8 An intermediate federal appellate court concluded that prejudice had been shown because the objection would have been sustained under the caselaw that existed at the 5 See id. 408. 6 See id. 403. 7 506 U.S. at 366 . 8 Id.

12024–2024
The City of El Paso v. Lilli M. Heinrich green
tex · 2009
1 sentence

2022Heinrich, 284 S.W.3d at 376 .

12022–2022
Somer v. Bogart green
texapp · 1988
2 sentences

2022In this situation a presumption of gift arises, and no resulting trust exists until the presumption is rebutted.” Id. (citations omitted). –15– In Somer, we considered whether the presumption of gift arises in circumstances where title is taken in the name of a son-in-law.

2022Id.

12022–2022
Crockett v. State green
texapp · 1992
1 sentence

2020Rather, it merely sought leave to amend language in the original motion and 1 This circumstance distinguishes the situation at bar from that in Crockett v. State, 840 S.W.2d 160 (Tex. App.—Houston [1st Dist.] 1992, no pet.).

12020–2020
Doe v. Messina green
texapp · 2011
1 sentence

2018That the events began with inappropriate behavior between children on a couch and turned into oral sex in a bathroom are also important bits of evidence serving to distinguish the situation at bar from those in an opinion upon which Dad and his children place much reliance, Doe v. Messina, 349 S.W.3d 797 (Tex. App.—Houston [14th Dist.] 2011, pet. denied).

12018–2018
Crystal Spurck v. Texas Department of Family and Protective Services green
texapp · 2013
1 sentence

2018Spurck, 396 S.W.3d at 222 .

12018–2018
West Texas Municipal Power Agency v. Republic Power Partners, L.P. green
texapp · 2014
12015–2015
Taylor v. State green
texapp · 2005
12015–2015
Missouri v. Seibert green
scotus · 2004
12014–2014
Martinez v. State green
texcrimapp · 2008
12014–2014
Bell v. Smith green
texapp · 1976
11988–1988
Clark v. State green
texcrimapp · 1973
11985–1985
Wilmans v. Harston green
texapp · 1921
11985–1985
Maldonado v. State green
texcrimapp · 1975
11984–1984
Hardinge v. State green
texcrimapp · 1973
11984–1984
Rodriguez v. State green
texcrimapp · 1979
11984–1984
Ceniceros v. State green
texcrimapp · 1977
11984–1984
United States v. John Cardillo, Lawrence Harris, Ralph Kaminsky, John Knapp, Louis Margolis, and Louis Piselli green
ca2 · 1963
11984–1984
Reynolds v. State green
texcrimapp · 1974
11983–1983
Jackson v. Virginia red
scotus · 1979
11982–1982
Drakes v. State green
texcrimapp · 1974
11982–1982
Pack v. City of Fort Worth green
texapp · 1977
11979–1979
Barfield v. Howard M. Smith Company of Amarillo green
tex · 1968
11978–1978
Smith v. State neutral
texcrimapp · 1974
11975–1975
Seay v. State neutral
texcrimapp · 1965
11975–1975
Lee v. State green
texcrimapp · 1974
11974–1974
Seydler v. Keuper green
texapp · 1939
11971–1971
Ross v. McLelland green
texapp · 1955
11971–1971
Closner v. Gannaway green
texapp · 1932
11971–1971
Rose v. Baker green
tex · 1944
11971–1971
Singleton v. Carmichael green
texapp · 1957
11970–1970
Newspapers, Inc. v. Love green
tex · 1964
11969–1969
Petco Corporation v. Plummer green
texapp · 1965
11967–1967
Great American Reserve Insurance Co. v. Mitchell green
texapp · 1960
11964–1964
Traders & General Insurance Co. v. Lange neutral
texapp · 1962
11964–1964
Panhandle & Sante Fe Railway Co. v. Napier neutral
tex · 1940
11964–1964

Where else courts name it

NY 192 (1873–2024) CA 98 (1928–2026) IL 89 (1908–2026) TX 73 (1927–2024) PA 50 (1923–2024) FL 36 (1922–2015) MI 36 (1914–2025) MD 34 (1930–2025) AL 33 (1922–2017) LA 33 (1912–2018) GA 33 (1931–2012) IN 32 (1882–2018) MO 26 (1924–2012) OH 26 (1932–2019) IA 23 (1910–2026) OK 22 (1922–2022) WA 21 (1916–2020) WI 20 (1901–2021) KS 20 (1907–2014) NJ 18 (1929–2005) CT 17 (1902–2002) NE 17 (1930–2014) UT 14 (1894–2024) OR 14 (1919–2026) CO 14 (1938–2025) MA 13 (1885–2025) AZ 12 (1919–2017) TN 11 (1936–2005) NM 11 (1958–2024) DC 11 (1956–2013) KY 11 (1966–2018) MS 10 (1976–2017) WY 9 (1959–2003) WV 8 (1931–2014) MN 8 (1924–2017) NC 8 (1940–2021) DE 7 (1963–1995) ID 7 (1908–2014) AR 7 (1963–2001) VA 7 (1988–2023) RI 6 (1976–2024) MT 6 (1935–2005) ME 6 (1941–2024) SD 5 (1919–1999) SC 5 (1927–2014) VT 5 (1942–2006) AK 4 (1976–2022) HI 3 (2009–2014) ND 3 (1981–1999) NV 2 (1972–1994)

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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