first prong test (Florida) · Go Syfert
← Florida issues

first prong test in Florida

71 Florida opinions name it 2 courts 1981–2025 6 in the last five years

The cases below were cited by Florida 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
Woodard Chevrolet, Inc. v. Taylor Corp.green
fladistctapp · 2007 · cited in 2 Florida opinions naming this issue, 2009–2016
2 sentences

2016Florida’s long-arm statute, section 48.193(l)(a)(7), Florida Statutes (2013), provides in part that a nonresident subjects himself to personal jurisdiction in a Florida court if he “[b]reach[es] a contract in this state by failing to perform acts required by the contract to be performed in this state.” “It is sufficient for purposes of the first prong of the test that a contract is made with a Florida resident and payment is to be made in this state.” Woodard Chevrolet, Inc. v. Taylor Corp., 949 So.2d 268, 270 (Fla. 4th DCA 2007). ‘Where no place of payment is designated in a contract, payment

2009CCC claims that the trial court had personal jurisdiction through Florida's long arm statute by virtue of the contract requiring payments to be made in Florida. *668 This court has found that "[i]t is sufficient for purposes of the first prong of the test that a contract is made with a Florida resident and payment is to be made in this state." Woodard Chevrolet, Inc. v. Taylor Corp., 949 So.2d 268, 270 (Fla. 4th DCA 2007) (citation omitted).

22
Stomar, Inc. v. Lucky Seven Riverboat Company, LLCgreen
fladistctapp · 2002 · cited in 2 Florida opinions naming this issue, 2004–2007
2 sentences

2007See Smith Architectural Group, Inc. v. Dehaan, 867 So.2d 434, 436 (Fla. 4th DCA 2004) (citing Stomar, Inc. v. Lucky Seven Riverboat Co., 821 So.2d 1183 (Fla. 4th DCA 2002) (finding allegation that owner of vessel breached agreement with Florida ship broker by failing to pay commission owed to broker in Florida sufficient to satisfy first prong of jurisdictional inquiry)); see also Tallmadge v. Mortgage Fin.

2004See Stomar, Inc. v. Lucky Seven Riverboat Co., 821 So.2d 1183 (Fla. 4th DCA 2002) (allegation that owner of vessel breached agreement with Florida ship broker by failing to pay commission owed to broker in Florida sufficient to satisfy first prong of jurisdictional inquiry); see also Tallmadge v. Mortgage Fin.

22
BAA v. Stategreen
fla · 1978 · cited in 2 Florida opinions naming this issue, 1987–1987
2 sentences

1987See D.A. v. State, 471 So.2d 147, 152 (Fla. 3d DCA 1985); see also B.A.A. v. State, 356 So.2d 304 (Fla. 1978); Ingram v. State, 502 So.2d 529 (Fla. 4th DCA 1987); cf. V.S. v. State, 446 So.2d 232 (Fla. 3d DCA 1984) (delinquency adjudication reversed where juvenile arrested for loitering and prowling based on police officer's hunch).

1987See D.A. v. State, 471 So.2d 147, 152 (Fla. 3d DCA 1985); see also B.A.A. v. State, 356 So.2d 304 (Fla.1978); Ingram v. State, 502 So.2d 529 (Fla. 4th DCA 1987); cf. V.S. v. State, 446 So.2d 232 (Fla. 3d DCA 1984) (delinquency adjudication reversed where juvenile arrested for loitering and prowling based on police officer’s hunch).

22
DA v. Stategreen
fladistctapp · 1985 · cited in 2 Florida opinions naming this issue, 1987–1987
2 sentences

1987See D.A. v. State, 471 So.2d 147, 152 (Fla. 3d DCA 1985); see also B.A.A. v. State, 356 So.2d 304 (Fla. 1978); Ingram v. State, 502 So.2d 529 (Fla. 4th DCA 1987); cf. V.S. v. State, 446 So.2d 232 (Fla. 3d DCA 1984) (delinquency adjudication reversed where juvenile arrested for loitering and prowling based on police officer's hunch).

1987See D.A. v. State, 471 So.2d 147, 152 (Fla. 3d DCA 1985); see also B.A.A. v. State, 356 So.2d 304 (Fla.1978); Ingram v. State, 502 So.2d 529 (Fla. 4th DCA 1987); cf. V.S. v. State, 446 So.2d 232 (Fla. 3d DCA 1984) (delinquency adjudication reversed where juvenile arrested for loitering and prowling based on police officer’s hunch).

22
Hewlett v. Stategreen
fladistctapp · 1995 · cited in 2 Florida opinions naming this issue, 2019–2019
2 sentences

2019See Hewlett, 661 So. 2d at 115-16 (where a chief judge exceeded his authority under both Florida Rule of Judicial Administration 2.050(b) and section 948.08(6) by issuing an administrative order which attempted to amend the pretrial intervention statute by adding terms and conditions that were not part of the original legislation, such an order constitutes a departure from the essential requirements of the law); Gincley, 267 So. 3d at 446 (“An order based upon the unauthorized portion of an administrative order is a departure from the essential requirements of law and meets the first prong of

2019An order “based upon the unauthorized portion of [an] administrative order” is a departure from the essential requirements of law and “meets the first prong of the test for certiorari jurisdiction . . . .” Hewlett, 661 So. 2d at 115 .

12
DG v. Stategreen
fladistctapp · 1995 · cited in 2 Florida opinions naming this issue, 1999–2018
2 sentences

2018The dissent cites cases holding, for example, that an officer is executing a legal duty if he asks “for assistance with an ongoing emergency.” Dissent at 12-13 (quoting D.G. v. State, 661 So. 2d 75, 76 (Fla. 2d DCA 1995)); accord S.G. v. 8 State, 252 So. 3d 323, 325 (Fla. 1st DCA 2018) (“Legal duties include things like serving process, legally detaining a person, or asking for assistance in an emergency situation.”); Brandful v. State, 858 So. 2d 367, 370 (Fla. 3d DCA 2003) (“[I]nvestigating a complaint constitutes the lawful execution of a legal duty.”); Francis v. State, 736 So. 2d 97 , 99

1999D.G., 661 So.2d at 76 ; Jay v. State, No. 98-0109, 731 So.2d 774 (Fla. 4th DCA 1999).

12
Baze v. Reesgreen
scotus · 2008 · cited in 1 Florida opinions naming this issue, 2025–2025
2 sentences

2025Under the first prong of this test, the question is not merely whether any pain is inflicted, for “the Eighth Amendment ‘does not demand the avoidance of all risk of pain in carrying out executions.’ ” Bucklew v. Precythe, 587 U.S. 119, 134 (2019) (quoting Baze v. Rees, 553 U.S. 35, 47 (2008)).

2025Rather, “[t]he Eighth Amendment does not come into play unless the risk of pain associated with the State’s method is ‘substantial when compared to a known and available alternative.’ ” Id. (quoting Glossip, 576 U.S. at 878 ).

11
Bucklew v. Precythegreen
scotus · 2019 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025Under the first prong of this test, the question is not merely whether any pain is inflicted, for “the Eighth Amendment ‘does not demand the avoidance of all risk of pain in carrying out executions.’ ” Bucklew v. Precythe, 587 U.S. 119, 134 (2019) (quoting Baze v. Rees, 553 U.S. 35, 47 (2008)).

11
THE BURGESS LAW FIRM, P.A. and FREDERICK BURGESS v. JBJ INVESTMENT OF S. FLORIDA, INC.green
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2021–2021
1 sentence

2021There is no legal requirement for a single formalized document to demonstrate an attorney-client relationship exists; instead, the test for determining that the relationship exists “is a subjective one and hinges upon the client’s belief that he is consulting a lawyer in that capacity and his manifested intention is to seek professional legal advice.” JBJ Inv. of S. Fla., Inc. v. S. Title Grp., Inc., 251 So. 3d 173, 177 (Fla. 4th DCA 2018) (quoting Bartholomew v. Bartholomew, 611 So. 2d 85, 86 (Fla. 2d DCA 1992)).

11
Bartholomew v. Bartholomewgreen
fladistctapp · 1992 · cited in 1 Florida opinions naming this issue, 2021–2021
1 sentence

2021There is no legal requirement for a single formalized document to demonstrate an attorney-client relationship exists; instead, the test for determining that the relationship exists “is a subjective one and hinges upon the client’s belief that he is consulting a lawyer in that capacity and his manifested intention is to seek professional legal advice.” JBJ Inv. of S. Fla., Inc. v. S. Title Grp., Inc., 251 So. 3d 173, 177 (Fla. 4th DCA 2018) (quoting Bartholomew v. Bartholomew, 611 So. 2d 85, 86 (Fla. 2d DCA 1992)).

11
Yang Enterprises, Inc. v. Georgalisgreen
fladistctapp · 2008 · cited in 1 Florida opinions naming this issue, 2021–2021
1 sentence

2021Appellants only dispute the first prong of the test. 4 To satisfy the first prong of the test, the moving party must demonstrate that their perception that an attorney-client relationship existed is “objectively reasonable.” See Yang Enters., Inc. v. Georgalis, 988 So. 2d 1180, 1184 (Fla 1st DCA 2008).

11
JAMES EVAN GINCLEY v. STATE OF FLORIDAgreen
fladistctapp · 2019 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019See Hewlett, 661 So. 2d at 115-16 (where a chief judge exceeded his authority under both Florida Rule of Judicial Administration 2.050(b) and section 948.08(6) by issuing an administrative order which attempted to amend the pretrial intervention statute by adding terms and conditions that were not part of the original legislation, such an order constitutes a departure from the essential requirements of the law); Gincley, 267 So. 3d at 446 (“An order based upon the unauthorized portion of an administrative order is a departure from the essential requirements of law and meets the first prong of

11
Brandful v. Stategreen
fladistctapp · 2003 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018The dissent cites cases holding, for example, that an officer is executing a legal duty if he asks “for assistance with an ongoing emergency.” Dissent at 12-13 (quoting D.G. v. State, 661 So. 2d 75, 76 (Fla. 2d DCA 1995)); accord S.G. v. 8 State, 252 So. 3d 323, 325 (Fla. 1st DCA 2018) (“Legal duties include things like serving process, legally detaining a person, or asking for assistance in an emergency situation.”); Brandful v. State, 858 So. 2d 367, 370 (Fla. 3d DCA 2003) (“[I]nvestigating a complaint constitutes the lawful execution of a legal duty.”); Francis v. State, 736 So. 2d 97 , 99

11
VL v. Stategreen
fladistctapp · 2001 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018The dissent cites cases holding, for example, that an officer is executing a legal duty if he asks “for assistance with an ongoing emergency.” Dissent at 12-13 (quoting D.G. v. State, 661 So. 2d 75, 76 (Fla. 2d DCA 1995)); accord S.G. v. 8 State, 252 So. 3d 323, 325 (Fla. 1st DCA 2018) (“Legal duties include things like serving process, legally detaining a person, or asking for assistance in an emergency situation.”); Brandful v. State, 858 So. 2d 367, 370 (Fla. 3d DCA 2003) (“[I]nvestigating a complaint constitutes the lawful execution of a legal duty.”); Francis v. State, 736 So. 2d 97 , 99

11
S. G., a child v. State of Floridagreen
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018The dissent cites cases holding, for example, that an officer is executing a legal duty if he asks “for assistance with an ongoing emergency.” Dissent at 12-13 (quoting D.G. v. State, 661 So. 2d 75, 76 (Fla. 2d DCA 1995)); accord S.G. v. 8 State, 252 So. 3d 323, 325 (Fla. 1st DCA 2018) (“Legal duties include things like serving process, legally detaining a person, or asking for assistance in an emergency situation.”); Brandful v. State, 858 So. 2d 367, 370 (Fla. 3d DCA 2003) (“[I]nvestigating a complaint constitutes the lawful execution of a legal duty.”); Francis v. State, 736 So. 2d 97 , 99

11
Francis v. Stategreen
fladistctapp · 1999 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018The dissent cites cases holding, for example, that an officer is executing a legal duty if he asks “for assistance with an ongoing emergency.” Dissent at 12-13 (quoting D.G. v. State, 661 So. 2d 75, 76 (Fla. 2d DCA 1995)); accord S.G. v. 8 State, 252 So. 3d 323, 325 (Fla. 1st DCA 2018) (“Legal duties include things like serving process, legally detaining a person, or asking for assistance in an emergency situation.”); Brandful v. State, 858 So. 2d 367, 370 (Fla. 3d DCA 2003) (“[I]nvestigating a complaint constitutes the lawful execution of a legal duty.”); Francis v. State, 736 So. 2d 97 , 99

11
Ware v. Polk Countygreen
fladistctapp · 2005 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017The resolution of this appeal squarely depends on the first prong of the test because “where the government seeks an injunction in order to enforce its police power, any alternative legal remedy is ignored and irreparable harm is presumed.” Ware v. Polk County, 918 So.2d 977, 979 (Fla. 2d DCA 2005) (citing Metro.

11
Metropolitan Dade County v. O'BRIENgreen
fladistctapp · 1995 · cited in 1 Florida opinions naming this issue, 2017–2017
11
William Thompson v. State of Floridagreen
fla · 2016 · cited in 1 Florida opinions naming this issue, 2017–2017
11
Foster v. Californiagreen
scotus · 1969 · cited in 1 Florida opinions naming this issue, 2016–2016
11
State v. Sepulvadogreen
fladistctapp · 1978 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Corporacion Aero Angeles, S.A. v. Fernandezgreen
fladistctapp · 2011 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Osterweil v. Bartlettgreen
ca2 · 2013 · cited in 1 Florida opinions naming this issue, 2015–2015
11
The League of Women Voters of Florida, etc. v. Ken Detzner Opiniongreen
fla · 2015 · cited in 1 Florida opinions naming this issue, 2015–2015
11
Nixon v. Stategreen
fla · 2009 · cited in 1 Florida opinions naming this issue, 2011–2011
11
Commonwealth v. Leonegreen
mass · 1982 · cited in 1 Florida opinions naming this issue, 2010–2010
11
Smith Architectural Group, Inc. v. Dehaangreen
fladistctapp · 2004 · cited in 1 Florida opinions naming this issue, 2007–2007
11
Radcliffe v. Gyvesgreen
fladistctapp · 2005 · cited in 1 Florida opinions naming this issue, 2007–2007
11
Turner v. Crosbygreen
ca11 · 2003 · cited in 1 Florida opinions naming this issue, 2004–2004
11
Fairbanks, Inc. v. State, Dept. of Transp.green
fladistctapp · 1994 · cited in 1 Florida opinions naming this issue, 2003–2003
11
Gainesville Coca-Cola v. Younggreen
fladistctapp · 1992 · cited in 1 Florida opinions naming this issue, 2003–2003
11
Fritz v. Courtyard by Marriottgreen
fladistctapp · 1992 · cited in 1 Florida opinions naming this issue, 2003–2003
11
City of Boca Raton v. Stategreen
fla · 1992 · cited in 1 Florida opinions naming this issue, 2002–2002
11
Sperry v. Californiagreen
scotus · 1998 · cited in 1 Florida opinions naming this issue, 2000–2000
11
Coleman v. Calderongreen
scotus · 1998 · cited in 1 Florida opinions naming this issue, 2000–2000
11
Sperry v. Californiagreen
scotus · 1998 · cited in 1 Florida opinions naming this issue, 2000–2000
11
Collie v. Stategreen
fladistctapp · 1998 · cited in 1 Florida opinions naming this issue, 2000–2000
11
Pellerito Foods, Inc. v. American Conveyors Corp.green
fladistctapp · 1989 · cited in 1 Florida opinions naming this issue, 1996–1996
11
Martin-Johnson, Inc. v. Savagegreen
fla · 1987 · cited in 1 Florida opinions naming this issue, 1995–1995
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (41)

CaseCitedYears
Strickland v. Washington green
scotus · 1984
2 sentences

2024The Court stated that the first prong of the test is the same deficiency of counsel performance prong established by the Court the preceding year in Strickland v. Washington, 466 U.S. 668 (1984).

2000In further explaining the first prong of the test, the Supreme Court stated that "the defendant must show that counsel's representation fell below an objective standard of reasonableness" based on "prevailing professional norms." Strickland, 466 U.S. at 688 , 104 S.Ct. 2052 .

61986–2024
Cruz v. State green
fla · 1985
2 sentences

1993In Burch , however, the sting operation passed the first prong of the test enunciated in Cruz v. State, 465 So.2d 516 (Fla.), cert. denied, 473 U.S. 905 , 105 S.Ct. 3527 , 87 L.Ed.2d 652 (1985), because it was undertaken in response to a high volume of drug trade near the school.

1988This lack of focus is sufficient for the scenario to fail the first prong of the test. 465 So.2d at 522 .

51988–1993
Sorrells v. United States green
scotus · 1932
2 sentences

1992As Justice Roberts wrote in his separate opinion in Sorrells [ v. United States, 287 U.S. 435 , 53 S.Ct. 210 , 77 L.Ed. 413 (1932)], "Society is at war with the criminal classes," 287 U.S. at 453-54 , 53 S.Ct. at 217 .

1992As Justice Roberts wrote in his separate opinion in Sorrells [ v. United States, 287 U.S. 435 , 53 S.Ct. 210 , 77 L.Ed. 413 (1932)], "Society is at war with the criminal classes," 287 U.S. at 453-54 , 53 S.Ct. at 217 .

31985–1992
LC v. State green
fladistctapp · 1987
2 sentences

1999Id. at 96-97 .

1999Id. at 96-97 .

21999–1999
Ingram v. State neutral
fladistctapp · 1987
2 sentences

1987See D.A. v. State, 471 So.2d 147, 152 (Fla. 3d DCA 1985); see also B.A.A. v. State, 356 So.2d 304 (Fla. 1978); Ingram v. State, 502 So.2d 529 (Fla. 4th DCA 1987); cf. V.S. v. State, 446 So.2d 232 (Fla. 3d DCA 1984) (delinquency adjudication reversed where juvenile arrested for loitering and prowling based on police officer's hunch).

1987See D.A. v. State, 471 So.2d 147, 152 (Fla. 3d DCA 1985); see also B.A.A. v. State, 356 So.2d 304 (Fla.1978); Ingram v. State, 502 So.2d 529 (Fla. 4th DCA 1987); cf. V.S. v. State, 446 So.2d 232 (Fla. 3d DCA 1984) (delinquency adjudication reversed where juvenile arrested for loitering and prowling based on police officer’s hunch).

21987–1987
Vs v. State neutral
fladistctapp · 1984
2 sentences

1987See D.A. v. State, 471 So.2d 147, 152 (Fla. 3d DCA 1985); see also B.A.A. v. State, 356 So.2d 304 (Fla. 1978); Ingram v. State, 502 So.2d 529 (Fla. 4th DCA 1987); cf. V.S. v. State, 446 So.2d 232 (Fla. 3d DCA 1984) (delinquency adjudication reversed where juvenile arrested for loitering and prowling based on police officer's hunch).

1987See D.A. v. State, 471 So.2d 147, 152 (Fla. 3d DCA 1985); see also B.A.A. v. State, 356 So.2d 304 (Fla.1978); Ingram v. State, 502 So.2d 529 (Fla. 4th DCA 1987); cf. V.S. v. State, 446 So.2d 232 (Fla. 3d DCA 1984) (delinquency adjudication reversed where juvenile arrested for loitering and prowling based on police officer’s hunch).

21987–1987
Mark James Asay v. State of Florida green
fla · 2017
1 sentence

2025Even if Tanzi’s claims satisfied the first prong of the test to which we subject claims like his, he has failed to “identify a known and available alternative method of execution that entails a significantly less severe risk of pain.” Asay, 224 So. 3d at 701 (citing Glossip, 576 U.S. at 877 ).

12025–2025
Glossip v. Gross green
scotus · 2015
2 sentences

2025Rather, “[t]he Eighth Amendment does not come into play unless the risk of pain associated with the State’s method is ‘substantial when compared to a known and available alternative.’ ” Id. (quoting Glossip, 576 U.S. at 878 ).

2025Even if Tanzi’s claims satisfied the first prong of the test to which we subject claims like his, he has failed to “identify a known and available alternative method of execution that entails a significantly less severe risk of pain.” Asay, 224 So. 3d at 701 (citing Glossip, 576 U.S. at 877 ).

12025–2025
Hill v. Lockhart green
scotus · 1985
1 sentence

2024Hill, 474 U.S. at 58 .

12024–2024
Florida Insurance Guaranty Ass'n v. Devon Neighborhood Ass'n green
fla · 2011
1 sentence

2024In Devon, the court determined the Legislature did not clearly intend a statutory amendment to apply retroactively for two main reasons. 67 So. 3d at 194– 97.

12024–2024
Perez v. State green
fla · 1995
1 sentence

2023As mentioned above, although a show-up is inherently suggestive, Perez, 648 So. 2d at 719 , it is not unnecessarily suggestive unless police aggravate the suggestiveness of the procedure.

12023–2023
Menendez v. Progressive Express Insurance Co. green
fla · 2010
2 sentences

2023The Menendez Court itself did not acknowledge a preliminary “substantive” inquiry, but rather assumed the first-prong presumption against retroactivity applied, and found it overcome by clear legislative intent. 35 So. 3d at 877 .

2023But the Menendez Court’s ultimate conclusion that the statutory amendment at issue could not be applied retroactively because it worked a “substantive change to the statute,” 35 So. 3d at 875 , indicates the preliminary inquiry would have supported application of the first-prong presumption against retroactivity.

12023–2023
District of Columbia v. Heller green
scotus · 2008
2 sentences

2017Id. at 219 (quoting Heller, 554 U.S. at 599 , 128 S.Ct. 2783 ).

2017Id. at 219 (quoting Heller, 554 U.S. at 599 ).

12017–2017
Berenson v. Deutsche Bank National Trust Co. green
fladistctapp · 2016
12017–2017
Fitzpatrick v. State green
fla · 2005
12016–2016
Witt v. State green
fla · 1980
12016–2016
Stovall v. Denno green
scotus · 1967
12016–2016
Johnson v. State green
fla · 2005
12016–2016
Munoz v. State green
fla · 1993
12016–2016
Little v. Consolidated Publishing Co. green
alacivapp · 2011
12015–2015
In re Senate Joint Resolution of Legislative Apportionment 1176 green
fla · 2012
12015–2015
Marshall v. State green
fla · 2012
12015–2015
Cherry v. State red
fla · 2007
12011–2011
Kearse v. State green
fla · 2007
12009–2009
Wade v. Hirschman green
fla · 2005
12008–2008
Thornber v. City of Ft. Walton Beach green
fla · 1990
12006–2006
Jones v. Jack Maxton Chevrolet, Inc. green
fladistctapp · 1986
12006–2006
Byrd v. Richardson-Greenshields Securities, Inc. green
fla · 1989
12006–2006
Rolling v. State green
fla · 1997
12005–2005
State v. Towery green
ariz · 2003
12004–2004
Allen v. Hardy green
scotus · 1986
12004–2004
Arlt v. Buchanan green
fla · 1966
12004–2004
Key Largo Restaurant, Inc. v. TH Old Town Associates, Ltd. green
fladistctapp · 2000
12001–2001
Simmons v. State green
fladistctapp · 2000
12000–2000
St. Johns County v. NE Fla. Builders Ass'n, Inc. green
fla · 1991
12000–2000
Jay v. State green
fladistctapp · 1999
11999–1999
Del Duca v. Anthony green
fla · 1991
11997–1997
Collins Ex Rel. Burton v. Skinner green
fladistctapp · 1991
11997–1997
Ashley v. State green
fla · 1993
11995–1995
State v. Alen green
fla · 1993
11994–1994

Statutes the citing opinions construe

FL § 48.193 (7) FL § 856.021 (4) FL § 921.141 (4) FL § 775.082 (3) FL § 777.201 (3) FL § 948.08 (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

TX 450 (1982–2026) OH 227 (1980–2026) CA 162 (1982–2026) IL 137 (1983–2026) NY 127 (1969–2026) GA 105 (1975–2026) WA 100 (1982–2026) NJ 95 (1985–2026) CT 93 (1981–2025) PA 91 (1975–2026) FL 71 (1981–2025) IA 65 (1983–2024) MI 57 (1977–2026) TN 49 (1991–2025) NM 48 (1988–2026) AL 46 (1985–2024) MA 41 (1982–2023) IN 41 (1988–2024) MO 38 (1984–2016) RI 36 (1987–2017) NC 35 (1984–2024) NH 35 (1988–2025) UT 35 (1983–2025) MS 31 (1992–2024) WI 31 (1978–2025) KS 30 (1978–2024) MT 29 (1985–2023) KY 28 (1993–2026) VA 26 (1986–2026) VT 26 (1988–2025) CO 25 (1973–2026) HI 23 (1981–2024) LA 21 (1991–2025) MD 18 (1988–2024) SD 18 (1976–2025) MN 16 (1977–2024) OR 16 (1996–2021) AZ 14 (1983–2020) ME 14 (1984–2023) DC 13 (1978–2025) ND 12 (1980–2024) NE 12 (1985–2018) SC 12 (1992–2015) AK 11 (1975–2023) OK 9 (1986–2021) WV 9 (1991–2018) ID 7 (1989–2020) WY 7 (1991–2025) NV 6 (1996–2021) AR 5 (2003–2024) DE 5 (2018–2025) VI 4 (2007–2023)

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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