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9 California opinions name it 2 courts 1996–2026 1 in the last five years
The cases below were cited by California 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.
| Case | Followed | Cited |
|---|---|---|
People v. Morgantigreen2 sentences2026The technique is employed when the DNA sample available is too small and/or degraded to perform a more common type of DNA analysis known as RFLP.” (People v. Morganti (1996) 43 Cal.App.4th 643, 662 (Morganti).) PCR analysis may be used “to amplify a specific gene known as the DQ alpha. 2026Finally, the amplified gene is typed in order to identify the alleles present in the amplified DNA.” (Morganti, supra, 43 Cal.App.4th at p. 662 , fn. omitted.) A Polymarker analysis is a different kind of PCR test that “compare[s] five different genes rather than the single gene used in the DQ-Alpha test.” (People v. Jones (2013) 57 Cal.4th 899, 935 (Jones).) 13 PEOPLE v. BERTSCH and HRONIS Opinion of the Court by Guerrero, C. | 2 | 5 |
People v. Reevesgreen2 sentences2013(People v. Reeves (2001) 91 Cal.App.4th 14, 24-25 [ 109 Cal.Rptr.2d 728 ].) PCR analysis of the DQ-Alpha gene is now firmly established as a scientific technique that satisfies the Kelly test. 2013(People v. Reeves (2001) 91 Cal.App.4th 14, 24-25 [ 109 Cal.Rptr.2d 728 ].) PCR analysis of the DQ-Alpha gene is now firmly established as a scientific technique that satisfies the Kelly test. | 2 | 3 |
People v. Sotogreen2 sentences2011The NRC formed the Committee on DNA Technology in Forensic Science to study the use of DNA analysis for forensic purposes, resulting in the issuance of the 1992 report.” (Soto, supra, 21 Cal.4th at p. 536, fn. 30 .) This analysis compares the lengths of sets of multiple polymorphic fragments containing “ ‘variable number tandem repeats’ ” (VNTR alleles) obtained from a suspect’s DNA and from crime scene samples. ( Venegas, supra, 18 Cal.4th at pp. 59-60.) The 1996 NRC Report also notes that PCR analysis permits an exact identification of each allele, and it obviates the need for matching and “ 2001(See Soto, supra, 21 Cal.4th at pp. 538-539.) Thus, while Soto’s discussion of the population substructure issue is informative, it does not settle the question with respect to PCR analysis. | 1 | 2 |
People v. Leahygreen2 sentences2001He also argues that the product rule, as applied to both RFLP and PCR testing, has not gained general acceptance because a controversy remains as to whether the rule should be modified to account for laboratory error rates. “‘ General acceptance’ under Kelly means a consensus drawn from a typical cross-section of the relevant, qualified scientific community.” (People v. Leahy (1994) 8 Cal.4th 587, 612 [ 34 Cal.Rptr.2d 663 , 882 P.2d 321 ] (Leahy).) “The Kelly test does not demand ‘absolute unanimity of views in the scientific community .... 1996Grunbaum conceded that PCR analysis is generally accepted among scientists and that it will become the method of choice in DNA analysis, but opined that PCR analysis ofDQ alpha is not generally accepted in the scientific community as a reliable forensic tool. 12 The trial court accorded little weight to Grunbaum’s opinion because he (1) lacked sufficient hands-on experience, 13 (2) lacked credibility because of his bias toward Mr. Harmor, and (3) expressed opinions and criticisms which were unsupported by reason or lacked foundation. 14 This ruling was proper: “[0]position by persons minimally | 1 | 2 |
The People v. Jonesgreen2 sentences2026Finally, the amplified gene is typed in order to identify the alleles present in the amplified DNA.” (Morganti, supra, 43 Cal.App.4th at p. 662 , fn. omitted.) A Polymarker analysis is a different kind of PCR test that “compare[s] five different genes rather than the single gene used in the DQ-Alpha test.” (People v. Jones (2013) 57 Cal.4th 899, 935 (Jones).) 13 PEOPLE v. BERTSCH and HRONIS Opinion of the Court by Guerrero, C. 2026(See, e.g., Jones, supra, 57 Cal.4th at p. 937 [“PCR analysis of the DQ- Alpha gene is now firmly established as a scientific technique that satisfies the Kelly test”]; People v. Stevey (2012) 209 Cal.App.4th 1400, 1411 .) 121 PEOPLE v. BERTSCH and HRONIS Opinion of the Court by Guerrero, C. | 1 | 1 |
District Attorney's Office for the Third Judicial District v. Osbornegreen2 sentences2011The NRC formed the Committee on DNA Technology in Forensic Science to study the use of DNA analysis for forensic purposes, resulting in the issuance of the 1992 report.” (Soto, supra, 21 Cal.4th at p. 536, fn. 30 .) This analysis compares the lengths of sets of multiple polymorphic fragments containing “ ‘variable number tandem repeats’ ” (VNTR alleles) obtained from a suspect’s DNA and from crime scene samples. ( Venegas, supra, 18 Cal.4th at pp. 59-60.) The 1996 NRC Report also notes that PCR analysis permits an exact identification of each allele, and it obviates the need for matching and “ 2011The NRC formed the Committee on DNA Technology in Forensic Science to study the use of DNA analysis for forensic purposes, resulting in the issuance of the 1992 report.” (Soto, supra, 21 Cal.4th at p. 536, fn. 30 .) This analysis compares the lengths of sets of multiple polymorphic fragments containing “ ‘variable number tandem repeats’ ” (VNTR alleles) obtained from a suspect’s DNA and from crime scene samples. ( Venegas, supra, 18 Cal.4th at pp. 59-60.) The 1996 NRC Report also notes that PCR analysis permits an exact identification of each allele, and it obviates the need for matching and “ | 1 | 1 |
People v. Wilsongreen2 sentences2011(Henderson, supra, 107 Cal.App.4th atp. 778 ; People v. Wilson (2006) 38 Cal.4th 1237, 1242 [ 45 Cal.Rptr.3d 73 , 136 P.3d 864 ].) The analyst calculates the statistical probability that the DNA profile of a person, selected at random from the relevant population, would contain the same pattern of alleles represented in the evidence sample. 2011(Henderson, supra, 107 Cal.App.4th atp. 778 ; People v. Wilson (2006) 38 Cal.4th 1237, 1242 [ 45 Cal.Rptr.3d 73 , 136 P.3d 864 ].) The analyst calculates the statistical probability that the DNA profile of a person, selected at random from the relevant population, would contain the same pattern of alleles represented in the evidence sample. | 1 | 1 |
People v. Hillgreen2 sentences2003The analyst then compares the configuration of these peaks against known reference standards in order to determine the number of alleles present at the target loci in a given sample.” (U.S. v. Trala, supra, 162 F.Supp.2d at p. 342 ; see also People v. Hill (2001) 89 Cal.App.4th 48, 57-58 [ 107 Cal.Rptr.2d 110 ]; Rosenblum, Improved Single-Strand DNA Sizing Accuracy in Capillary Electrophoresis (1997) 25 Nucleic Acids Research, No. 19, pp. 3928, 3929; <http://www.appliedbiosystems.com/products/productdetail.cfm?prod_id=38> [as on Apr. 1, 2003].) As our colleagues in the Court of Appeal for the 2003The analyst then compares the configuration of these peaks against known reference standards in order to determine the number of alleles present at the target loci in a given sample.” (U.S. v. Trala, supra, 162 F.Supp.2d at p. 342 ; see also People v. Hill (2001) 89 Cal.App.4th 48, 57-58 [ 107 Cal.Rptr.2d 110 ]; Rosenblum, Improved Single-Strand DNA Sizing Accuracy in Capillary Electrophoresis (1997) 25 Nucleic Acids Research, No. 19, pp. 3928, 3929; <http://www.appliedbiosystems.com/products/productdetail.cfm?prod_id=38> [as on Apr. 1, 2003].) As our colleagues in the Court of Appeal for the | 1 | 1 |
People v. Axellgreen1 sentence2001Rather, the test is met if use of the technique is supported by a clear majority of the members of that community.’ ” (Leahy, supra, 8 Cal.4th at p. 612 , quoting People v. Guerra, supra, 37 Cal.3d at p. 418 , italics added by Leahy , see also People v. Axell, supra, 235 Cal.App.3d at p. 860 [“[T]he defense witnesses’ testimony on the issue of general acceptance did not undermine the validity of the trial court’s determination that forensic use of RFLP analysis is generally accepted in the relevant scientific community.”].) 14 Appellant complains the trial court could not have found that use o | 1 | 1 |
San Diego Gas & Electric Co. v. Superior Courtgreen2 sentences2001(See San Diego Gas & Electric Co. v. Superior Court (1996) 13 Cal.4th 893, 943 [ 55 Cal.Rptr.2d 724 , 920 P.2d 669 ] [“Cases are not authority ... for issues not raised and resolved.”].) Nor do we consider the appellate court decisions in Morganti, supra, 43 Cal.App.4th 643 , and People v. Wright (1998) 62 Cal.App.4th 31 [ 72 Cal.Rptr.2d 246 ], to be controlling because neither case involved a Kelly challenge to the product rule. 2001(See San Diego Gas & Electric Co. v. Superior Court (1996) 13 Cal.4th 893, 943 [ 55 Cal.Rptr.2d 724 , 920 P.2d 669 ] [“Cases are not authority ... for issues not raised and resolved.”].) Nor do we consider the appellate court decisions in Morganti, supra, 43 Cal.App.4th 643 , and People v. Wright (1998) 62 Cal.App.4th 31 [ 72 Cal.Rptr.2d 246 ], to be controlling because neither case involved a Kelly challenge to the product rule. | 1 | 1 |
People v. Farmergreen1 sentence1996(People v. Farmer, supra, 47 Cal.3d at p. 913.) Further, probative value is a different issue from reliability. 13 Grunbaum has never done forensic case work on evidence using PCR analysis of DQ alpha, never written any article or lectured on PCR or RFLP, and never received training to use the Kit. 14 “Grunbaum was extremely hostile toward Harmor, testifying that Harmor did not “follow any protocol whatsoever,” that his work was “experimentation” and “hit and run kind of analysis,” and that his results were not reliable either “scientifically or unscientifically.” Grunbaum accused Mr. Harmor o | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Doolin
green
2 sentences2013(People v. Doolin, supra, 45 Cal.4th at p. 448 ; People v. Morganti, supra, 43 Cal.App.4th at p. 669 .) 13 “Once a published appellate decision has affirmed admission of a scientific technique, the technique’s general acceptance is established as a matter of law. 2013(People v. Doolin, supra, 45 Cal.4th at p. 448 ; People v. Morganti, supra, 43 Cal.App.4th at p. 669 .)13 ―Once a published appellate decision has affirmed admission of a scientific technique, the technique‘s general acceptance is established as a matter of law. | 2 | 2013–2013 |
People v. Kelly
red
2 sentences2001While a trial court’s ruling on expert qualifications is entitled to substantial deference on appeal (Kelly, supra, 17 Cal.3d at p. 39 ), the court here did not expressly find Word qualified to give an opinion as to the product rule’s reliability in PCR analysis, nor do we think such a ruling can be implied from the overruling of certain defense objections. 1999A. Motion to Continue Kelly-Frye Hearing In April 1992, defendant filed a motion in limine to exclude DNA evidence, including PCR analysis of saliva on the cigarette butt found on the floor in the Wedens’ home on the ground that the prosecution had not established an adequate foundation, under People v. Kelly (1976) 17 Cal.3d 24 [ 130 Cal.Rptr. 144 , 549 P.2d 1240 ] and Frye v. United States (D.C. | 2 | 1999–2001 |
People v. Stevey
green
1 sentence2026(See, e.g., Jones, supra, 57 Cal.4th at p. 937 [“PCR analysis of the DQ- Alpha gene is now firmly established as a scientific technique that satisfies the Kelly test”]; People v. Stevey (2012) 209 Cal.App.4th 1400, 1411 .) 121 PEOPLE v. BERTSCH and HRONIS Opinion of the Court by Guerrero, C. | 1 | 2026–2026 |
People v. Henderson
green
2 sentences2011After amplification, in the third and final step of PCR analysis, the amplified gene is “typed,” through the use of DNA probes, to identify the specific alleles it contains. [Citation.] If the DNA profile thus constructed differs in any way between the suspect and the sample, the suspect is excluded.’ ” (Henderson, supra, 107 Cal.App.4th at p. 778 .) If a match is found, the next question is the statistical significance of the match. 2011(Henderson, supra, 107 Cal.App.4th atp. 778 ; People v. Wilson (2006) 38 Cal.4th 1237, 1242 [ 45 Cal.Rptr.3d 73 , 136 P.3d 864 ].) The analyst calculates the statistical probability that the DNA profile of a person, selected at random from the relevant population, would contain the same pattern of alleles represented in the evidence sample. | 1 | 2011–2011 |
United States v. Trala
green
2 sentences2003The analyst then compares the configuration of these peaks against known reference standards in order to determine the number of alleles present at the target loci in a given sample.” (U.S. v. Trala, supra, 162 F.Supp.2d at p. 342 ; see also People v. Hill (2001) 89 Cal.App.4th 48, 57-58 [ 107 Cal.Rptr.2d 110 ]; Rosenblum, Improved Single-Strand DNA Sizing Accuracy in Capillary Electrophoresis (1997) 25 Nucleic Acids Research, No. 19, pp. 3928, 3929; <http://www.appliedbiosystems.com/products/productdetail.cfm?prod_id=38> [as on Apr. 1, 2003].) As our colleagues in the Court of Appeal for the 2003The analyst then compares the configuration of these peaks against known reference standards in order to determine the number of alleles present at the target loci in a given sample.” (U.S. v. Trala, supra, 162 F.Supp.2d at p. 342 ; see also People v. Hill (2001) 89 Cal.App.4th 48, 57-58 [ 107 Cal.Rptr.2d 110 ]; Rosenblum, Improved Single-Strand DNA Sizing Accuracy in Capillary Electrophoresis (1997) 25 Nucleic Acids Research, No. 19, pp. 3928, 3929; <http://www.appliedbiosystems.com/products/productdetail.cfm?prod_id=38> [as on Apr. 1, 2003].) As our colleagues in the Court of Appeal for the | 1 | 2003–2003 |
People v. Wright
green
2 sentences2001(See San Diego Gas & Electric Co. v. Superior Court (1996) 13 Cal.4th 893, 943 [ 55 Cal.Rptr.2d 724 , 920 P.2d 669 ] [“Cases are not authority ... for issues not raised and resolved.”].) Nor do we consider the appellate court decisions in Morganti, supra, 43 Cal.App.4th 643 , and People v. Wright (1998) 62 Cal.App.4th 31 [ 72 Cal.Rptr.2d 246 ], to be controlling because neither case involved a Kelly challenge to the product rule. 2001(See San Diego Gas & Electric Co. v. Superior Court (1996) 13 Cal.4th 893, 943 [ 55 Cal.Rptr.2d 724 , 920 P.2d 669 ] [“Cases are not authority ... for issues not raised and resolved.”].) Nor do we consider the appellate court decisions in Morganti, supra, 43 Cal.App.4th 643 , and People v. Wright (1998) 62 Cal.App.4th 31 [ 72 Cal.Rptr.2d 246 ], to be controlling because neither case involved a Kelly challenge to the product rule. | 1 | 2001–2001 |
People v. Guerra
green
1 sentence2001Rather, the test is met if use of the technique is supported by a clear majority of the members of that community.’ ” (Leahy, supra, 8 Cal.4th at p. 612 , quoting People v. Guerra, supra, 37 Cal.3d at p. 418 , italics added by Leahy , see also People v. Axell, supra, 235 Cal.App.3d at p. 860 [“[T]he defense witnesses’ testimony on the issue of general acceptance did not undermine the validity of the trial court’s determination that forensic use of RFLP analysis is generally accepted in the relevant scientific community.”].) 14 Appellant complains the trial court could not have found that use o | 1 | 2001–2001 |
People v. Venegas
green
1 sentence2001(Venegas, supra, 18 Cal.4th at p. 65 .) In RFLP, bands at each locus have been assigned to fixed bins, each of which is known to contain alleles that occur at certain frequencies in population databases specific to Caucasians, African-Americans and Híspanles. | 1 | 2001–2001 |
Frye v. United States
red
2 sentences1999Cir. 1923) 293 F. 1013 [ 54 App.D.C. 46 , 34 A.L.R. 145 ], as to the general *503 acceptance of PCR analysis in the scientific community. 1999Cir. 1923) 293 F. 1013 [ 54 App.D.C. 46 , 34 A.L.R. 145 ], as to the general *503 acceptance of PCR analysis in the scientific community. | 1 | 1999–1999 |
State v. Gentry
green
2 sentences1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. 1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. | 1 | 1996–1996 |
Seritt v. State
green
1 sentence1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. | 1 | 1996–1996 |
State v. Gollehon
green
1 sentence1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. | 1 | 1996–1996 |
State v. Moore
green
2 sentences1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. 1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. | 1 | 1996–1996 |
People v. Reilly
green
1 sentence1996Harmor has testified in 10 criminal cases in which PCR analysis was used. *667 This court has previously recognized that “ ‘a certain degree of “interest” must be tolerated if scientists familiar with the theory and practice of a new technique are to testify at all. [Citations.]’” (People v. Reilly, supra, 196 Cal.App.3d at p. 1140 .) The trial court found insufficient evidence that Blake or Harmor was interested and concluded that both qualified as experts. | 1 | 1996–1996 |
Spencer v. Commonwealth
green
2 sentences1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. 1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. | 1 | 1996–1996 |
State v. Williams
green
1 sentence1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. | 1 | 1996–1996 |
State v. Russell
green
1 sentence1996(See Spencer v. Com. (1990) 240 Va. 78 [ 393 S.E.2d 609, 620 ]; State v. Gentry (1995) 125 Wn.2d 570 [ 888 P.2d 1105, 1117-1118 ]; State v. Russell (Wash. 1994) 882 P.2d 747, 759-769 ; State v. Moore (1994) 268 Mont. 20 [ 885 P.2d 457, 474-475 ], disapproved on other grounds in State v. Gollehon (Mont. 1995) 906 P.2d 697, 700-701 ; Seritt v. State (Ala.App. 1994) 647 So.2d 1, 3-5 ; State v. Williams (1991) 252 N.J. | 1 | 1996–1996 |
People v. Shirley
green
1 sentence1996(People v. Leahy, supra, 8 Cal.4th at pp. 611-612.) “ ‘[I]f a fair overview of the literature discloses that scientists significant either in number or expertise publicly oppose [the technique] as unreliable, the court may safely conclude there is no such consensus at the present time.’ ” (Id. at p. 611, quoting People v. Shirley, supra, 31 Cal.3d at p. 56 .) Our review of the literature in this record confirms there is no such significant public opposition. 17 *666 (iii) Judicial decisions PCR evidence has not been found admissible under Kelly in published California appellate precedent. 18 B | 1 | 1996–1996 |
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.
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.