grounds rule (Pennsylvania) · Go Syfert
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grounds rule in Pennsylvania

69 Pennsylvania opinions name it 9 courts 1905–2024 3 in the last five years

The cases below were cited by Pennsylvania 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 (21)

CaseFollowedCited
Commonwealth v. Turzagreen
pa · 1940 · cited in 16 Pennsylvania opinions naming this issue, 1973–2010
2 sentences

2010Such a rule “is fundamental to our criminal judicial process. ‘The grounds on which the doctrine rests is the hasty and unguarded character which is often attached to confessions and admissions and the consequent danger of a conviction where no crime has in fact been committed.’” Herman at 1022 (citing Commonwealth v. Turza, 340 Pa. 128, 134 , 16 A.2d 401, 404 (Pa. 1940)).

2010Such a rule “is fundamental to our criminal judicial process. ‘The grounds on which the doctrine rests is the hasty and unguarded character which is often attached to confessions and admissions and the consequent danger of a conviction where no crime has in fact been committed.’” Herman at 1022 (citing Commonwealth v. Turza, 340 Pa. 128, 134 , 16 A.2d 401, 404 (Pa. 1940)).

1416
Sevin v. Kelshawgreen
pasuperct · 1992 · cited in 10 Pennsylvania opinions naming this issue, 2001–2015
2 sentences

2015Unified Sportsmen of Pennsylvania v. Pennsylvania Game Com’n (PGC), 950 A.2d 1120, 1134 (Pa. Cmwlth. 2008) (quoting Sevin v. Kelshaw, 417 Pa. Super. 1 , 611 A.2d 1232, 1235 (1992)).

2015Unified Sportsmen of Pennsylvania v. Pennsylvania Game Com’n (PGC), 950 A.2d 1120, 1134 (Pa. Cmwlth. 2008) (quoting Sevin v. Kelshaw, 417 Pa. Super. 1 , 611 A.2d 1232, 1235 (1992)).

1010
Unified Sportsmen v. Pennsylvania Game Commissiongreen
pacommwct · 2008 · cited in 9 Pennsylvania opinions naming this issue, 2010–2015
2 sentences

2015Unified Sportsmen of Pennsylvania v. Pennsylvania Game Com’n (PGC), 950 A.2d 1120, 1134 (Pa. Cmwlth. 2008) (quoting Sevin v. Kelshaw, 417 Pa. Super. 1 , 611 A.2d 1232, 1235 (1992)).

2014Unified Sportsmen of Pennsylvania v. Pennsylvania Game Com’n (PGC), 950 A.2d 1120, 1134 (Pa. Cmwlth. 2008) (quoting Sevin v. Kelshaw, 417 Pa. Super. 1 , 611 A.2d 1232, 1235 (1992)).

99
Commonwealth v. Waregreen
pa · 1974 · cited in 6 Pennsylvania opinions naming this issue, 1976–2003
2 sentences

1996See e.g., Commonwealth v. Turza, supra at 134, 16 A.2d at 404 (“the grounds on which the rule rests are the hasty and unguarded character which is often attached to confessions and admissions ...” (emphasis supplied)); Commonwealth v. Ware, supra at 365, 329 A.2d at 274 (“a criminal conviction may not be based on the extra-judicial confession or admission of the defendant unless it is corroborated ...” (emphasis supplied)).

1984This evidentiary requirement, known as the corpus delicti rule, “is rooted in a hesitancy to convict one of crime on the basis of his own statements only. ‘The grounds on which the rule rests are the hasty and unguarded character which is often attached to confessions and admissions and the consequent danger of a conviction where no crime has in fact been committed . . . .’ ” Commonwealth v. Moore, *239 supra, 466 Pa. at 513 , 353 A.2d at 809 quoting Commonwealth v. Ware, 459 Pa. 334, 365 , 329 A.2d 258, 274 (1974).

36
Commonwealth v. Leamergreen
pa · 1972 · cited in 3 Pennsylvania opinions naming this issue, 1974–1984
2 sentences

1984Accord Commonwealth v. Learner, 449 Pa. 76, 83 , 295 A.2d 272, 275 (1972); Commonwealth v. Palmer, 448 Pa. 282, 286 , 292 A.2d 921, 922 (1972); Commonwealth v. Turza, 340 Pa. 128, 134 , 16 A.2d 401, 404 (1940); Commonwealth v. Herman, 288 Pa.Super. 219, 230 , 431 A.2d 1016, 1022 (1981).

1984Accord Commonwealth v. Learner, 449 Pa. 76, 83 , 295 A.2d 272, 275 (1972); Commonwealth v. Palmer, 448 Pa. 282, 286 , 292 A.2d 921, 922 (1972); Commonwealth v. Turza, 340 Pa. 128, 134 , 16 A.2d 401, 404 (1940); Commonwealth v. Herman, 288 Pa.Super. 219, 230 , 431 A.2d 1016, 1022 (1981).

33
Commonwealth v. Hermangreen
pasuperct · 1981 · cited in 2 Pennsylvania opinions naming this issue, 1984–2010
2 sentences

2010Such a rule “is fundamental to our criminal judicial process. ‘The grounds on which the doctrine rests is the hasty and unguarded character which is often attached to confessions and admissions and the consequent danger of a conviction where no crime has in fact been committed.’” Herman at 1022 (citing Commonwealth v. Turza, 340 Pa. 128, 134 , 16 A.2d 401, 404 (Pa. 1940)).

1984Accord Commonwealth v. Learner, 449 Pa. 76, 83 , 295 A.2d 272, 275 (1972); Commonwealth v. Palmer, 448 Pa. 282, 286 , 292 A.2d 921, 922 (1972); Commonwealth v. Turza, 340 Pa. 128, 134 , 16 A.2d 401, 404 (1940); Commonwealth v. Herman, 288 Pa.Super. 219, 230 , 431 A.2d 1016, 1022 (1981).

22
Commonwealth v. Palmergreen
pa · 1972 · cited in 2 Pennsylvania opinions naming this issue, 1981–1984
2 sentences

1984Accord Commonwealth v. Learner, 449 Pa. 76, 83 , 295 A.2d 272, 275 (1972); Commonwealth v. Palmer, 448 Pa. 282, 286 , 292 A.2d 921, 922 (1972); Commonwealth v. Turza, 340 Pa. 128, 134 , 16 A.2d 401, 404 (1940); Commonwealth v. Herman, 288 Pa.Super. 219, 230 , 431 A.2d 1016, 1022 (1981).

1984Accord Commonwealth v. Learner, 449 Pa. 76, 83 , 295 A.2d 272, 275 (1972); Commonwealth v. Palmer, 448 Pa. 282, 286 , 292 A.2d 921, 922 (1972); Commonwealth v. Turza, 340 Pa. 128, 134 , 16 A.2d 401, 404 (1940); Commonwealth v. Herman, 288 Pa.Super. 219, 230 , 431 A.2d 1016, 1022 (1981).

12
Commonwealth v. Abu-Jamalgreen
pa · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024See Abu-Jamal, 941 A.2d at 1268 .

11
Keller v. Meygreen
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020See Pa.R.A.P. 2119; see also Keller v. Mey, 67 A.3d 1, 7 (Pa. Super. 2013) (“Our Rules provide that an appellant’s argument must contain citation to relevant authorities as well as reference to the portions of the record and evidence that support the issue on appeal. . .

11
Commonwealth v. Turetskygreen
pasuperct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019Turetsky, 925 A.2d 876, 879 (Pa. Super. 2007) (A claim that the defendant's guilty plea was not knowingly, intelligently and voluntarily made was found waived on the grounds that the claim could have been raised on direct appeal but was not}). 4 As such, with regard to the Defendant's first issue, he must establish by a preponderance of the evidence that his plea of guilty was unlawfully induced because he requested, but was not provided, an interpreter and that such circumstances make it.likely that the inducement caused the petitioner to plead guilty and the petitioner is innocent, AND that

11
Commonwealth v. Rachakgreen
pasuperct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
1 sentence

2019"Ordinarily, failure to petition to withdraw a plea, combined with failure to pursue direct appeal will bar consideration of an attack on one's plea in collateral proceedings." Commonwealth v. Rachak, 62 A.3d 389, 395 (Pa. Super. 2012).

11
Commonwealth v. Taylorgreen
pa · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
1 sentence

2015Commonwealth v. Taylor, 831 A.2d 587, 590 (Pa. 2003) (citations and some quotation marks omitted).

11
Commonwealth v. Braceygreen
pa · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
1 sentence

2014Commonwealth v. Bracey, 795 A.2d 935, 940, n.4 (Pa. 2001)("Such an undeveloped argument, which fails to meaningfully discuss and apply the standard governing the review of ineffectiveness claims, simply does not satisfy Appellant's burden of establishing that he is entitled to any relief.").

11
Youndt v. First National Bank of Port Alleganygreen
pasuperct · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
1 sentence

2007Youndt v. First National Bank of Port Allegany, 868 A.2d 539, 544 (Pa. Super. 2005) (citing Sevin v. Kelshaw, 417 Pa. Super. 1, 7 , 611 A.2d 1232, 1235 (1992)).

11
Postill v. Booth Newspapers, Incgreen
michctapp · 1982 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
11
Edward J. Rich v. United States Lines, Inc.green
ca3 · 1979 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
11
Janklow v. Viking Pressgreen
sd · 1985 · cited in 1 Pennsylvania opinions naming this issue, 1988–1988
2 sentences

1988For example, the Michigan Court of Appeals "decline[d] to embrace Edwards as the press is adequately protected by the burden of proof required in Sullilvan." Postill v. Booth Newspaper, Inc., 118 Mich.App. 608, 622 , 325 N.W.2d 511, 578 (1982); accord, Janklow v. Viking Press, Inc., 378 N.W.2d 875, 881 (S.D. 1985) ("[T]he media already enjoys the generous protection accorded by New York Times Co. v. Sullivan with respect to erroneous statements of fact and opinion").

1988For example, the Michigan Court of Appeals “decline[d] to embrace Edwards as the press is adequately protected by the burden of proof required in Sullilvan.” Postill v. Booth Newspaper, Inc., 118 Mich.App. 608, 622 , 325 N.W.2d 511, 578 (1982); accord, Janklow v. Viking Press, Inc., 378 N.W.2d 875, 881 (S.D.1985) (“[T]he media already enjoys the generous protection accorded by New York Times Co. v. Sullivan with respect to erroneous statements of fact and opinion”).

11
United States v. Jorngreen
scotus · 1971 · cited in 1 Pennsylvania opinions naming this issue, 1983–1983
11
Commonwealth v. Coylegreen
pasuperct · 1959 · cited in 1 Pennsylvania opinions naming this issue, 1982–1982
11
Commonwealth v. Johnsongreen
pasuperct · 1975 · cited in 1 Pennsylvania opinions naming this issue, 1979–1979
11
Commonwealth v. Amatogreen
pasuperct · 1941 · cited in 1 Pennsylvania opinions naming this issue, 1942–1942
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (43)

CaseCitedYears
Commonwealth v. Dancer green
pa · 1975
2 sentences

1979Commonwealth v. Dancer, 460 Pa. 95 , 331 A.2d 435 (1975); Commonwealth v. Tolbert, 246 Pa.Super. 23 , 369 A.2d 791 (1977). .

1979Commonwealth v. Dancer, 460 Pa. 95 , 331 A.2d 435 (1975); Commonwealth v. Tolbert, 246 Pa.Super. 23 , 369 A.2d 791 (1977). .

31977–1979
Commonwealth v. Tolbert green
pasuperct · 1977
2 sentences

1979Commonwealth v. Dancer, 460 Pa. 95 , 331 A.2d 435 (1975); Commonwealth v. Tolbert, 246 Pa.Super. 23 , 369 A.2d 791 (1977). .

1979Commonwealth v. Dancer, 460 Pa. 95 , 331 A.2d 435 (1975); Commonwealth v. Tolbert, 246 Pa.Super. 23 , 369 A.2d 791 (1977). .

21979–1979
Commonwealth v. Puglise green
pa · 1923
2 sentences

1967Thus, whenever, as here, the *336 Commonwealth, in a homicide case, has established that the person for whose death the prosecution was instituted is in fact dead and that the death occurred under circumstances indicating that it was criminally caused by someone, the rule is satisfied and admissions or confessions of the accused may then always be received as proof of the identity of the guilty agent: Com. v. Gardner, 282 Pa. 458, 462 ; Com. v. Puglise, 276 Pa. 235, 238 .” (Emphasis in original) Therefore, in the instant case, the corpus delicti would be established if the Commonwealth were ab

1940Thus, whenever, as here, the Commonwealth, in a homicide case, has established that the person for whose death the prosecution was instituted is in fact dead and that the death occurred under circumstances indicating that it was criminally caused by someone, the rule is satisfied and admissions or confessions of the accused may then always be received as proof of the identity of the guilty agent: Com. v. Gardner, 282 Pa. 458, 463 ; Com. v. Puglise, 276 Pa. 235, 238 .

21940–1967
Commonwealth v. Gardner green
pa · 1925
2 sentences

1967Thus, whenever, as here, the *336 Commonwealth, in a homicide case, has established that the person for whose death the prosecution was instituted is in fact dead and that the death occurred under circumstances indicating that it was criminally caused by someone, the rule is satisfied and admissions or confessions of the accused may then always be received as proof of the identity of the guilty agent: Com. v. Gardner, 282 Pa. 458, 462 ; Com. v. Puglise, 276 Pa. 235, 238 .” (Emphasis in original) Therefore, in the instant case, the corpus delicti would be established if the Commonwealth were ab

1940Thus, whenever, as here, the Commonwealth, in a homicide case, has established that the person for whose death the prosecution was instituted is in fact dead and that the death occurred under circumstances indicating that it was criminally caused by someone, the rule is satisfied and admissions or confessions of the accused may then always be received as proof of the identity of the guilty agent: Com. v. Gardner, 282 Pa. 458, 463 ; Com. v. Puglise, 276 Pa. 235, 238 .

21940–1967
Banner v. COM., DEPT. OF TRANSP. green
pa · 1999
2 sentences

2021Id. at 19a-21a.4 Licensee’s counsel also objected to introduction of the preliminary breath test conducted by Trooper that revealed Licensee had a 0.188% BAC on the grounds that the test was unreliable.

2021Id. at 25a.

12021–2021
Commonwealth v. Freeman green
pasuperct · 2015
1 sentence

2021Appellant’s suppression motions before Judge Bright specified the evidence he sought to suppress and the grounds for his claim.9 See Freeman, 128 A.3d at 1241 - 42.

12021–2021
Commonwealth v. Sodomsky green
pasuperct · 2016
1 sentence

2021Further, Judge Bright had the discretion to consider Appellant’s supplemental suppression motions “in the interests of justice.”10 See Pa.R.Crim.P. 581(B); Sodomsky, 137 A.3d at 626 . ____________________________________________ 9 We note, however, that Appellant did not seek the suppression of “other physical evidence” before the trial court, and instead focused his supplemental suppression motions before Judge Bright on his phone information and his DNA sample.

12021–2021
Commonwealth v. Fried green
pa · 1984
1 sentence

2018The grounds on which the rule rests are the hasty and unguarded character which is often attached to confessions and admissions and the consequent danger of a conviction where no crime has in fact been committed[.]” Id. (citations and internal quotation marks omitted).

12018–2018
Beeson v. Beeson green
pa · 1848
1 sentence

2011As a result, the Court held that an attorney was competent to testify regarding his client’s identity and an objection on the grounds of privilege could not prevail. *251 This rule was more clearly expressed by the Pennsylvania Supreme Court in Beeson v. Beeson, 9 Pa. 279 , 1848 WL 5605 (Pa.1848), where the Court explained: With respect to the testimony of Mr. Veech[,] [an attorney], it is not objected that he was permitted to disclose the fact of his having been retained by Jesse Beeson....

12011–2011
Malley v. American Indemnity Co. green
· 1929
2 sentences

2004In Malley v. American Indemnity Co., 297 Pa. 216 , 146 A. 571 (1929), our Supreme Court held that once an insurer takes charge of a defense of an action, it will be estopped to later deny liability on the grounds that the claim was not covered by the terms of the policy.

2004In Malley v. American Indemnity Co., 297 Pa. 216 , 146 A. 571 (1929), our Supreme Court held that once an insurer takes charge of a defense of an action, it will be estopped to later deny liability on the grounds that the claim was not covered by the terms of the policy.

12004–2004
William Barnes v. The American Tobacco Company green
ca3 · 1998
2 sentences

2001As a result, the plaintiffs base their claim on Barnes v. American Tobacco Co., 161 F.3d 127 (3d Cir. 1998), in which, the plaintiffs contend, the Third Circuit “anticipated that the Pennsylvania Supreme Court would recognize claims such as strict liability as a basis for recovering on a medical monitoring theory.” Plaintiffs’ memorandum at 3 (citing Barnes, 161 F.3d at 152 n.31).

2001As a result, the plaintiffs base their claim on Barnes v. American Tobacco Co., 161 F.3d 127 (3d Cir. 1998), in which, the plaintiffs contend, the Third Circuit “anticipated that the Pennsylvania Supreme Court would recognize claims such as strict liability as a basis for recovering on a medical monitoring theory.” Plaintiffs’ memorandum at 3 (citing Barnes, 161 F.3d at 152 n.31).

12001–2001
Ector v. Motorists Insurance Companies green
pa · 1990
2 sentences

1994Companies, supra, 391 Pa.Super. 458 , 571 A.2d 457 .

1994Companies, supra, 391 Pa.Super. 458 , 571 A.2d 457 .

11994–1994
Commonwealth v. Fried green
pa · 1989
2 sentences

1991Therefore, the rule requires that the prosecution introduce evidence independent of the defendant’s statement which establishes that a crime has in fact occurred.” (citations omitted) In Commonwealth v. Fried, 382 Pa. Super. 156 , 555 A.2d 119 (1989), the court quotes from Com monwealth v. Drexel, 349 Pa. Super. 335 , 503 A.2d 27 (1986), as follows: “Pennsylvania has developed a corpus delicti rule of evidence that states that before the Commonwealth may introduce a defendant’s confession or admission, it must offer independent evidence that a crime, in fapt, occurred . . .

1991Therefore, the rule requires that the prosecution introduce evidence independent of the defendant’s statement which establishes that a crime has in fact occurred.” (citations omitted) In Commonwealth v. Fried, 382 Pa. Super. 156 , 555 A.2d 119 (1989), the court quotes from Com monwealth v. Drexel, 349 Pa. Super. 335 , 503 A.2d 27 (1986), as follows: “Pennsylvania has developed a corpus delicti rule of evidence that states that before the Commonwealth may introduce a defendant’s confession or admission, it must offer independent evidence that a crime, in fapt, occurred . . .

11991–1991
Commonwealth v. Drexel green
pa · 1986
2 sentences

1991Therefore, the rule requires that the prosecution introduce evidence independent of the defendant’s statement which establishes that a crime has in fact occurred.” (citations omitted) In Commonwealth v. Fried, 382 Pa. Super. 156 , 555 A.2d 119 (1989), the court quotes from Com monwealth v. Drexel, 349 Pa. Super. 335 , 503 A.2d 27 (1986), as follows: “Pennsylvania has developed a corpus delicti rule of evidence that states that before the Commonwealth may introduce a defendant’s confession or admission, it must offer independent evidence that a crime, in fapt, occurred . . .

1991Therefore, the rule requires that the prosecution introduce evidence independent of the defendant’s statement which establishes that a crime has in fact occurred.” (citations omitted) In Commonwealth v. Fried, 382 Pa. Super. 156 , 555 A.2d 119 (1989), the court quotes from Com monwealth v. Drexel, 349 Pa. Super. 335 , 503 A.2d 27 (1986), as follows: “Pennsylvania has developed a corpus delicti rule of evidence that states that before the Commonwealth may introduce a defendant’s confession or admission, it must offer independent evidence that a crime, in fapt, occurred . . .

11991–1991
Board of Commissioners of McCandless Township v. Beho Development Co. green
pacommwct · 1975
1 sentence

1989(Emphasis added, footnotes omitted.) In McCandless Township v. Beho Development Corp., 16 Pa.Commonwealth Ct. 448, 332 A.2d 848 (1975), this court was confronted by the issue of whether a letter requesting a zoning change was a request for rezoning or a curative amendment.

11989–1989
Samuel R. Dickey v. Cbs Inc. green
ca3 · 1978
11988–1988
Vann v. Board of Education green
pacommwct · 1983
11987–1987
Commonwealth v. Tomasso green
pasuperct · 1983
11985–1985
Commonwealth v. Moore green
pa · 1976
11984–1984
Spencer v. Board of Supervisors green
pacommwct · 1976
11983–1983
In re American Medical Centers, Inc. green
pacommwct · 1980
11983–1983
Shelley v. Zoning Hearing Board green
pacommwct · 1983
11983–1983
Hopt v. People of Territory of Utah green
scotus · 1884
11982–1982
Mishkin v. Lancaster Redevelopment Authority green
pacommwct · 1972
11982–1982
Murphy v. Philadelphia green
pa · 1966
11982–1982
Union Run Corp. v. Lower Paxton Township Board of Supervisors neutral
pacommwct · 1980
11982–1982
Commonwealth v. Christopher green
pasuperct · 1951
11982–1982
Commonwealth v. Haimbach green
pasuperct · 1942
11982–1982
Commonwealth v. Burns green
pa · 1963
11981–1981
Phelan v. Zoning Hearing Board green
pacommwct · 1975
11981–1981
Commonwealth v. Froelich green
pa · 1974
11979–1979
Commonwealth v. Bestwick green
pasuperct · 1978
11979–1979
Mayer v. City of Chicago green
scotus · 1971
11978–1978
Commonwealth v. Meadows green
pasuperct · 1974
11977–1977
Commonwealth v. Turner green
pa · 1976
11977–1977
Commonwealth v. Stewart green
pa · 1972
11974–1974
New York Times Co. v. Sullivan green
scotus · 1964
11970–1970
Morgan v. United States green
scotus · 1938
11939–1939
Rohrer v. Milk Control Board green
· 1936
11939–1939
Yard v. Patton neutral
pa · 1850
11931–1931

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 3701 (5) PA § 18 Pa. Cons. Stat. § 903 (5) PA § 18 Pa. Cons. Stat. § 3502 (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 221 (1882–2026) LA 173 (1911–2026) OH 100 (1876–2026) CA 75 (1863–2026) PA 69 (1905–2024) NC 62 (1886–2026) NY 62 (1851–2026) IL 53 (1908–2026) AL 49 (1881–2015) VA 49 (1912–2025) GA 42 (1888–2024) ID 40 (1916–2025) MO 40 (1894–2018) FL 36 (1901–2026) MI 28 (1921–2025) MN 26 (1916–2025) IN 25 (1873–2018) CT 23 (1896–2014) IA 22 (1899–2021) OR 22 (1892–2022) WI 21 (1885–2024) OK 18 (1910–2009) WV 18 (1890–2016) WA 18 (1904–2020) MD 16 (1945–2025) KY 16 (1921–2025) MT 14 (1923–2022) SC 14 (1924–2024) KS 14 (1896–2018) CO 14 (1899–2025) MA 13 (1975–2024) MS 13 (1925–2008) VT 12 (1911–2026) NJ 11 (1895–2025) AR 10 (1894–2014) ND 9 (1890–2000) TN 8 (1951–2019) DE 8 (1964–2024) NM 8 (1971–2025) AZ 8 (1956–2020) RI 8 (1985–2014) HI 7 (1943–2026) DC 7 (1978–2012) UT 6 (1898–2009) WY 5 (1900–2020) NH 5 (1964–2020) NE 5 (1911–1999) AK 4 (1984–1998) NV 4 (1867–1983) SD 3 (1894–1905) PR 2 (1928–1942) ME 2 (1947–2026)

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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