Barker factors (Louisiana) · Go Syfert
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Barker factors in Louisiana

68 Louisiana opinions name it 2 courts 1983–2025 3 in the last five years

The cases below were cited by Louisiana 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 (24)

CaseFollowedCited
State v. Reavesgreen
la · 1979 · cited in 21 Louisiana opinions naming this issue, 1986–2019
2 sentences

2019“In determining whether a defendant's constitutional right to a speedy trial has been violated, courts consider the four Barker factors: (1) the length of delay; (2) the reason for delay; (3) the assertion of his right to speedy trial; and (4) the prejudice resulting from the delay.” Love, 00- 3347, p.15, 847 So.2d at 1210 (citing Barker v. Wingo, 407 U.S. 514, 530 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972)); see also State v. Reaves, 376 So.2d 136 (La. 1979) (adopting Barker).

2017Id. at 531-532 , 92 S.Ct. at 2192-93 ; see also State v. Reaves , 376 So.2d 136 (La.1979) (adopting Barker factors).

1021
State v. Santiagogreen
lactapp · 2003 · cited in 16 Louisiana opinions naming this issue, 2005–2013
2 sentences

2006In State v. Santiago, XXXX-XXXX (La.App. 4 Cir. 7/23/03), 853 So.2d 671 , this Court considered all of the Barker factors even though it found that a fifteen-month delay was not presumptively prejudicial.

2006In State v. Santiago, XXXX-XXXX (La.App. 4 Cir. 7/23/03), 853 So.2d 671 , this Court considered all of the Barker factors even though it found that a fifteen-month delay was not presumptively prejudicial.

816
State v. Scottgreen
lactapp · 2005 · cited in 7 Louisiana opinions naming this issue, 2008–2013
2 sentences

2013See State v. Brown, 11-0947 (La.App. 4 Cir. 3/7/12) , 88 So.3d 662 ; State v. Scott, 04-1142 (La.App. 4 Cir. 7/27/05) , 913 So.2d 843 ; State v. Santiago, 03-0693 (La.App. 4 Cir. 7/23/03) , 853 So.2d 671 .

2013See State v. Brown, 2011-0947 (La.App. 4 Cir. 3/7/12) , 88 So.3d 662 ; State v. Scott, 2004-1142 (La.App. 4 Cir. 7/27/05) , 913 So.2d 843 ; State v. Santiago, 2003-0693 (La.App. 4 Cir. 7/23/03) , 853 So.2d 671 .

57
State v. DeRouengreen
lactapp · 1996 · cited in 5 Louisiana opinions naming this issue, 2003–2013
2 sentences

2007The first of the factors — the length of the delay — has been held by Louisiana courts to be the "triggering mechanism" and "absent a presumptively prejudicial delay, further inquiry into the Barker factors is unnecessary." State v. DeRouen, 96-0725 (La.App. 4 Cir. 6/26/96) , 678 So.2d 39, 40 .

2007The first of the factors — the length of the delay — has been held by Louisiana courts to be the "triggering mechanism" and "absent a presumptively prejudicial delay, further inquiry into the Barker factors is unnecessary." State v. DeRouen, 96-0725 (La.App. 4 Cir. 6/26/96) , 678 So.2d 39, 40 .

45
State v. Lovegreen
la · 2003 · cited in 18 Louisiana opinions naming this issue, 2003–2025
2 sentences

2025As explained by this Court in Andrews, “[n]one of the four Barker factors is ‘either a necessary or sufficient condition to the finding of a deprivation of the right to a speedy trial,” but rather “are related and must be considered together in light of the circumstances of each case.” Id. at pp. 8-9, 255 So.3d at 1113 (quoting State v. Love, 2000-3347, p. 15 (La. 5/23/03), 847 So.2d 1198, 1210 ). (1) The Length of Delay Though the Barker factors must be considered together, this Court has explained that “[t]he first [Barker] factor, the length of the delay, is a ‘triggering mechanism’ for fur

2025As explained by this Court in Andrews, “[n]one of the four Barker factors is ‘either a necessary or sufficient condition to the finding of a deprivation of the right to a speedy trial,” but rather “are related and must be considered together in light of the circumstances of each case.” Id. at pp. 8-9, 255 So.3d at 1113 (quoting State v. Love, 2000-3347, p. 15 (La. 5/23/03), 847 So.2d 1198, 1210 ). (1) The Length of Delay Though the Barker factors must be considered together, this Court has explained that “[t]he first [Barker] factor, the length of the delay, is a ‘triggering mechanism’ for fur

318
United States v. Jose Avalos and Rudolfo Castrillongreen
ca5 · 1976 · cited in 4 Louisiana opinions naming this issue, 2003–2024
2 sentences

2024State v. Love, citing United States v. Avalos, 541 F. 2d 1100 (5 Cir., 1976), cert. denied, 430 U.S. 970 , 97 S. Ct. 1656 , 52 L.

2024State v. Love, citing United States v. Avalos, 541 F. 2d 1100 (5 Cir., 1976), cert. denied, 430 U.S. 970 , 97 S. Ct. 1656 , 52 L.

34
State v. Browngreen
lactapp · 2012 · cited in 4 Louisiana opinions naming this issue, 2013–2016
2 sentences

2016“The first Barker factor, the length of the delay, is a threshold requirement for invoking a speedy trial, analysis; it functions as a triggering mechanism for further inquiry into the other three Barker factors.” State v. Brown, 2011-0947, p. 9 (La.App, 4 Cir. 3/7/12), 88 So.3d 662, 668 , citing State v. Love, 2000-3347, p. 16 (La. 5/23/03), 847 So.2d 1198, 1210 , “Only if there is a presumptively prejudicial’ delay will courts proceed to analyze the other Barker factors.” Id.

2016“The first Barker factor, the length of the delay, is a threshold requirement for invoking a speedy trial, analysis; it functions as a triggering mechanism for further inquiry into the other three Barker factors.” State v. Brown, 2011-0947, p. 9 (La.App, 4 Cir. 3/7/12), 88 So.3d 662, 668 , citing State v. Love, 2000-3347, p. 16 (La. 5/23/03), 847 So.2d 1198, 1210 , “Only if there is a presumptively prejudicial’ delay will courts proceed to analyze the other Barker factors.” Id.

34
Barker v. Wingogreen
scotus · 1972 · cited in 18 Louisiana opinions naming this issue, 1983–2020
2 sentences

2020Id., 407 U.S. at 530 , 92 S. Ct. at 2192 The Louisiana Supreme Court has explained: The first of the Barker factors, the length of the delay, is a threshold requirement for courts reviewing speedy trial claims.

2020Id., 407 U.S. at 530 , 92 S. Ct. at 2192 The Louisiana Supreme Court has explained: The first of the Barker factors, the length of the delay, is a threshold requirement for courts reviewing speedy trial claims.

218
State v. Harrisgreen
lactapp · 2003 · cited in 2 Louisiana opinions naming this issue, 2006–2007
2 sentences

2007See, State v. Love, 2000-3347 (La.5/23/03), 847 So.2d 1198 , and State v. Harris, 2003-0524 (La.App. 4 Cir. 9/10/03) , 857 So.2d 16 .

2007See, State v. Love, 2000-3347 (La.5/23/03), 847 So.2d 1198 , and State v. Harris, 2003-0524 (La.App. 4 Cir. 9/10/03) , 857 So.2d 16 .

22
Doggett v. United Statesgreen
scotus · 1992 · cited in 3 Louisiana opinions naming this issue, 1998–2014
2 sentences

2010In applying the Barker factors to Dog-gett’s case, the Court recognized that such an inquiry involved four separate questions: “whether delay before trial was |3uncommonly long, whether the government or the criminal defendant is more to blame for that delay, whether, in due course, the defendant asserted his right to a speedy trial, and whether he suffered prejudice as the delay’s result.” Doggett, 505 U.S. at 651 , 112 S.Ct. 2686 (citing Barker v. Wingo, 407 U.S. 514, 530 , 92 S.Ct. 2182, 2192 , 33 L.Ed.2d 101 ). 3 In determining whether the delay “has crossed the threshold dividing ordinary

2010In applying the Barker factors to Dog-gett’s case, the Court recognized that such an inquiry involved four separate questions: “whether delay before trial was |3uncommonly long, whether the government or the criminal defendant is more to blame for that delay, whether, in due course, the defendant asserted his right to a speedy trial, and whether he suffered prejudice as the delay’s result.” Doggett, 505 U.S. at 651 , 112 S.Ct. 2686 (citing Barker v. Wingo, 407 U.S. 514, 530 , 92 S.Ct. 2182, 2192 , 33 L.Ed.2d 101 ). 3 In determining whether the delay “has crossed the threshold dividing ordinary

13
State v. Batistegreen
la · 2006 · cited in 2 Louisiana opinions naming this issue, 2009–2014
2 sentences

2014“The circumstances of a case will determine the weight to be ascribed to the length of and reason for the delay.” Batiste , 2005-1571, p. 7, 939 So.2d at 1250 . “[T]he delay that can be tolerated for an ordinary street crime is considerably less than for a serious, complex conspiracy charge.” Reaves, 376 So.2d at 138 (quoting Barker, 407 U.S. at 531 , 92 S.Ct. at 2192 ).

2014“The circumstances of a case will determine the weight to be ascribed to the length of and reason for the delay.” Batiste , 2005-1571, p. 7, 939 So.2d at 1250 . “[T]he delay that can be tolerated for an ordinary street crime is considerably less than for a serious, complex conspiracy charge.” Reaves, 376 So.2d at 138 (quoting Barker, 407 U.S. at 531 , 92 S.Ct. at 2192 ).

12
State v. Van Dykegreen
lactapp · 2003 · cited in 2 Louisiana opinions naming this issue, 2005–2011
2 sentences

2011In the matter before us, however, the vast majority of the delays are attributable to the defense.” Id. at 199.

2011In the matter before us, however, the vast majority of the delays are attributable to the defense.” Id. at 199.

12
State v. Andrews (In re Andrews)green
lactapp · 2018 · cited in 1 Louisiana opinions naming this issue, 2025–2025
2 sentences

2025As explained by this Court in Andrews, “[n]one of the four Barker factors is ‘either a necessary or sufficient condition to the finding of a deprivation of the right to a speedy trial,” but rather “are related and must be considered together in light of the circumstances of each case.” Id. at pp. 8-9, 255 So.3d at 1113 (quoting State v. Love, 2000-3347, p. 15 (La. 5/23/03), 847 So.2d 1198, 1210 ). (1) The Length of Delay Though the Barker factors must be considered together, this Court has explained that “[t]he first [Barker] factor, the length of the delay, is a ‘triggering mechanism’ for fur

2025As explained by this Court in Andrews, “[n]one of the four Barker factors is ‘either a necessary or sufficient condition to the finding of a deprivation of the right to a speedy trial,” but rather “are related and must be considered together in light of the circumstances of each case.” Id. at pp. 8-9, 255 So.3d at 1113 (quoting State v. Love, 2000-3347, p. 15 (La. 5/23/03), 847 So.2d 1198, 1210 ). (1) The Length of Delay Though the Barker factors must be considered together, this Court has explained that “[t]he first [Barker] factor, the length of the delay, is a ‘triggering mechanism’ for fur

11
State v. Jonesgreen
lactapp · 2013 · cited in 1 Louisiana opinions naming this issue, 2014–2014
11
State v. Mathewsgreen
la · 2013 · cited in 1 Louisiana opinions naming this issue, 2014–2014
11
United States v. Bergfeldgreen
ca5 · 2002 · cited in 1 Louisiana opinions naming this issue, 2012–2012
11
United States v. Serna-Villarrealgreen
ca5 · 2003 · cited in 1 Louisiana opinions naming this issue, 2012–2012
11
State v. Shannongreen
lactapp · 2009 · cited in 1 Louisiana opinions naming this issue, 2012–2012
11
United States v. Carnie Simmons, A/K/A Haroldgreen
ca2 · 1964 · cited in 1 Louisiana opinions naming this issue, 2010–2010
11
Simmons v. United Statesgreen
scotus · 1965 · cited in 1 Louisiana opinions naming this issue, 2010–2010
11
State v. Stewartgreen
lactapp · 2008 · cited in 1 Louisiana opinions naming this issue, 2009–2009
11
State v. Jamesgreen
la · 1985 · cited in 1 Louisiana opinions naming this issue, 1996–1996
11
State v. Jamesgreen
lactapp · 1984 · cited in 1 Louisiana opinions naming this issue, 1996–1996
11
United States v. MacDonaldgreen
scotus · 1978 · cited in 1 Louisiana opinions naming this issue, 1983–1983
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (40)

CaseCitedYears
State v. Leban green
lactapp · 1992
2 sentences

2010Noting that the delay was presumptively prejudicial, this Court considered the Barker factors, and without specifically determining whether the defendant was prejudiced 11sby the delay, found that taking all the factors into consideration, the judgment granting the motion to quash was proper. 20 Leban, 611 So.2d at 169 .

2010Noting that the delay was presumptively prejudicial, this Court considered the Barker factors, and without specifically determining whether the defendant was prejudiced 11sby the delay, found that taking all the factors into consideration, the judgment granting the motion to quash was proper. 20 Leban, 611 So.2d at 169 .

41997–2012
State v. Pham green
lactapp · 1997
2 sentences

2007For example, in State v. Pham, 97-0459 (La.App. 4 Cir. 3/26/97) , 692 So.2d 11 , this court found that a nine-month delay for a defendant forced to travel from Houston to New Orleans after being charged with cheating at gaming did not merit the granting of a motion to quash.

2007For example, in State v. Pham, 97-0459 (La.App. 4 Cir. 3/26/97) , 692 So.2d 11 , this court found that a nine-month delay for a defendant forced to travel from Houston to New Orleans after being charged with cheating at gaming did not merit the granting of a motion to quash.

42006–2007
Curry v. Califano green
scotus · 1977
2 sentences

2024State v. Love, citing United States v. Avalos, 541 F. 2d 1100 (5 Cir., 1976), cert. denied, 430 U.S. 970 , 97 S. Ct. 1656 , 52 L.

2024State v. Love, citing United States v. Avalos, 541 F. 2d 1100 (5 Cir., 1976), cert. denied, 430 U.S. 970 , 97 S. Ct. 1656 , 52 L.

32003–2024
Casper v. United States green
scotus · 1977
2 sentences

2024State v. Love, citing United States v. Avalos, 541 F. 2d 1100 (5 Cir., 1976), cert. denied, 430 U.S. 970 , 97 S. Ct. 1656 , 52 L.

2024State v. Love, citing United States v. Avalos, 541 F. 2d 1100 (5 Cir., 1976), cert. denied, 430 U.S. 970 , 97 S. Ct. 1656 , 52 L.

32003–2024
Harbolt v. McCune green
scotus · 1977
2 sentences

2024State v. Love, citing United States v. Avalos, 541 F. 2d 1100 (5 Cir., 1976), cert. denied, 430 U.S. 970 , 97 S. Ct. 1656 , 52 L.

2024State v. Love, citing United States v. Avalos, 541 F. 2d 1100 (5 Cir., 1976), cert. denied, 430 U.S. 970 , 97 S. Ct. 1656 , 52 L.

32003–2024
State v. Firshing green
lactapp · 1993
2 sentences

2010In Firshing , this Court applied the Barker factors to the facts of the case, noting that with regard to prejudice suffered by the defendant as a result of the delay, defendant asserted that “he has had to appear in court repeatedly and to retain counsel for this protracted litigation.” Firshing, 624 So.2d at 926 .

2010In Firshing , this Court applied the Barker factors to the facts of the case, noting that with regard to prejudice suffered by the defendant as a result of the delay, defendant asserted that “he has had to appear in court repeatedly and to retain counsel for this protracted litigation.” Firshing, 624 So.2d at 926 .

32005–2010
State v. Bell green
la · 2013
2 sentences

2020Cf.State v. Bell, 13- 0117 ( La. 9/ 27/ 13), 122 So. 3d 1007 ; Love, 847 So. 2d at 1210 .

2014See also State v. Mathews, 129 So.3d at 1218-19 (per curiam) (15 and one-half months delay was not presumptively prejudicial and did not require an inquiry into the remaining three Barker factors); State v. Bell, 13-117 (La.9/27/13), 122 So.3d 1007 (per curiam) (defendant’s right to a speedy trial was not violated by the 30-month delay where defendant was shown to be an active party in delay, failed to object to ^continuances, and made no formal speedy trial claim until motion to quash).

22014–2020
State v. Johnson green
lactapp · 1993
2 sentences

2009In State v. Johnson, 622 So.2d 845 (La.App. 4th Cir.1993), a delay of twenty-two months was found not to be excessive.

2009In State v. Johnson, 622 So.2d 845 (La.App. 4th Cir.1993), a delay of twenty-two months was found not to be excessive.

22008–2009
State v. Brown neutral
lactapp · 1994
2 sentences

2009App. 4 Cir. 7/27/94), 641 So.2d 687 , did not specifically state that nineteen months was presumptively prejudicial, but we nevertheless considered all the Barker factors.

2009App. 4 Cir. 7/27/94), 641 So.2d 687 , did not specifically state that nineteen months was presumptively prejudicial, but we nevertheless considered all the Barker factors.

22008–2009
State v. Willis neutral
lactapp · 1995
2 sentences

2005Id.

2005Id.

22003–2005
State v. James green
la · 1981
2 sentences

1988State v. James, 394 So.2d 1197 (La.1981); State v. Reaves, 376 So.2d 136 (La.1979).

1988State v. James, 394 So.2d 1197 (La.1981); State v. Reaves, 376 So.2d 136 (La.1979).

21986–1988
State v. Gaines green
lactapp · 2009
2 sentences

2025App. 4 Cir. 2/11/09), 5 So.3d 915, 917 ; and then citing State v. DeRouen, 1996-0725, p. 3 (La.

2025App. 4 Cir. 2/11/09), 5 So.3d 915, 917 ; and then citing State v. DeRouen, 1996-0725, p. 3 (La.

12025–2025
State v. Sanders green
lactapp · 2012
1 sentence

2025App. 4 Cir. 11/14/12) 104 So. 3d 619, 626 .

12025–2025
State ex rel. L.L. green
lactapp · 2009
2 sentences

2019L.L., 09-0595, p.3, 23 So.3d at 973 , our Court applied the Barker factors in a juvenile case.

2019L.L., 09-0595, p.3, 23 So.3d at 973 , our Court applied the Barker factors in a juvenile case.

12019–2019
State v. Smith green
lactapp · 2016
2 sentences

2018App. 4 Cir. 11/23/16), 204 So.3d 1035 , 1038, applying the Mathews method of calculation, this Court found that a twenty-five month delay on a charge of possession of heroin arguably constituted a presumptively prejudicial delay that triggered the consideration of the remaining Barker factors. 6 In State v. Noel , supra , this Court found that a nineteen-month delay from the filing of the bill of information charging simple burglary of an outdoor shed was sufficiently great to trigger an analysis of the three remaining Barker factors.

2018App. 4 Cir. 11/23/16), 204 So.3d 1035 , 1038, applying the Mathews method of calculation, this Court found that a twenty-five month delay on a charge of possession of heroin arguably constituted a presumptively prejudicial delay that triggered the consideration of the remaining Barker factors. 6 In State v. Noel , supra , this Court found that a nineteen-month delay from the filing of the bill of information charging simple burglary of an outdoor shed was sufficiently great to trigger an analysis of the three remaining Barker factors.

12018–2018
State v. Toney green
la · 2003
2 sentences

2016The State relies in part on State v. Toney, 2002-0992 (La.4/9/03), 842 So.2d 1083 , wherein the Louisiana Supreme Court distinguished both McQueen and Broussard , finding that a seventeen-month delay between the filing of the multiple bill of information, and: the hearing on the multiple bill was not an unreasonable delay where 1 there was. no evidence that the State engaged.-in dilatory tactics nor was the defendant surprised by the filing of the multiple bill: ■ Ifi the instant case, we cannot say that dilatory tactics of the district attorney caused the delay between the filing of the multi

2016The State relies in part on State v. Toney, 2002-0992 (La.4/9/03), 842 So.2d 1083 , wherein the Louisiana Supreme Court distinguished both McQueen and Broussard , finding that a seventeen-month delay between the filing of the multiple bill of information, and: the hearing on the multiple bill was not an unreasonable delay where 1 there was. no evidence that the State engaged.-in dilatory tactics nor was the defendant surprised by the filing of the multiple bill: ■ Ifi the instant case, we cannot say that dilatory tactics of the district attorney caused the delay between the filing of the multi

12016–2016
State v. Richardson green
lactapp · 2014
2 sentences

2016Id. at pp. 15-18, 155 So.3d at 95-97 .

2016Id. at pp. 15-18, 155 So.3d at 95-97 .

12016–2016
State v. Esteen green
la · 1996
12014–2014
State v. Esteen green
lactapp · 1996
12014–2014
State v. King green
la · 2011
12014–2014
State v. Lee green
lactapp · 2012
12014–2014
State v. Ervin green
lactapp · 2009
12014–2014
State v. Lollis green
lactapp · 1988
12010–2010
State v. Cowger green
lactapp · 1991
12010–2010
State v. Shanklin green
lactapp · 2007
12009–2009
State v. Scott green
lactapp · 2007
12009–2009
State v. Bias green
lactapp · 2006
12009–2009
State v. Dees green
lactapp · 2007
12009–2009
State v. Chambers green
lactapp · 2007
12009–2009
State v. Brown green
lactapp · 2006
12007–2007
State v. Brown neutral
lactapp · 2006
12007–2007
State v. Larce green
lactapp · 2002
12006–2006
State v. Trotter green
la · 2004
12005–2005
United States v. Loud Hawk green
scotus · 1986
12003–2003
United States v. Banco Cafetero Panama, Banco Cafetero Colon, Defendants-In-Rem-Appellants green
ca2 · 1986
11998–1998
United States v. Eight Thousand Eight Hundred & Fifty Dollars green
scotus · 1983
11998–1998
State v. Leban green
la · 1993
11997–1997
State v. Hicks green
lactapp · 1992
11993–1993
Castaneda v. Partida green
scotus · 1977
11993–1993
State v. Dewey green
la · 1982
11993–1993

Statutes the citing opinions construe

LA § La. Rev. Stat. § 40:967 (10) LA § La. Rev. Stat. § 40:966 (8) LA § La. Rev. Stat. § 14:30.1 (6) LA § La. Rev. Stat. § 14:30 (4) LA § La. Rev. Stat. § 14:62 (4) LA § La. Rev. Stat. § 14:64 (4) LA § La. Rev. Stat. § 15:529.1 (4) LA § La. Rev. Stat. § 1 (3) LA § La. Rev. Stat. § 14:2 (3) LA § La. Rev. Stat. § 14:24 (3) LA § La. Rev. Stat. § 14:34 (3) LA § La. Rev. Stat. § 15 (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 479 (1995–2026) MS 238 (1986–2026) NM 227 (1987–2026) GA 146 (1976–2026) OH 129 (1985–2026) TN 91 (1987–2026) AL 75 (1977–2026) CA 69 (1980–2026) LA 68 (1983–2025) NJ 47 (1999–2026) WA 45 (2009–2026) KS 42 (1979–2026) NC 41 (1993–2026) MI 40 (2006–2026) MT 40 (1975–2020) IL 39 (1989–2025) ID 38 (1981–2025) WY 38 (1989–2023) IN 32 (1980–2020) MO 29 (1979–2025) DE 28 (1987–2026) PA 28 (1976–2025) MN 27 (1986–2025) MD 26 (1975–2024) CO 25 (1975–2026) KY 23 (1978–2024) VT 21 (1983–2025) VA 19 (1990–2025) RI 18 (1967–2015) WI 17 (1990–2026) UT 16 (1986–2026) NH 16 (1985–2022) AZ 16 (1982–2026) HI 14 (1981–2025) DC 13 (1977–2012) FL 12 (1982–2024) ME 11 (1981–2025) MA 9 (1982–2025) SC 9 (2009–2026) VI 8 (2010–2026) CT 8 (1987–2018) OR 8 (1977–2021) ND 8 (1994–2021) NV 8 (1983–2020) AK 6 (1991–2024) NE 5 (1999–2019) OK 5 (1994–2023) SD 3 (1994–2026) IA 3 (2001–2019) NY 3 (1896–2018) AR 2 (2004–2023)

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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