vehicle challenge (Florida) · Go Syfert
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vehicle challenge in Florida

67 Florida opinions name it 3 courts 1954–2026 11 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 (64)

CaseFollowedCited
Curbelo v. Ullmangreen
fla · 1990 · cited in 2 Florida opinions naming this issue, 2018–2026
2 sentences

2026See Franco v. Thomas, 251 So. 3d 325, 327 (Fla. 3d DCA 2018) (“Neither rule 1.540, nor its family law equivalent (rule 12.540), is an appropriate vehicle to challenge a judgment based upon alleged legal error.” (citing Curbelo v. Ullman, 571 So. 2d 443, 445 (Fla. 1990), and Theodorides v. Theodorides, 201 So. 3d 141 , 143–44 (Fla. 3d DCA 2015))); Curbelo, 571 So. 2d at 445 (“[W]here a court . . . has jurisdiction of the subject matter and the adverse parties are given an opportunity to be heard, then errors, irregularities or wrongdoing in proceedings, short of illegal deprivation of opportuni

2026See Franco v. Thomas, 251 So. 3d 325, 327 (Fla. 3d DCA 2018) (“Neither rule 1.540, nor its family law equivalent (rule 12.540), is an appropriate vehicle to challenge a judgment based upon alleged legal error.” (citing Curbelo v. Ullman, 571 So. 2d 443, 445 (Fla. 1990), and Theodorides v. Theodorides, 201 So. 3d 141 , 143–44 (Fla. 3d DCA 2015))); Curbelo, 571 So. 2d at 445 (“[W]here a court . . . has jurisdiction of the subject matter and the adverse parties are given an opportunity to be heard, then errors, irregularities or wrongdoing in proceedings, short of illegal deprivation of opportuni

22
Theodorides v. Theodoridesgreen
fladistctapp · 2015 · cited in 2 Florida opinions naming this issue, 2018–2026
2 sentences

2026See Franco v. Thomas, 251 So. 3d 325, 327 (Fla. 3d DCA 2018) (“Neither rule 1.540, nor its family law equivalent (rule 12.540), is an appropriate vehicle to challenge a judgment based upon alleged legal error.” (citing Curbelo v. Ullman, 571 So. 2d 443, 445 (Fla. 1990), and Theodorides v. Theodorides, 201 So. 3d 141 , 143–44 (Fla. 3d DCA 2015))); Curbelo, 571 So. 2d at 445 (“[W]here a court . . . has jurisdiction of the subject matter and the adverse parties are given an opportunity to be heard, then errors, irregularities or wrongdoing in proceedings, short of illegal deprivation of opportuni

2018Curbelo v. Ullman, 571 So. 2d 443, 445 (Fla. 1990); Theodorides v. Theodorides, 201 So. 3d 141, 143-44 (Fla. 3d DCA 2015).

22
Simeus v. Ramboskgreen
fladistctapp · 2011 · cited in 2 Florida opinions naming this issue, 2012–2024
2 sentences

2024See Simeus v. Rambosk, 100 So. 3d 2, 3 (Fla. 2d DCA 2011) ("A petition for writ of habeas corpus is the proper vehicle to challenge an order of pretrial detention.").

2012See Simeus v. Rambosk, — So.3d—, 2011 WL 3503504 (Fla. 2d DCA 2011) (“A petition for writ of habeas corpus is the proper vehicle to challenge an order of pretrial detention.”) (citations omitted).

22
Riehle v. State, Department of Highway Safety & Motor Vehiclesgreen
fladistctapp · 1996 · cited in 2 Florida opinions naming this issue, 2022–2023
2 sentences

2023Saf. & Motor Veh., 684 So. 2d 823, 824-25 (Fla. 2d DCA 1996) (explaining that if law enforcement support personnel are not vested with arrest powers, they cannot be relied upon to establish probable cause for a warrantless DUI arrest).

2022Saf. & Motor Veh., 684 So. 2d 823, 824-25 (Fla. 2d DCA 1996) (explaining that if law enforcement support personnel are not vested with arrest powers, they cannot be relied upon to establish probable cause for a warrantless DUI arrest).

22
Sawyer v. Stategreen
fladistctapp · 2005 · cited in 2 Florida opinions naming this issue, 2022–2023
2 sentences

2023See § 901.15(5), Fla. Stat. (2019) (“Any law enforcement officer, upon receiving information relayed to him or her from a fellow officer . . . that a driver of a vehicle has violated chapter 316, may arrest the driver for violation of those laws when reasonable and proper identification of the vehicle and the violation has been communicated to the arresting officer.” (emphasis added)); see also Sawyer v. State, 905 So. 2d 232, 234 (Fla. 2d DCA 2005) (“The [fellow officer] rule does not impute the knowledge of citizen informants to officers.”); Riehle v. Dep’t of High.

2022See § 901.15(5), Fla. Stat. (2019) (“Any law enforcement officer, upon receiving information relayed to him or her from a fellow officer . . . that a driver of a vehicle has violated chapter 316, may arrest the driver for violation of those laws when reasonable and proper identification of the vehicle and the violation has been communicated to the arresting officer.” (emphasis added)); Sawyer v. State, 905 So. 2d 232, 234 (Fla. 2d DCA 2005) (“The [fellow officer] rule does not impute the knowledge of citizen informants to officers.”); see also Riehle v. Dep’t of High.

22
Miller v. Stategreen
fladistctapp · 2008 · cited in 2 Florida opinions naming this issue, 2011–2021
2 sentences

2021State v. Broom, 523 So. 2d 639, 641 (Fla. 2d DCA 1988); see also Miller v. State, 980 So. 2d 1092 (Fla. 2d DCA 2008); Holmes v. State, 933 So. 2d 1205 (Fla. 2d DCA 2006).

2011State v. Broom, 523 So.2d 639, 641 (Fla. 2d DCA 1988); see also Miller v. State, 980 So.2d 1092 (Fla. 2d DCA 2008); Holmes v. State, 933 So.2d 1205 (Fla. 2d DCA 2006).

22
State v. Broomgreen
fladistctapp · 1988 · cited in 2 Florida opinions naming this issue, 2011–2021
2 sentences

2021State v. Broom, 523 So. 2d 639, 641 (Fla. 2d DCA 1988); see also Miller v. State, 980 So. 2d 1092 (Fla. 2d DCA 2008); Holmes v. State, 933 So. 2d 1205 (Fla. 2d DCA 2006).

2011State v. Broom, 523 So.2d 639, 641 (Fla. 2d DCA 1988); see also Miller v. State, 980 So.2d 1092 (Fla. 2d DCA 2008); Holmes v. State, 933 So.2d 1205 (Fla. 2d DCA 2006).

22
Caleffe v. Vitalegreen
fladistctapp · 1986 · cited in 2 Florida opinions naming this issue, 2015–2025
2 sentences

2025Corp., 165 So. 3d 812, 813 (Fla. 1st DCA 2015) (quoting Caleffe v. Vitale, 488 So. 2d 627, 627 (Fla. 4th DCA 1986)). 2 person a well-founded fear of not receiving a fair and impartial trial.”); Fla. R.

2015“A petition for writ of prohibition is the appropriate vehicle to test the validity of the denial of a motion for disqualification.” Caleffe, 488 So.2d at 627-28 .

12
Taylor v. Stategreen
fladistctapp · 2006 · cited in 2 Florida opinions naming this issue, 2008–2008
2 sentences

2008Taylor v. State, 919 So.2d 669 (Fla. 2d DCA 2006); see Balkaran v. State, 950 So.2d 478 (Fla. 4th DCA 2007).

2008See Taylor v. State, 919 So.2d 669 (Fla. 2d DCA 2006); see also Barber v. State, 901 So.2d 364 (Fla. 5th DCA 2005).

12
Wright v. Stategreen
fladistctapp · 2003 · cited in 2 Florida opinions naming this issue, 2005–2006
2 sentences

2006See Wood v. State, 867 So.2d 590, 592 (Fla. 5th DCA 2004)(holding that "the validity vel non of departure reasons given for departure sentences, which do not exceed the statutory maximum, cannot be raised in a motion filed pursuant to rule 3.800(a) or rule 3.850, but must be raised on direct appeal"); Wright v. State, 864 So.2d 1153, 1154 (Fla. 2d DCA 2003)(noting that "a challenge to departure reasons is not cognizable in a rule 3.800(a) motion"), decision approved, 911 So.2d 81 (Fla.2005).

2005Wright, 864 So.2d at 1154 .

12
Thompson v. Stategreen
fla · 2000 · cited in 1 Florida opinions naming this issue, 2026–2026
1 sentence

2026See Franco v. Thomas, 251 So. 3d 325, 327 (Fla. 3d DCA 2018) (“Neither rule 1.540, nor its family law equivalent (rule 12.540), is an appropriate vehicle to challenge a judgment based upon alleged legal error.” (citing Curbelo v. Ullman, 571 So. 2d 443, 445 (Fla. 1990), and Theodorides v. Theodorides, 201 So. 3d 141 , 143–44 (Fla. 3d DCA 2015))); Curbelo, 571 So. 2d at 445 (“[W]here a court . . . has jurisdiction of the subject matter and the adverse parties are given an opportunity to be heard, then errors, irregularities or wrongdoing in proceedings, short of illegal deprivation of opportuni

11
Booker v. Bookergreen
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2026–2026
1 sentence

2026See Franco v. Thomas, 251 So. 3d 325, 327 (Fla. 3d DCA 2018) (“Neither rule 1.540, nor its family law equivalent (rule 12.540), is an appropriate vehicle to challenge a judgment based upon alleged legal error.” (citing Curbelo v. Ullman, 571 So. 2d 443, 445 (Fla. 1990), and Theodorides v. Theodorides, 201 So. 3d 141 , 143–44 (Fla. 3d DCA 2015))); Curbelo, 571 So. 2d at 445 (“[W]here a court . . . has jurisdiction of the subject matter and the adverse parties are given an opportunity to be heard, then errors, irregularities or wrongdoing in proceedings, short of illegal deprivation of opportuni

11
Felice Kline v. JRD Management Corp. and CCMSIgreen
fladistctapp · 2015 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025Corp., 165 So. 3d 812, 813 (Fla. 1st DCA 2015) (quoting Caleffe v. Vitale, 488 So. 2d 627, 627 (Fla. 4th DCA 1986)). 2 person a well-founded fear of not receiving a fair and impartial trial.”); Fla. R.

11
KOENEMUND v. McNeilgreen
fla · 2010 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024See Gilbert v. State, 315 So. 3d 791 , 791 (Fla. 1st DCA 2021) (dismissing petition because “Florida Rule of Appellate Procedure 9.141(d) does not provide a vehicle to challenge postconviction appellate counsel’s effectiveness”); see also Hunter v. State, 48 So. 3d 836 , 1 (Fla. 2010) (“This Court has repeatedly rejected claims of ineffective assistance of postconviction counsel.” (citing cases)).

11
Valdes v. Stategreen
fla · 2009 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024Compare with Valdes v. State, 3 So. 3d 1067, 1077-78 (Fla. 2009) (finding dual convictions of discharging a firearm from a vehicle in violation of section 790.15(2) and shooting into an occupied vehicle in violation of section 790.19 did not satisfy the second exception because the two offenses are found in separate statutory provisions, and observing: “This is in contrast to sections 790.15(1), 790.15(2), and 790.15(3), which are explicitly degree variants of the same offense.”) (footnotes omitted); Velazco v. State, 342 So. 3d 614 , 616 (Fla. 2022) (holding that dual convictions of DUI and D

11
MacNeil v. Stategreen
fladistctapp · 1991 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024See Thurston v. Navarro, 546 So. 2d 448, 449 (Fla. 4th DCA 1989); see also MacNeil v. State, 586 So. 2d 98, 99 (Fla. 5th DCA 1991) (“Habeas corpus is the traditional remedy used to obtain a person’s release from an illegal order of involuntary commitment.”).

11
Thurston v. Navarrogreen
fladistctapp · 1989 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024See Thurston v. Navarro, 546 So. 2d 448, 449 (Fla. 4th DCA 1989); see also MacNeil v. State, 586 So. 2d 98, 99 (Fla. 5th DCA 1991) (“Habeas corpus is the traditional remedy used to obtain a person’s release from an illegal order of involuntary commitment.”).

11
Scott J. Israel, Sheriff v. Ron DeSantis, Governorgreen
fla · 2019 · cited in 1 Florida opinions naming this issue, 2023–2023
2 sentences

2023See Israel, 269 So. 3d at 494 .

2023See Israel, 269 So. 3d at 494 .

11
Sheppard v. Stategreen
fla · 2009 · cited in 1 Florida opinions naming this issue, 2022–2022
1 sentence

2022See Mourra v. State, 884 So. 2d 316, 319 (Fla. 2d DCA 2004), abrogated on other grounds by Sheppard v. State, 17 So. 3d 275 (Fla. 2009) (observing that the Florida Supreme Court adopted rule 3.170(l) in an effort to implement the Florida Legislature’s Criminal Appeal Reform Act of 1996, and noting that a rule 3.170(l) motion was intended to occur as a part of the initial criminal proceedings and direct appeal, when a defendant still has a right to counsel). 5 3.850 motion to vacate plea based on alleged involuntariness of plea); Tatum v. State, 27 So. 3d 700 (Fla. 3d DCA 2010) (same); Miller v

11
Smith v. Stategreen
fladistctapp · 2004 · cited in 1 Florida opinions naming this issue, 2022–2022
1 sentence

2022See Mourra v. State, 884 So. 2d 316, 319 (Fla. 2d DCA 2004), abrogated on other grounds by Sheppard v. State, 17 So. 3d 275 (Fla. 2009) (observing that the Florida Supreme Court adopted rule 3.170(l) in an effort to implement the Florida Legislature’s Criminal Appeal Reform Act of 1996, and noting that a rule 3.170(l) motion was intended to occur as a part of the initial criminal proceedings and direct appeal, when a defendant still has a right to counsel). 5 3.850 motion to vacate plea based on alleged involuntariness of plea); Tatum v. State, 27 So. 3d 700 (Fla. 3d DCA 2010) (same); Miller v

11
Gadd v. NEWS-PRESS PUB. CO., INCgreen
fladistctapp · 1982 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019This conclusion was incorrect; a petition for writ of mandamus is an appropriate vehicle to challenge the denial of a public records request, even where an exemption has been asserted.1 See Gonzalez v. State, 240 So. 3d 99, 101 (Fla. 2d DCA 2018) (quoting Walton v. Dugger, 634 So. 2d 1059, 1061-62 (Fla. 1993)); Lorei v. Smith, 464 So. 2d 1330, 1331-32 (Fla. 2d DCA 1985); Gadd v. News-Press Publ'g Co., 412 So. 2d 894, 895-96 (Fla. 2d DCA 1982).

11
ALBERTO ROMERO GONZALEZ v. STATE OF FLORIDAgreen
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019This conclusion was incorrect; a petition for writ of mandamus is an appropriate vehicle to challenge the denial of a public records request, even where an exemption has been asserted.1 See Gonzalez v. State, 240 So. 3d 99, 101 (Fla. 2d DCA 2018) (quoting Walton v. Dugger, 634 So. 2d 1059, 1061-62 (Fla. 1993)); Lorei v. Smith, 464 So. 2d 1330, 1331-32 (Fla. 2d DCA 1985); Gadd v. News-Press Publ'g Co., 412 So. 2d 894, 895-96 (Fla. 2d DCA 1982).

11
Robichaud v. Kennedygreen
fladistctapp · 1998 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019See Robichaud v. Kennedy, 711 So. 2d 186, 187 (Fla. 2d DCA 1998) (citing 1In the written order, the trial court granted portions of the motion to quash the subpoena duces tecum relating to requests that could be obtained directly from third parties.

11
Walton v. Duggergreen
fla · 1993 · cited in 1 Florida opinions naming this issue, 2019–2019
11
Lorei v. Smithgreen
fladistctapp · 1985 · cited in 1 Florida opinions naming this issue, 2019–2019
11
Loren v. Stategreen
fladistctapp · 1992 · cited in 1 Florida opinions naming this issue, 2018–2018
11
Fox v. Stategreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2018–2018
11
Florida House of Representatives v. Cristgreen
fla · 2008 · cited in 1 Florida opinions naming this issue, 2017–2017
11
Rutherford v. Mooregreen
fla · 2000 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Torbert v. Stategreen
fladistctapp · 2002 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Freeman v. Stategreen
fla · 2000 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Potts v. Stategreen
fladistctapp · 2004 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Haynes v. Stategreen
fladistctapp · 2013 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Hampton v. Stategreen
fladistctapp · 2015 · cited in 1 Florida opinions naming this issue, 2016–2016
11
In the Interest of APgreen
fladistctapp · 1994 · cited in 1 Florida opinions naming this issue, 2015–2015
11
Matos v. Stategreen
fladistctapp · 2007 · cited in 1 Florida opinions naming this issue, 2013–2013
11
Baker v. Stategreen
fla · 2010 · cited in 1 Florida opinions naming this issue, 2011–2011
11
Boatman v. Stategreen
fladistctapp · 2010 · cited in 1 Florida opinions naming this issue, 2011–2011
11
Hunter v. Dennies Contracting Co., Inc.green
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2011–2011
11
Calicchio v. Calicchiogreen
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2011–2011
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 (16)

CaseCitedYears
Holmes v. State neutral
fladistctapp · 2006
2 sentences

2021State v. Broom, 523 So. 2d 639, 641 (Fla. 2d DCA 1988); see also Miller v. State, 980 So. 2d 1092 (Fla. 2d DCA 2008); Holmes v. State, 933 So. 2d 1205 (Fla. 2d DCA 2006).

2011State v. Broom, 523 So.2d 639, 641 (Fla. 2d DCA 1988); see also Miller v. State, 980 So.2d 1092 (Fla. 2d DCA 2008); Holmes v. State, 933 So.2d 1205 (Fla. 2d DCA 2006).

22011–2021
United States v. Ross green
scotus · 1982
2 sentences

2013In Crump , the supreme court held the lower court correctly denied a defendant’s motion to suppress evidence obtained without a warrant from his pickup truck, stating: Under the vehicle exception to the warrant requirement “[o]nly the prior approval of the magistrate is waived; the search otherwise [must be such] as the magistrate could authorize.” Carney, 471 U.S. at 394, 105 S.Ct. at 2071 (quoting United States v. Ross, 456 U.S. 798, 823 , 102 S.Ct. 2157, 2172 , 72 L.Ed.2d 572 (1982)).

2013In Crump , the supreme court held the lower court correctly denied a defendant’s motion to suppress evidence obtained without a warrant from his pickup truck, stating: Under the vehicle exception to the warrant requirement “[o]nly the prior approval of the magistrate is waived; the search otherwise [must be such] as the magistrate could authorize.” Carney, 471 U.S. at 394, 105 S.Ct. at 2071 (quoting United States v. Ross, 456 U.S. 798, 823 , 102 S.Ct. 2157, 2172 , 72 L.Ed.2d 572 (1982)).

21993–2013
Hampton v. McDonough green
fladistctapp · 2007
2 sentences

2008As we recognized in Hampton v. McDonough, 967 So.2d 317 (Fla. 1st DCA 2007), Florida Rule of Civil Procedure 1.540(b) is unavailable as a vehicle to challenge an interlocutory lien order in a proceeding of this nature.

2008Hampton v. McDonough, 967 So.2d 317 (Fla. 1st DCA 2007).

22008–2008
King v. State green
fladistctapp · 2003
2 sentences

2005With regard to Wright's second claim, the Second District first receded from its prior decision in King v. State, 835 So.2d 1224 (Fla. 2d DCA 2003), which "held that a rule 3.800(a) motion is a proper vehicle to challenge" a trial court's order retaining jurisdiction that does not comply with all statutory requirements.

2003In King, 835 So.2d at 1225 , this court held that a rule 3.800(a) motion is a proper vehicle to challenge the trial court's reservation of jurisdiction over a sentence.

22003–2005
Miller v. State green
fladistctapp · 2005
1 sentence

2022See Mourra v. State, 884 So. 2d 316, 319 (Fla. 2d DCA 2004), abrogated on other grounds by Sheppard v. State, 17 So. 3d 275 (Fla. 2009) (observing that the Florida Supreme Court adopted rule 3.170(l) in an effort to implement the Florida Legislature’s Criminal Appeal Reform Act of 1996, and noting that a rule 3.170(l) motion was intended to occur as a part of the initial criminal proceedings and direct appeal, when a defendant still has a right to counsel). 5 3.850 motion to vacate plea based on alleged involuntariness of plea); Tatum v. State, 27 So. 3d 700 (Fla. 3d DCA 2010) (same); Miller v

12022–2022
Tatum v. State green
fladistctapp · 2010
1 sentence

2022See Mourra v. State, 884 So. 2d 316, 319 (Fla. 2d DCA 2004), abrogated on other grounds by Sheppard v. State, 17 So. 3d 275 (Fla. 2009) (observing that the Florida Supreme Court adopted rule 3.170(l) in an effort to implement the Florida Legislature’s Criminal Appeal Reform Act of 1996, and noting that a rule 3.170(l) motion was intended to occur as a part of the initial criminal proceedings and direct appeal, when a defendant still has a right to counsel). 5 3.850 motion to vacate plea based on alleged involuntariness of plea); Tatum v. State, 27 So. 3d 700 (Fla. 3d DCA 2010) (same); Miller v

12022–2022
Maura v. State neutral
fladistctapp · 1985
1 sentence

2022See Mourra v. State, 884 So. 2d 316, 319 (Fla. 2d DCA 2004), abrogated on other grounds by Sheppard v. State, 17 So. 3d 275 (Fla. 2009) (observing that the Florida Supreme Court adopted rule 3.170(l) in an effort to implement the Florida Legislature’s Criminal Appeal Reform Act of 1996, and noting that a rule 3.170(l) motion was intended to occur as a part of the initial criminal proceedings and direct appeal, when a defendant still has a right to counsel). 5 3.850 motion to vacate plea based on alleged involuntariness of plea); Tatum v. State, 27 So. 3d 700 (Fla. 3d DCA 2010) (same); Miller v

12022–2022
Johnson v. Fulton neutral
fladistctapp · 2007
12011–2011
Beverly Enterprises-Florida, Inc. v. Ives green
fladistctapp · 2002
12006–2006
Wright v. State green
fla · 2005
12006–2006
Scott v. State green
fladistctapp · 2004
12005–2005
State v. St. Jean green
fladistctapp · 1995
12004–2004
Hampton v. State green
fladistctapp · 2000
12003–2003
Judge v. State green
fladistctapp · 1992
12002–2002
Powell v. Wingard green
fladistctapp · 1981
12002–2002
Jenkins v. State green
fladistctapp · 2000
12001–2001

Statutes the citing opinions construe

FL § 316.193 (3) FL § 893.13 (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

PA 170 (1947–2026) NY 141 (1962–2026) CA 117 (1963–2026) TX 104 (1973–2026) CT 100 (1987–2022) OH 91 (1947–2026) FL 67 (1954–2026) MI 45 (1894–2026) IL 34 (1975–2026) IN 27 (1980–2025) GA 27 (1979–2025) ND 22 (1984–2020) IA 22 (1986–2023) MD 19 (1971–2025) KS 19 (1984–2026) TN 15 (1978–2019) LA 14 (1927–2019) ID 12 (1991–2025) CO 12 (1989–2018) WI 12 (1970–2025) MS 11 (1988–2020) AZ 11 (1941–2025) NJ 10 (1985–2021) VA 10 (1995–2017) AL 10 (1985–2006) OR 10 (2006–2026) MA 9 (1946–2025) UT 9 (1988–2023) MO 9 (1980–2025) NV 8 (1975–2024) OK 7 (1997–2016) WA 7 (1980–2025) MT 6 (1980–2024) RI 6 (1976–2022) AR 6 (1973–2021) NC 5 (1952–2018) NM 5 (1938–2017) NE 5 (1977–2008) DE 5 (1993–2026) KY 5 (1977–2026) DC 4 (1985–2017) VT 4 (1997–2007) MN 4 (1993–2016) HI 3 (1994–2020) WY 3 (1988–2019) AK 3 (1979–1993) SC 3 (1986–2001) SD 3 (1982–1998) ME 2 (2003–2022) WV 2 (2019–2024)

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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