American rule (Missouri) · Go Syfert
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American rule in Missouri

66 Missouri opinions name it 2 courts 1877–2019 0 in the last five years

The cases below were cited by Missouri 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 (41)

CaseFollowedCited
Laubinger v. Laubingergreen
moctapp · 1999 · cited in 6 Missouri opinions naming this issue, 2000–2009
2 sentences

2009Cohen v. Cohen, 73 S.W.3d 39, 55 (Mo.App.2002). “ ‘However, a trial court may order one party to pay the other’s attorney’s fees and costs where such is authorized by statute.’ ” Id. (quoting Laubinger v. Laubinger, 5 S.W.3d 166, 181 (Mo.App.1999)).

2007Cohen v. Cohen, 73 S.W.3d 39, 55 (Mo.App.2002). “ ‘However, a trial court may order one party to pay the other’s attorney’s fees and costs where such is authorized by statute.’ ” Id. (quoting Laubinger v. Laubinger, 5 S.W.3d 166, 181 (Mo.App.1999)).

56
Cohen v. Cohengreen
moctapp · 2002 · cited in 4 Missouri opinions naming this issue, 2004–2013
2 sentences

2013“Missouri courts typically follow the ‘American rule’ with regard to awards of attorney’s fees and costs[,] which provides that each litigant should bear his or her own litigation expenses.” Cohen v. Cohen, 73 S.W.3d 39, 55 (Mo.App.2002).

2009Cohen v. Cohen, 73 S.W.3d 39, 55 (Mo.App.2002). “ ‘However, a trial court may order one party to pay the other’s attorney’s fees and costs where such is authorized by statute.’ ” Id. (quoting Laubinger v. Laubinger, 5 S.W.3d 166, 181 (Mo.App.1999)).

44
Nix v. Nixgreen
moctapp · 1993 · cited in 4 Missouri opinions naming this issue, 1996–2000
2 sentences

2000Nix v. Nix, 862 S.W.2d 948, 952 (Mo.App.

1996Ordinarily, any exceptions fit into one of four categories: recovery of fees pursuant to contract, recovery provided by statute, recovery as an item of damage to a wronged party involved in collateral litigation, and, occasionally, reimbursement when ordered by a court of equity to balance benefits.” Nix v. Nix, 862 S.W.2d 948, 952 (Mo.App.1993).

44
Midland Property Partners, LLC v. Watkinsgreen
moctapp · 2013 · cited in 3 Missouri opinions naming this issue, 2015–2015
2 sentences

2015We further recognize, consistent with the -American rule, that Missouri courts “have favored the award of attorneys’ fees only where a contract expressly authorizes their recovery.” Watkins, 416 S.W.3d at 819 .

2015The assignment agreement provides: “[I]n the event of default, I [Appellant] agree to pay all collection costs incurred by [Community Bank].” “Missouri courts, in accordance with the American rule, have favored the award of attorneys’ fees only where a contract expressly authorizes their recovery.” Midland Property Partners, LLC v. Watkins, 416 S.W.3d 805, 819 (Mo.App.W.D. 2013).

33
Brown v. Mercantile Bank of Poplar Bluffgreen
moctapp · 1991 · cited in 3 Missouri opinions naming this issue, 1995–1999
2 sentences

1999As explained in Architectural Resources, Inc. v. Rakey, 912 S.W.2d 676 (Mo.App. 1995): Missouri courts have historically adhered to the “American rule” that with certain exceptions, litigants bear the expense of their own attorney fees, Brown v. Mercantile Bank of Poplar Bluff, 820 S.W.2d 327, 340 [23] (Mo.App.1991), and of paying the fees of the experts needed to make them case.

1995Missouri courts have historically adhered to the “American rule” that with certain exceptions, litigants bear the expense of their own attorney fees, Brown v. Mercantile Bank of Poplar Bluff, 820 S.W.2d. 327, 340 [23] (Mo.App.1991), and of paying the fees of the experts needed to make their ease.

33
Capitol Group, Inc. v. Colliergreen
moctapp · 2012 · cited in 2 Missouri opinions naming this issue, 2015–2015
2 sentences

2015The rules governing construction of contracts similarly apply to the Acknowledgment, but we must be cognir zant that, “the liability of a guarantor is to be strictly construed according to the terms of the guaranty agreement and may not be extended by implication beyond the strict letter of the obligation.” Capitol Group, Inc. v. Collier, 365 S.W.3d 644, 648 (Mo. App. E.D. 2012) (citation and quotations omitted).

2015The rules governing construction of contracts similarly apply to the Acknowledgment, but we must be cognizant that “the liability of a guarantor is to be strictly construed according to the terms of the guaranty agreement and may not be extended by implication beyond the strict letter of the obligation.” Capitol Group, Inc. v. Collier, 365 S.W.3d 644, 648 (Mo. App. E.D. 2012) (citation and quotations omitted).

22
Wansing v. Wansinggreen
moctapp · 2009 · cited in 2 Missouri opinions naming this issue, 2010–2011
2 sentences

2011“Missouri courts generally follow the ‘American rule,’ which provides that each party should bear his or her own litigation expenses.” Wansing v. Wansing, 277 S.W.3d 760, 770 (Mo.App.2009).

2010With respect to attorney’s fees, “Missouri courts generally follow the ‘American rule,’ which provides that each party should bear his or her own litigation expenses.” Warning v. Wansing, 277 S.W.3d 760, 770 (Mo.App.2009).

22
Wall USA, Inc. v. City of Ballwingreen
moctapp · 2001 · cited in 2 Missouri opinions naming this issue, 2004–2004
2 sentences

2004Wall USA, Inc. v. City of Ballwin, 53 S.W.3d 168, 172 (Mo.App.E.D.2001).

2004Wall USA, Inc. v. City of Ballwin, 53 S.W.3d 168, 172 (Mo.App.

22
MAYOR, COUNCILMEN, & CITIZENS ETC. v. Beardgreen
mo · 1982 · cited in 2 Missouri opinions naming this issue, 2000–2002
2 sentences

2002Liberty v. Beard, 636 S.W.2d 330, 331 (Mo. banc 1982).

2000See Liberty v. Beard, 636 S.W.2d 330, 331 [2] (Mo.banc 1982); Architectural Resources, Inc. v. Rakey, 912 S.W.2d 676, 678 [1] (Mo.App.1995).

22
Jackson v. Christian Salvesen Holdings, Inc.green
moctapp · 1998 · cited in 2 Missouri opinions naming this issue, 2000–2002
2 sentences

2002“While ‘[i]n most circumstances, the trial court is granted broad discretion to award attorney’s fees ... if a claim for attorney’s fees is made under a provision of the contract, the trial court must comply with the terms set forth therein.’” Id. (quoting Jackson v. Christian Salvesen Holdings, Inc., 978 S.W.2d 377, 385 (Mo.App.1998)). *366 Although the language of the agreement required Father to pay child support only until the children reached age eighteen or finished high school, that agreement ran afoul of § 452.340.5, as explained above.

2000Paragraph J, of Article III, of the separation agreement at issue provides that “[H]usband will be personally liable for any costs, including attorney's fees, that may be incurred by [Wife] in enforcing her rights or collecting such ben- *930 efíts from [Husband].” While, “[i]n most circumstances, the trial court is granted broad discretion to award attorney’s fees ... if a claim for attorney’s fees is made under a provision of the contract, the trial court must comply with the terms set forth therein.” Jackson v. Christian Salvesen Holdings, Inc., 978 S.W.2d 377, 385 (Mo.App.1998) (citation o

22
Garner v. Hubbsgreen
moctapp · 2000 · cited in 2 Missouri opinions naming this issue, 2002–2002
2 sentences

2002Generally, exceptions to this rule fit into one of four categories: “recovery of fees pursuant to contract, recovery provided by statute, recovery as an item of damage to a wronged party involved in collateral litigation, and, occasionally, reimbursement when ordered by a court of equity to balance benefits.” Attorney fee provisions in separation agreements fit under the “contract” exception to the “American rule.” Gamer v. Hubbs, 17 S.W.3d 922, 929 (Mo.App.2000).

2002Generally, exceptions to this rule fit into one of four categories: “recovery of fees pursuant to contract, recovery provided by statute, recovery as an item of damage to a wronged party involved in collateral litigation, and, occasionally, reimbursement when ordered by a court of equity to balance benefits.” Attorney fee provisions in separation agreements fit under the “contract” exception to the “American rule.” Gamer v. Hubbs, 17 S.W.3d 922, 929 (Mo.App.2000).

22
Nichols v. Bossertgreen
moctapp · 1987 · cited in 2 Missouri opinions naming this issue, 1995–1999
2 sentences

1999See Anderson v. Howald, 897 S.W.2d 176, 181 [9] (Mo. App.1995) (quoting Nichols v. Bossert, 727 S.W.2d 211, 213-14 [3] (Mo.App. 1987)).

1995See Anderson v. Howald, 897 S.W.2d 176, 181 [9] (Mo.App.1995) (quoting Nichols v. Bossert, 727 S.W.2d 211, 213-14 [3] (Mo.App. 1987)).

22
Anderson v. Howaldgreen
moctapp · 1995 · cited in 2 Missouri opinions naming this issue, 1995–1999
2 sentences

1999See Anderson v. Howald, 897 S.W.2d 176, 181 [9] (Mo. App.1995) (quoting Nichols v. Bossert, 727 S.W.2d 211, 213-14 [3] (Mo.App. 1987)).

1995See Anderson v. Howald, 897 S.W.2d 176, 181 [9] (Mo.App.1995) (quoting Nichols v. Bossert, 727 S.W.2d 211, 213-14 [3] (Mo.App. 1987)).

22
County Court of Washington County v. Murphygreen
mo · 1983 · cited in 2 Missouri opinions naming this issue, 1991–1993
2 sentences

1993County Court of Washington County v. Murphy, 658 S.W.2d 14, 16 (Mo. banc 1983).

1991County Court of Washington County v. Murphy, *340 658 S.W.2d 14, 16 (Mo.banc 1983); Mo. Damages, § 19.2 (Mo.Bar 1988).

22
McCreary v. McCrearygreen
moctapp · 1997 · cited in 2 Missouri opinions naming this issue, 2000–2002
2 sentences

2002“Missouri courts have historically adhered to the ‘American rule’ that, with certain exceptions, litigants bear the expense of their own attorney fees.” McCreary v. McCreary, 954 S.W.2d 433, 452 (Mo.App. 1997).

2000Attorney fee provisions in separation agreements fit under the “contract” exception to the “American rule.” See Id.

12
Architectural Resources, Inc. v. Rakeygreen
moctapp · 1995 · cited in 2 Missouri opinions naming this issue, 1999–2000
2 sentences

2000See Liberty v. Beard, 636 S.W.2d 330, 331 [2] (Mo.banc 1982); Architectural Resources, Inc. v. Rakey, 912 S.W.2d 676, 678 [1] (Mo.App.1995).

1999As explained in Architectural Resources, Inc. v. Rakey, 912 S.W.2d 676 (Mo.App. 1995): Missouri courts have historically adhered to the “American rule” that with certain exceptions, litigants bear the expense of their own attorney fees, Brown v. Mercantile Bank of Poplar Bluff, 820 S.W.2d 327, 340 [23] (Mo.App.1991), and of paying the fees of the experts needed to make them case.

12
Frontenac Bank v. GB Investments, LLCgreen
moctapp · 2017 · cited in 1 Missouri opinions naming this issue, 2019–2019
2 sentences

2019Frontenac Bank v. GB Investments, LLC, 528 S.W.3d 381, 397 (Mo. App. E.D. 2017); see also generally LaBarca v. LaBarca, 534 S.W.3d 329, 338 (Mo. App. W.D. 2017) (attorney fee provisions in separation agreements fall within the ‘contract’ exception to the American rule that parties pay for their own attorney’s fees).

2019Frontenac Bank v. GB Investments, LLC, 528 S.W.3d 381, 397 (Mo. App. E.D. 2017); see also generally LaBarca v. LaBarca, 534 S.W.3d 329, 338 (Mo. App. W.D. 2017) (attorney fee provisions in separation agreements fall within the ‘contract’ exception to the American rule that parties pay for their own attorney’s fees).

11
Labarca v. Labarcagreen
moctapp · 2017 · cited in 1 Missouri opinions naming this issue, 2019–2019
2 sentences

2019Frontenac Bank v. GB Investments, LLC, 528 S.W.3d 381, 397 (Mo. App. E.D. 2017); see also generally LaBarca v. LaBarca, 534 S.W.3d 329, 338 (Mo. App. W.D. 2017) (attorney fee provisions in separation agreements fall within the ‘contract’ exception to the American rule that parties pay for their own attorney’s fees).

2019Frontenac Bank v. GB Investments, LLC, 528 S.W.3d 381, 397 (Mo. App. E.D. 2017); see also generally LaBarca v. LaBarca, 534 S.W.3d 329, 338 (Mo. App. W.D. 2017) (attorney fee provisions in separation agreements fall within the ‘contract’ exception to the American rule that parties pay for their own attorney’s fees).

11
Bell v. Commonwealth, Cabinet for Health & Family Services, Department for Community Based Servicesgreen
ky · 2014 · cited in 1 Missouri opinions naming this issue, 2018–2018
2 sentences

2018Under the American rule, "attorney's fees in Kentucky are not awarded as costs to the prevailing party unless there is a statute permitting it or as a term of a contractual agreement between the parties." Id.

2018Under the American rule, "attorney's fees in Kentucky are not awarded as costs to the prevailing party unless there is a statute permitting it or as a term of a contractual agreement between the parties." Id.

11
Schottel-Lehde v. Schottelgreen
moctapp · 2002 · cited in 1 Missouri opinions naming this issue, 2017–2017
1 sentence

2017“Attorney fee provisions in separation agreements fit under the ‘contract’ exception to the ‘American rule.’” Schottel-Lehde v. Schottel, 75 S.W.3d 359, 365 (Mo. App. W.D. 2002).

11
Reed v. Reedgreen
moctapp · 1999 · cited in 1 Missouri opinions naming this issue, 2017–2017
1 sentence

2017Reed v. Reed, 10 S.W.3d 173, 181 (Mo. App. W.D. 1999).

11
Berry v. Volkswagen Group of America, Inc.green
mo · 2013 · cited in 1 Missouri opinions naming this issue, 2015–2015
2 sentences

2015Berry v. Volkswagen Grp. of Am., 6 Inc., 397 S.W.3d 425, 431 (Mo. banc 2013); Essex Contracting, Inc. v. Jefferson Cnty., 277 S.W.3d 647, 657 (Mo. banc 2009).

2015Berry v. Volkswagen Grp. of Am., Inc., 397 S.W.3d 425, 431 (Mo. banc 2013); Essex Contracting, Inc. v. Jefferson Cnty., 277 S.W.3d 647, 657 (Mo. banc 2009).

11
Essex Contracting, Inc. v. Jefferson Countygreen
mo · 2009 · cited in 1 Missouri opinions naming this issue, 2015–2015
2 sentences

2015Berry v. Volkswagen Grp. of Am., 6 Inc., 397 S.W.3d 425, 431 (Mo. banc 2013); Essex Contracting, Inc. v. Jefferson Cnty., 277 S.W.3d 647, 657 (Mo. banc 2009).

2015Berry v. Volkswagen Grp. of Am., Inc., 397 S.W.3d 425, 431 (Mo. banc 2013); Essex Contracting, Inc. v. Jefferson Cnty., 277 S.W.3d 647, 657 (Mo. banc 2009).

11
Lorenzini v. Shortgreen
moctapp · 2010 · cited in 1 Missouri opinions naming this issue, 2012–2012
2 sentences

2012Lorenzini v. Short, 312 S.W.3d 467, 473 (Mo.App.

2012Lorenzini v. Short, 312 S.W.3d 467, 473 (Mo.App.

11
Sheppard v. Eastgreen
moctapp · 2006 · cited in 1 Missouri opinions naming this issue, 2007–2007
2 sentences

2007Sheppard v. East, 192 S.W.3d 518, 523 (Mo.App.

2007Id.

11
Sullivan v. Sullivangreen
moctapp · 2005 · cited in 1 Missouri opinions naming this issue, 2007–2007
1 sentence

2007Sullivan v. Sullivan, 159 S.W.3d 529, 541-42 (Mo.App.2005).

11
David Ranken, Jr. Technical Institute v. Boykinsgreen
mo · 1991 · cited in 1 Missouri opinions naming this issue, 2003–2003
11
Memco, Inc. v. Chronistergreen
moctapp · 2000 · cited in 1 Missouri opinions naming this issue, 2002–2002
11
Murphy v. Carrongreen
mo · 1976 · cited in 1 Missouri opinions naming this issue, 2002–2002
11
Harris v. DeSistogreen
moctapp · 1996 · cited in 1 Missouri opinions naming this issue, 1999–1999
11
Crews v. Crewsgreen
moctapp · 1997 · cited in 1 Missouri opinions naming this issue, 1999–1999
11
Skyles v. Burgegreen
moctapp · 1992 · cited in 1 Missouri opinions naming this issue, 1996–1996
11
Bryson v. Brysongreen
moctapp · 1981 · cited in 1 Missouri opinions naming this issue, 1996–1996
11
Vinson v. Vinsongreen
moctapp · 1987 · cited in 1 Missouri opinions naming this issue, 1995–1995
11
Rustici v. Weidemeyergreen
mo · 1984 · cited in 1 Missouri opinions naming this issue, 1995–1995
11
Johnson v. Mercantile Trust Company National Ass'ngreen
mo · 1974 · cited in 1 Missouri opinions naming this issue, 1995–1995
11
Groves v. State Farm Mutual Automobile Insurance Co.green
mo · 1976 · cited in 1 Missouri opinions naming this issue, 1995–1995
11
Ohlendorf v. Feinsteingreen
moctapp · 1985 · cited in 1 Missouri opinions naming this issue, 1991–1991
11
Haughton Elevator Co. v. C. Rallo Contracting Co.green
moctapp · 1965 · cited in 1 Missouri opinions naming this issue, 1981–1981
11
Reynolds v. Rayborngreen
texapp · 1938 · cited in 1 Missouri opinions naming this issue, 1978–1978
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (39)

CaseCitedYears
Sarah Tupper, Respondents/Cross-Appellants v. City of St. Louis, Appellants/Cross-Respondents. green
mo · 2015
2 sentences

2019Those portions of the transcript, however, do not specifically address postjudgment interest or the application of section 408.040, RSMo Supp. 2012, instead of Wentzville’s interest ordinance. 38 the trial court again found the Cities were entitled to attorney fees under sections 392.350, 488.472, and 527.100 and awarded $1,190,610.77 in attorney fees and expenses. 18 Missouri courts follow the American rule, “which provides that, absent statutory authorization or contractual agreement, each party bears the expense of his or her own attorney’s fees.” Tupper, 468 S.W.3d at 374 .

2019Those portions of the transcript, however, do not specifically address postjudgment interest or the application of section 408.040, RSMo Supp. 2012, instead of Wentzville’s interest ordinance. 38 the trial court again found the Cities were entitled to attorney fees under sections 392.350, 488.472, and 527.100 and awarded $1,190,610.77 in attorney fees and expenses. 18 Missouri courts follow the American rule, “which provides that, absent statutory authorization or contractual agreement, each party bears the expense of his or her own attorney’s fees.” Tupper, 468 S.W.3d at 374 .

12019–2019
Monsanto Co. v. Garst Seed Co. green
moctapp · 2007
2 sentences

2017“One exception to the American rule is where a contract states that a prevailing party is entitled to recover attorney’s fees.” Id.

2017“One exception to the American rule is where a contract states that a prevailing party is entitled to recover attorney’s fees.” Id.

12017–2017
McPherson v. U.S. Physicians Mutual Risk Retention Group green
moctapp · 2003
2 sentences

2014In fact, “Missouri, with few exceptions, follows the majority American rule that litigants pay their own attorney[] fees.” McPherson, 99 S.W.3d at 481 .

2014“A [trial] court has the inherent power to sanction bad faith conduct, probably by way of awarding attorney!] fees, on analogy to the power to award attorney[ ] fees related to prosecuting a contemnor.” Id. (internal citations omitted) “But it may do so only when the sanctioned party acted in bad faith.” Id.

12014–2014
66, Inc. v. Crestwood Commons Redevelopment Corp. green
moctapp · 2004
2 sentences

2010Id. at 594 .

2010Id.

12010–2010
Rhodes v. Marsh green
moctapp · 1991
11995–1995
State Board of Registration for the Healing Arts v. Warren green
moctapp · 1991
11993–1993
Bernheimer Ex Rel. Bernheimer v. First National Bank green
· 1949
11993–1993
Arnold v. Edelman green
mo · 1965
11993–1993
Alyeska Pipeline Service Co. v. Wilderness Society red
scotus · 1975
11978–1978
Stone v. Stone neutral
wash · 1943
11978–1978
Remmers v. Remmers green
· 1909
11967–1967
American Steel Foundries v. Tri-City Central Trades Council green
· 1921
11956–1956
Nichols v. Eaton green
scotus · 1875
11937–1937
Jones v. Harrison neutral
ca8 · 1925
11937–1937
Barlow v. Shawnee Investment Co. green
moctapp · 1932
11933–1933
Doyle v. Fitchburg Railroad neutral
mass · 1896
11914–1914
Dugan v. Blue Hill Street Railway Co. neutral
mass · 1907
11914–1914
Denver & Berkeley Park Rapid Transit Co. v. Dwyer green
colo · 1894
11914–1914
Peterson v. Seattle Traction Co. green
wash · 1900
11914–1914
Harris v. Puget Sound Electric Railway neutral
wash · 1909
11914–1914
Eberts v. Detroit, Mt. Clemens & Marine City Railway neutral
mich · 1908
11914–1914
Arnot v. Woodburn neutral
mo · 1864
11906–1906
Berthold v. Berthold green
mo · 1870
11906–1906
Furnold v. Bank of the State neutral
mo · 1869
11906–1906
Butler v. Lawson green
mo · 1880
11906–1906
Hammons v. Renfrow neutral
mo · 1884
11906–1906
Ferguson's Administrator v. Carson's Administrator neutral
mo · 1885
11906–1906
Blair v. Chicago & Alton Railroad green
mo · 1886
11906–1906
Humphreys v. Atlantic Milling Co. green
mo · 1889
11906–1906
Benne v. Schnecko neutral
mo · 1889
11906–1906
Hackett v. Watts green
mo · 1897
11906–1906
Storts v. George green
· 1899
11906–1906
George v. Somerville neutral
mo · 1899
11906–1906
Miller v. Woodward neutral
mo · 1843
11906–1906
Seligman v. Rogers neutral
mo · 1893
11905–1905
Anchor Milling Co. v. Walsh green
mo · 1891
11905–1905
Walser v. Wear green
mo · 1897
11905–1905
Borgess Investment Co. v. Vette neutral
mo · 1898
11905–1905
Huntington v. Attrill green
scotus · 1892
11905–1905

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 452.355 (9) MO § Mo. Rev. Stat. § 452.300 (6) MO § Mo. Rev. Stat. § 452.330 (6) MO § Mo. Rev. Stat. § 527.100 (4) MO § Mo. Rev. Stat. § 452.375 (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

CA 271 (1858–2026) MI 189 (1863–2026) OH 141 (1869–2026) WA 129 (1891–2026) CT 126 (1895–2026) IL 99 (1851–2026) TN 83 (1887–2026) NY 72 (1885–2026) TX 69 (1888–2026) MO 66 (1877–2019) WY 60 (1916–2026) MD 58 (1906–2025) NJ 58 (1862–2025) AL 54 (1851–2016) NM 49 (1931–2025) MA 49 (1854–2026) VA 48 (1920–2026) CO 45 (1881–2026) DC 44 (1957–2024) PA 42 (1839–2026) WI 40 (1871–2016) IN 40 (1872–2024) FL 37 (1880–2024) AR 32 (1884–2026) AZ 30 (1874–2026) DE 29 (1899–2026) VT 28 (1877–2025) RI 27 (1918–2025) WV 25 (1890–2019) UT 25 (1881–2025) SD 23 (1892–2025) IA 22 (1871–2026) ID 21 (1897–2024) MS 21 (1875–2024) MT 21 (1888–2024) GA 20 (1897–2016) OK 20 (1931–2025) KY 19 (1846–2026) OR 19 (1953–2024) HI 15 (1914–2025) KS 14 (1900–2022) ME 14 (1980–2023) MN 13 (1890–2016) NC 13 (1892–2012) NE 11 (1888–2007) ND 10 (1917–2020) AK 10 (1977–2023) NV 9 (1918–2021) LA 9 (1853–2018) NH 9 (1850–1999) SC 3 (1881–2022)

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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