spirit doctrine (Vermont) · Go Syfert
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spirit doctrine in Vermont

66 Vermont opinions name it 2 courts 1883–2025 5 in the last five years

The cases below were cited by Vermont 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 (27)

CaseFollowedCited
In Re Moxley's Willgreen
vt · 1930 · cited in 12 Vermont opinions naming this issue, 1960–2003
2 sentences

1996If the charge as a whole “‘breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it, it ought to stand.’” Choiniere v. Sulikowski, 126 Vt. 274, 277 , 229 A.2d 305, 307 (1967) (quoting In re Moxley’s Will, 103 Vt. 100, 114 , 152 A. 713, 718 (1930)).

1996If the charge as a whole “‘breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it, it ought to stand.’” Choiniere v. Sulikowski, 126 Vt. 274, 277 , 229 A.2d 305, 307 (1967) (quoting In re Moxley’s Will, 103 Vt. 100, 114 , 152 A. 713, 718 (1930)).

712
Fassett v. Town of Roxburygreen
vt · 1883 · cited in 14 Vermont opinions naming this issue, 1883–2003
2 sentences

1991Finding that the charge as a whole “breathes the true spirit and doctrine of the law,” Fassett v. Town of Roxbury, 55 Vt. 552, 556 (1883), we cannot agree that the isolated language complained of amounts to error.

1986State v. Miller, supra, 146 Vt. at 175 , 502 A.2d at 839 . “ ‘[I]f, as a whole [the charge] breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it, it ought to stand.’ ” State v. Bishop, 128 Vt. 221, 230 , 260 A.2d 393, 399 (1969) (quoting Fassett v. Town of Roxbury, 55 Vt. 552, 556 (1883)).

614
Harris v. Carbonneaugreen
vt · 1996 · cited in 7 Vermont opinions naming this issue, 2000–2006
2 sentences

2006A jury charge will be upheld “[i]f the charge as a whole breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it.” Harris v. Carbonneau, 165 Vt. 433, 438 , 685 A.2d 296, 300 (1996) (internal quotation marks and citations omitted).

2006A jury charge will be upheld “[i]f the charge as a whole breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it.” Harris v. Carbonneau, 165 Vt. 433, 438 , 685 A.2d 296, 300 (1996) (internal quotation marks and citations omitted).

57
Choiniere v. Sulikowskigreen
vt · 1967 · cited in 5 Vermont opinions naming this issue, 1980–1996
2 sentences

1996If the charge as a whole “‘breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it, it ought to stand.’” Choiniere v. Sulikowski, 126 Vt. 274, 277 , 229 A.2d 305, 307 (1967) (quoting In re Moxley’s Will, 103 Vt. 100, 114 , 152 A. 713, 718 (1930)).

1996If the charge as a whole “‘breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it, it ought to stand.’” Choiniere v. Sulikowski, 126 Vt. 274, 277 , 229 A.2d 305, 307 (1967) (quoting In re Moxley’s Will, 103 Vt. 100, 114 , 152 A. 713, 718 (1930)).

55
State v. Streichgreen
vt · 1995 · cited in 4 Vermont opinions naming this issue, 2012–2021
2 sentences

2021“There is no error if the jury charge as a whole conveys the true spirit and doctrine of the law, and there is no fair ground to say the jury has been misled by it.” State v. Streich, 163 Vt. 331, 352-53 , 658 A.2d 38, 53 (1995) (quotation omitted). ¶ 32.

2021“There is no error if the jury charge as a whole conveys the true spirit and doctrine of the law, and there is no fair ground to say the jury has been misled by it.” State v. Streich, 163 Vt. 331, 352-53 , 658 A.2d 38, 53 (1995) (quotation omitted). ¶ 32.

44
State v. Bishopgreen
vt · 1969 · cited in 6 Vermont opinions naming this issue, 1970–1986
2 sentences

1986State v. Miller, supra, 146 Vt. at 175 , 502 A.2d at 839 . “ ‘[I]f, as a whole [the charge] breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it, it ought to stand.’ ” State v. Bishop, 128 Vt. 221, 230 , 260 A.2d 393, 399 (1969) (quoting Fassett v. Town of Roxbury, 55 Vt. 552, 556 (1883)).

1986State v. Miller, supra, 146 Vt. at 175 , 502 A.2d at 839 . “ ‘[I]f, as a whole [the charge] breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it, it ought to stand.’ ” State v. Bishop, 128 Vt. 221, 230 , 260 A.2d 393, 399 (1969) (quoting Fassett v. Town of Roxbury, 55 Vt. 552, 556 (1883)).

36
State v. Nortongreen
vt · 1986 · cited in 4 Vermont opinions naming this issue, 1989–2004
2 sentences

2004See State v. Norton, 147 Vt. 223, 235 , 514 A.2d 1053, 1061 (1986) (“If, as a whole the charge breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it, it ought to stand.”) (internal quotations and citations omitted).

2004See State v. Norton, 147 Vt. 223, 235 , 514 A.2d 1053, 1061 (1986) (“If, as a whole the charge breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it, it ought to stand.”) (internal quotations and citations omitted).

34
Turgeon v. Schneidergreen
vt · 1988 · cited in 3 Vermont opinions naming this issue, 1994–2017
2 sentences

2017See Turgeon v. Schneider , 150 Vt. 268 , 276, 553 A.2d 548 , 553 (1988) (explaining that party "claiming error in jury instructions must establish not only that they were erroneous but that prejudice resulted," and no error will be found where jury charge "as a whole, ... breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it" (quotations omitted)).

2017See Turgeon v. Schneider , 150 Vt. 268 , 276, 553 A.2d 548 , 553 (1988) (explaining that party "claiming error in jury instructions must establish not only that they were erroneous but that prejudice resulted," and no error will be found where jury charge "as a whole, ... breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it" (quotations omitted)).

33
State v. Rebideaugreen
vt · 1974 · cited in 4 Vermont opinions naming this issue, 1974–1978
2 sentences

1978In considering appellant’s challenge to the instructions given the jury by the court below, we must ask whether the charge, as a whole, “breathes the true spirit and doctrine of the law” or whether on the contrary there is “ground to say that the jury has been misled.” State v. Girouard, 135 Vt. 123, 139 , 373 A.2d 836, 847 (1977); State v. Bebideau, 132 Vt. 445, 454 , 321 A.2d 58, 64 (1974).

1978In considering appellant’s challenge to the instructions given the jury by the court below, we must ask whether the charge, as a whole, “breathes the true spirit and doctrine of the law” or whether on the contrary there is “ground to say that the jury has been misled.” State v. Girouard, 135 Vt. 123, 139 , 373 A.2d 836, 847 (1977); State v. Bebideau, 132 Vt. 445, 454 , 321 A.2d 58, 64 (1974).

24
State v. Williamsgreen
vt · 1990 · cited in 2 Vermont opinions naming this issue, 1992–2002
2 sentences

1992Cf. State v. Williams, 154 Vt. 76, 81 , 574 A.2d 1264, 1267 (1990) (no error where charge as a whole breathes "the true spirit and doctrine of the law," and there is no reasonable basis to find that the jury was misled by it).

1992Cf. State v. Williams, 154 Vt. 76, 81 , 574 A.2d 1264, 1267 (1990) (no error where charge as a whole breathes "the true spirit and doctrine of the law," and there is no reasonable basis to find that the jury was misled by it).

22
Winey v. William E. Dailey, Inc.green
vt · 1993 · cited in 3 Vermont opinions naming this issue, 2007–2025
2 sentences

2007If the charge as a whole "breathes the true spirit and doctrine of the law and there is no fair ground to say the jury has been misled, there is no ground for reversal." Id. (quotations omitted).

2007If the charge as a whole “breathes the true spirit and doctrine of the law and there is no fair ground to say the jury has been misled, there is no ground for reversal.” Id. (quotations omitted).

13
State v. Jackowskigreen
vt · 2006 · cited in 3 Vermont opinions naming this issue, 2008–2021
2 sentences

2021See State v. Jackowski, 2006 VT 119, ¶ 4 , 181 Vt. 73 , 915 A.2d 767 (“A jury charge will be upheld if the charge as a whole breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it.” (alteration omitted) (quotation omitted)); see also Day, 150 Vt. at 123 , 549 A.2d at 1064 (“[A]ll that is required is that the court provide the jury with a charge that is full, fair, and correct on all issues, theories, and claims within the pleadings, so far as the evidence requires.” (quotation omitted)).

2009The essential inquiry, therefore, is whether the charge “undermines our confidence in the verdict.” State v. Jackowski, 2006 VT 119, ¶ 4 , 181 Vt. 73 , 915 A.2d 767 . ¶ 18.

13
Laferriere v. Salibagreen
vt · 1955 · cited in 3 Vermont opinions naming this issue, 1960–1965
2 sentences

1965“If, as a whole, it breathes the true spirit and doctrine of the law and there is no' fair ground.to say that the jury has been misled by it, it ought to stand.” State v. Coburn, 122 Vt. 102, 110 , 165 A.2d 349 ; Laferriere v. Saliba, 119 Vt. 25 , 117 A.2d 380 .

1965“If, as a whole, it breathes the true spirit and doctrine of the law and there is no' fair ground.to say that the jury has been misled by it, it ought to stand.” State v. Coburn, 122 Vt. 102, 110 , 165 A.2d 349 ; Laferriere v. Saliba, 119 Vt. 25 , 117 A.2d 380 .

13
In re Cohngreen
vt · 2001 · cited in 2 Vermont opinions naming this issue, 2004–2025
2 sentences

2025“When reviewing jury instructions, we look at the instructions as a whole to determine whether they capture the true spirit and doctrine of the law.” Irving v. Agency of Transp., 172 Vt. 527, 530 (2001) (citations and quotations omitted).

2004The propriety of a jury instruction depends upon whether the charge, as a whole and not piecemeal, captures “ ‘the true spirit and doctrine of the law.’” Irving v. Agency of Transp., 172 Vt. 527, 530 , 768 A.2d 1286, 1290 (2001) (mem.) (quoting Harris v. Carbonneau, 165 Vt. 433, 438 , 685 A.2d 296, 300 (1996)); Mobbs, 155 Vt. at 218 , 583 A.2d at 571 .

12
State v. Pittsgreen
vt · 2002 · cited in 2 Vermont opinions naming this issue, 2018–2018
2 sentences

2018When reviewing jury instructions, this Court must "read the charge as a whole, rather than piecemeal, and will uphold the instruction where it breathes the true spirit and doctrine of the law and does not mislead the jury." State v. Pitts , 174 Vt. 21 , 23, 800 A.2d 481 , 483 (2002) (quotation omitted).

2018When reviewing jury instructions, this Court must "read the charge as a whole, rather than piecemeal, and will uphold the instruction where it breathes the true spirit and doctrine of the law and does not mislead the jury." State v. Pitts , 174 Vt. 21 , 23, 800 A.2d 481 , 483 (2002) (quotation omitted).

12
State v. Jonesgreen
vt · 2008 · cited in 2 Vermont opinions naming this issue, 2016–2016
2 sentences

2016See State v. Jones, 2008 VT 67, ¶ 23 , 184 Vt. 150 , 955 A.2d 1190 (“If the jury charge as a whole breathes the true spirit and doctrine of the law, we will uphold it.”).

2016See State v. Jones, 2008 VT 67, ¶ 23 , 184 Vt. 150 , 955 A.2d 1190 (“If the jury charge as a whole breathes the true spirit and doctrine of the law, we will uphold it.”).

12
State v. Valleygreen
vt · 1989 · cited in 2 Vermont opinions naming this issue, 1991–1993
2 sentences

1991“If as a whole the charge ‘breathes the true spirit and doctrine of the law’ and there is no fair ground to say the jury has been misled, there is no error.” Id. (quoting State v. Norton, 147 Vt. 223, 235 , 514 A.2d 1053, 1061 (1986)).

1991"If as a whole the charge `breathes *74 the true spirit and doctrine of the law' and there is no fair ground to say the jury has been misled, there is no error." Id. (quoting State v. Norton, 147 Vt. 223, 235 , 514 A.2d 1053, 1061 (1986)).

12
State v. Shabazzgreen
vt · 1999 · cited in 1 Vermont opinions naming this issue, 2025–2025
1 sentence

2025In addition, the Vermont Supreme Court “‘will assign error only where the instructions undermine our confidence in the verdict.’” Id. (quoting State v. Shabazz, 169 Vt. 448, 450 (1999)).

11
State v. Daygreen
· 1988 · cited in 1 Vermont opinions naming this issue, 2021–2021
2 sentences

2021See State v. Jackowski, 2006 VT 119, ¶ 4 , 181 Vt. 73 , 915 A.2d 767 (“A jury charge will be upheld if the charge as a whole breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it.” (alteration omitted) (quotation omitted)); see also Day, 150 Vt. at 123 , 549 A.2d at 1064 (“[A]ll that is required is that the court provide the jury with a charge that is full, fair, and correct on all issues, theories, and claims within the pleadings, so far as the evidence requires.” (quotation omitted)).

2021See State v. Jackowski, 2006 VT 119, ¶ 4 , 181 Vt. 73 , 915 A.2d 767 (“A jury charge will be upheld if the charge as a whole breathes the true spirit and doctrine of the law, and there is no fair ground to say that the jury has been misled by it.” (alteration omitted) (quotation omitted)); see also Day, 150 Vt. at 123 , 549 A.2d at 1064 (“[A]ll that is required is that the court provide the jury with a charge that is full, fair, and correct on all issues, theories, and claims within the pleadings, so far as the evidence requires.” (quotation omitted)).

11
DeYoung v. Ruggeriogreen
vt · 2009 · cited in 1 Vermont opinions naming this issue, 2015–2015
2 sentences

2015See DeYoung v. Ruggiero, 2009 VT 9, ¶ 36 , 185 Vt. 267 , 971 A.2d 627 (stating that this Court reviews trial court jury instructions to determine whether they “convey the true spirit and doctrine of the law” (quotation omitted)).

2015See DeYoung v. Ruggiero, 2009 VT 9, ¶ 36 , 185 Vt. 267 , 971 A.2d 627 (stating that this Court reviews trial court jury instructions to determine whether they “convey the true spirit and doctrine of the law” (quotation omitted)).

11
Callan v. Hackettgreen
vt · 2000 · cited in 1 Vermont opinions naming this issue, 2014–2014
2 sentences

2014Supra, ¶ 22. 9 Again, we look to the jury instruction as a whole, rather than any particular sentence, to see whether it “breathes the true spirit and doctrine of the law.” Callan v. Hackett, 170 Vt. 609, 609 , 749 A.2d 626, 628 (2000) (mem.) (quotation omitted).

2014Supra, ¶ 22. 9 Again, we look to the jury instruction as a whole, rather than any particular sentence, to see whether it “breathes the true spirit and doctrine of the law.” Callan v. Hackett, 170 Vt. 609, 609 , 749 A.2d 626, 628 (2000) (mem.) (quotation omitted).

11
State v. Pelicangreen
vt · 1993 · cited in 1 Vermont opinions naming this issue, 2009–2009
2 sentences

2009Moreover, “[i]f the jury charge as a whole breathes the true spirit and doctrine of the law, we will uphold it.” Id.; see also State v. Pelican, 160 Vt. 536, 539 , 632 A.2d 24, 26 (1993).

2009Moreover, “[i]f the jury charge as a whole breathes the true spirit and doctrine of the law, we will uphold it.” Id.; see also State v. Pelican, 160 Vt. 536, 539 , 632 A.2d 24, 26 (1993).

11
Irving v. Agency of Transportationgreen
vt · 2001 · cited in 1 Vermont opinions naming this issue, 2004–2004
11
State v. Morrillgreen
vt · 1969 · cited in 1 Vermont opinions naming this issue, 1984–1984
11
State v. Lumbragreen
vt · 1962 · cited in 1 Vermont opinions naming this issue, 1984–1984
11
State v. Morsegreen
vt · 1968 · cited in 1 Vermont opinions naming this issue, 1979–1979
11
State v. Girouardgreen
vt · 1977 · cited in 1 Vermont opinions naming this issue, 1978–1978
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (27)

CaseCitedYears
State v. Coburn green
vt · 1960
2 sentences

1965“If, as a whole, it breathes the true spirit and doctrine of the law and there is no' fair ground.to say that the jury has been misled by it, it ought to stand.” State v. Coburn, 122 Vt. 102, 110 , 165 A.2d 349 ; Laferriere v. Saliba, 119 Vt. 25 , 117 A.2d 380 .

1965“If, as a whole, it breathes the true spirit and doctrine of the law and there is no' fair ground.to say that the jury has been misled by it, it ought to stand.” State v. Coburn, 122 Vt. 102, 110 , 165 A.2d 349 ; Laferriere v. Saliba, 119 Vt. 25 , 117 A.2d 380 .

31963–1968
State v. Adams green
vt · 1973
2 sentences

1975State v. Adams, 131 Vt. 413 , 306 A.2d 92 (1973); State v. Rebideau, 132 Vt. 445, 454 , 321 A.2d 58 (1974).

1975State v. Adams, 131 Vt. 413 , 306 A.2d 92 (1973); State v. Rebideau, 132 Vt. 445, 454 , 321 A.2d 58 (1974).

21974–1975
Flanders v. Newport Trucking Co. neutral
vt · 1930
2 sentences

1939Flanders v. Newport Trucking Co., 102 Vt. 437, 438 , 150 Atl. 128 ; Taylor v. Mayhew, 109 Vt. 251, 255 , 195 Atl. 249 .

1937“A charge is not to be tested piecemeal, but as a whole; and if, when so considered, it ‘breathes the true spirit and doctrine of the law’ it will be sustained unless we are convinced that the jury was misled.” Flanders v. Newport Trucking Co., 102 Vt. 437, 438 , 150 Atl. 128 ; Cummings v. Conn. Gen’l Life Ins.

21937–1939
In Re Sawyer's Will neutral
vt · 1930
2 sentences

1939Flanders v. Newport Trucking Co., 102 Vt. 437, 438 , 150 Atl. 128 ; Taylor v. Mayhew, 109 Vt. 251, 255 , 195 Atl. 249 .

1937“A charge is not to be tested piecemeal, but as a whole; and if, when so considered, it ‘breathes the true spirit and doctrine of the law’ it will be sustained unless we are convinced that the jury was misled.” Flanders v. Newport Trucking Co., 102 Vt. 437, 438 , 150 Atl. 128 ; Cummings v. Conn. Gen’l Life Ins.

21937–1939
State v. Nathaniel R. Peatman green
vt · 2018
1 sentence

2021“When reviewing jury instructions, this Court must read the charge as a whole, rather than piecemeal, and will uphold the instruction where it breathes the true spirit and doctrine of the law and does not mislead the jury.” Id. (quotation omitted).

12021–2021
Currier v. Letourneau green
vt · 1977
2 sentences

2018However, a trial court "is not required to make every comment that conceivably could be made on the issues and evidence" and "[t]he degree to which the court is to elaborate on the points charged lies within the sound exercise of its discretion." *1262 Currier v. Letourneau , 135 Vt. 196 , 204, 373 A.2d 521 , 527 (1977). ¶ 15.

2018However, a trial court "is not required to make every comment that conceivably could be made on the issues and evidence" and "[t]he degree to which the court is to elaborate on the points charged lies within the sound exercise of its discretion." *1262 Currier v. Letourneau , 135 Vt. 196 , 204, 373 A.2d 521 , 527 (1977). ¶ 15.

12018–2018
Willard v. PARSONS HILL PARTNERSHIP green
vt · 2005
2 sentences

2015The question of whether “latent” defects require actual notice was addressed by this Court in Willard v. Parsons Hill P’ship, 2005 VT 69 , 178 Vt. 300 , 882 A.2d 1213 .

2015The question of whether “latent” defects require actual notice was addressed by this Court in Willard v. Parsons Hill P’ship, 2005 VT 69 , 178 Vt. 300 , 882 A.2d 1213 .

12015–2015
Knapp v. State green
vt · 1998
1 sentence

2013We consider the jury instructions in their entirety, and if the “charge as a whole breathes the true spirit and doctrine of the law and there is no fair ground to say that the jury has been misled, it ought to stand.” Id. (quotation omitted).

12013–2013
Mobbs v. Central Vermont Railway, Inc. green
vt · 1990
12004–2004
State v. Miller green
vt · 1985
11986–1986
State v. Lapham green
vt · 1977
11979–1979
Gould v. Gould neutral
vt · 1939
11963–1963
Taylor v. Mayhew neutral
vt · 1937
11939–1939
Landry v. Hubert green
vt · 1927
11937–1937
Cummings v. Connecticut General Life Insurance green
vt · 1928
11937–1937
Ide v. Boston & Maine Railroad green
vt · 1909
11917–1917
Melendy v. Town of Bradford neutral
vt · 1883
11905–1905
United States v. Cook green
scotus · 1872
11898–1898
State v. Butler green
vt · 1845
11898–1898
State v. Barker neutral
vt · 1846
11898–1898
State v. Abbey neutral
· 1856
11898–1898
State v. Norton green
vt · 1873
11898–1898
State v. Stokes green
vt · 1881
11898–1898
State v. Smith neutral
vt · 1889
11898–1898
State v. Stevenson neutral
vt · 1896
11898–1898
State v. McCaffrey green
vt · 1896
11898–1898
Bovee v. Town of Danville green
· 1880
11883–1883

Statutes the citing opinions construe

VT § Vt. Stat. Ann. tit. 13, § 1024 (8) VT § Vt. Stat. Ann. tit. 12, § 1036 (4) VT § Vt. Stat. Ann. tit. 09, § 2453 (3) VT § Vt. Stat. Ann. tit. 13, § 3 (3) VT § Vt. Stat. Ann. tit. 13, § 3705 (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

VT 66 (1883–2025) NY 36 (1843–2008) IL 23 (1903–2023) TX 20 (1884–2015) IN 20 (1984–2024) AL 17 (1840–2024) CA 15 (1896–2010) PA 14 (1900–2025) NJ 13 (1933–2025) FL 13 (1970–2011) AZ 12 (1965–2025) MO 11 (1884–2020) IA 10 (1862–2018) WA 9 (1901–2020) KS 8 (1900–2026) WY 8 (1906–2005) OH 8 (1837–2020) MT 8 (1982–2026) SD 8 (1892–1998) DC 7 (1884–2014) VA 7 (1833–2025) ID 7 (1978–2009) WV 7 (1966–2004) CO 7 (1895–2021) MA 7 (1845–2018) TN 6 (1896–2002) MI 6 (1890–2001) GA 6 (1901–1990) WI 5 (1936–2006) MS 5 (1873–2025) NM 5 (1929–2014) AR 5 (1898–2003) CT 5 (1969–2003) OR 4 (1904–1970) NH 4 (1826–2015) NC 4 (1887–2012) MN 4 (1893–2018) ND 3 (1910–2006) KY 2 (1978–2017) HI 2 (1953–1955) LA 2 (1964–1991) MD 2 (1967–2017) SC 2 (1908–1925) DE 2 (2020–2022) RI 2 (2012–2014)

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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