abuse of discretion standard (Maine) · Go Syfert
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abuse of discretion standard in Maine

65 Maine opinions name it 2 courts 1980–2024 6 in the last five years

The cases below were cited by Maine 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 (48)

CaseFollowedCited
Green Tree Servicing, LLC v. Thelma J. Copegreen
me · 2017 · cited in 2 Maine opinions naming this issue, 2020–2020
2 sentences

2020See Green Tree Servicing, LLC v. Cope, 2017 ME 68, ¶ 12 , 158 A.3d 931 (articulating the abuse of discretion standard). 6 B.

2020See Green Tree Servicing, LLC v. Cope, 2017 ME 68, ¶ 12 , 158 A.3d 931 (articulating the abuse of discretion standard). 6 B.

22
Green Tree Servicing, LLC v. Copegreen
me · 2017 · cited in 2 Maine opinions naming this issue, 2020–2020
2 sentences

2020See Green Tree Servicing, LLC v. Cope, 2017 ME 68, ¶ 12 , 158 A.3d 931 (articulating the abuse of discretion standard). 6 B.

2020See Green Tree Servicing, LLC v. Cope, 2017 ME 68, ¶ 12 , 158 A.3d 931 (articulating the abuse of discretion standard). 6 B.

22
City of Biddeford v. Adamsgreen
me · 1999 · cited in 2 Maine opinions naming this issue, 2019–2019
2 sentences

2019See City of Biddeford v. Adams, 1999 ME 49, ¶¶ 24-25 , 727 A.2d 346 .

2019See City of Biddeford v. Adams, 1999 ME 49, ¶¶ 24-25 , 727 A.2d 346 .

22
State v. Dechainegreen
me · 1990 · cited in 2 Maine opinions naming this issue, 1995–2009
2 sentences

2009By contrast, "[bjecause ... [the] admissibility of evidence frequently involves the weighing of probative value against considerations militating against its admissibility ... the decision to admit evidence is more frequently reviewed under an abuse of discretion standard.” State v. Dechaine, 572 A.2d 130, 133 (Me.1990).

1995State v. Dechaine, 572 A.2d 130, 133 (Me.1990).

22
State v. Robinsongreen
me · 1993 · cited in 2 Maine opinions naming this issue, 1995–2001
2 sentences

2001State v. Robinson, 628 A.2d 664, 666 (1993). [¶ 9] The State argues that the evidence was properly excluded because Howe did not make an adequate offer of proof.

1995We review the decision of the trial court to admit or exclude such evidence under an abuse of discretion standard “because the question of admissibility frequently involves the weighing of probative value against considerations militating against its admissibility.” State v. Robinson, 628 A.2d 664, 666 (Me.1993); See M.R.Evid. 403.

22
State v. Nyegreen
me · 1986 · cited in 2 Maine opinions naming this issue, 1990–1993
2 sentences

1993See id. (citing M.R.Evid. 403; State v. Nye, 516 A.2d 560, 562 (Me.1986)).

1990State v. Nye, 516 A.2d 560, 562 (Me.1986); accord State v. Morton, 397 A.2d 171, 178-79 (Me.1979).

22
Morse Bros., Inc. v. Webstergreen
me · 2001 · cited in 3 Maine opinions naming this issue, 2004–2017
2 sentences

2017Pursuant to the practice established by Morse Brothers, 2001 ME 70, ¶ 18 , 772 A.2d 842 , when conflicting facts 6 In Morse Brothers, we stated that on appeal, we review the denial of a special motion to dismiss on anti-SLAPP grounds for an abuse of discretion or error of law. 2001 ME 70, ¶ 18 , 772 A.2d 842 .

2017Pursuant to the practice established by Morse Brothers, 2001 ME 70, ¶ 18 , 772 A.2d 842 , when conflicting facts 6 In Morse Brothers, we stated that on appeal, we review the denial of a special motion to dismiss on anti-SLAPP grounds for an abuse of discretion or error of law. 2001 ME 70, ¶ 18 , 772 A.2d 842 .

13
Hawksley v. Gerowgreen
me · 2011 · cited in 2 Maine opinions naming this issue, 2012–2015
2 sentences

2015We review an order on a post-divorce judgment motion, including a motion to enforce, “for an abuse of discretion or error of law,” and we .“review factual findings contained therein for clear error.” Lewin v. Skehan, 2012 ,ME 31, ¶ 24, 39 A.3d 58 ; see also Hawksley v. Gerow, 2011 ME 3 ,. ¶ 4, 10 A.3d 715 (2011).

2015We review an order on a post-divorce judgment motion, including a motion to enforce, “for an abuse of discretion or error of law,” and we .“review factual findings contained therein for clear error.” Lewin v. Skehan, 2012 ,ME 31, ¶ 24, 39 A.3d 58 ; see also Hawksley v. Gerow, 2011 ME 3 ,. ¶ 4, 10 A.3d 715 (2011).

12
State v. Crockergreen
me · 1981 · cited in 2 Maine opinions naming this issue, 2006–2008
2 sentences

2008See State v. Crocker, 435 A.2d 58, 71 (Me.1981); cf. State v. Lowry, 2003 ME 38, ¶ 7 , 819 A.2d 331, 333 (applying the abuse of discretion standard to challenges to the court’s conduct during voir dire, which includes the use of peremptory challenges).

2006We assume that Allen’s motion in limine served to preserve the objection, and we apply the abuse of discretion standard of review, which is more beneficial to Allen than the obvious error standard. 3 Even with the more beneficial *459 standard of review, Allen cannot prevail in this appeal because the trial court acted well within its discretion by ruling on the motion in limine to admit the photograph. [¶ 10] In State v. Crocker, 435 A.2d 58 (Me.1981), we articulated the three determinations that a court should make when it rules on the admissibility of photographs.

12
Commonwealth, Department of Corrections v. Reesegreen
pasuperct · 2001 · cited in 1 Maine opinions naming this issue, 2021–2021
1 sentence

2021Va. 2006) (“We review the final order and the ultimate disposition under an abuse of discretion standard; the underlying factual findings under a clearly erroneous standard; and questions of law are subject to a de novo review.”); Commonwealth v. Reese, 774 A.2d 1255, 1261 (Pa. Super.

11
Villa v. Smithgreen
me · 1987 · cited in 1 Maine opinions naming this issue, 2021–2021
1 sentence

2021See Smith v. 26 Rideout, 2010 ME 69, ¶¶ 15-18 , 1 A.3d 441 ; Villa v. Smith, 534 A.2d 1310, 1312 (Me. 1987) (explaining that the trial court has broad discretion to determine whether a change in circumstances has affected the children’s best interests to a degree significant enough to justify a change of primary custody).

11
Smith v. Rideoutgreen
me · 2010 · cited in 1 Maine opinions naming this issue, 2021–2021
2 sentences

2021See Smith v. 26 Rideout, 2010 ME 69, ¶¶ 15-18 , 1 A.3d 441 ; Villa v. Smith, 534 A.2d 1310, 1312 (Me. 1987) (explaining that the trial court has broad discretion to determine whether a change in circumstances has affected the children’s best interests to a degree significant enough to justify a change of primary custody).

2021See Smith v. 26 Rideout, 2010 ME 69, ¶¶ 15-18 , 1 A.3d 441 ; Villa v. Smith, 534 A.2d 1310, 1312 (Me. 1987) (explaining that the trial court has broad discretion to determine whether a change in circumstances has affected the children’s best interests to a degree significant enough to justify a change of primary custody).

11
Finn v. Lipmangreen
me · 1987 · cited in 1 Maine opinions naming this issue, 2021–2021
1 sentence

2021“A court has the discretion to judicially notice a fact that is not subject to reasonable dispute when it is either generally known within the territorial jurisdiction of the trial court or capable of accurate and ready determination by resort to sources whose accuracy cannot reasonably be questioned.” Finn v. Lipman, 526 A.2d 1380, 1381 (Me. 1987) (quotation marks omitted); see 11Here, we apply the abuse of discretion standard, not the clear error standard, because the judicially noticed fact—a judgment issued by the same trial court that took judicial notice of the judgment—is not subject to

11
Otis v. Town of Sebagogreen
me · 1994 · cited in 1 Maine opinions naming this issue, 2021–2021
1 sentence

2021See id. ¶ 9; Otis v. Town of Sebago, 645 A.2d 3, 4-5 (Me. 1994).

11
State v. Soucygreen
me · 2006 · cited in 1 Maine opinions naming this issue, 2020–2020
2 sentences

2020Cf. Soucy, 2006 ME 8, ¶¶ 1, 10, 19 , 890 A.2d 719 (finding no abuse of discretion where maximum sentence at step two was eight years on Class B unlawful sexual contact counts); see also Gall v. United States, 552 U.S. 38, 51-53 (2007) (discussing the “practical considerations” underpinning use of the abuse of discretion standard for review of sentences by appellate courts). [¶32] At the third step of the analysis, after considering the purposes and goals of sentencing, 17-A M.R.S. § 1151 (2018), and observing that “[t]he age of the victim is . . . absolutely paramount in this case,” the court

2020Cf. Soucy, 2006 ME 8, ¶¶ 1, 10, 19 , 890 A.2d 719 (finding no abuse of discretion where maximum sentence at step two was eight years on Class B unlawful sexual contact counts); see also Gall v. United States, 552 U.S. 38, 51-53 (2007) (discussing the “practical considerations” underpinning use of the abuse of discretion standard for review of sentences by appellate courts). [¶32] At the third step of the analysis, after considering the purposes and goals of sentencing, 17-A M.R.S. § 1151 (2018), and observing that “[t]he age of the victim is . . . absolutely paramount in this case,” the court

11
Gall v. United Statesgreen
scotus · 2007 · cited in 1 Maine opinions naming this issue, 2020–2020
1 sentence

2020Cf. Soucy, 2006 ME 8, ¶¶ 1, 10, 19 , 890 A.2d 719 (finding no abuse of discretion where maximum sentence at step two was eight years on Class B unlawful sexual contact counts); see also Gall v. United States, 552 U.S. 38, 51-53 (2007) (discussing the “practical considerations” underpinning use of the abuse of discretion standard for review of sentences by appellate courts). [¶32] At the third step of the analysis, after considering the purposes and goals of sentencing, 17-A M.R.S. § 1151 (2018), and observing that “[t]he age of the victim is . . . absolutely paramount in this case,” the court

11
Anne M. McBride v. Jeffrey R. Worthgreen
me · 2018 · cited in 1 Maine opinions naming this issue, 2020–2020
1 sentence

2020See McBride v. Worth, 2018 ME 54, ¶ 10 , 184 A.3d 14 .

11
McBride v. Worthgreen
me · 2018 · cited in 1 Maine opinions naming this issue, 2020–2020
1 sentence

2020See McBride v. Worth, 2018 ME 54, ¶ 10 , 184 A.3d 14 .

11
Boothbay Harbor Condominium I v. Whittengreen
me · 1978 · cited in 1 Maine opinions naming this issue, 2020–2020
1 sentence

2020I v. Whitten, 387 A.2d 1117, 1120-21 (Me. 1978).

11
People ex rel. T.I.green
sd · 2005 · cited in 1 Maine opinions naming this issue, 2019–2019
11
Tyrus H. Thompson and Ja'Ree C. Thompson v. Fairfax County Department of Family Servicesgreen
vactapp · 2013 · cited in 1 Maine opinions naming this issue, 2019–2019
1 sentence

2019J.L.P. , 870 P.2d at 1258 ; In re S.B.C. , 377 Mont. 400 , 340 P.3d 534 , 539 (2014) ; In re Interest of D.M. , 685 N.W.2d 768 , 771 (S.D. 2004) ; Thompson , 747 S.E.2d at 844 (stating that the abuse of discretion standard "requires a reviewing court to show enough deference to a primary decisionmaker's judgment that the court does not reverse merely because it would have come to a different result in the first instance" (quotation marks omitted) ).

11
MacDonald v. MacDonaldgreen
me · 1990 · cited in 1 Maine opinions naming this issue, 2015–2015
11
Ma v. Bryangreen
me · 2010 · cited in 1 Maine opinions naming this issue, 2011–2011
11
Daubert v. Merrell Dow Pharmaceuticals, Inc.green
scotus · 1993 · cited in 1 Maine opinions naming this issue, 2009–2009
11
State v. Lowrygreen
me · 2003 · cited in 1 Maine opinions naming this issue, 2008–2008
11
State v. McLeangreen
me · 2002 · cited in 1 Maine opinions naming this issue, 2008–2008
11
State v. Cooksongreen
me · 2003 · cited in 1 Maine opinions naming this issue, 2006–2006
11
Landry v. Stategreen
me · 1990 · cited in 1 Maine opinions naming this issue, 2006–2006
11
Qualey v. Secretary of Stategreen
me · 1993 · cited in 1 Maine opinions naming this issue, 2006–2006
11
Department of Human Services v. Levesquegreen
me · 1996 · cited in 1 Maine opinions naming this issue, 2006–2006
11
John W. Goodwin, Inc. v. Foxgreen
me · 1994 · cited in 1 Maine opinions naming this issue, 2003–2003
11
Bangor Motor Co. v. Chapmangreen
me · 1982 · cited in 1 Maine opinions naming this issue, 2003–2003
11
Jacobsen v. Mintzgreen
me · 1988 · cited in 1 Maine opinions naming this issue, 2003–2003
11
Barclay v. Eckertgreen
me · 2000 · cited in 1 Maine opinions naming this issue, 2001–2001
11
State v. Jonesgreen
me · 1979 · cited in 1 Maine opinions naming this issue, 1994–1994
11
Higgins v. Higginsgreen
me · 1977 · cited in 1 Maine opinions naming this issue, 1993–1993
11
Morris v. Resolution Trust Corp.green
me · 1993 · cited in 1 Maine opinions naming this issue, 1993–1993
11
Town of Freeport v. Brickyard Cove Associatesgreen
me · 1991 · cited in 1 Maine opinions naming this issue, 1993–1993
11
Wexler v. Citicorp Mortgage, Inc.green
scotus · 1990 · cited in 1 Maine opinions naming this issue, 1993–1993
11
Bryant v. Bryantgreen
me · 1980 · cited in 1 Maine opinions naming this issue, 1992–1992
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (32)

CaseCitedYears
Patricia Mae Voter v. Dexter R. Voter green
me · 2015
2 sentences

2017If we conclude that the judgment is ambiguous, we then “consider, using an abuse of discretion standard, whether the clarification is consistent with its language read as a whole and is objectively supported by the record.” Id. (quotation marks omitted). [¶ 15] The divorce judgment, as construed by the clarifying judgment, was ambiguous because it contained an internal inconsistency.

2017If we conclude that the judgment is ambiguous, we then “consider, using an abuse of discretion standard, whether the clarification is consistent with its language read as a whole and is objectively supported by the record.” Id. (quotation marks omitted). [¶ 15] The divorce judgment, as construed by the clarifying judgment, was ambiguous because it contained an internal inconsistency.

42017–2017
Lewin v. Skehan green
me · 2012
2 sentences

2021“We review an order on a post-divorce motion for an abuse of discretion or error of law and review factual findings contained therein for clear error.” Lewin v. Skehan, 2012 ME 31, ¶ 24 , 39 A.3d 58 . “[O]nly a substantial change in circumstances since the entry of the most recent decree can justify the modification of the decree, and . . . the overriding consideration whenever a proposed modification is sought is the best interest[s] of the minor children.” Levy, Maine Family Law § 6.6[1] at 6-61 (8th ed. 2013) (quotation marks omitted). [¶35] We do not agree with Martin that the court acted

2021“We review an order on a post-divorce motion for an abuse of discretion or error of law and review factual findings contained therein for clear error.” Lewin v. Skehan, 2012 ME 31, ¶ 24 , 39 A.3d 58 . “[O]nly a substantial change in circumstances since the entry of the most recent decree can justify the modification of the decree, and . . . the overriding consideration whenever a proposed modification is sought is the best interest[s] of the minor children.” Levy, Maine Family Law § 6.6[1] at 6-61 (8th ed. 2013) (quotation marks omitted). [¶35] We do not agree with Martin that the court acted

22015–2021
Marc B. Terfloth v. Town of Scarborough green
me · 2014
2 sentences

2019“That the record contains evidence inconsistent with the result, or that inconsistent conclusions could be drawn from the evidence, does not render the Board’s findings invalid if a reasonable mind might accept the relevant evidence as adequate to support the Board’s conclusion.” Terfloth v. Town of Scarborough, 2014 ME 57, ¶ 10 , 90 A.3d 1131 (alterations omitted). [¶14] Although the Superior Court and the Board gave significant weight to the requirement of 36 M.R.S. § 843(1) that any abatement provided by the Board be “reasonable,” our case law suggests that an abatement is reasonable if it

2019“That the record contains evidence inconsistent with the result, or that inconsistent conclusions could be drawn from the evidence, does not render the Board’s findings invalid if a reasonable mind might accept the relevant evidence as adequate to support the Board’s conclusion.” Terfloth v. Town of Scarborough, 2014 ME 57, ¶ 10 , 90 A.3d 1131 (alterations omitted). [¶14] Although the Superior Court and the Board gave significant weight to the requirement of 36 M.R.S. § 843(1) that any abatement provided by the Board be “reasonable,” our case law suggests that an abatement is reasonable if it

22019–2019
David Sullivan v. Zoe (Sullivan) Rockwood green
me · 2015
2 sentences

2018A party to a divorce judgment who files a motion to enforce is entitled to an order of enforcement when the other party has failed to comply with an unambiguous provision of the judgment." Sullivan v. Rockwood , 2015 ME 119 , ¶ 19, 124 A.3d 150 (citations omitted) (quotation marks omitted).

2018A party to a divorce judgment who files a motion to enforce is entitled to an order of enforcement when the other party has failed to comply with an unambiguous provision of the judgment." Sullivan v. Rockwood , 2015 ME 119 , ¶ 19, 124 A.3d 150 (citations omitted) (quotation marks omitted).

22018–2018
Wendell K. Brasier v. Vanessa L. Preble green
me · 2013
2 sentences

2016DISCUSSION [¶ 12] “We review the findings of fact in an order on a post-divorce' motion for clear error, and the court’s ultimate decision for an abuse of discretion or error of law.” Brasier v. Preble, 2013 ME 109, ¶ 12 , 82 A.3d 841 (quotation marks' omitted).

2016DISCUSSION [¶ 12] “We review the findings of fact in an order on a post-divorce' motion for clear error, and the court’s ultimate decision for an abuse of discretion or error of law.” Brasier v. Preble, 2013 ME 109, ¶ 12 , 82 A.3d 841 (quotation marks' omitted).

22016–2016
State v. Reese green
me · 2010
2 sentences

2024State v. Reese, 2010 ME 30, ¶ 23 , 991 A.2d 806 .

2024State v. Reese, 2010 ME 30, ¶ 23 , 991 A.2d 806 .

12024–2024
In re Children of Anthony L. green
me · 2019
1 sentence

2021Indeed, Wells Fargo does not contest the accuracy of the 2013 judgment. 11 also In re Children of Anthony L., 2019 ME 62 , ¶ 9 n.4, 207 A.3d 624 (“A judge may take judicial notice of any matter of record when that matter is relevant to the proceedings at hand.” (quotation marks omitted)).

12021–2021
In re Children of Anthony L. green
me · 2019
1 sentence

2021Indeed, Wells Fargo does not contest the accuracy of the 2013 judgment. 11 also In re Children of Anthony L., 2019 ME 62 , ¶ 9 n.4, 207 A.3d 624 (“A judge may take judicial notice of any matter of record when that matter is relevant to the proceedings at hand.” (quotation marks omitted)).

12021–2021
Pamela Haskell v. Dusty Haskell green
me · 2017
1 sentence

2021We have explained that “[r]eview for an abuse of discretion involves resolution of three questions: (1) are factual findings, if any, supported by the record according to the clear error standard; (2) did the court understand the law applicable to its exercise of discretion; and (3) given all the facts and applying the appropriate law, was the court’s weighing of the applicable facts and choices within the bounds of reasonableness.” Haskell v. Haskell, 2017 ME 91, ¶ 12 , 160 A.3d 1176 (quotation marks omitted).

12021–2021
Haskell v. Haskell green
me · 2017
1 sentence

2021We have explained that “[r]eview for an abuse of discretion involves resolution of three questions: (1) are factual findings, if any, supported by the record according to the clear error standard; (2) did the court understand the law applicable to its exercise of discretion; and (3) given all the facts and applying the appropriate law, was the court’s weighing of the applicable facts and choices within the bounds of reasonableness.” Haskell v. Haskell, 2017 ME 91, ¶ 12 , 160 A.3d 1176 (quotation marks omitted).

12021–2021
People in Interest of JLP green
coloctapp · 1994
12019–2019
In the Interest of D.M. green
sd · 2004
12019–2019
Matter of S.B.C. Jr. green
mont · 2014
12019–2019
Sager v. Town of Bowdoinham green
me · 2004
12018–2018
Thompson v. Rothman green
me · 2002
12015–2015
Diane L. Charette v. Dale N. Charette green
me · 2013
12015–2015
Desmond v. Desmond green
me · 2011
12013–2013
United States v. Tejada green
ca1 · 2007
12012–2012
United States v. Lawrence Orlando, Sr. (00-6312) and Tera M. Daniels (00-6409) green
ca6 · 2002
12012–2012
UNITED STATES v. ARSENIO RODRÍGUEZ-ORTIZ, UNITED STATES OF AMERICA v. LEONARDO SANTANA-RODRÍGUEZ, A/K/A VIEJO green
ca1 · 2006
12012–2012
State v. Bickart green
me · 2009
12009–2009
cluster 2070630 green
·
12008–2008
State v. Sweet green
me · 2000
12006–2006
Gagne v. Cianbro Corp. green
me · 1981
12006–2006
West Point-Pepperell, Inc. v. State Tax Assessor green
me · 1997
12003–2003
State v. Williams green
me · 1995
12003–2003
Gregory v. City of Calais green
me · 2001
12003–2003
Ferguson v. WAYLAND MANOR ASSOCIATES green
ri · 2001
12003–2003
Gray v. Gray green
me · 1992
11997–1997
State v. Ruest green
me · 1986
11995–1995
State v. Pickering green
me · 1985
11991–1991
Rios v. Enterprise Ass'n Steamfitters, Local No. 638 green
scotus · 1977
11983–1983

Statutes the citing opinions construe

ME § Me. Rev. Stat. tit. 14, § 1901 (9) ME § Me. Rev. Stat. tit. 17-A, § 253 (6) ME § Me. Rev. Stat. tit. 17-A, § 201 (5) ME § Me. Rev. Stat. tit. 14, § 4651 (4) ME § Me. Rev. Stat. tit. 19-A, § 951-A (4) ME § Me. Rev. Stat. tit. 17-A, § 1252 (3) ME § Me. Rev. Stat. tit. 17-A, § 1252-C (3) ME § Me. Rev. Stat. tit. 19-A, § 1653 (3) ME § Me. Rev. Stat. tit. 19-A, § 1657 (3) ME § Me. Rev. Stat. tit. 19-A, § 953 (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 15264 (1977–2026) OH 6694 (1971–2026) CA 3798 (1957–2026) TN 3512 (1978–2026) IL 2286 (1898–2026) PA 2069 (1965–2026) WV 1906 (1994–2026) FL 1373 (1980–2026) NJ 1267 (1978–2026) MS 1162 (1990–2026) ID 1147 (1978–2026) AZ 951 (1957–2026) WA 864 (1970–2026) IN 844 (1976–2026) LA 730 (1984–2026) SD 685 (1982–2026) CT 648 (1975–2026) ND 645 (1982–2026) KS 624 (1966–2026) NC 603 (1981–2026) VA 564 (1991–2026) NM 554 (1985–2026) MN 524 (1983–2026) UT 521 (1927–2026) KY 500 (1988–2026) MD 498 (1972–2026) AR 434 (1989–2026) HI 423 (1983–2026) MI 402 (1973–2026) GA 323 (1930–2026) SC 293 (1982–2026) MO 288 (1979–2025) MA 266 (1974–2026) WY 262 (1983–2026) IA 200 (1947–2026) AK 198 (1974–2026) AL 181 (1981–2026) CO 177 (1978–2026) DE 145 (1979–2026) RI 134 (1989–2026) MT 132 (1983–2026) OK 119 (1992–2025) NV 118 (1979–2026) DC 106 (1976–2026) VT 76 (1964–2026) ME 65 (1980–2024) NE 60 (1991–2026) NY 51 (1978–2026) OR 50 (1996–2026) NH 45 (1987–2024) WI 25 (1970–2003) VI 21 (2004–2025) MP 7 (1990–2025) GU 3 (2021–2026)

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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