Chimel doctrine in Washington

9 Washington opinions name it 2 courts 1970–2015 0 in the last five years

The cases below were cited by Washington 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 (2)

Case	Followed	Cited
New York v. Beltonred scotus · 1981 · cited in 5 Washington opinions naming this issue, 1986–2011 2 sentences 2011To read Belton as authorizing a vehicle search incident to every recent occupant's arrest would thus untether the rule from the justifications underlying the Chimel exceptiona result clearly incompatible with our statement in Belton that it "in no way alters the fundamental principles established in the Chimel case regarding the basic scope of searches incident to lawful custodial arrests." [ Belton, ] 453 U.S. [at 460 n. 3, 101 S.Ct. 2860 ]. 2011To read Belton as authorizing a vehicle search incident to every recent occupant’s arrest would thus untether the rule from the justifications underlying the Chimel exception — a result clearly incompatible with our statement in Belton that it “in no way alters the fundamental principles established in the Chimel case regarding the basic scope of searches incident to lawful custodial arrests.” [Belton,] 453 U. S., at 460, n. 3 .	2	5
Thornton v. United Statesgreen scotus · 2004 · cited in 2 Washington opinions naming this issue, 2010–2010 2 sentences 2010In another concurring opinion, Justice Scalia suggested limiting a Belton search to cases where it is reasonable to believe evidence relevant to the crime of arrest might be “found in the vehicle.” Thornton, 541 U.S. at 632 (Scalia, J., concurring in judgment). ¶20 In Gant , the Court rejected the long-accepted broad interpretation of the Belton rule because it “untether [ed] the rule from the justifications underlying the Chimel exception — a result clearly incompatible with our statement in Belton that it ‘in no way alters the fundamental principles established in the Chimel case regarding t 2010In another concurring opinion, Justice Scalia suggested limiting a Belton search to cases where it is reasonable to believe evidence relevant to the crime of arrest might be "found in the *1068 vehicle." Thornton, 541 U.S. at 632 , 124 S.Ct. 2127 , (Scalia, J., concurring in judgment). ¶ 20 In Gant , the Court rejected the long-accepted broad interpretation of the Belton rule because it "untether[ed] the rule from the justifications underlying the Chimel exceptiona result clearly incompatible with our statement in Belton that it `in no way alters the fundamental principles established in the	1	2

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (23)

Case	Cited	Years
Arizona v. Gant green scotus · 2009 2 sentences 2015There is ample justification, therefore, for a search of the arrestee's person and the area 'within his immediate control'—construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence."[28] The Court next summarized Robinson, which it said applied the Chimel analysis to a search of an arrestee's person and adopted the rule that a search of the person incident to a custodial arrest based upon probable cause requires no additional justification.29 It noted that the underlying basis for this search remained the need to disarm and to disco 2015There is ample justification, therefore, for a search of the arrestee's person and the area 'within his immediate control'—construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence."[28] The Court next summarized Robinson, which it said applied the Chimel analysis to a search of an arrestee's person and adopted the rule that a search of the person incident to a custodial arrest based upon probable cause requires no additional justification.29 It noted that the underlying basis for this search remained the need to disarm and to disco	3	2010–2015
Chimel v. California red scotus · 1969 2 sentences 2015There is ample justification, therefore, for a search of the arrestee's person and the area 'within his immediate control'—construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence."[28] The Court next summarized Robinson, which it said applied the Chimel analysis to a search of an arrestee's person and adopted the rule that a search of the person incident to a custodial arrest based upon probable cause requires no additional justification.29 It noted that the underlying basis for this search remained the need to disarm and to disco 2015There is ample justification, therefore, for a search of the arrestee's person and the area 'within his immediate control'—construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence."[28] The Court next summarized Robinson, which it said applied the Chimel analysis to a search of an arrestee's person and adopted the rule that a search of the person incident to a custodial arrest based upon probable cause requires no additional justification.29 It noted that the underlying basis for this search remained the need to disarm and to disco	1	2015–2015
Riley v. Cal. United States green · 2014 2 sentences 2015There is ample justification, therefore, for a search of the arrestee's person and the area 'within his immediate control'—construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence."[28] The Court next summarized Robinson, which it said applied the Chimel analysis to a search of an arrestee's person and adopted the rule that a search of the person incident to a custodial arrest based upon probable cause requires no additional justification.29 It noted that the underlying basis for this search remained the need to disarm and to disco 2015There is ample justification, therefore, for a search of the arrestee's person and the area 'within his immediate control'—construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence."[28] The Court next summarized Robinson, which it said applied the Chimel analysis to a search of an arrestee's person and adopted the rule that a search of the person incident to a custodial arrest based upon probable cause requires no additional justification.29 It noted that the underlying basis for this search remained the need to disarm and to disco	1	2015–2015
State v. Patton green wash · 2009 2 sentences 2011Id. at 395 , 219 P.3d 651 (emphasis added). ¶ 41 In sum, just as the Court in Belton had labored under a sweeping, and ultimately erroneous, empirical assumption in applying the Chimel standard to a particular set of factual circumstances, the lead opinion in Stroud (and the cases that followed) relied on the flawed empirical assumption that a search of the passenger compartment that excluded locked containers would fall within 94 the permissible scope set forth in Ringer . 2011Id. at 395 , 219 P.3d 651 (emphasis added). ¶ 41 In sum, just as the Court in Belton had labored under a sweeping, and ultimately erroneous, empirical assumption in applying the Chimel standard to a particular set of factual circumstances, the lead opinion in Stroud (and the cases that followed) relied on the flawed empirical assumption that a search of the passenger compartment that excluded locked containers would fall within 94 the permissible scope set forth in Ringer .	1	2011–2011
State v. Jones green washctapp · 1970 2 sentences 1986App. 405, 408 , 487 P.2d 627 , review denied, 79 Wn.2d 1012 (1971); State v. Jones, 2 Wn. 1986App. 405, 408 , 487 P.2d 627 , review denied, 79 Wn.2d 1012 (1971); State v. Jones, 2 Wn.	1	1986–1986
State v. Palmer green washctapp · 1971 2 sentences 1986App. 120, 124 , 627 P.2d 978 (1981) (decided before New York v. Belton, 453 U.S. 454 , 69 L.Ed.2d 768 , 101 S.Ct. 2860 (1981) (allowing search incident to arrest of entire passenger compartment of automobile and any container therein as compatible with Chimel rule)); State v. Palmer, 5 Wn. 1986Ed. 2d 768 , 101 S. Ct. 2860 (1981) (allowing search incident to arrest of entire passenger compartment of automobile and any container therein as compatible with Chimel rule)); State v. Palmer, 5 Wn.	1	1986–1986
State v. Keyser neutral washctapp · 1981 1 sentence 1986App. 120, 124 , 627 P.2d 978 (1981) (decided before New York v. Belton, 453 U.S. 454 , 69 L.Ed.2d 768 , 101 S.Ct. 2860 (1981) (allowing search incident to arrest of entire passenger compartment of automobile and any container therein as compatible with Chimel rule)); State v. Palmer, 5 Wn.	1	1986–1986
United States v. Rogelio Pino green ca2 · 1970 1 sentence 1973The state urges that United States v. Rubin, 474 F.2d 262 (3d Cir. 1973) and United States v. Pino, 431 F.2d 1043 (2d Cir. 1970), support the search made in this case.	1	1973–1973
United States v. Paul Gary Rubin United States of America v. Louis Martin Agnes A/K/A Louis Martin green ca3 · 1973 1 sentence 1973The state urges that United States v. Rubin, 474 F.2d 262 (3d Cir. 1973) and United States v. Pino, 431 F.2d 1043 (2d Cir. 1970), support the search made in this case.	1	1973–1973
Coolidge v. New Hampshire green scotus · 1971 2 sentences 1971Utter and Williams, JJ., concur. 1 The findings of the court at the CR 101.20W hearing well summarize the facts of the case as the jury might have found them in a trial on the merits. 2 The Chimel doctrine was reaffirmed in Coolidge v. New Hampshire, 403 U.S. 443 , 29 L. 1971Utter and Williams, JJ., concur. 1 The findings of the court at the CR 101.20W hearing well summarize the facts of the case as the jury might have found them in a trial on the merits. 2 The Chimel doctrine was reaffirmed in Coolidge v. New Hampshire, 403 U.S. 443 , 29 L.	1	1971–1971
State v. Bustamante green arizctapp · 1969 2 sentences 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr. 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr.	1	1970–1970
Derouen v. Sheriff, Washoe County green nev · 1969 2 sentences 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr. 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr.	1	1970–1970
Thornton v. State green texcrimapp · 1970 2 sentences 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr. 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr.	1	1970–1970
People v. Edwards green cal · 1969 2 sentences 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr. 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr.	1	1970–1970
United States v. Charles T. Bennett, Wilbert Haywood, Elmer Jessup, Henry Stanton and Farris Thomas green ca2 · 1969 2 sentences 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480	1	1970–1970
Winfield H. Lyon, Jr. v. United States green ca5 · 1970 2 sentences 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480	1	1970–1970
Clarence Williams and Arlene Jackson v. United States green ca9 · 1969 2 sentences 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480	1	1970–1970
Porter v. Ashmore green ca4 · 1970 2 sentences 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480	1	1970–1970
United States v. Richard Edward Blassick green ca7 · 1970 2 sentences 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480	1	1970–1970
United States v. August Edward Schartner, Jr. green ca3 · 1970 2 sentences 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480	1	1970–1970
Gene Robert Turner v. United States green ca6 · 1970 2 sentences 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480	1	1970–1970
State v. Reyes green nm · 1970 2 sentences 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr. 1970App. 505 , 256 A.2d 384 (1969); State v. Bustamante, 11 Ariz. App. 129 , 462 P.2d 822 (1969); DeRouen v. Sheriff, Washoe County, 85 Nev. 637 , 461 P.2d 865 (1969); People v. Edwards, 80 Cal. Rptr. 633 , 458 P.2d 713 (1969); State v. Reyes, ___ N.M. ___, 467 P.2d 730 (1970); Thornton v. State, 451 S.W. 2d 898 (Tex. Cr.	1	1970–1970
Scott v. State green mdctspecapp · 1969 2 sentences 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480 1970The overwhelming majority of those courts has rejected retroactive application of the Chimel doctrine. 3 The following decisions are those in which the named court has considered and rejected retroactive application of Chimel , holding that its standards apply only to searches conducted after June 23, 1969: United States v. Bennett, 415 F.2d 1113 (2d Cir. 1969) cert. denied; United States v. Shartner, 426 F.2d 470 (3d Cir. 1970) filed 3/9/70; Porter v. Ashmore, 421 F.2d 1186 (4th Cir. 1970); Lyon v. United States, 416 F.2d 91 (5th Cir. 1969) cert. denied; Turner v. United States, 426 F.2d 480	1	1970–1970

Where else courts name it

CA 20 (1969–2018) IL 14 (1972–2014) WA 9 (1970–2015) NJ 9 (1976–2006) WI 8 (1986–2020) ID 8 (1988–2014) TX 6 (1990–2010) AZ 5 (1969–2007) KS 4 (1984–2014) IN 4 (1973–2018) NY 3 (1975–2009) ME 3 (1975–2018) FL 3 (1971–1999) MD 3 (1974–2016) OH 3 (1995–2017) ND 3 (1979–2016) IA 3 (2015–2024) DC 3 (1993–2016) SD 2 (2018–2018) MN 2 (1970–2015) MO 2 (1975–2016) CO 2 (1995–1995) CT 2 (1970–1971) KY 2 (2010–2023) NM 2 (1970–1997) LA 2 (2012–2021)

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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