64 New York opinions name it 9 courts 1973–2025 3 in the last five years
The cases below were cited by New York 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.
| Case | Followed | Cited |
|---|---|---|
People v. Gilmangreen2 sentences2014Thus, there was no evidence before the suppression court that defendant took an “aggressive fighter stance” (see People v Hall, 208 AD2d 1044, 1046 [1994]; People v Blanchard, 177 AD2d 854, 856 [1991], lv denied 79 NY2d 918 [1992]; People v Gilman, 135 AD2d 951, 952-953 [1987], lv denied 71 NY2d 896 [1988]). 2014Thus, there was no evidence before the suppression court that defendant took an “aggressive fighter stance” (see People v Hall, 208 AD2d 1044, 1046 [1994]; People v Blanchard, 177 AD2d 854, 856 [1991], lv denied 79 NY2d 918 [1992]; People v Gilman, 135 AD2d 951, 952-953 [1987], lv denied 71 NY2d 896 [1988]). | 2 | 3 |
People v. Blanchardgreen2 sentences2014Thus, there was no evidence before the suppression court that defendant took an “aggressive fighter stance” (see People v Hall, 208 AD2d 1044, 1046 [1994]; People v Blanchard, 177 AD2d 854, 856 [1991], lv denied 79 NY2d 918 [1992]; People v Gilman, 135 AD2d 951, 952-953 [1987], lv denied 71 NY2d 896 [1988]). 2014Thus, there was no evidence before the suppression court that defendant took an “aggressive fighter stance” (see People v Hall, 208 AD2d 1044, 1046 [1994]; People v Blanchard, 177 AD2d 854, 856 [1991], lv denied 79 NY2d 918 [1992]; People v Gilman, 135 AD2d 951, 952-953 [1987], lv denied 71 NY2d 896 [1988]). | 2 | 3 |
People v. Hallgreen2 sentences2014Thus, there was no evidence before the suppression court that defendant took an “aggressive fighter stance” (see People v Hall, 208 AD2d 1044, 1046 [1994]; People v Blanchard, 177 AD2d 854, 856 [1991], lv denied 79 NY2d 918 [1992]; People v Gilman, 135 AD2d 951, 952-953 [1987], lv denied 71 NY2d 896 [1988]). 2014Thus, there was no evidence before the suppression court that defendant took an “aggressive fighter stance” (see People v Hall, 208 AD2d 1044, 1046 [1994]; People v Blanchard, 177 AD2d 854, 856 [1991], lv denied 79 NY2d 918 [1992]; People v Gilman, 135 AD2d 951, 952-953 [1987], lv denied 71 NY2d 896 [1988]). | 2 | 3 |
People ex rel. Hirschberg v. Closegreen2 sentences2008Hirschberg v Close, 1 NY2d 258, 261 [1956]; Matter of Angell v Ferris, 227 AD2d 475, 476 [1996] , lv denied 88 NY2d 816 [1996]; Preiser, Practice Commentaries, McKinney’s Cons Laws of NY, Book 11A, CPL 180.10, at 162). 1988Hirschberg v Close, 1 NY2d 258, 261 ). | 2 | 3 |
Vega v. Bellgreen2 sentences1988What would otherwise be a valid indictment is not tainted by any error which might have occurred at a prior felony hearing, since, " 'the Grand Jury [has] power to investigate and indict regardless of what [has] occurred before the magistrate and regardless of whether the magistrate [has] held or discharged the prisoner or still [has] the matter pending, or of whether there had ever been such a preliminary hearing’ ” (Matter of Vega v Bell, supra, at 549-550, quoting from People ex rel. 1979In view of the apparent attitude of the Court of Appeals to equate the preliminary felony hearing with a removal hearing under the new juvenile offender statutes (see Matter of Vega v Bell, 47 NY2d 543, 549 , supra), it is here appropriate to comment on a recent unpublished decision by our colleague, the Honorable Gerald S. Held, in People v Rios (Supreme Ct, Kings County, July 26, 1979, Indictment No. 1495/79) in which an indictment was dismissed as defective because the prosecutor failed to charge the Grand Jury as requested that it could remove the case of a juvenile offender to the Family | 1 | 4 |
People v. Arroyogreen2 sentences1993(People v Arroyo, 54 NY2d 567, 575 .) A felony hearing is a critical stage of a criminal prosecution at which the accused has a constitutional right to the assistance of counsel, and to cross-examine the witness against him. 1990Although the defendant had been charged only with attempted murder at the time of the felony hearing, the hearing delved into substantially the same subject matter as did the subsequent murder trial (see, People v Arroyo, 54 NY2d 567, 575 , cert denied 456 US 979 ) and a review of the record reveals that the defendant was afforded ample opportunity to cross-examine Brogdon at the hearing (see, People v Arroyo, supra, at 574-575; People v Ayala, 142 AD2d 147 , affd 75 NY2d 422 ; People v Claudio, 130 AD2d 759 ). | 1 | 3 |
United States v. Wadegreen2 sentences1984At a Wade hearing and at a preliminary felony hearing, however, the defendant will be represented by counsel (United States v Wade, 388 US 218 , supra; Moore v Illinois, 434 US 220 ), and thus there will be an unavoidable awareness that an identification has taken place within these contexts. 1980The fact that such an identification was conducted before a court in the felony hearing or before the Grand Jury by the use of a single photograph or improper display does not magically alleviate the evidentiary problem of potential misidentification which has been the core concern of all cases post-Wade ( 388 US 218 , supra), i.e., the "high incidence of miscarriage of justice”, resulting from the admission of mistaken identification evidence at court trials (United States v Wade, supra, at p 228; accord People v Thomas, 60 AD2d 993 ; cf. People v Rivera, 74 AD2d 857 , supra; People v Leite, | 1 | 3 |
People v. D'Amicogreen2 sentences2010In that case, a *569 defendant generally may not agree to be prosecuted on an SCI that contains a lesser included offense since such a substitution would be nothing more than an “end run” around the statutory prohibition against the use of a waiver of indictment by a defendant held for grand jury action on a complaint charging such a class A felony (see People v Trueluck, 88 NY2d 546 [1996]; cf. People v D’Amico, 76 NY2d 877 [1990]). “[T]he basic objective of article 195 was to permit waiver of indictment for defendants who wished to go directly to trial without waiting for a grand jury to han 1997The defendant signed a written waiver of indictment whereby he consented to be prosecuted by a superior court information and pleaded guilty to the sole charge contained therein (see, CPL 180.30, 195.20; see also, People v D’Amico, 76 NY2d 877 ; People v Hart, 171 AD2d 755 ; People v Washington, 138 AD2d 857 ). | 1 | 2 |
People v. Cruzgreen2 sentences1984Since the prosecution is required to give notice of intent to use identification testimony by a witness who testified at a felony hearing (CPL 710.30, subd 3; see People v Cruz, 88 AD2d 621 ), it is only logical to give the defendant an opportunity to suppress tainted testimony by offering proof at an evidentiary hearing of undue suggestiveness (CPL 710.20, subd 5). 1984Although this court has previously reached conflicting conclusions on this issue (see People v Jones, 99 AD2d 471 ; but see People v James, 100 AD2d 552 ; People v Cruz, 88 AD2d 621 ), I believe that the legislative history of CPL 710.30 and the salutary purpose to be served by the provision are consistent with a conclusion that no notice is required. | 1 | 2 |
People v. Eppsgreen2 sentences1984Since the statute codifying this right was enacted for the benefit of the defendant, it may be waived by him (People v Chambliss, 106 Misc 2d 342 ; see People v Epps, 37 NY2d 343 , cert den 423 US 999 ). 1980(People v Epps, 37 NY2d 343, 350 ; Johnson v Zerhst, 304 US 458, 464 .) The People, however, argue that the situation is different for the “rights” of a criminal defendant at a felony hearing. | 1 | 2 |
Manson v. Brathwaitegreen2 sentences1980"The standard, after all, is that of fairness as required by the Due Process Clause of the Fourteenth Amendment * * * Stovall * * * and Biggers * * * did not * * * establish a strict exclusionary rule or new standard of due process. [What they did do was to protect] an evidentiary interest * * * in our adversary system.” (Manson v Brathwaite, supra, at p 113 ; NY Const, art 1, § 6; emphasis added.) It is conceded that at a felony hearing the People have the burden of proof with respect to two issues: establishing reasonable cause to believe a felony was committed and that defendant was the one 1980Legally, it should also be noted that the touch of State action in both the felony hearing procedure itself, mandated by statute and conducted by its officers, as well as the official function of the prosecutor in the Grand Jury is sufficient, in the court’s opinion, to invoke sanctions wherein due process standards are violated by actions which may carry with it the potential for abuse of the evidentiary identification concern of Manson v Brathwaite (supra). | 1 | 2 |
| People v. Wilkinsongreen | 1 | 1 |
People v. Nelsongreen1 sentence2025Contrary to defendant's contention, County Court properly admitted in evidence the victim's testimony from the felony hearing because, although she testified at trial, she failed to testify truthfully or consistently with her prior testimony due to defendant's misconduct and was thereby rendered "effectively unavailable" ( People v Wilkinson , 185 AD3d 734, 735-736 [2d Dept 2020], lv denied 36 NY3d 1101 [2021]; see People v Nelson , 156 AD3d 1112, 1117 [3d Dept 2017], lv denied 31 NY3d 1151 [2018]; see generally People v Geraci , 85 NY2d 359, 363-364, 370 [1995]). | 1 | 1 |
People v. Geracigreen1 sentence2025Contrary to defendant's contention, County Court properly admitted in evidence the victim's testimony from the felony hearing because, although she testified at trial, she failed to testify truthfully or consistently with her prior testimony due to defendant's misconduct and was thereby rendered "effectively unavailable" ( People v Wilkinson , 185 AD3d 734, 735-736 [2d Dept 2020], lv denied 36 NY3d 1101 [2021]; see People v Nelson , 156 AD3d 1112, 1117 [3d Dept 2017], lv denied 31 NY3d 1151 [2018]; see generally People v Geraci , 85 NY2d 359, 363-364, 370 [1995]). | 1 | 1 |
| People v. Smartgreen | 1 | 1 |
| People v. Turgeongreen | 1 | 1 |
| People v. Gausegreen | 1 | 1 |
| People v. Phillipsgreen | 1 | 1 |
| People v. Browngreen | 1 | 1 |
| People v. Closuregreen | 1 | 1 |
| Angell ex rel Brown v. Ferrisgreen | 1 | 1 |
| People v. Belizairegreen | 1 | 1 |
| People v. Garciagreen | 1 | 1 |
| People v. Alejandrogreen | 1 | 1 |
| People v. Salazargreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
People v. Jamesgreen2 sentences1988It is clear that a defendant may waive his presence at a felony hearing or move for suppression of an identification which occurred at a felony hearing (see, People v Cummings, 109 AD2d 748 ; People v James, 100 AD2d 552 ). 1988However, inasmuch as no issue existed as to identification since the complainant knew the defendant and, indeed, identified him to the police by name (see, People v Tas, 51 NY2d 915 ; People v Gissendanner, 48 NY2d 543 ) and the complainant did not testify at the trial regarding her identification of the defendant at the felony hearing, any error in the hearing court’s denial of the defendant’s requests to absent himself from the felony hearing and in the denial of that branch of the defendant’s omnibus motion which was for suppression of the identification made at the felony hearing was harml | 1 | 5 |
| Case | Cited | Years |
|---|---|---|
People v. Lyde
green
2 sentences1988In view of the independent sources for all of the in-court identifications and the fact that no testimony was adduced at the trial concerning the in-person identification at the felony hearing, the denial of the defendant’s request to waive his presence at the felony hearing was, at worst, harmless error (see, People v Lyde, 104 AD2d 957 ; cf., People v Cummings, 109 AD2d 748, 749 ). 1987In addition, although not reversible error in itself, we note that the defendant’s request to waive his presence at the felony hearing held in the City Court of Mount Vernon, where he was identified by one of the eyewitnesses and the arresting police officer, should have been granted (see, People v Lyde, 104 AD2d 957 ; People v James, 100 AD2d 552 ). | 4 | 1985–1988 |
Anders v. California
green
2 sentences2019Assigned counsel has submitted a brief in accordance with Anders v California ( 386 US 738 ), in which he moves for leave to withdraw as counsel for the appellant. 2018Assigned counsel has submitted a brief in accordance with Anders v California ( 386 US 738 ), in which he moves for leave to withdraw as counsel for the appellant. | 3 | 2017–2019 |
People v. Hodge
green
2 sentences1990A felony hearing is "a virtual minitrial of the [People’s] prima facie case” on the merits (People v Hodge, 53 NY2d 313, 318 ). 1988The police and prosecutors are not required to disclose all of their evidence in an application for an arrest warrant or at a felony hearing (see, e.g., CPL 120.20, 180.70; People v Hodge, 53 NY2d 313, 318-319 ) and are not generally required to disclose all discrepancies or potential weaknesses in the case uncovered during the investigation. | 3 | 1988–1993 |
People v. Cummings
green
2 sentences1988In view of the independent sources for all of the in-court identifications and the fact that no testimony was adduced at the trial concerning the in-person identification at the felony hearing, the denial of the defendant’s request to waive his presence at the felony hearing was, at worst, harmless error (see, People v Lyde, 104 AD2d 957 ; cf., People v Cummings, 109 AD2d 748, 749 ). 1988It is clear that a defendant may waive his presence at a felony hearing or move for suppression of an identification which occurred at a felony hearing (see, People v Cummings, 109 AD2d 748 ; People v James, 100 AD2d 552 ). | 3 | 1987–1988 |
People v. Lowe
green
2 sentences2025"The procedures established by article 730 are not discretionary and, once a court makes a preliminary determination that a defendant may be incapacitated, the statutory steps must be followed." People v Lowe , 109 AD2d 300 . 2025"The procedures established by article 730 are not discretionary and, once a court makes a preliminary determination that a defendant may be incapacitated, the statutory steps must be followed." People v Lowe , 109 AD2d 300 . | 2 | 2025–2025 |
People v. Ayala
green
2 sentences2015And because no jury is present and the defendant's guilt is not being assessed, counsel might pursue strategies prejudicial to his or her client's interests, fail to interpose objections to testimony by the People's witnesses or delve into facts tending to implicate the client in the crime ( id. at 429-430 ). 1990Although the defendant had been charged only with attempted murder at the time of the felony hearing, the hearing delved into substantially the same subject matter as did the subsequent murder trial (see, People v Arroyo, 54 NY2d 567, 575 , cert denied 456 US 979 ) and a review of the record reveals that the defendant was afforded ample opportunity to cross-examine Brogdon at the hearing (see, People v Arroyo, supra, at 574-575; People v Ayala, 142 AD2d 147 , affd 75 NY2d 422 ; People v Claudio, 130 AD2d 759 ). | 2 | 1990–2015 |
In re Gupta
neutral
2 sentences2014On May 1, 2014, the New York Court of Appeals dismissed the respondent's appeal on the ground that the issues presented became moot by virtue of his automatic disbarment on March 14, 2014 ( see Matter of Gupta, 23 NY3d 925 ). 2014On May 1, 2014, the New York Court of Appeals dismissed the respondent’s appeal on the ground that the issues presented became moot by virtue of his automatic disbarment on March 14, 2014 (see Matter of Gupta, 23 NY3d 925 [2014]). | 2 | 2014–2014 |
People v. Gissendanner
green
2 sentences1988However, inasmuch as no issue existed as to identification since the complainant knew the defendant and, indeed, identified him to the police by name (see, People v Tas, 51 NY2d 915 ; People v Gissendanner, 48 NY2d 543 ) and the complainant did not testify at the trial regarding her identification of the defendant at the felony hearing, any error in the hearing court’s denial of the defendant’s requests to absent himself from the felony hearing and in the denial of that branch of the defendant’s omnibus motion which was for suppression of the identification made at the felony hearing was harml 1988However, inasmuch as no issue existed as to identification since the complainant knew the defendant and, indeed, identified him to the police by name (see, People v Tas, 51 NY2d 915 ; People v Gissendanner, 48 NY2d 543 ) and the complainant did not testify at the trial regarding her identification of the defendant at the felony hearing, any error in the hearing court’s denial of the defendant’s requests to absent himself from the felony hearing and in the denial of that branch of the defendant’s omnibus motion which was for suppression of the identification made at the felony hearing was harml | 2 | 1980–1988 |
People v. Logan
green
2 sentences1985The circumstances surrounding this encounter were not so suggestive as to be inconsistent with defendant’s constitutional rights, and the witnesses’ testimony as to their observation of defendant prior to the felony hearing was therefore permissible for purposes of corroborating their in-court identification of defendant (CPL 60.30; see, People v Gonzalez, 61 AD2d 666 , affd 46 NY2d 1011 ; People v Logan, 25 NY2d 184, 193 , cert denied 396 US 1020 ). 1980(CPL 710.60, subd 2, par [a] ; 710.20, subd 5; 60.30; cf. People v Gruden, 42 NY2d 214 .) It should be made clear that by this court’s decision no judgment has been made concerning the “reliability” or lack thereof, of such felony hearing identification or whether or not the identification itself was “impermissively suggestive.” Manson v Brathwaite ( 432 US 98,106,113, n 13 , supra) made it clear that the normal concern in such “identification procedure does not in itself intrude upon a constitutionally protected interest.” “The exclusionary rules [of United States v Wade ( 388 US 218 ) and St | 2 | 1980–1985 |
People v. Martinez
neutral
2 sentences1983(People v Martinez, 80 Misc 2d 735 ; People v Dash, 95 Misc 2d 1005 .) The purposes of a preliminary hearing were summarized by the court in Mattioli v Brown ( 71 Misc 2d 99, 100 ). 1978In the case of People v Martinez ( 80 Misc 2d 735, 736 ), it was stated that: "The felony hearing is basically a first screening of the charge. | 2 | 1978–1983 |
People v. Gruden
green
2 sentences1980(CPL 710.60, subd 2, par [a] ; 710.20, subd 5; 60.30; cf. People v Gruden, 42 NY2d 214 .) It should be made clear that by this court’s decision no judgment has been made concerning the “reliability” or lack thereof, of such felony hearing identification or whether or not the identification itself was “impermissively suggestive.” Manson v Brathwaite ( 432 US 98,106,113, n 13 , supra) made it clear that the normal concern in such “identification procedure does not in itself intrude upon a constitutionally protected interest.” “The exclusionary rules [of United States v Wade ( 388 US 218 ) and St 1978Since the operative facts have not been denied by the People, and since they have not even requested this court to order a hearing in the event of a reversal on this ground, we believe that no useful purpose would be served by remanding the matter for a hearing in accordance with CPL 210.45 (see People v Gruden, 42 NY2d 214, 217 ; see, also, People v Swinton, 52 AD2d 561, 562 ). | 2 | 1978–1980 |
In re Abrams
green
2 sentences1978We also reject respondent’s argument that the automatic disbarment provision of subdivision 4 of section 90 of the Judiciary Law, by not providing an attorney convicted of a felony with a hearing before depriving him of his right to practice law, violates the due process, equal protection and cruel and unusual punishment clauses of the Federal and State Constitutions (see Matter of Chu, supra; Matter of Mitchell, 40 NY2d 153 ; Matter of Abrams, 38 AD2d 334 , mot for lv to app den 30 NY2d 486 , app dsmd 30 NY2d 879 ). 1978We have considered respondent’s argument that the automatic disbarment provision of subdivision 4 of section 90 violates due process in not providing an attorney convicted of a felony with a hearing before depriving him of his right to practice law, and find it to be without merit (see Matter of Chu, 42 NY2d 490 ; Matter of Mitchell, 40 NY2d 153 ; Matter of Abrams, 38 AD2d 334 , mot for lv to app den 30 NY2d 486 , app dsmd 30 NY2d 879 ). | 2 | 1978–1978 |
Jochnowitz v. Mack
neutral
2 sentences1978We also reject respondent’s argument that the automatic disbarment provision of subdivision 4 of section 90 of the Judiciary Law, by not providing an attorney convicted of a felony with a hearing before depriving him of his right to practice law, violates the due process, equal protection and cruel and unusual punishment clauses of the Federal and State Constitutions (see Matter of Chu, supra; Matter of Mitchell, 40 NY2d 153 ; Matter of Abrams, 38 AD2d 334 , mot for lv to app den 30 NY2d 486 , app dsmd 30 NY2d 879 ). 1978We have considered respondent’s argument that the automatic disbarment provision of subdivision 4 of section 90 violates due process in not providing an attorney convicted of a felony with a hearing before depriving him of his right to practice law, and find it to be without merit (see Matter of Chu, 42 NY2d 490 ; Matter of Mitchell, 40 NY2d 153 ; Matter of Abrams, 38 AD2d 334 , mot for lv to app den 30 NY2d 486 , app dsmd 30 NY2d 879 ). | 2 | 1978–1978 |
In re Chu
green
2 sentences1978We also reject respondent’s argument that the automatic disbarment provision of subdivision 4 of section 90 of the Judiciary Law, by not providing an attorney convicted of a felony with a hearing before depriving him of his right to practice law, violates the due process, equal protection and cruel and unusual punishment clauses of the Federal and State Constitutions (see Matter of Chu, supra; Matter of Mitchell, 40 NY2d 153 ; Matter of Abrams, 38 AD2d 334 , mot for lv to app den 30 NY2d 486 , app dsmd 30 NY2d 879 ). 1978We have considered respondent’s argument that the automatic disbarment provision of subdivision 4 of section 90 violates due process in not providing an attorney convicted of a felony with a hearing before depriving him of his right to practice law, and find it to be without merit (see Matter of Chu, 42 NY2d 490 ; Matter of Mitchell, 40 NY2d 153 ; Matter of Abrams, 38 AD2d 334 , mot for lv to app den 30 NY2d 486 , app dsmd 30 NY2d 879 ). | 2 | 1978–1978 |
In re Mitchell
green
2 sentences1978We also reject respondent’s argument that the automatic disbarment provision of subdivision 4 of section 90 of the Judiciary Law, by not providing an attorney convicted of a felony with a hearing before depriving him of his right to practice law, violates the due process, equal protection and cruel and unusual punishment clauses of the Federal and State Constitutions (see Matter of Chu, supra; Matter of Mitchell, 40 NY2d 153 ; Matter of Abrams, 38 AD2d 334 , mot for lv to app den 30 NY2d 486 , app dsmd 30 NY2d 879 ). 1978We have considered respondent’s argument that the automatic disbarment provision of subdivision 4 of section 90 violates due process in not providing an attorney convicted of a felony with a hearing before depriving him of his right to practice law, and find it to be without merit (see Matter of Chu, 42 NY2d 490 ; Matter of Mitchell, 40 NY2d 153 ; Matter of Abrams, 38 AD2d 334 , mot for lv to app den 30 NY2d 486 , app dsmd 30 NY2d 879 ). | 2 | 1978–1978 |
People v. Scarposi
neutral
2 sentences1975It is not necessary for the People to present a prima facie case in order to meet its burden at the felony hearing (People v. Soto, 76 Misc 2d 491 ; People v. Anderson, supra; People v. Scarposi, supra). 1973(People v. Scarposi, 69 Misc 2d 264 .) A defendant giving CPL 170.75 the literal reading argued for by defendant, might be justified in urging that even where a preliminary felony hearing has been held and he has been held by the court for Grand Jury action, he would be entitled to another hearing if the Grand Jury reduced the charge to a misdemeanor and ordered filing of a prosecutor’s information. | 2 | 1973–1975 |
| People v. Walls green | 1 | 2019–2019 |
| People v. Ojeda green | 1 | 2018–2018 |
| People v. Dawson green | 1 | 2018–2018 |
| People v. Stinson green | 1 | 2010–2010 |
| People v. Adams green | 1 | 2010–2010 |
| People v. Trueluck green | 1 | 2010–2010 |
| People v. Coager green | 1 | 2010–2010 |
| United States v. Attique Ahmad, AKA Ed Ahmad green | 1 | 2005–2005 |
| People v. Snow green | 1 | 2005–2005 |
| cluster 750093 green | 1 | 2005–2005 |
| In re Desmond J. green | 1 | 2004–2004 |
| People v. Martinez green | 1 | 1998–1998 |
| People v. Smith green | 1 | 1998–1998 |
| People v. Washington green | 1 | 1997–1997 |
| People v. Hart green | 1 | 1997–1997 |
| Dukes v. New York State Board of Parole neutral | 1 | 1993–1993 |
| Coleman v. Alabama green | 1 | 1993–1993 |
| Hynes v. George green | 1 | 1991–1991 |
| People v. Ruiz green | 1 | 1991–1991 |
| People v. Goggans green | 1 | 1991–1991 |
| People v. Uruburu green | 1 | 1991–1991 |
| People v. White green | 1 | 1990–1990 |
| People v. Claudio green | 1 | 1990–1990 |
| People v. Ayala green | 1 | 1990–1990 |
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.
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.