circumstances test (New Jersey) · Go Syfert
← New Jersey issues

circumstances test in New Jersey

61 New Jersey opinions name it 3 courts 1949–2026 8 in the last five years

The cases below were cited by New Jersey 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 (33)

CaseFollowedCited
Shammas v. Shammasgreen
nj · 1952 · cited in 5 New Jersey opinions naming this issue, 1955–2020
2 sentences

2020Furthermore, the movant must show that "the fact of the falsity of the testimony 'could not have been discovered by reasonable diligence in time to offset it at the trial or that [f]or other good reason the failure to use diligence is in all the circumstances not a bar to relief.'" Ibid. (emphasis in original) (quoting Shammas v. Shammas, 9 N.J. 321, 330 (1952)).

2017Regarding her claim of fraud upon the court, the law provides: a party seeking to be relieved from the judgment must show that the fact of the falsity of the testimony could not have been discovered by reasonable diligence in time to offset it at the trial or that for other good reason the failure to use diligence is in all the circumstances not a bar to relief. [Shammas v. Shammas, 9 N.J. 321, 330 (1952).] Here, defendant had over a decade to bring the alleged fraud to the court's attention, and in fact litigated numerous issues before the trial court, and in one instance, an appeal before th

45
State v. Stovallgreen
nj · 2002 · cited in 3 New Jersey opinions naming this issue, 2022–2025
2 sentences

2025It "is a highly fact-intensive inquiry that demands evaluation of 'the totality of circumstances surrounding the police- citizen encounter, balancing the State's interest in effective law enforcement against the individual's right to be protected from unwarranted and/or overbearing police intrusions.'" State v. Nyema, 249 N.J. 509 , 528 (2022) (quoting State v. Privott, 203 N.J. 16, 25-26 (2010)); see also State v. Stovall, 170 N.J. 346, 363 (2002) (explaining the trial court considers an officer's training and experience in its totality of the circumstances analysis).

2025"Determining whether reasonable and articulable suspicion exists for an investigatory stop is a highly fact-intensive inquiry that demands evaluation of 'the totality of circumstances surrounding the police-citizen encounter, balancing the State's interest in effective law enforcement against the individual's right to be protected from unwarranted and/or overbearing police intrusions.'" State v. Nyema, 249 N.J. 509 , 528 (2022) (quoting State v. Privott, 203 N.J. 16, 25-26 (2010)); see also State v. Stovall, 170 N.J. 346, 363 (2002) (explaining the trial court considers an officer's training a

33
State v. Smithgreen
nj · 1998 · cited in 3 New Jersey opinions naming this issue, 2003–2019
2 sentences

2019Courts analyze the reliability of a CI's tip under a "totality of the circumstances test." State v. Smith, 155 N.J. 83, 92 (1998).

2018Courts analyze the reliability of a confidential informant's tip under a "totality of the circumstances test." State v. Smith, 155 N.J. 83, 92 (1998).

23
State v. Privottgreen
nj · 2010 · cited in 2 New Jersey opinions naming this issue, 2025–2025
2 sentences

2025It "is a highly fact-intensive inquiry that demands evaluation of 'the totality of circumstances surrounding the police- citizen encounter, balancing the State's interest in effective law enforcement against the individual's right to be protected from unwarranted and/or overbearing police intrusions.'" State v. Nyema, 249 N.J. 509 , 528 (2022) (quoting State v. Privott, 203 N.J. 16, 25-26 (2010)); see also State v. Stovall, 170 N.J. 346, 363 (2002) (explaining the trial court considers an officer's training and experience in its totality of the circumstances analysis).

2025"Determining whether reasonable and articulable suspicion exists for an investigatory stop is a highly fact-intensive inquiry that demands evaluation of 'the totality of circumstances surrounding the police-citizen encounter, balancing the State's interest in effective law enforcement against the individual's right to be protected from unwarranted and/or overbearing police intrusions.'" State v. Nyema, 249 N.J. 509 , 528 (2022) (quoting State v. Privott, 203 N.J. 16, 25-26 (2010)); see also State v. Stovall, 170 N.J. 346, 363 (2002) (explaining the trial court considers an officer's training a

22
Kpmg LLP v. Cocchigreen
scotus · 2011 · cited in 2 New Jersey opinions naming this issue, 2025–2025
2 sentences

2025Johnson's claims against Everyrealm and its executives all arise from his employment at Everyrealm and are clearly properly joined in a common lawsuit. [657 F. Supp. 3d at 562 n.23.] Relying on this footnote and KPMG LLP, 565 U.S. at 19, 22, the court concluded, as noted, McDermott's counts four through fourteen did not satisfy the "related to" language of the EFAA, 9 U.S.C. § 402 (a), because it was not "inextricably intertwined with the allegations of sexual harassment" in her count two, unlike her gender discrimination and constructive discharge causes of action.

2025Johnson's claims against Everyrealm and its executives all arise from his employment at Everyrealm and are clearly properly joined in a common lawsuit. [657 F. Supp. 3d at 562 n.23.] Relying on this footnote and KPMG LLP, 565 U.S. at 19, 22, the court concluded, as noted, McDermott's counts four through fourteen did not satisfy the "related to" language of the EFAA, 9 U.S.C. § 402 (a), because it was not "inextricably intertwined with the allegations of sexual harassment" in her count two, unlike her gender discrimination and constructive discharge causes of action.

22
State v. Czachorgreen
nj · 1980 · cited in 2 New Jersey opinions naming this issue, 2017–2017
2 sentences

2017"The test for plain error is whether under the circumstances the error possessed a clear capacity for producing an unjust result, that is, one sufficient to raise a reasonable doubt as to whether the error led the jury to a result it otherwise might not have reached." State v. Czachor, 82 N.J. 392, 402 (1980) (citations and quotation marks omitted).

2017Under this deferential standard, this court disregards any error or omission "unless it is of such a nature as to have been clearly capable of producing an unjust result[.]" R. 2:10-2; see also State v. Czachor, 82 N.J. 392, 402 (1980) (explaining "[t]he test for plain error is whether under the circumstances the error possessed a clear capacity for 2 Defendant also filed a pro se supplemental brief arguing that the jury's verdict was against the weight of the evidence and that the trial court erred by not granting defendant's motion for a new trial after the passenger recanted his testimony p

22
State v. Johnsongreen
nj · 2002 · cited in 2 New Jersey opinions naming this issue, 2007–2025
2 sentences

2025Although evidence concerning "the high- crime reputation an area" is permitted to be considered as part of the "totality of the circumstances test" in determining probable cause, see State v. Moore, 181 N.J. 40, 46 (2004), citing State v. Johnson, 171 N.J. 192, 217 (2002), the court's finding that this general knowledge that the convenience store parking lot is a high crime area somehow equates to specific knowledge that defendant's vehicle contained CDS was foreseeable misapplies the established legal principles of Witt and Smart.

2007In sum, the third prong required that the judge consider the factual circumstances in the context of the definition of probable cause provided by the Court in State v. Johnson : "Probable cause exists if at the time of the police action there is a `well grounded' suspicion that a crime has been or is being committed." It requires nothing more than "a practical, common-sense decision whether, given all the circumstances . . . there is a fair probability that contraband or evidence of a crime will be found in a particular place." The flexible, practical totality of the circumstances standard has

12
Franz v. Raymond Eisenhardt & Sons, Inc.green
njd · 1990 · cited in 2 New Jersey opinions naming this issue, 1998–2005
2 sentences

2005In its decision in Pukowsky v. Caruso, the Appellate Division utilized the twelve part “totality of the circumstances test” established in Franz v. Raymond Eisenhardt & Sons, Inc., 732 F.Supp. 521, 528 (D.N.J.1990) (citing E.E.O.C. v. Zippo Mfg.

1998On appeal, plaintiff urges that the twelvepart "totality of the circumstances test" established in Franz, supra, 732 F.Supp. at 528 , should be applied in this case.

12
Idaho v. Wrightgreen
scotus · 1990 · cited in 2 New Jersey opinions naming this issue, 1991–1991
2 sentences

1991The Court rejected any procedural requirement, such as that the interview be taped, or that the statement be the product of nonleading questions, substituting a "totality of the circumstances test." The Court specifically excluded from consideration on the question of trustworthiness any extrinsic evidence tending to prove or disprove that sexual assault had taken place. 497 U.S. at ___ -___, 110 S.Ct. at 3149-3150 , 111 L.Ed. 2d at 656-657 . *514 Concerning the case before it, the Court noted that the trial court had been influenced by extrinsic evidence, whereas the Idaho Supreme Court had p

1991The Court rejected any procedural requirement, such as that the interview be taped, or that the statement be the product of nonleading questions, substituting a "totality of the circumstances test." The Court specifically excluded from consideration on the question of trustworthiness any extrinsic evidence tending to prove or disprove that sexual assault had taken place. 497 U.S. at ___ -___, 110 S.Ct. at 3149-3150 , 111 L.Ed. 2d at 656-657 . *514 Concerning the case before it, the Court noted that the trial court had been influenced by extrinsic evidence, whereas the Idaho Supreme Court had p

12
State v. Mooregreen
nj · 2004 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025Although evidence concerning "the high- crime reputation an area" is permitted to be considered as part of the "totality of the circumstances test" in determining probable cause, see State v. Moore, 181 N.J. 40, 46 (2004), citing State v. Johnson, 171 N.J. 192, 217 (2002), the court's finding that this general knowledge that the convenience store parking lot is a high crime area somehow equates to specific knowledge that defendant's vehicle contained CDS was foreseeable misapplies the established legal principles of Witt and Smart.

11
United States v. Agursgreen
scotus · 1976 · cited in 1 New Jersey opinions naming this issue, 2024–2024
1 sentence

2024United States v. Agurs, 427 U.S. 97, 111-13 (1976); see also Bagley, 473 U.S. at 678-81 ; Carter, 85 N.J. at 312 .

11
United States v. Bagleygreen
scotus · 1985 · cited in 1 New Jersey opinions naming this issue, 2024–2024
1 sentence

2024United States v. Agurs, 427 U.S. 97, 111-13 (1976); see also Bagley, 473 U.S. at 678-81 ; Carter, 85 N.J. at 312 .

11
State v. Nashgreen
nj · 2013 · cited in 1 New Jersey opinions naming this issue, 2019–2019
1 sentence

2019R. 3:22-4(a)(1) to (3); see also Nash, 212 N.J. at 546-47 (describing the circumstances under which the bar will not be enforced by a court).

11
State v. Zuticgreen
nj · 1998 · cited in 1 New Jersey opinions naming this issue, 2019–2019
1 sentence

2019"An informant's 'veracity' and 'basis of knowledge' are two highly relevant factors under the totality of the circumstances." State v. Zutic, 155 N.J. 103, 110 (1998) (citing Smith, 155 N.J. at 93 ).

11
New Concepts for Living v. Hackensackgreen
njsuperctappdiv · 2005 · cited in 1 New Jersey opinions naming this issue, 2017–2017
1 sentence

2017Equitable relief under the doctrine “cannot be exercised or withheld rigidly, but [is] always subject to the guiding principles of fundamental fairness.” New Concepts For Living, Inc. v. City of Hackensack, 376 N.J.

11
State v. Timothy Adkins (073803)green
nj · 2015 · cited in 1 New Jersey opinions naming this issue, 2017–2017
1 sentence

2017State v. Adkins, 221 N.J. 300, 317 (2015).

11
Matter of Freshwater Wetlands Rulesgreen
njsuperctappdiv · 1989 · cited in 1 New Jersey opinions naming this issue, 2013–2013
11
Selective Insurance Co. of America v. Rothmangreen
nj · 2012 · cited in 1 New Jersey opinions naming this issue, 2012–2012
11
Mull v. Zeta Consumer Productsgreen
nj · 2003 · cited in 1 New Jersey opinions naming this issue, 2012–2012
11
Groceman v. United States Department of Justicegreen
ca5 · 2004 · cited in 1 New Jersey opinions naming this issue, 2005–2005
11
Roy Padgett v. James E. Donaldgreen
ca11 · 2005 · cited in 1 New Jersey opinions naming this issue, 2005–2005
11
Boling v. Romergreen
ca10 · 1997 · cited in 1 New Jersey opinions naming this issue, 2005–2005
11
United States v. Knightsgreen
scotus · 2001 · cited in 1 New Jersey opinions naming this issue, 2005–2005
11
Jones v. Murraygreen
ca4 · 1992 · cited in 1 New Jersey opinions naming this issue, 2005–2005
11
New Jersey Transit PBA Local 304 v. New Jersey Transit Corp.green
nj · 1997 · cited in 1 New Jersey opinions naming this issue, 2005–2005
11
United States v. Thomas Cameron Kincadegreen
ca9 · 2004 · cited in 1 New Jersey opinions naming this issue, 2005–2005
11
United States v. Paul G. Sczubelekgreen
ca3 · 2005 · cited in 1 New Jersey opinions naming this issue, 2005–2005
11
Terry v. Ohiogreen
scotus · 1968 · cited in 1 New Jersey opinions naming this issue, 2002–2002
11
Lehmann v. Toys 'R' US, Inc.green
nj · 1993 · cited in 1 New Jersey opinions naming this issue, 1998–1998
11
Harris v. Forklift Systems, Inc.green
scotus · 1993 · cited in 1 New Jersey opinions naming this issue, 1998–1998
11
United States v. Kamorudeen Adekunle, United States of America v. Saheed Mashagreen
ca5 · 1992 · cited in 1 New Jersey opinions naming this issue, 1993–1993
11
State v. Harrisgreen
wisctapp · 1993 · cited in 1 New Jersey opinions naming this issue, 1993–1993
11
Gomez v. United Statesgreen
scotus · 1993 · cited in 1 New Jersey opinions naming this issue, 1993–1993
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (47)

CaseCitedYears
Schneider v. Simonini green
nj · 2000
2 sentences

2003This flexible, practical totality of the circumstances standard has been adopted because probable cause is a "`fluid concept—turning on the assessment of probabilities in particular factual contexts—not readily, or even usefully, reduced to a neat set of legal rules.'" Schneider, supra, 163 N.J. at 361 , 749 A. 2d 336 (quoting Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed. 2d at 544 ).

2003This flexible, practical totality of the circumstances standard has been adopted because probable cause is a "`fluid concept—turning on the assessment of probabilities in particular factual contexts—not readily, or even usefully, reduced to a neat set of legal rules.'" Schneider, supra, 163 N.J. at 361 , 749 A. 2d 336 (quoting Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed. 2d at 544 ).

32002–2003
Illinois v. Gates green
scotus · 1983
2 sentences

2003This flexible, practical totality of the circumstances standard has been adopted because probable cause is a "`fluid concept—turning on the assessment of probabilities in particular factual contexts—not readily, or even usefully, reduced to a neat set of legal rules.'" Schneider, supra, 163 N.J. at 361 , 749 A. 2d 336 (quoting Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed. 2d at 544 ).

2003This flexible, practical totality of the circumstances standard has been adopted because probable cause is a "`fluid concept—turning on the assessment of probabilities in particular factual contexts—not readily, or even usefully, reduced to a neat set of legal rules.'" Schneider, supra, 163 N.J. at 361 , 749 A. 2d 336 (quoting Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed. 2d at 544 ).

32002–2003
State v. Presha green
nj · 2000
2 sentences

2004Id. at 317 , 748 A. 2d 1108 .

2004Id. at 317 , 748 A. 2d 1108 .

22004–2004
State v. Novembrino green
nj · 1987
2 sentences

2003Ed. 2d 527, 543-44 (1983)); Novembrino, supra, 105 N.J. at 122 , 519 A. 2d 820 (adopting totality of the circumstances test).

2003Ed. 2d 527, 543-44 (1983)); Novembrino, supra, 105 N.J. at 122 , 519 A. 2d 820 (adopting totality of the circumstances test).

21997–2003
Thorpe v. Redevelopment Authority of Allentown green
scotus · 2001
2 sentences

2002The flexible, practical totality of the circumstances standard has been adopted because probable cause is a “ ‘fluid concept — turning on the assessment of probabilities in particular factual contexts — not readily, or even usefully, reduced to a neat set of legal rules.’ ” Schneider v. Simonini, 163 N.J. 336, 361 , 749 A.2d 336 (2000) (quoting Illinois v. Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed.2d at 544 ), cert. denied, 531 U.S. 1146 , 121 S.Ct. 1083 , 148 L.Ed.2d 959 (2001).

2002The flexible, practical totality of the circumstances standard has been adopted because probable cause is a “ ‘fluid concept — turning on the assessment of probabilities in particular factual contexts — not readily, or even usefully, reduced to a neat set of legal rules.’ ” Schneider v. Simonini, 168 N.J. 336, 361 , 749 A.2d 336 (2000), cert. denied, 531 U.S. 1146 , 121 S.Ct. 1083 , 148 L.Ed.2d 959 (2001) (quoting Illinois v. Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed. 2d at 544 ).

22002–2002
Caso v. Florida green
scotus · 2001
2 sentences

2002The flexible, practical totality of the circumstances standard has been adopted because probable cause is a “ ‘fluid concept — turning on the assessment of probabilities in particular factual contexts — not readily, or even usefully, reduced to a neat set of legal rules.’ ” Schneider v. Simonini, 163 N.J. 336, 361 , 749 A.2d 336 (2000) (quoting Illinois v. Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed.2d at 544 ), cert. denied, 531 U.S. 1146 , 121 S.Ct. 1083 , 148 L.Ed.2d 959 (2001).

2002The flexible, practical totality of the circumstances standard has been adopted because probable cause is a “ ‘fluid concept — turning on the assessment of probabilities in particular factual contexts — not readily, or even usefully, reduced to a neat set of legal rules.’ ” Schneider v. Simonini, 168 N.J. 336, 361 , 749 A.2d 336 (2000), cert. denied, 531 U.S. 1146 , 121 S.Ct. 1083 , 148 L.Ed.2d 959 (2001) (quoting Illinois v. Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed. 2d at 544 ).

22002–2002
McLeod v. California green
scotus · 2001
2 sentences

2002The flexible, practical totality of the circumstances standard has been adopted because probable cause is a “ ‘fluid concept — turning on the assessment of probabilities in particular factual contexts — not readily, or even usefully, reduced to a neat set of legal rules.’ ” Schneider v. Simonini, 163 N.J. 336, 361 , 749 A.2d 336 (2000) (quoting Illinois v. Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed.2d at 544 ), cert. denied, 531 U.S. 1146 , 121 S.Ct. 1083 , 148 L.Ed.2d 959 (2001).

2002The flexible, practical totality of the circumstances standard has been adopted because probable cause is a “ ‘fluid concept — turning on the assessment of probabilities in particular factual contexts — not readily, or even usefully, reduced to a neat set of legal rules.’ ” Schneider v. Simonini, 168 N.J. 336, 361 , 749 A.2d 336 (2000), cert. denied, 531 U.S. 1146 , 121 S.Ct. 1083 , 148 L.Ed.2d 959 (2001) (quoting Illinois v. Gates, supra, 462 U.S. at 232 , 103 S.Ct. at 2329 , 76 L.Ed. 2d at 544 ).

22002–2002
D'Annunzio v. Prudential Insurance Co. of America green
nj · 2007
1 sentence

2026Co. of Am., 192 N.J. 110 (2007), stating that Pukowsky's twelve-factor totality of the circumstances test still applied to cases brought under the LAD.

12026–2026
Sam Hargrove v. Sleepy's, LLC (072742) green
nj · 2015
1 sentence

2026Hargrove, 220 N.J. at 315-16 .

12026–2026
State v. Atwood green
nj · 2018
1 sentence

2025A-3265-22 13 In State v. Smith, 251 N.J. at 252, the Court considered "whether a purported violation of N.J.S.A. 39:3-74[10] based on tinted windows justified an investigatory stop of a motor vehicle." The Court held "that reasonable and articulable suspicion of a tinted windows violation arises only when a vehicle's front windshield or front side windows are so darkly tinted that police cannot clearly see people or articles within the car." Id. at 253.11 Here, the suppression hearing record establishes no error in the trial court's finding that Soulias had "articulable and reasonable suspicio

12025–2025
State v. Carter green
nj · 1981
1 sentence

2024United States v. Agurs, 427 U.S. 97, 111-13 (1976); see also Bagley, 473 U.S. at 678-81 ; Carter, 85 N.J. at 312 .

12024–2024
Pavlicka v. Pavlicka green
njsuperctappdiv · 1964
1 sentence

2020Furthermore, the movant must show that "the fact of the falsity of the testimony 'could not have been discovered by reasonable diligence in time to offset it at the trial or that [f]or other good reason the failure to use diligence is in all the circumstances not a bar to relief.'" Ibid. (emphasis in original) (quoting Shammas v. Shammas, 9 N.J. 321, 330 (1952)).

12020–2020
Cole v. Jersey City Medical Center green
nj · 2013
1 sentence

2019Id. at 280 .

12019–2019
Clohesy v. Food Circus Supermarkets, Inc. green
nj · 1997
1 sentence

2019Id. at 507-08 .

12019–2019
State of New Jersey v. Timothy Adkins green
njsuperctappdiv · 2013
12015–2015
Missouri v. McNeely green
scotus · 2013
12014–2014
In Re Freshwater Wetlands Protection Act Rules green
nj · 2004
12013–2013
State v. Diaz-Bridges green
nj · 2012
12012–2012
State v. Nyhammer green
nj · 2009
12010–2010
Aleru v. Gonzales, Attorney General green
scotus · 2005
12005–2005
Eliakim v. Florida green
scotus · 2005
12005–2005
cluster 422044 green
ca3 · 1983
12005–2005
Padilla v. Hanft neutral
scotus · 2005
12005–2005
Maxwell v. Illinois green
scotus · 1992
12005–2005
Jones v. Murray green
scotus · 1992
12005–2005
State v. Waltz green
nj · 1972
12003–2003
State v. Sullivan green
nj · 2001
12003–2003
Carroll v. United States green
scotus · 1925
12002–2002
State v. Bruzzese green
nj · 1983
12002–2002
Texas v. Brown green
scotus · 1983
12002–2002
State v. Royster green
nj · 1988
12001–2001
State v. Morton green
nj · 1988
12001–2001
State v. Sloan green
njsuperctappdiv · 1988
12001–2001
State v. Sharpless green
njsuperctappdiv · 1998
12000–2000
United States v. Ronald T. Clipper green
cadc · 1992
12000–2000
McDonnell Douglas Corp. v. Green green
scotus · 1973
12000–2000
State v. Harvey green
nj · 1999
11999–1999
State v. Coleman green
nj · 1965
11998–1998
Caraballo v. LaVallee green
scotus · 1966
11998–1998
State v. New Jersey Trade Waste Ass'n. green
nj · 1984
11996–1996

Statutes the citing opinions construe

NJ § N.J. Stat. § 2C:12-1 (6) NJ § N.J. Stat. § 2C:39-5 (5) NJ § N.J. Stat. § 10:5-1 (3) NJ § N.J. Stat. § 10:5-12 (3) NJ § N.J. Stat. § 2C:11-3 (3) NJ § N.J. Stat. § 2C:29-2 (3) NJ § N.J. Stat. § 2C:35-10 (3) NJ § N.J. Stat. § 2C:35-5 (3) NJ § N.J. Stat. § 2C:39-4 (3) NJ § N.J. Stat. § 2C:44-1 (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

NY 214 (1885–2025) CA 182 (1900–2026) PA 125 (1903–2026) IL 121 (1856–2026) TX 115 (1908–2025) OH 76 (1902–2025) FL 62 (1933–2020) NJ 61 (1949–2026) WI 60 (1915–2026) MD 52 (1964–2025) MA 49 (1917–2020) VA 43 (1877–2023) NC 42 (1924–2026) GA 42 (1905–2025) LA 41 (1965–2020) TN 40 (1918–2026) MO 39 (1897–2021) IN 33 (1925–2020) CO 32 (1945–2026) AL 30 (1926–2024) WA 29 (1960–2026) MT 28 (1912–2020) OR 28 (1959–2026) NE 28 (1932–2026) MI 27 (1921–2026) CT 27 (1978–2026) WY 26 (1934–2026) KY 26 (1916–2023) MN 26 (1949–2024) KS 26 (1926–2025) AZ 26 (1963–2022) VT 26 (1913–2026) NM 22 (1990–2023) SD 18 (1940–2024) MS 16 (1921–2020) HI 16 (1925–2021) DC 16 (1973–2024) IA 16 (1915–2023) ND 13 (1974–2012) ID 12 (1925–2024) DE 12 (1977–2026) NV 11 (1948–2026) AR 11 (1956–2001) ME 11 (1965–2022) UT 11 (1985–2024) SC 10 (1925–2024) OK 9 (1910–2021) WV 8 (1940–2026) NH 8 (1973–2021) AK 7 (1976–1996) RI 6 (1971–2012) VI 3 (2006–2012)

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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