61 Pennsylvania opinions name it 10 courts 1893–2025 5 in the last five years
The cases below were cited by Pennsylvania 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 |
|---|---|---|
Commonwealth v. One 1988 Ford Coupe Vin 1FABP41A9JF143651green2 sentences2014See, e.g., Commonwealth v. One 1988 Ford Coupe, 393 Pa.Super. 320 , 574 A.2d 631 , 633 n. 2 (1990) (“At common law, forfeiture could not attach unless there was a conviction, and evidence of that conviction was necessary to prove a forfeiture claim.”), appeals denied, 527 Pa. 631 , 592 A.2d 1299 & 1301 (1991); Commonwealth v. Real Prop. & Improvements at 2838 N. Beechwood St., 65 A.3d 1055 , 1063 n. 16 (Pa.Cmwlth.2013) (en banc) (Beechwood Street). 2014See, e.g., Commonwealth v. One 1988 Ford Coupe, 393 Pa.Super. 320 , 574 A.2d 631 , 633 n. 2 (1990) (“At common law, forfeiture could not attach unless there was a conviction, and evidence of that conviction was necessary to prove a forfeiture claim.”), appeals denied, 527 Pa. 631 , 592 A.2d 1299 & 1301 (1991); Commonwealth v. Real Prop. & Improvements at 2838 N. Beechwood St., 65 A.3d 1055 , 1063 n. 16 (Pa.Cmwlth.2013) (en banc) (Beechwood Street). | 3 | 4 |
United States v. Antone R. White, A/K/A Tonegreen2 sentences2023All Circuit Courts of Appeals considering the matter of a defendant who has removed an adverse witness have similarly concluded that “simple equity” and “common sense” support a forfeiture principle so that “a defendant who wrongfully procures the absence of a witness or potential witness may not assert confrontation rights as to that witness.” Id. at 652 (quoting United States v. White, 116 F.3d 903, 911 (D.C. 2008All Circuit Courts of Appeals considering the matter of a defendant who has removed an adverse witness have similarly concluded that “simple equity” and “common sense” support a forfeiture principle so that “a defendant who wrongfully procures the absence of a witness "or potential witness may not assert confrontation rights as to that witness.” Id. at 652 (quoting United States v. White, 116 F.3d 903, 911 (D.C.Cir.1997)). | 2 | 2 |
Estate of Fullergreen2 sentences2019See In re Estate of Fuller, 87 A.3d 330, 334 (Pa. Super. 2014). 2019See In re Estate of Fuller, 87 A.3d 330, 334 (Pa. Super. 2014). | 2 | 2 |
Commonwealth v. 1992 Chevroletgreen2 sentences2014The Act, however, is silent in several respects, contrary to the Commonwealth Court Plurality’s holding that the General Assembly provided a “complete procedure.” See e.g., Commonwealth v. $3961.00 Cash, 1 A.3d 999, 1002 (Pa.Cmwlth.2010) (applying Pa.R.C.P. 1007.1(c)(2) to determine if there was a valid jury trial waiver); One 1991 Cadillac Seville, 853 A.2d 1093 (relying on the Rules to determine proper service by certified mail when there was a question that was not resolved by the Forfeiture Act); Commonwealth v. 1992 Chevrolet Seized from Hill, 844 A.2d 583, 585-86 (Pa.Cmwlth.2004) (applyi 2012We further relied on the Rules in Commonwealth v. 1992 Chevrolet Seized from Hill, 844 A.2d 583, 585-86 (Pa.Cmwlth.2004), to hold that, even where a respondent/property owner does not appear at a forfeiture hearing, the Commonwealth is required to proceed with its case in chief and is obligated to present evidence in support of its forfeiture petition. 2 In contrast, the Forfeiture Act provides no procedure for the courts or parties to follow in resolving such questions. | 2 | 2 |
Kalina v. Eckertgreen2 sentences2013“A forfeiture clause is enforceable, but only if it is expressed with clearness and certainty.” Kalina v. Eckert, 345 Pa.Super. 220 , 497 A.2d 1384, 1385 (1985). 2013“A forfeiture clause is enforceable, but only if it is expressed with clearness and certainty.” Kalina v. Eckert, 345 Pa.Super. 220 , 497 A.2d 1384, 1385 (1985). | 2 | 2 |
Jones v. West. Penna. N. Gas Co.green2 sentences1927In Craig v. Cosgrove, 277 Pa. 580, 584 , the Supreme Court held: “A forfeiture clause for non-payment of rent or for failure to fulfill a covenant for drilling wells in an oil and gas lease is for the benefit of the lessor and is enforceable only at his option: see Jones v. Natural Gas Co., 146 Pa. 204 ; Wills v. Manufacturers Natural Gas Co., 130 Pa. 222 . 1923A forfeiture clause, for nonpayment of rent or for failure to fulfill a covenant for drilling wells in an oil and gas lease, is for the benefit of the lessor and is enforceable only at his option: see Jones v. N. Gas Co., 146 Pa. 204 ; Wills v. Manufacturers N. Gas Co., 130 Pa. 222 . | 2 | 2 |
Commonwealth v. Hanngreen2 sentences2013AND NOW, this 19th day of December 2013, the Petition for Allowance of Appeal is GRANTED, the decision of the Superior Court is VACATED, and the matter is REMANDED to the Court of Common Pleas of Pike County to conduct a new forfeiture hearing in accordance with Commonwealth v. Hann, 622 Pa. 636 , 81 A.3d 57 , 2013 WL 5827034 (2013). 2013AND NOW, this 19th day of December 2013, the Petition for Allowance of Appeal is GRANTED, the decision of the Superior Court is VACATED, and the matter is REMANDED to the Court of Common Pleas of Pike County to conduct a new forfeiture hearing in accordance with Commonwealth v. Hann, 622 Pa. 636 , 81 A.3d 57 , 2013 WL 5827034 (2013). | 1 | 5 |
One 1958 Plymouth Sedan v. Pennsylvaniagreen2 sentences2017“Contraband” connotes property that is inherently illegal, the mere “possession of which, without more, constitutes a crime.” One 1958 Plymouth Sedan v. Pennsylvania, 880 U.S. 693 , 699, 85 S.Ct. 1246 , 14 L.Ed.2d 170 (1965). 2017“Contraband” connotes property that is inherently illegal, the mere “possession of which, without more, constitutes a crime.” One 1958 Plymouth Sedan v. Pennsylvania, 880 U.S. 693 , 699, 85 S.Ct. 1246 , 14 L.Ed.2d 170 (1965). | 1 | 2 |
Cape May Real Estate Co. v. Hendersongreen1 sentence2025See, e.g., Cape May Real Estate Co. v. Henderson, 42 Pa. Super. 1, 3 (1910) (en banc), affirmed, 79 A. 982 (Pa. 1911) (presuming “that the forfeiture clause is for the benefit of the [seller] and enforceable at his election.”). | 1 | 1 |
White v. Philadelphia Rapid Transit Co.green1 sentence2025See, e.g., Cape May Real Estate Co. v. Henderson, 42 Pa. Super. 1, 3 (1910) (en banc), affirmed, 79 A. 982 (Pa. 1911) (presuming “that the forfeiture clause is for the benefit of the [seller] and enforceable at his election.”). | 1 | 1 |
Commonwealth v. Stakleygreen2 sentences2022Similarly, in Commonwealth v. Stakley, 365 A.2d 1298, 1300 (Pa.Super. 1976) (en banc), this court found that defense counsel’s suggestion that the defendant had been honorably discharged from the military opened the door to rebuttal testimony that he had not, explaining that an appellant who delves into objectionable testimony at trial cannot later claim error on appeal. -6- J-A11001-22 This forfeiture analysis is consistent with well-established federal law, which provides that a defendant cannot later challenge an adverse motion in limine ruling on appeal if he testifies and admits the at-is 2022Similarly, in Commonwealth v. Stakley, 365 A.2d 1298 , 1300 (Pa.Super. 1976) (en banc), this court found that defense counsel’s suggestion that the defendant had been honorably discharged from the military opened the door to rebuttal testimony that he had not, explaining that an appellant who delves into objectionable testimony at trial cannot later claim error on appeal. -6- J-A11001-22 This forfeiture analysis is consistent with well-established federal law, which provides that a defendant cannot later challenge an adverse motion in limine ruling on appeal if he testifies and admits the at-i | 1 | 1 |
Ohler v. United Statesgreen2 sentences2022In Ohler v. United States, 529 U.S. 753, 760 (2000), the defendant admitted a prior conviction on direct examination after the district court issued an in limine ruling that the prior conviction was admissible. 2022In Ohler v. United States, 529 U.S. 753 , 760 (2000), the defendant admitted a prior conviction on direct examination after the district court issued an in limine ruling that the prior conviction was admissible. | 1 | 1 |
LJL Transportation, Inc. v. Pilot Air Freight Corp.green1 sentence2021See LJL Transp., 962 A.2d at 642-643, 652 (concluding that a franchisee materially breached a franchise agreement by diverting shipments to the franchisor’s competition and that the breach permitted the franchisor to terminate the contract without permitting the franchisee recourse to a cure provision under the franchise agreement); McCausland, 78 A.3d at 1097-98, 1105-06 (concluding that a lessor in an oil and gas lease was entitled to enforce a forfeiture clause in the lease based on the lessee’s breach by failure to pay royalties and notwithstanding a settlement agreement between the lessor | 1 | 1 |
McCausland v. Wagnergreen1 sentence2021See LJL Transp., 962 A.2d at 642-643, 652 (concluding that a franchisee materially breached a franchise agreement by diverting shipments to the franchisor’s competition and that the breach permitted the franchisor to terminate the contract without permitting the franchisee recourse to a cure provision under the franchise agreement); McCausland, 78 A.3d at 1097-98, 1105-06 (concluding that a lessor in an oil and gas lease was entitled to enforce a forfeiture clause in the lease based on the lessee’s breach by failure to pay royalties and notwithstanding a settlement agreement between the lessor | 1 | 1 |
Commonwealth v. Nineteen Hundred & Twenty Dollars United States Currencygreen1 sentence2020Id. (“[Appellant] agrees and states that [he] is waiving [his] rights to a forfeiture hearing/trial with full knowledge of the consequences of [his] action and without any duress or coercion placed upon [him].”). | 1 | 1 |
Carpenter's Estategreen2 sentences2018Moreover, the Commonwealth Court noted that In re Carpenter's Estate , 170 Pa. 203 , 32 A. 637 (1895), had rejected a forfeiture claim following a murder conviction on the basis that Article I, Sections 18 and 19 of the Pennsylvania Constitution prohibited attainder and the corresponding forfeiture. 2018Moreover, the Commonwealth Court noted that In re Carpenter's Estate , 170 Pa. 203 , 32 A. 637 (1895), had rejected a forfeiture claim following a murder conviction on the basis that Article I, Sections 18 and 19 of the Pennsylvania Constitution prohibited attainder and the corresponding forfeiture. | 1 | 1 |
Owens v. . Owensgreen2 sentences2018See id. at 208 , 32 A. at 637 ("The legislature has never imposed any penalty of corruption of blood or forfeiture of estate for the crime of murder, and therefore no such penalty has any legal existence."); see also id. at 209 , 32 A. at 638 ("Forfeitures of property for crime are unknown to our law ...." (quoting Owens v. Owens , 100 N.C. 240 , 6 S.E. 794 , 795 (1888) ) ). 6 Ultimately, the Commonwealth Court reasoned that, "[f]ollowing *375 the natural direction of Carpenter's Estate and the unquestioned view espoused by various courts and commentators, ... there is no such thing as common 2018See id. at 208 , 32 A. at 637 ("The legislature has never imposed any penalty of corruption of blood or forfeiture of estate for the crime of murder, and therefore no such penalty has any legal existence."); see also id. at 209 , 32 A. at 638 ("Forfeitures of property for crime are unknown to our law ...." (quoting Owens v. Owens , 100 N.C. 240 , 6 S.E. 794 , 795 (1888) ) ). 6 Ultimately, the Commonwealth Court reasoned that, "[f]ollowing *375 the natural direction of Carpenter's Estate and the unquestioned view espoused by various courts and commentators, ... there is no such thing as common | 1 | 1 |
Com. v. J. Irland Smith and Wesson 9MM Semi-Automatic Pistol, Serial PDW0493green1 sentence2018See id. at 208 , 32 A. at 637 ("The legislature has never imposed any penalty of corruption of blood or forfeiture of estate for the crime of murder, and therefore no such penalty has any legal existence."); see also id. at 209 , 32 A. at 638 ("Forfeitures of property for crime are unknown to our law ...." (quoting Owens v. Owens , 100 N.C. 240 , 6 S.E. 794 , 795 (1888) ) ). 6 Ultimately, the Commonwealth Court reasoned that, "[f]ollowing *375 the natural direction of Carpenter's Estate and the unquestioned view espoused by various courts and commentators, ... there is no such thing as common | 1 | 1 |
| Geib v. Lebanon Valley Savings & Loan Ass'ngreen | 1 | 1 |
| Commonwealth v. Culvergreen | 1 | 1 |
| Commonwealth v. $3961.00 Cashgreen | 1 | 1 |
| Commonwealth v. $6,425.00 Seized from Esquilingreen | 1 | 1 |
| Slater v. Slatergreen | 1 | 1 |
| Liazis v. Kosta, Inc.green | 1 | 1 |
| Friend's Estategreen | 1 | 1 |
| West Penn Sand & Gravel Co. v. Shippingport Sand Co.green | 1 | 1 |
| Korman v. Trainergreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Wills v. Manufacturers N. Gas Co.
green
2 sentences1927In Craig v. Cosgrove, 277 Pa. 580, 584 , the Supreme Court held: “A forfeiture clause for non-payment of rent or for failure to fulfill a covenant for drilling wells in an oil and gas lease is for the benefit of the lessor and is enforceable only at his option: see Jones v. Natural Gas Co., 146 Pa. 204 ; Wills v. Manufacturers Natural Gas Co., 130 Pa. 222 . 1923A forfeiture clause, for nonpayment of rent or for failure to fulfill a covenant for drilling wells in an oil and gas lease, is for the benefit of the lessor and is enforceable only at his option: see Jones v. N. Gas Co., 146 Pa. 204 ; Wills v. Manufacturers N. Gas Co., 130 Pa. 222 . | 4 | 1893–1927 |
Craig v. Cosgrove
neutral
2 sentences1927In Craig v. Cosgrove, 277 Pa. 580, 584 , the Supreme Court held: “A forfeiture clause for non-payment of rent or for failure to fulfill a covenant for drilling wells in an oil and gas lease is for the benefit of the lessor and is enforceable only at his option: see Jones v. Natural Gas Co., 146 Pa. 204 ; Wills v. Manufacturers Natural Gas Co., 130 Pa. 222 . 1926The first objection, which we deem controlling, is “that upon the facts averred the plaintiff has a full, complete and adequate remedy at law.” Assuming, without deciding, that the decree of the United States District Court, entered Jan. 5, 1926, was sufficient ground for the forfeiture of the defendant’s lease, the forfeiture clause being solely for the benefit of the lessors, was enforcible only at their option, for such covenants are not self-enforcing: Craig et al. v. Cosgrove, 277 Pa. 580, 584 . | 3 | 1925–1927 |
United States v. Gurmeet Singh Dhinsa
green
2 sentences2023All Circuit Courts of Appeals considering the matter of a defendant who has removed an adverse witness have similarly concluded that “simple equity” and “common sense” support a forfeiture principle so that “a defendant who wrongfully procures the absence of a witness or potential witness may not assert confrontation rights as to that witness.” Id. at 652 (quoting United States v. White, 116 F.3d 903, 911 (D.C. 2008All Circuit Courts of Appeals considering the matter of a defendant who has removed an adverse witness have similarly concluded that “simple equity” and “common sense” support a forfeiture principle so that “a defendant who wrongfully procures the absence of a witness "or potential witness may not assert confrontation rights as to that witness.” Id. at 652 (quoting United States v. White, 116 F.3d 903, 911 (D.C.Cir.1997)). | 2 | 2008–2023 |
In Re Commonwealth, $803 Cash, U.S. Currency
green
2 sentences2012Incarcerated property owners are “entitled to a real opportunity, not merely an illusory one, to attend the forfeiture hearing and defend against the Commonwealth’s attempt to forfeit property removed from his person.” $803 Cash, 589 A.2d at 737 . 2004In In Re: Commonwealth, $803 Cash, U.S. Currency, 403 Pa.Super. 526 , 589 A.2d 735 (1991), the Superior Court reviewed forfeiture notice requirements and held a claimant was entitled to a real opportunity, not an illusory one, to attend a forfeiture hearing. | 2 | 2004–2012 |
Bilec v. Auburn & Associates, Inc. Pension Trust
green
2 sentences2001Similarly, the Bilec court generally ignored the right to amend and focused on the elements required for the addition of a noncompetition provision to the pension plan: “[w]hile we are not in agreement with the appellants’ blanket contention that all pre-ERISA forfeiture clauses are violative of the public policy of this Commonwealth, we do find that this particular forfeiture clause violates public policy of Pennsylvania in regards to the enforcement of covenants not to compete.” 403 Pa. Super. at 182 , 588 A.2d at 540 . 2001Similarly, the Bilec court generally ignored the right to amend and focused on the elements required for the addition of a noncompetition provision to the pension plan: “[w]hile we are not in agreement with the appellants’ blanket contention that all pre-ERISA forfeiture clauses are violative of the public policy of this Commonwealth, we do find that this particular forfeiture clause violates public policy of Pennsylvania in regards to the enforcement of covenants not to compete.” 403 Pa. Super. at 182 , 588 A.2d at 540 . | 2 | 2001–2001 |
One 1965 Buick 4 Door Sedan v. Commonwealth
green
2 sentences1986(See One 1965 Buick Four-Door Sedan v. Commonwealth, 46 Pa. Commw. 189 , 408 A.2d 157 (1979), which introduced the concept of prejudice into the analysis of whether a delay of three years before commencement of a forfeiture hearing violated the owner’s right to a hearing within a reasonable time). 1986(See One 1965 Buick Four-Door Sedan v. Commonwealth, 46 Pa. Commw. 189 , 408 A.2d 157 (1979), which introduced the concept of prejudice into the analysis of whether a delay of three years before commencement of a forfeiture hearing violated the owner’s right to a hearing within a reasonable time). | 2 | 1984–1986 |
Lichetti v. Conway
green
2 sentences1950If plaintiffs had been able to sell at the same price (Lichetti v. Conway, supra) or at an increased price (Sanders v. Brock, 230 Pa. 609 (1911)), they would have been entitled to pocket the sum paid on account as liquidated damages; but, where, as in the instant case, they sold at a lower price, they are entitled to be made whole, because, admittedly, the default was solely on the part of defendants. 1914The principle was recognized and thus expressed by Justice Elkin in McHenry v. Mitchell, 219 Pa. 297 : “A different question would be presented if the forfeiture clause required payment on a day certain, without reference to the presentation and delivery of a deed; in which event payment must be made within the time, whether the deed be delivered or tendered or not.” Here, by the terms of the contract, the plaintiff was under obligation to pay the whole of the purchase money before he was entitled to demand a deed: McCullough v. Boyd, 120 Pa. 552 ; Lichetti v. Conway, 44 Pa. Superior Ct. 71 . | 2 | 1914–1950 |
Thompson v. Christie
green
2 sentences1925The plaintiff, in seeking to enforce the forfeiture of the lease, is bound by the rule applied in Craig et al. v. Cos-grove, 277 Pa. 580, 584 , which is as follows: “As such a forfeiture clause is operative only at the option of the lessor, the lease continues a valid obligation until he declares it forfeited, and unless he acts promptly, his right to do so is gone. ‘The rule undoubtedly is that the right to declare a forfeiture must be distinctly reserved; that the proof of the happening of the event on which the right is to be exercised must be clear; that the party entitled to do so must ex 1923“The rule undoubtedly is that the right to declare a forfeiture must be distinctly reserved ; that the proof of the happening of the event on which the right is to be exercised must be clear; that the party entitled to do so must exercise his right promptly; and that the result of enforcing the forfeiture must not be unconscionable”: Thompson v. Christie, 138 Pa. 230, 249 ; and see Casinghead Gas Co. v. Osborn, 269 Pa. 395, 399 ; Ray v. Natural Gas Co., 138 Pa. 576 ; also McKean W. | 2 | 1923–1925 |
Ray v. West. Penna. N. Gas Co.
green
2 sentences1925The plaintiff, in seeking to enforce the forfeiture of the lease, is bound by the rule applied in Craig et al. v. Cos-grove, 277 Pa. 580, 584 , which is as follows: “As such a forfeiture clause is operative only at the option of the lessor, the lease continues a valid obligation until he declares it forfeited, and unless he acts promptly, his right to do so is gone. ‘The rule undoubtedly is that the right to declare a forfeiture must be distinctly reserved; that the proof of the happening of the event on which the right is to be exercised must be clear; that the party entitled to do so must ex 1923“The rule undoubtedly is that the right to declare a forfeiture must be distinctly reserved ; that the proof of the happening of the event on which the right is to be exercised must be clear; that the party entitled to do so must exercise his right promptly; and that the result of enforcing the forfeiture must not be unconscionable”: Thompson v. Christie, 138 Pa. 230, 249 ; and see Casinghead Gas Co. v. Osborn, 269 Pa. 395, 399 ; Ray v. Natural Gas Co., 138 Pa. 576 ; also McKean W. | 2 | 1923–1925 |
Casinghead Gas Co. v. Osborn
green
2 sentences1925The plaintiff, in seeking to enforce the forfeiture of the lease, is bound by the rule applied in Craig et al. v. Cos-grove, 277 Pa. 580, 584 , which is as follows: “As such a forfeiture clause is operative only at the option of the lessor, the lease continues a valid obligation until he declares it forfeited, and unless he acts promptly, his right to do so is gone. ‘The rule undoubtedly is that the right to declare a forfeiture must be distinctly reserved; that the proof of the happening of the event on which the right is to be exercised must be clear; that the party entitled to do so must ex 1923“The rule undoubtedly is that the right to declare a forfeiture must be distinctly reserved ; that the proof of the happening of the event on which the right is to be exercised must be clear; that the party entitled to do so must exercise his right promptly; and that the result of enforcing the forfeiture must not be unconscionable”: Thompson v. Christie, 138 Pa. 230, 249 ; and see Casinghead Gas Co. v. Osborn, 269 Pa. 395, 399 ; Ray v. Natural Gas Co., 138 Pa. 576 ; also McKean W. | 2 | 1923–1925 |
Merlino v. Philadelphia Board of Pensions & Retirement
green
1 sentence2022O’Neill, 2020 WL 6129169 , at *6-8; Merlino, 916 A.2d at 1236 . | 1 | 2022–2022 |
Noweck v. PennDOT
neutral
2 sentences2019The Commonwealth Court, however, concluded that the Commonwealth’s forfeiture claim was “neither initiated under, nor authorized by statute[.]” Id. 2019Specifically, the Commonwealth Court explained that common law forfeiture does not exist in Pennsylvania, and that “the Crimes Code does not authorize forfeiture as a sanction for this criminal conviction.” Id. (unpublished memorandum at 6). | 1 | 2019–2019 |
| Scilly v. Bramer green | 1 | 2016–2016 |
| Wolf v. Guffey neutral | 1 | 2016–2016 |
| Bertani v. Beck green | 1 | 2016–2016 |
| Giles v. California green | 1 | 2015–2015 |
| Commonwealth v. Durham green | 1 | 2014–2014 |
| Commonwealth v. One 1991 Cadillac Seville green | 1 | 2014–2014 |
| Commonwealth v. $8006.00 U.S. Currency Seized green | 1 | 2014–2014 |
| Commonwealth v. Real Property & Improvements at 2338 N. Beechwood Street green | 1 | 2014–2014 |
| Commonwealth v. Mayfield green | 1 | 2013–2013 |
| McGaffin v. Workers' Compensation Appeal Board green | 1 | 2007–2007 |
| Commonwealth v. Marshall green | 1 | 2004–2004 |
| Maritrans GP Inc. v. Pepper, Hamilton & Scheetz green | 1 | 2002–2002 |
| Cohen v. Lord green | 1 | 2001–2001 |
| Piercing Pagoda, Inc. v. Hoffner green | 1 | 2001–2001 |
| In Re Estate of Simpson green | 1 | 1993–1993 |
| Fisher v. Pittsburgh Public Parking Authority green | 1 | 1990–1990 |
| In re Maglisco green | 1 | 1990–1990 |
| Commonwealth v. One 1976 Oldsmobile Cutlass Supreme green | 1 | 1990–1990 |
| Spaulding v. Porter green | 1 | 1985–1985 |
| Richfield Oil Corp. v. Bloomfield green | 1 | 1985–1985 |
| First Nat. Bank of Wagener v. Glens Falls Ins. Co. of Glen Falls neutral | 1 | 1979–1979 |
| Palermo v. Old Tram Hunting Club neutral | 1 | 1979–1979 |
| Commonwealth v. Wayman green | 1 | 1975–1975 |
| McDanel v. McDanel green | 1 | 1975–1975 |
| Sanders v. Brock green | 1 | 1950–1950 |
| Duffield v. Hue green | 1 | 1927–1927 |
| Steiner v. Marks neutral | 1 | 1927–1927 |
| Kleppner v. Lemon green | 1 | 1927–1927 |
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.