operation rule (North Carolina) · Go Syfert
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operation rule in North Carolina

59 North Carolina opinions name it 2 courts 1855–2025 5 in the last five years

The cases below were cited by North Carolina 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 (15)

CaseFollowedCited
Shearl v. Town of Highlandsgreen
ncctapp · 2014 · cited in 5 North Carolina opinions naming this issue, 2017–2022
2 sentences

2022Since Petitioner obtained the Property on 29 June 2016, during the ineffective period of the Town’s attempts to regulate short-term rentals, it follows that Petitioner’s use first acquired a nonconforming character on the effective date of the 2019 Amendment. (4) The BOA Erred and Exceeded its Authority by Failing to Conclude Petitioner Established a Prima Facie Case of Nonconforming Use and Denying His Claim ¶ 28 “[T]he burden of proving the existence of an operation in violation of the local zoning ordinance is on [the Town].” Shearl v. Town of Highlands, 236 N.C.

2022Since Petitioner obtained the Property on 29 June 2016, during the ineffective period of the Town’s attempts to regulate short-term rentals, it follows that Petitioner’s use first acquired a nonconforming character on the effective date of the 2019 Amendment. (4) The BOA Erred and Exceeded its Authority by Failing to Conclude Petitioner Established a Prima Facie Case of Nonconforming Use and Denying His Claim ¶ 28 “[T]he burden of proving the existence of an operation in violation of the local zoning ordinance is on [the Town].” Shearl v. Town of Highlands, 236 N.C.

55
City of Winston-Salem v. Hoots Concrete Co.green
ncctapp · 1980 · cited in 6 North Carolina opinions naming this issue, 2010–2022
2 sentences

2017Standard of Review A. Review of the Board's order by the Superior Court "The [County bears] the burden of proving the existence of an operation in violation of its zoning ordinance." City of Winston-Salem v. Hoots Concrete Co. , 47 N.C.

2017Stat. § 153A-340(b)(1)-(2) and the express farm exemption in the Cumberland County Zoning Ordinance § 109 in concluding the Hamptons' use of their Property for a target range "is a reasonable and incidental use of the property as both a home and farm site" and the uncontested fact recited in the superior court's order that the Hamptons "obtained a farm number from the United States Department of Agriculture for the subject property." "The [County bears] the burden of proving the existence of an operation in violation of its zoning ordinance." City of Winston- Salem, 47 N.C.

26
State v. Braswellgreen
nc · 1985 · cited in 2 North Carolina opinions naming this issue, 1999–1999
2 sentences

1999We reviewed the operation of this test in the recent case of State v. Lee: [Defendant must first show that counsel’s performance fell below an objective standard of reasonableness as defined by professional norms. [State v. Braswell, 312 N.C. 553, 561-62 , 324 S.E.2d 241, 248 (1985).] . . .

1999We reviewed the operation of this test in the recent case of State v. Lee: [Defendant must first show that counsel’s performance fell below an objective standard of reasonableness as defined by professional norms. [State v. Braswell, 312 N.C. 553, 561-62 , 324 S.E.2d 241, 248 (1985).] . . .

22
State v. Mitchellgreen
nc · 1970 · cited in 2 North Carolina opinions naming this issue, 1983–1984
2 sentences

1984“An assertion ... by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” State v. Mitchell, 276 N.C. 404, 410 , 172 S.E. 2d 527, 530 (1970).

1984“An assertion ... by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” State v. Mitchell, 276 N.C. 404, 410 , 172 S.E. 2d 527, 530 (1970).

22
Crescent City Live Stock Co. v. Batchers' Union Slaughter-House Co.green
scotus · 1887 · cited in 2 North Carolina opinions naming this issue, 1921–1935
2 sentences

1935See a learned discussion of this subject in Orescent City Livestock v. Butchers’ Union, 120 U. S., 141 -149, et seq.; 18 R.

1921See a learned discussion of this subject in Crescent City Livestock v. Butcher’s Union, 120 U. S., 141 -149 et seq.; 18 R.

22
State v. Foddrellgreen
nc · 1977 · cited in 2 North Carolina opinions naming this issue, 1978–1989
2 sentences

1989"An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this state, does not prevent the operation of this rule." State v. Foddrell, 291 N.C. 546, 557 , 231 S.E.2d 618, 626 (1977).

1989"An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this state, does not prevent the operation of this rule." State v. Foddrell, 291 N.C. 546, 557 , 231 S.E.2d 618, 626 (1977).

12
Hawkins v. M & J FINANCE CORP.green
nc · 1953 · cited in 2 North Carolina opinions naming this issue, 1955–1962
2 sentences

1962The general principles governing the operation of the doctrine of equitable estoppel are stated by Johnson, J., in Hawkins v. Finance Corp., 238 N.C. 174 , 77 S.E. 2d 669 .

1962The general principles governing the operation of the doctrine of equitable estoppel are stated by Johnson, J., in Hawkins v. Finance Corp., 238 N.C. 174 , 77 S.E. 2d 669 .

12
Jacobson v. Massachusettsgreen
scotus · 1905 · cited in 1 North Carolina opinions naming this issue, 2025–2025
2 sentences

2025See Jacobson, 197 U.S. at 26 , 25 S. Ct. at 361 (“Real liberty for all could not exist under the operation of a principle which recognizes the right of each individual person to use his own, . . . regardless of the injury that may be done to others.”); Hay, 126 N.C. at 1000 , 35 S.E. at 460 (“All government is a necessary evil.

2025See Jacobson, 197 U.S. at 26 , 25 S. Ct. at 361 (“Real liberty for all could not exist under the operation of a principle which recognizes the right of each individual person to use his own, . . . regardless of the injury that may be done to others.”); Hay, 126 N.C. at 1000 , 35 S.E. at 460 (“All government is a necessary evil.

11
Hutchins v. Durham.green
nc · 1904 · cited in 1 North Carolina opinions naming this issue, 2025–2025
2 sentences

2025It is, however, a much lesser evil than the intolerable state of things which would exist if there were no government to bridle the absolute right of every man to do that which seems right in his own eyes . . . .”); Hutchins, 137 N.C. at 71–72, 49 S.E. at 47 (“That [the plaintiff’s daughter] cannot safely be vaccinated may make it preferable that she herself should run the risk of taking the smallpox, but is no reason that the children of the public school should be exposed to like risk . . . .”).

2025It is, however, a much lesser evil than the intolerable state of things which would exist if there were no government to bridle the absolute right of every man to do that which seems right in his own eyes . . . .”); Hutchins, 137 N.C. at 71–72, 49 S.E. at 47 (“That [the plaintiff’s daughter] cannot safely be vaccinated may make it preferable that she herself should run the risk of taking the smallpox, but is no reason that the children of the public school should be exposed to like risk . . . .”).

11
State v. . Haygreen
nc · 1900 · cited in 1 North Carolina opinions naming this issue, 2025–2025
2 sentences

2025See Jacobson, 197 U.S. at 26 , 25 S. Ct. at 361 (“Real liberty for all could not exist under the operation of a principle which recognizes the right of each individual person to use his own, . . . regardless of the injury that may be done to others.”); Hay, 126 N.C. at 1000 , 35 S.E. at 460 (“All government is a necessary evil.

2025See Jacobson, 197 U.S. at 26 , 25 S. Ct. at 361 (“Real liberty for all could not exist under the operation of a principle which recognizes the right of each individual person to use his own, . . . regardless of the injury that may be done to others.”); Hay, 126 N.C. at 1000 , 35 S.E. at 460 (“All government is a necessary evil.

11
Drake v. . Spencergreen
nc · 1920 · cited in 1 North Carolina opinions naming this issue, 2010–2010
1 sentence

2010Notably, the policy specifically exempted coverage resulting from loss or damage due to the “Lis Pendens against Francesca Agnoli by Thomas Michael Kelley, in the amount (not given), filed 11/28/2007 in, ID number D7M142 in Davie County Records.” “[W]here one buys from a litigant with full notice or knowledge of the suit and of its nature and purpose and the specific property to be affected, he is concluded or his purchase will be held ineffective and fraudulent as to decree rendered in the cause and the rights thereby established.” Morris v. Basnight, 179 N.C. 298, 303 , 102 S.E. 389, 392 (19

11
Edelman v. Californiagreen
scotus · 1953 · cited in 1 North Carolina opinions naming this issue, 1983–1983
2 sentences

1983See Edelman v. California, 344 U.S. 357 , 73 S.Ct. 293 , 97 L.Ed. 387 (1953); State v. Parks, 290 N.C. 748 , 228 S.E.2d 248 (1976).

1983See Edelman v. California, 344 U.S. 357 , 73 S.Ct. 293 , 97 L.Ed. 387 (1953); State v. Parks, 290 N.C. 748 , 228 S.E.2d 248 (1976).

11
Shoe v. Hoodgreen
nc · 1960 · cited in 1 North Carolina opinions naming this issue, 1980–1980
2 sentences

1980Tew v. Runnels, supra. To avoid the operation of the doctrine, the owner of the vehicle must prove that he relinquished, “for the time being, the incidents of ownership and the right to control the manner and methods of its use.” Shoe v. Hood, 251 N.C. 719, 724 , 112 S.E. 2d 543, 548 (1960).

1980Tew v. Runnels, supra. To avoid the operation of the doctrine, the owner of the vehicle must prove that he relinquished, “for the time being, the incidents of ownership and the right to control the manner and methods of its use.” Shoe v. Hood, 251 N.C. 719, 724 , 112 S.E. 2d 543, 548 (1960).

11
Mann v. . Manngreen
· 1918 · cited in 1 North Carolina opinions naming this issue, 1977–1977
11
Swann v. . Myersgreen
· 1876 · cited in 1 North Carolina opinions naming this issue, 1891–1891
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (65)

CaseCitedYears
State v. Lowery green
nc · 1975
2 sentences

1987An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” See State v. Lowery, 286 N.C. 698 , 213 S.E. 2d 255 (1975); State v. Gurley, 283 N.C. 541 , 196 S.E. 2d 725 (1973); 4 Strong’s North Carolina Index 3d Criminal Law § 162 (1976).

1987An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” See State v. Lowery, 286 N.C. 698 , 213 S.E. 2d 255 (1975); State v. Gurley, 283 N.C. 541 , 196 S.E. 2d 725 (1973); 4 Strong’s North Carolina Index 3d Criminal Law § 162 (1976).

41977–1987
Puckett v. . Morgan green
nc · 1912
2 sentences

1954In Puckett v. Morgan, 158 N.C. 344 , 74 S.E. 15 , the devise was: “I leave Martha Morgan . . . the Rachel tract . . . during her life, then to her bodily heirs, if any; but if she have none, back to her brothers and sisters.” The Court construed “bodily heirs” to mean children or issue living at her death, the devise therefore being outside the operation of the rule in Shelley’s case.

1954In Puckett v. Morgan, 158 N.C. 344 , 74 S.E. 15 , the devise was: “I leave Martha Morgan . . . the Rachel tract . . . during her life, then to her bodily heirs, if any; but if she have none, back to her brothers and sisters.” The Court construed “bodily heirs” to mean children or issue living at her death, the devise therefore being outside the operation of the rule in Shelley’s case.

41922–1954
State v. Gurley green
nc · 1973
2 sentences

1987An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” See State v. Lowery, 286 N.C. 698 , 213 S.E. 2d 255 (1975); State v. Gurley, 283 N.C. 541 , 196 S.E. 2d 725 (1973); 4 Strong’s North Carolina Index 3d Criminal Law § 162 (1976).

1987An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” See State v. Lowery, 286 N.C. 698 , 213 S.E. 2d 255 (1975); State v. Gurley, 283 N.C. 541 , 196 S.E. 2d 725 (1973); 4 Strong’s North Carolina Index 3d Criminal Law § 162 (1976).

31977–1987
Strickland v. Washington green
scotus · 1984
2 sentences

1999Second, once defendant satisfies the first prong, he must show that the error committed was so serious that a reasonable probability exists that the trial result would have been different absent the error. [Strickland, 466 U.S. at 698 , 80 L.

1999Second, once defendant satisfies the first prong, he must show that the error committed was so serious that a reasonable probability exists that the trial result would have been different absent the error. [Strickland, 466 U.S.] at 695, 80 L.

21999–1999
Elledge v. Welch green
nc · 1953
2 sentences

1968“And the fact that deeds exchanged between tenants in common in effecting partition may be regular form deeds of bargain and sale, with the usual covenants of title, seizen [sic], and warranty, ordinarily does not affect the operation of the rule that a partition deed creates no new, different, or additional title.” Elledge v. Welch, 238 N.C. 61, 67 , 76 S.E. 2d 340, 344 , and cases cited.

1968“And the fact that deeds exchanged between tenants in common in effecting partition may be regular form deeds of bargain and sale, with the usual covenants of title, seizen [sic], and warranty, ordinarily does not affect the operation of the rule that a partition deed creates no new, different, or additional title.” Elledge v. Welch, 238 N.C. 61, 67 , 76 S.E. 2d 340, 344 , and cases cited.

21968–1968
Doggett v. . Vaughan neutral
nc · 1930
2 sentences

1939Hence, according to a number of decisions this would seem to take the case out of the operation of the rule in Shelley’s case, and assign it to that class of cases of which the following may be said to be fairly illustrative: Rollins v. Keel, 115 N. C., 68 , 20 S. E., 209 ; Puckett v. Morgan, 158 N. C., 344 , 74 S. E., 15 ; Jones v. Whichard, 163 N. C., 241 , 79 S. E., 503 ; Pugh v. Allen, 179 N. C., 307 , 102 S. E., 394 ; Blackledge v. Simmons, 180 N. C., 535 , 105 S. E., 202 ; Wallace v. Wallace, 181 N. C., 158 , 106 S. E., 501 ; Reid v. Neal, 182 N. C., 192 , 108 S. E., 769 ; Hampton v. Gri

1939Hence, according to a number of decisions this would seem to take the case out of the operation of the rule in Shelley’s case, and assign it to that class of cases of which the following may be said to be fairly illustrative: Rollins v. Keel, 115 N. C., 68 , 20 S. E., 209 ; Puckett v. Morgan, 158 N. C., 344 , 74 S. E., 15 ; Jones v. Whichard, 163 N. C., 241 , 79 S. E., 503 ; Pugh v. Allen, 179 N. C., 307 , 102 S. E., 394 ; Blackledge v. Simmons, 180 N. C., 535 , 105 S. E., 202 ; Wallace v. Wallace, 181 N. C., 158 , 106 S. E., 501 ; Reid v. Neal, 182 N. C., 192 , 108 S. E., 769 ; Hampton v. Gri

21937–1939
Carver v. . Brady neutral
nc · 1889
2 sentences

1916Carver v. Brady , 104 N.C. 219 ; Cushman v. Sutphen , 42 Ill. 255 .

1916Carver v. Brady, 104 N. C., 219 ; Cushman v. Sutphen, 42 Ill., 255 . ' In reaching our conclusion we have followed the unbroken line of precedents in this Court for half a century, as well as the overwhelming weight of authority in this country as well as in England.

21916–1916
Davis v. Siloo Inc. green
nc · 1980
2 sentences

2017App. 405 , 414, 267 S.E.2d 569 , 575, disc. review denied , 301 N.C. 234 , 283 S.E.2d 131 (1980).

2017App. 405 , 414, 267 S.E.2d 569 , 575, disc. review denied , 301 N.C. 234 , 283 S.E.2d 131 (1980).

12017–2017
Morris v. . Basnight green
nc · 1920
1 sentence

2010Notably, the policy specifically exempted coverage resulting from loss or damage due to the “Lis Pendens against Francesca Agnoli by Thomas Michael Kelley, in the amount (not given), filed 11/28/2007 in, ID number D7M142 in Davie County Records.” “[W]here one buys from a litigant with full notice or knowledge of the suit and of its nature and purpose and the specific property to be affected, he is concluded or his purchase will be held ineffective and fraudulent as to decree rendered in the cause and the rights thereby established.” Morris v. Basnight, 179 N.C. 298, 303 , 102 S.E. 389, 392 (19

12010–2010
Chevron Oil Co. v. Huson red
scotus · 1971
2 sentences

1991Chevron, 404 U.S. at 106-107 , 92 S.Ct. at 355 , 30 L.Ed.2d at 306 .

1991Chevron, 404 U.S. at 106-107 , 92 S.Ct. at 355 , 30 L.Ed.2d at 306 .

11991–1991
State v. Hammond green
nc · 1983
2 sentences

1987The present appeal is on all fours with State v. Hammond, 307 N.C. 662 , 300 S.E. 2d 361 (1983) (holding that failure to renew objection to in-court identification testimony waived appellate review).

1987The present appeal is on all fours with State v. Hammond, 307 N.C. 662 , 300 S.E. 2d 361 (1983) (holding that failure to renew objection to in-court identification testimony waived appellate review).

11987–1987
Carolina v. Parks green
nc · 1976
2 sentences

1983See Edelman v. California, 344 U.S. 357 , 73 S.Ct. 293 , 97 L.Ed. 387 (1953); State v. Parks, 290 N.C. 748 , 228 S.E.2d 248 (1976).

1983See Edelman v. California, 344 U.S. 357 , 73 S.Ct. 293 , 97 L.Ed. 387 (1953); State v. Parks, 290 N.C. 748 , 228 S.E.2d 248 (1976).

11983–1983
State v. Monk green
nc · 1976
2 sentences

1982(Citation omitted.) Id. at 53 , 229 S.E. 2d at 173-74 .

1982(Citation omitted.) Id. at 53 , 229 S.E. 2d at 173-74 .

11982–1982
State v. Jones green
nc · 1972
2 sentences

1978An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” See also State v. Lowery, 286 N.C. 698 , 213 S.E. 2d 255 (1975), modified on other grounds, 428 U.S. 902 , 49 L.Ed. 2d 1206 , 96 S.Ct. 3203 (1976); State v. Jones, 280 N.C. 322 , 185 S.E. 2d 858 (1972).

1978An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” See also State v. Lowery, 286 N.C. 698 , 213 S.E. 2d 255 (1975), modified on other grounds, 428 U.S. 902 , 49 L.Ed. 2d 1206 , 96 S.Ct. 3203 (1976); State v. Jones, 280 N.C. 322 , 185 S.E. 2d 858 (1972).

11978–1978
Henderson v. North Carolina green
scotus · 1976
1 sentence

1978An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” See also State v. Lowery, 286 N.C. 698 , 213 S.E. 2d 255 (1975), modified on other grounds, 428 U.S. 902 , 49 L.Ed. 2d 1206 , 96 S.Ct. 3203 (1976); State v. Jones, 280 N.C. 322 , 185 S.E. 2d 858 (1972).

11978–1978
Noell v. North Carolina neutral
scotus · 1976
1 sentence

1978An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” See also State v. Lowery, 286 N.C. 698 , 213 S.E. 2d 255 (1975), modified on other grounds, 428 U.S. 902 , 49 L.Ed. 2d 1206 , 96 S.Ct. 3203 (1976); State v. Jones, 280 N.C. 322 , 185 S.E. 2d 858 (1972).

11978–1978
Dillard v. North Carolina green
scotus · 1976
1 sentence

1978An assertion in this Court by the appellant that evidence, to the introduction of which he interposed no objection, was obtained in violation of his rights under the Constitution of the United States, or under the Constitution of this State, does not prevent the operation of this rule.” See also State v. Lowery, 286 N.C. 698 , 213 S.E. 2d 255 (1975), modified on other grounds, 428 U.S. 902 , 49 L.Ed. 2d 1206 , 96 S.Ct. 3203 (1976); State v. Jones, 280 N.C. 322 , 185 S.E. 2d 858 (1972).

11978–1978
Wright v. Vaden green
nc · 1966
11968–1968
In Re the Will of Covington green
nc · 1960
11962–1962
Wilson v. Commercial Finance Co. green
nc · 1954
11962–1962
Steele v. . Beaty green
nc · 1939
11955–1955
Tynch v. Briggs neutral
nc · 1949
11954–1954
Paine v. Drew neutral
nh · 1860
11953–1953
Duckett v. . Lyda green
nc · 1943
11953–1953
Harrison v. . Ray green
nc · 1891
11953–1953
Ruggles v. Keeler green
nysupct · 1808
11953–1953
Blackledge v. . Simmons neutral
scotus · 1920
11939–1939
Wallace v. . Wallace neutral
nc · 1921
11939–1939
Jones v. . Whichard green
nc · 1913
11939–1939
Gurganus v. . Bullock neutral
nc · 1936
11939–1939
Pugh v. . Allen green
· 1920
11939–1939
Welch v. . Gibson neutral
nc · 1927
11939–1939
Rollins v. . Keel neutral
· 1894
11939–1939
Reid v. . Neal green
nc · 1921
11939–1939
Morehead v. . Montague neutral
nc · 1931
11937–1937
Nobles v. . Nobles neutral
nc · 1919
11937–1937
Whitehurst v. . Bowers neutral
nc · 1934
11937–1937
Parrish v. . Hodge neutral
nc · 1919
11937–1937
Martin v. . Knowles green
nc · 1928
11937–1937
Merchants National Bank v. Dortch neutral
nc · 1923
11937–1937

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 1A-1 (6) NC § N.C. Gen. Stat. § 160D-406 (4) NC § N.C. Gen. Stat. § 7A-27 (4) NC § N.C. Gen. Stat. § 15A-1446 (3) NC § N.C. Gen. Stat. § 8C-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

CA 154 (1857–2025) NY 132 (1823–2024) PA 89 (1834–2020) IL 86 (1864–2023) TX 84 (1860–2024) AL 77 (1846–2018) NC 59 (1855–2025) CT 57 (1874–2022) FL 52 (1924–2021) MD 50 (1873–2023) MO 46 (1879–2003) IA 46 (1864–2018) IN 39 (1833–2020) NJ 37 (1903–2002) WA 37 (1890–2017) NE 37 (1883–2017) MA 31 (1894–2014) CO 29 (1890–2020) OK 26 (1896–2012) NM 24 (1924–2010) KS 23 (1888–2013) OR 23 (1900–2017) OH 22 (1907–2019) GA 21 (1909–2020) VA 21 (1874–2023) KY 20 (1883–1997) MI 19 (1851–2025) AR 18 (1915–2003) WV 16 (1907–2016) MN 16 (1877–2019) AZ 16 (1934–2008) WI 14 (1894–2020) MS 14 (1875–2014) WY 13 (1899–2019) TN 13 (1906–2014) LA 11 (1860–2010) UT 10 (1987–2024) DC 10 (1914–2019) DE 8 (1880–2016) MT 7 (1923–1999) RI 6 (1873–2004) ID 6 (1918–1997) SD 5 (1897–2022) ND 5 (1976–1996) NH 5 (1853–1994) AK 5 (1967–1983) NV 5 (1867–1936) SC 4 (1879–1969) ME 4 (1897–1983) HI 4 (1958–1987)

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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