home rule (Nebraska) · Go Syfert
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home rule in Nebraska

59 Nebraska opinions name it 3 courts 1922–2020 0 in the last five years

The cases below were cited by Nebraska 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
Omaha Parking Authority v. City of Omahagreen
neb · 1956 · cited in 8 Nebraska opinions naming this issue, 1972–2007
2 sentences

1997"This has been construed to mean that a provision of a home rule charter takes precedence over a conflicting state statute in instances of local municipal concern, but when the Legislature enacts a law affecting municipal affairs which is of state-wide concern, the state law takes precedence over any municipal action taken under the home rule charter." Omaha Parking Authority v. City of Omaha , 163 Neb. 97 , 104 , 77 N.W.2d 862 , 868 (1956).

1997"This has been construed to mean that a provision of a home rule charter takes precedence over a conflicting state statute in instances of local municipal concern, but when the Legislature enacts a law affecting municipal affairs which is of state-wide concern, the state law takes precedence over any municipal action taken under the home rule charter." Omaha Parking Authority v. City of Omaha , 163 Neb. 97 , 104 , 77 N.W.2d 862 , 868 (1956).

38
Axberg v. City of Lincolngreen
neb · 1942 · cited in 8 Nebraska opinions naming this issue, 1943–1985
2 sentences

1985In Axberg v. City of Lincoln, 141 Neb. 55, 58 , 2 N.W.2d 613, 614-15 (1942), we observed: The purpose of the home rule charter provision of the Constitution was to render the cities adopting such charter provisions as nearly independent of state legislation as was possible.

1985In Axberg v. City of Lincoln, 141 Neb. 55, 58 , 2 N.W.2d 613, 614-15 (1942), we observed: The purpose of the home rule charter provision of the Constitution was to render the cities adopting such charter provisions as nearly independent of state legislation as was possible.

28
Mollner v. City of Omahagreen
neb · 1959 · cited in 4 Nebraska opinions naming this issue, 1964–2003
2 sentences

2003The charter of a home rule city is its constitution.” Mollner v. City of Omaha, 169 Neb. 44, 50 , 98 N.W.2d 33, 37 (1959).

2003The charter of a home rule city is its constitution.” Mollner v. City of Omaha, 169 Neb. 44, 50 , 98 N.W.2d 33, 37 (1959).

24
Consumers Coal Co. v. City of Lincolngreen
neb · 1922 · cited in 9 Nebraska opinions naming this issue, 1930–2006
2 sentences

2006The very purpose of a home rule charter is to permit municipalities to *361 exercise “ ‘every power connected with the proper and efficient government of the municipality, including those powers so connected, which might lawfully be delegated to it by the legislature, without waiting for such delegation. ’ ” In re Application of Lincoln Electric System, 265 Neb. 70, 82 , 655 N.W.2d 363, 373 (2003), quoting Consumers Coal Co. v. City of Lincoln, 109 Neb. 51 , 189 N.W. 643 (1922).

2006The very purpose of a home rule charter is to permit municipalities to *361 exercise “ ‘every power connected with the proper and efficient government of the municipality, including those powers so connected, which might lawfully be delegated to it by the legislature, without waiting for such delegation. ’ ” In re Application of Lincoln Electric System, 265 Neb. 70, 82 , 655 N.W.2d 363, 373 (2003), quoting Consumers Coal Co. v. City of Lincoln, 109 Neb. 51 , 189 N.W. 643 (1922).

19
City of Millard v. City of Omahagreen
neb · 1970 · cited in 4 Nebraska opinions naming this issue, 1977–1982
2 sentences

1977The Nebraska Supreme Court, in City of Milford v. City of Omaha, 185 Neb. 617 , 177 N.W.2d 576 (1970), held that the Legislature may provide for the dissolution of a municipal corporation even though the municipal corporation had adopted a home rule charter.

1977The Nebraska Supreme Court, in City of Milford v. City of Omaha, 185 Neb. 617 , 177 N.W.2d 576 (1970), held that the Legislature may provide for the dissolution of a municipal corporation even though the municipal corporation had adopted a home rule charter.

14
Stalder v. Anne T. (In Re S.T.)green
neb · 2018 · cited in 2 Nebraska opinions naming this issue, 2018–2018
2 sentences

2018Cite as 300 Neb. 72 [7] For a state to exercise jurisdiction over a child custody dispute, it must either be the home state as defined by the UCCJEA or fall under limited exceptions to the home state requirement specified by the UCCJEA.10 Generally speaking, § 43-1238(a)(1) grants jurisdiction to the home state of the child and § 43-1238(a)(2) through (4) sets out the exceptions under which a court will have jurisdiction, even if it is not in the child’s home state.11 Here, because the county court found Nebraska was the home state under the UCCJEA, it did not address any of the exceptions und

2018See In re Guardianship of S.T. , 300 Neb. 72 , 912 N.W.2d 262 (2018).

12
Dell v. City of Lincolngreen
neb · 1960 · cited in 2 Nebraska opinions naming this issue, 1982–2006
2 sentences

2006See Dell v. City of Lincoln, 170 Neb. 176 , 102 N.W.2d 62 (1960).

2006See Dell v. City of Lincoln, 170 Neb. 176 , 102 N.W.2d 62 (1960).

12
Lincoln Electric System v. Nebraska Public Service Commissiongreen
neb · 2003 · cited in 2 Nebraska opinions naming this issue, 2005–2006
2 sentences

2006Relying on In re Application of Lincoln Electric System, 265 Neb. 70 , 655 N.W.2d 363 (2003), the court determined that the City’s home rule charter was a limitation of powers charter, giving the City the power to take certain actions without explicit, authorizing language from the Legislature.

2006Relying on In re Application of Lincoln Electric System, 265 Neb. 70 , 655 N.W.2d 363 (2003), the court determined that the City’s home rule charter was a limitation of powers charter, giving the City the power to take certain actions without explicit, authorizing language from the Legislature.

12
Jacobberger v. Terrygreen
neb · 1982 · cited in 2 Nebraska opinions naming this issue, 1982–2005
2 sentences

1982In the recent case of Jacobberger v. Terry, 211 Neb. 878, 881 , 320 N.W.2d 903, 905 (1982), we said: “ ‘[A] provision of a home rule charter takes precedence over a conflicting state statute in instances of local municipal concern, but when the Legislature enacts a law affecting municipal affairs which is of state-wide concern, the state law takes precedence over any municipal action taken under the home rule charter.’ Omaha *895 Parking Authority v. City of Omaha, 163 Neb. 97, 104 , 77 N.W.2d 862, 868 (1956).” In the Jacobberger case we further noted: “ ‘Whether or not an act of the legislatu

1982In the recent case of Jacobberger v. Terry, 211 Neb. 878, 881 , 320 N.W.2d 903, 905 (1982), we said: “ ‘[A] provision of a home rule charter takes precedence over a conflicting state statute in instances of local municipal concern, but when the Legislature enacts a law affecting municipal affairs which is of state-wide concern, the state law takes precedence over any municipal action taken under the home rule charter.’ Omaha *895 Parking Authority v. City of Omaha, 163 Neb. 97, 104 , 77 N.W.2d 862, 868 (1956).” In the Jacobberger case we further noted: “ ‘Whether or not an act of the legislatu

12
Young v. City of Seattlegreen
wash · 1948 · cited in 2 Nebraska opinions naming this issue, 1959–1982
2 sentences

1982See Young v. Seattle, 30 Wash.2d 357 , 191 P.2d 273 (1948).

1982See Young v. Seattle, 30 Wash.2d 357 , 191 P.2d 273 (1948).

12
Carter v. Cartergreen
neb · 2008 · cited in 1 Nebraska opinions naming this issue, 2016–2016
2 sentences

2016See Carter v. Carter, 276 Neb. 840 , 758 N.W.2d 1 (2008).

2016See Carter v. Carter, 276 Neb. 840 , 758 N.W.2d 1 (2008).

11
Hall v. Cox Cable of Omaha, Inc.green
neb · 1982 · cited in 1 Nebraska opinions naming this issue, 1985–1985
11
Arrow Club, Inc. v. Nebraska Liquor Control Commissiongreen
neb · 1964 · cited in 1 Nebraska opinions naming this issue, 1982–1982
11
Belitz v. City of Omahagreen
neb · 1961 · cited in 1 Nebraska opinions naming this issue, 1964–1964
11
City of Wewoka v. Rodmangreen
okla · 1935 · cited in 1 Nebraska opinions naming this issue, 1942–1942
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (45)

CaseCitedYears
Nagle v. City of Grand Island green
neb · 1943
2 sentences

1959In Nagle v. City of Grand Island, 144 Neb. 67 , 12 N. W. 2d 540 , we held that the procedure in condemnation is a matter of state-wide concern: “When the legislature has enacted a law affecting municipal affairs, but which are also of state-wide concern, such law takes precedence over any provisions in a home rule charter and the provisions of the charter must yield. * * * Eminent domain is the right or power to take private property for a public use.

1959In Nagle v. City of Grand Island, 144 Neb. 67 , 12 N. W. 2d 540 , we held that the procedure in condemnation is a matter of state-wide concern: “When the legislature has enacted a law affecting municipal affairs, but which are also of state-wide concern, such law takes precedence over any provisions in a home rule charter and the provisions of the charter must yield. * * * Eminent domain is the right or power to take private property for a public use.

51951–1963
Carlberg v. Metcalfe green
neb · 1930
2 sentences

1937In Consumers Coal Co. v. City of Lincoln, 109 Neb. 51 , 189 N. W. 643 , opinion by Redick, district judge, referring to home rule charters, the second point of the syllabus says: “The purpose of the constitutional provision (as to home rule charters) is to render cities independent of state legislation as to all subjects which are of strictly municipal concern; therefore, as to such matters general laws applicable to cities yield to the charter.” In Carlberg v. Metcalfe, 120 Neb. 481 , 234 N. W. 87 , Judge Day reviews briefly some of the home rule charter cases from our state and cites cases f

1937In Consumers Coal Co. v. City of Lincoln, 109 Neb. 51 , 189 N. W. 643 , opinion by Redick, district judge, referring to home rule charters, the second point of the syllabus says: “The purpose of the constitutional provision (as to home rule charters) is to render cities independent of state legislation as to all subjects which are of strictly municipal concern; therefore, as to such matters general laws applicable to cities yield to the charter.” In Carlberg v. Metcalfe, 120 Neb. 481 , 234 N. W. 87 , Judge Day reviews briefly some of the home rule charter cases from our state and cites cases f

41937–1985
Schroeder v. Zehrung green
neb · 1922
2 sentences

1942I quote from a few of the Nebraska decisions: In Consumers Coal Co. v. City of Lincoln, 109 Neb. 51 , 189 N. W. 643 , the court held: “The purpose of the consti tutional provision is to render cities independent of state legislation as to all subjects which are of strictly municipal concern; therefore, as to such matters general laws applicable to cities yield to the charter.” In Schroeder v. Zehrung, 108 Neb. 573 , 188 N. W. 237 , the following language appears in the opinion: “If a city, after having adopted a home rule charter, was still to be subject to all the provisions of the former leg

1942I quote from a few of the Nebraska decisions: In Consumers Coal Co. v. City of Lincoln, 109 Neb. 51 , 189 N. W. 643 , the court held: “The purpose of the consti tutional provision is to render cities independent of state legislation as to all subjects which are of strictly municipal concern; therefore, as to such matters general laws applicable to cities yield to the charter.” In Schroeder v. Zehrung, 108 Neb. 573 , 188 N. W. 237 , the following language appears in the opinion: “If a city, after having adopted a home rule charter, was still to be subject to all the provisions of the former leg

41926–1942
State ex rel. Fischer v. City of Lincoln green
neb · 1939
2 sentences

1982Fischer v. City of Lincoln, 137 Neb. 97 , 288 N.W. 499 (1939), wherein we noted that “In adopting a home rule charter, however, the city had the right to make provision therein for any form of local govern ment it desired, which was not in conflict with the letter and spirit of our Constitution.

1982Fischer v. City of Lincoln, 137 Neb. 97 , 288 N.W. 499 (1939), wherein we noted that “In adopting a home rule charter, however, the city had the right to make provision therein for any form of local govern ment it desired, which was not in conflict with the letter and spirit of our Constitution.

31942–1982
Eppley Hotels Co. v. City of Lincoln neutral
neb · 1937
2 sentences

1979If a home rule charter means what the words imply, why were not the people of Lincoln authorized by the Constitution to hold a charter convention or to have a local constitutional convention of their own and to vote upon the amendments to any charter by which they were formerly governed and make the charter thereby formed supersede the charter formerly existing, so long as they did not thereby violate the Constitution or general laws of the state? " (Emphasis added.) 133 Neb. at 554 -555 .

1979While a home rule charter adopted pursuant to the constitutional provision may not contravene any provisions of the Constitution or of any general statute enacted by the legislature, it is, in all other respects, binding and controlling. . . . " (Emphasis added.) 133 Neb. at 555 .

31959–1979
Sandell v. City of Omaha green
neb · 1927
2 sentences

1959The power to act in each instance is constitutional but the action taken under the power is legislative.” Niklaus v. Miller, 159 Neb. 301 , 66 N. W. 2d 824 , speaking of a home rule charter, said: “As to all subjects of strictly local municipal concern such charter cities operate free and independent of state legislation.” Sandell v. City of Omaha, 115 Neb. 861 , 215 N. W. 135 , states: “The trend of judicial pronouncement appears to sanction an enlargement of the powers of the municipality for self-government, within constitutional limits, rather than a curtailment of such powers.

1959The power to act in each instance is constitutional but the action taken under the power is legislative.” Niklaus v. Miller, 159 Neb. 301 , 66 N. W. 2d 824 , speaking of a home rule charter, said: “As to all subjects of strictly local municipal concern such charter cities operate free and independent of state legislation.” Sandell v. City of Omaha, 115 Neb. 861 , 215 N. W. 135 , states: “The trend of judicial pronouncement appears to sanction an enlargement of the powers of the municipality for self-government, within constitutional limits, rather than a curtailment of such powers.

31934–1959
State ex rel. City of Lincoln v. Johnson green
neb · 1928
2 sentences

1954Consumers Coal Co. v. City of Lincoln, 109 Neb. 51 ; Sandell v. City of Omaha, 115 Neb. 861 ; State v. Johnson, 117 Neb. 301 ; Salsbury v. City of Lincoln, 117 Neb. 465 .” The same would be true here where the construction of a reservoir is involved.

1930Up to the present time this court has decided, in cases arising under a home rule charter adopted under the constitutional provision, that voting municipal bonds for an aviation field (State v. Johnson, 117 Neb. 301 ) and that improving the streets, alleys and highways within the corporate limits of a city (Salsbury v. City of Lincoln, 117 Neb. 465 ) are subjects of strictly municipal concern.

31930–1954
Salsbury v. City of Lincoln green
neb · 1928
2 sentences

1954Consumers Coal Co. v. City of Lincoln, 109 Neb. 51 ; Sandell v. City of Omaha, 115 Neb. 861 ; State v. Johnson, 117 Neb. 301 ; Salsbury v. City of Lincoln, 117 Neb. 465 .” The same would be true here where the construction of a reservoir is involved.

1930Up to the present time this court has decided, in cases arising under a home rule charter adopted under the constitutional provision, that voting municipal bonds for an aviation field (State v. Johnson, 117 Neb. 301 ) and that improving the streets, alleys and highways within the corporate limits of a city (Salsbury v. City of Lincoln, 117 Neb. 465 ) are subjects of strictly municipal concern.

31930–1954
Munch v. Tusa green
neb · 1941
2 sentences

1956Upon the adoption of its charter the legislative act of 1921 “lost its qualities as a statutory charter or law imposed by the sovereign power of the state, and in lieu thereof, by virtue of an explicit constitutional grant, its terms then existing became a home rule charter created and to be thereafter continued in force at the will of the grantee municipality lawfully expressed, every section of which was expressly made subject to its own lawful amendments.” Munch v. Tusa, 140 Neb. 457 , 300 N. W. 385 .

1956Upon the adoption of its charter the legislative act of 1921 “lost its qualities as a statutory charter or law imposed by the sovereign power of the state, and in lieu thereof, by virtue of an explicit constitutional grant, its terms then existing became a home rule charter created and to be thereafter continued in force at the will of the grantee municipality lawfully expressed, every section of which was expressly made subject to its own lawful amendments.” Munch v. Tusa, 140 Neb. 457 , 300 N. W. 385 .

21945–1956
DeLima v. Tsevi green
neb · 2018
2 sentences

2020DeLima v. Tsevi, 301 Neb. 933 , 921 N.W.2d 89 (2018).

2020DeLima v. Tsevi, 301 Neb. 933 , 921 N.W.2d 89 (2018).

12020–2020
Home Builders Ass'n v. City of Lincoln green
neb · 2006
2 sentences

2007Home Builders Association of Lincoln v. City of Lincoln, 271 Neb. 353 , 711 N.W.2d 871 (2006).

2007Home Builders Association of Lincoln v. City of Lincoln, 271 Neb. 353 , 711 N.W.2d 871 (2006).

12007–2007
Nicholson v. General Cas. Co. of Wisconsin green
neb · 2001
2 sentences

2003Co. of Wis., 262 Neb. 879 , 636 N.W.2d 372 (2001). (b) Charter Authority of City of Lincoln LES also contends that the home rule charter of the city of Lincoln confers authority on LES to provide for-hire telecommunications services.

2003Co. of Wis., 262 Neb. 879 , 636 N.W.2d 372 (2001). (b) Charter Authority of City of Lincoln LES also contends that the home rule charter of the city of Lincoln confers authority on LES to provide for-hire telecommunications services.

12003–2003
Adams v. Fort Madison Community School District green
iowa · 1970
1 sentence

1996School Dist. , 182 N.W.2d 132 (1970) (Iowa Supreme Court upheld statute requiring at least a 60 percent affirmative vote in order for school district bond proposals to carry). 6 Rimarcik v. Johansen , 310 F. Supp. 61 (1970) (federal district court held that a Minnesota statutory provision requiring a 55 percent favorable vote for adoption of amendment to a home rule charter violated the "one-man, one-vote" principle and, therefore, violated the equal protection clause of the federal Constitution), vacated and remanded for reconsideration , 403 U.S. 915 (1971). 7 Brenner v. School Dist. of Kans

11996–1996
Brenner v. School District of Kansas City, Missouri green
mowd · 1970
1 sentence

1996School Dist. , 182 N.W.2d 132 (1970) (Iowa Supreme Court upheld statute requiring at least a 60 percent affirmative vote in order for school district bond proposals to carry). 6 Rimarcik v. Johansen , 310 F. Supp. 61 (1970) (federal district court held that a Minnesota statutory provision requiring a 55 percent favorable vote for adoption of amendment to a home rule charter violated the "one-man, one-vote" principle and, therefore, violated the equal protection clause of the federal Constitution), vacated and remanded for reconsideration , 403 U.S. 915 (1971). 7 Brenner v. School Dist. of Kans

11996–1996
Rimarcik v. Johansen neutral
mnd · 1970
1 sentence

1996School Dist. , 182 N.W.2d 132 (1970) (Iowa Supreme Court upheld statute requiring at least a 60 percent affirmative vote in order for school district bond proposals to carry). 6 Rimarcik v. Johansen , 310 F. Supp. 61 (1970) (federal district court held that a Minnesota statutory provision requiring a 55 percent favorable vote for adoption of amendment to a home rule charter violated the "one-man, one-vote" principle and, therefore, violated the equal protection clause of the federal Constitution), vacated and remanded for reconsideration , 403 U.S. 915 (1971). 7 Brenner v. School Dist. of Kans

11996–1996
Lance v. Board of Education of County of Roane green
wva · 1969
1 sentence

1996Va. 559 , 170 S.E.2d 783 (1969), cert. granted sub. nom.

11996–1996
Lamar Life Broadcasting Co. v. Federal Communications Commission neutral
scotus · 1971
1 sentence

1996School Dist. , 182 N.W.2d 132 (1970) (Iowa Supreme Court upheld statute requiring at least a 60 percent affirmative vote in order for school district bond proposals to carry). 6 Rimarcik v. Johansen , 310 F. Supp. 61 (1970) (federal district court held that a Minnesota statutory provision requiring a 55 percent favorable vote for adoption of amendment to a home rule charter violated the "one-man, one-vote" principle and, therefore, violated the equal protection clause of the federal Constitution), vacated and remanded for reconsideration , 403 U.S. 915 (1971). 7 Brenner v. School Dist. of Kans

11996–1996
Adams v. Board of Regents green
scotus · 1971
1 sentence

1996School Dist. , 182 N.W.2d 132 (1970) (Iowa Supreme Court upheld statute requiring at least a 60 percent affirmative vote in order for school district bond proposals to carry). 6 Rimarcik v. Johansen , 310 F. Supp. 61 (1970) (federal district court held that a Minnesota statutory provision requiring a 55 percent favorable vote for adoption of amendment to a home rule charter violated the "one-man, one-vote" principle and, therefore, violated the equal protection clause of the federal Constitution), vacated and remanded for reconsideration , 403 U.S. 915 (1971). 7 Brenner v. School Dist. of Kans

11996–1996
Lance v. Board of Education green
wva · 1969
1 sentence

1996School Dist. , 182 N.W.2d 132 (1970) (Iowa Supreme Court upheld statute requiring at least a 60 percent affirmative vote in order for school district bond proposals to carry). 6 Rimarcik v. Johansen , 310 F. Supp. 61 (1970) (federal district court held that a Minnesota statutory provision requiring a 55 percent favorable vote for adoption of amendment to a home rule charter violated the "one-man, one-vote" principle and, therefore, violated the equal protection clause of the federal Constitution), vacated and remanded for reconsideration , 403 U.S. 915 (1971). 7 Brenner v. School Dist. of Kans

11996–1996
Kenneth R. Mancuso v. James L. Taft, Mayor green
ca1 · 1973
11993–1993
Michelson v. City of Grand Island green
neb · 1951
11985–1985
Midwest Employers Council, Inc. v. City of Omaha green
neb · 1964
11985–1985
Dell v. City of Lincoln green
neb · 1959
11982–1982
Jacobs v. City of Omaha green
neb · 1966
11981–1981
Simpson v. City of Grand Island green
neb · 1958
11980–1980
Coffin v. City of Lee's Summit neutral
moctapp · 1962
11979–1979
Frye v. Haas green
neb · 1967
11979–1979
Speer v. Kratzenstein green
neb · 1943
11967–1967
Bass v. County of Saline green
neb · 1960
11967–1967
City of Omaha v. Glissmann green
neb · 1949
11964–1964
Philson v. City of Omaha green
neb · 1958
11964–1964
Wagner v. City of Omaha green
neb · 1952
11962–1962
Application of City of Seward green
neb · 1954
11961–1961
Streat v. Vermilya green
mich · 1934
11959–1959
Niklaus v. Miller green
neb · 1954
11959–1959
Smart v. Mayer neutral
kan · 1920
11959–1959
Noble v. City of Lincoln green
neb · 1950
11959–1959
Sullivan v. City of Omaha neutral
neb · 1945
11956–1956
Pester v. City of Lincoln neutral
neb · 1934
11954–1954
Reid v. City of Omaha green
neb · 1948
11952–1952

Statutes the citing opinions construe

NE § Neb. Rev. Stat. § 43-1238 (4) NE § Neb. Rev. Stat. § 43-1244 (4) NE § Neb. Rev. Stat. § 43-1241 (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

IL 383 (1972–2026) TX 203 (1926–2025) NY 173 (1903–2026) PA 123 (1953–2026) MI 122 (1915–2026) CO 121 (1919–2026) CA 114 (1952–2026) LA 113 (1935–2025) FL 74 (1957–2026) OH 73 (1937–2026) NE 59 (1922–2020) OR 57 (1912–2026) KS 43 (1957–2019) MD 42 (1932–2025) WI 41 (1912–2024) MN 39 (1908–2019) RI 38 (1939–2023) NM 29 (1979–2025) MO 28 (1963–2023) IA 27 (1974–2021) CT 27 (1962–2022) WA 22 (1932–2019) MA 22 (1970–2018) AK 21 (1970–2024) OK 19 (1930–2014) AZ 19 (1939–2023) ND 19 (1972–2024) TN 18 (1975–2025) ME 17 (1979–2022) GA 17 (1967–2025) IN 12 (1988–2020) KY 10 (1953–2026) NJ 10 (1949–2024) AL 7 (1991–2017) DC 6 (1971–2010) WV 6 (1950–2023) NH 6 (1982–2010) DE 5 (1975–2020) VA 4 (1999–2022) AR 3 (1991–2000) NC 3 (1968–2016) ID 3 (1986–2018) UT 2 (1978–2013) SC 2 (2010–2021) SD 2 (2000–2003) MT 2 (1938–2005) VI 2 (1978–2017) VT 2 (1991–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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