probable cause standard (Missouri) · Go Syfert
← Missouri issues

probable cause standard in Missouri

57 Missouri opinions name it 2 courts 1970–2024 1 in the last five years

The cases below were cited by Missouri 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 (42)

CaseFollowedCited
Jamison v. State, Department of Social Services, Division of Family Servicesgreen
mo · 2007 · cited in 3 Missouri opinions naming this issue, 2007–2009
2 sentences

2009Servs., 218 S.W.3d 399, 411 (Mo. banc 2007).

2009Servs., 218 S.W.3d 399, 411 (Mo. banc 2007).

33
Riche v. Director of Revenuegreen
mo · 1999 · cited in 4 Missouri opinions naming this issue, 2004–2020
2 sentences

2012“Whether [the arresting officer] had a reasonable suspicion for a lawful stop is irrelevant in a civil driver’s license revocation proceeding.” Jones v. Dir. of Revenue, 291 S.W.3d 340, 344 (Mo.App. 2009); see also Riche v. Dir. of Revenue, 987 S.W.2d 331, 336 (Mo. banc 1999) (holding that the probable-cause requirement for the initial traffic stop and exclusionary rule do not apply to section 302.505 2 proceedings); Brown v. Dir. of Revenue, 85 S.W.3d 1 , 4 n. 4 (Mo. banc 2002) (equating probable-cause determinations in section 302.505 proceedings with reasonable-grounds determinations in sec

2009See Riche v. Dir. of Revenue, 987 S.W.2d 331, 336 (Mo. banc 1999) (holding that the probable cause requirement for the initial stop and the exclusionary rule do not apply in section 302.505 5 proceedings); Brown v. Dir. of Revenue, 85 S.W.3d 1 , 4 n. 4 (Mo. banc 2002) (discussing probable cause determinations in section 302.505 proceedings synonymously with reasonable grounds determinations in section 577.041 proceedings); see also State v. Roark, 229 S.W.3d 216 , 220 n. 2 (Mo.App.

24
Guhr v. Director of Revenuegreen
mo · 2007 · cited in 3 Missouri opinions naming this issue, 2008–2011
2 sentences

2011See Guhr v. Dir. of Revenue, 228 S.W.3d 581 , 585 n. 3 (Mo. banc 2007).

2008“The probable cause analysis requires consideration of all the information in the officer’s possession prior to arrest.” Guhr, 228 S.W.3d at 585 (emphasis added).

23
In Re Dyergreen
mo · 2005 · cited in 2 Missouri opinions naming this issue, 2016–2017
2 sentences

2017As relevant here, “[t]he false information requirement and the probable cause requirement, when combined, ‘necessarily imply and mean that a petitioner .., has the burden to affirmatively demonstrate at a hearing, by a preponderance of the evidence ... his actual innocence of the offense for which he was arrested.’ ” In re Dyer, 163 S.W.3d 915, 919 (Mo. banc 2005) (quoting Martinez v. State, 24 S.W.3d 10, 20 (Mo. App. E.D. 2000)).

2016The Supreme Court of Missouri has held “[t]he false information requirement arid the probable cause requirement, when combined, ‘necessarily imply and mean that a petitioner... has the burden to affirmatively demonstrate at a hearing, by a preponderance of the evidence... his actual innocence of the offense for which he was arrested.’ ” In re Dyer, 163 S.W.3d 915, 919 (Mo. banc 2005) (quoting Martinez, 24 S.W.3d at 20 ) (emphasis added). *455 This Court in Martinez separately analyzed the probable cause and false information requirements under § 610.122 and held: Probable cause is a legal term

22
Martinez v. Stategreen
moctapp · 2000 · cited in 3 Missouri opinions naming this issue, 2005–2017
2 sentences

2017As relevant here, “[t]he false information requirement and the probable cause requirement, when combined, ‘necessarily imply and mean that a petitioner .., has the burden to affirmatively demonstrate at a hearing, by a preponderance of the evidence ... his actual innocence of the offense for which he was arrested.’ ” In re Dyer, 163 S.W.3d 915, 919 (Mo. banc 2005) (quoting Martinez v. State, 24 S.W.3d 10, 20 (Mo. App. E.D. 2000)).

2016The Supreme Court of Missouri has held “[t]he false information requirement arid the probable cause requirement, when combined, ‘necessarily imply and mean that a petitioner... has the burden to affirmatively demonstrate at a hearing, by a preponderance of the evidence... his actual innocence of the offense for which he was arrested.’ ” In re Dyer, 163 S.W.3d 915, 919 (Mo. banc 2005) (quoting Martinez, 24 S.W.3d at 20 ) (emphasis added). *455 This Court in Martinez separately analyzed the probable cause and false information requirements under § 610.122 and held: Probable cause is a legal term

13
Commonwealth v. Perkinsgreen
mass · 2013 · cited in 1 Missouri opinions naming this issue, 2024–2024
1 sentence

2024As the Supreme Judicial Court of Massachusetts noted when analyzing a similar issue in Commonwealth v. Perkins, 981 N.E.2d 630, 640 (Mass. 2013): The Commonwealth is not entitled to proceed at whatever pace it might choose, either in marshaling evidence to establish probable cause for the probable cause hearing or in presenting a case to the grand jury in order to secure an indictment.

11
Hunt v. Commonwealthgreen
ky · 2010 · cited in 1 Missouri opinions naming this issue, 2019–2019
1 sentence

2019See Hunt v. Commonwealth, 326 S.W.3d 437 , 440 (Ky. 2010).

11
State v. Hawkinsgreen
moctapp · 2010 · cited in 1 Missouri opinions naming this issue, 2018–2018
1 sentence

2018See Hawkins , 328 S.W.3d at 808 .

11
Care & Treatment of Tyson v. Stategreen
mo · 2008 · cited in 1 Missouri opinions naming this issue, 2018–2018
2 sentences

2018See Tyson , 249 S.W.3d at 852-53 ("The SVP Act contemplates that additional discovery will be accomplished after the probable cause hearing.").

2018Also, as with a criminal preliminary hearing, the purpose of the probable cause hearing is "merely to determine if the State's evidence raises a triable issue of fact." Tyson , 249 S.W.3d at 852-53 (citations omitted); cf. Turner , 353 S.W.2d at 604 ; see also 544.250.

11
United States v. Jonesgreen
ca1 · 2005 · cited in 1 Missouri opinions naming this issue, 2015–2015
2 sentences

2015Id.

2015See Jones, 432 F.3d at 41 (stating it was irrelevant that booking officer cited defendant for “intent to rob while armed”; arrest was valid if, on facts known to arresting officers, probable cause existed to believe defendant was committing another crime).

11
State v. Bizovigreen
moctapp · 2004 · cited in 1 Missouri opinions naming this issue, 2014–2014
2 sentences

2014See Id. at 433 (distinguishing the probable-cause standard).

2014See Id. at 433 (distinguishing the probable-cause standard).

11
Peters v. Director of Revenuegreen
moctapp · 2001 · cited in 1 Missouri opinions naming this issue, 2012–2012
1 sentence

2012“Whether [the arresting officer] had a reasonable suspicion for a lawful stop is irrelevant in a civil driver’s license revocation proceeding.” Jones v. Dir. of Revenue, 291 S.W.3d 340, 344 (Mo.App. 2009); see also Riche v. Dir. of Revenue, 987 S.W.2d 331, 336 (Mo. banc 1999) (holding that the probable-cause requirement for the initial traffic stop and exclusionary rule do not apply to section 302.505 2 proceedings); Brown v. Dir. of Revenue, 85 S.W.3d 1 , 4 n. 4 (Mo. banc 2002) (equating probable-cause determinations in section 302.505 proceedings with reasonable-grounds determinations in sec

11
Gelsheimer v. Director of Revenuegreen
moctapp · 1993 · cited in 1 Missouri opinions naming this issue, 2012–2012
1 sentence

2012“Whether [the arresting officer] had a reasonable suspicion for a lawful stop is irrelevant in a civil driver’s license revocation proceeding.” Jones v. Dir. of Revenue, 291 S.W.3d 340, 344 (Mo.App. 2009); see also Riche v. Dir. of Revenue, 987 S.W.2d 331, 336 (Mo. banc 1999) (holding that the probable-cause requirement for the initial traffic stop and exclusionary rule do not apply to section 302.505 2 proceedings); Brown v. Dir. of Revenue, 85 S.W.3d 1 , 4 n. 4 (Mo. banc 2002) (equating probable-cause determinations in section 302.505 proceedings with reasonable-grounds determinations in sec

11
Jones v. DIRECTOR OF REVENUE, STATEgreen
moctapp · 2009 · cited in 1 Missouri opinions naming this issue, 2012–2012
1 sentence

2012“Whether [the arresting officer] had a reasonable suspicion for a lawful stop is irrelevant in a civil driver’s license revocation proceeding.” Jones v. Dir. of Revenue, 291 S.W.3d 340, 344 (Mo.App. 2009); see also Riche v. Dir. of Revenue, 987 S.W.2d 331, 336 (Mo. banc 1999) (holding that the probable-cause requirement for the initial traffic stop and exclusionary rule do not apply to section 302.505 2 proceedings); Brown v. Dir. of Revenue, 85 S.W.3d 1 , 4 n. 4 (Mo. banc 2002) (equating probable-cause determinations in section 302.505 proceedings with reasonable-grounds determinations in sec

11
State v. Roarkgreen
moctapp · 2007 · cited in 1 Missouri opinions naming this issue, 2009–2009
11
Quinones v. Illinoisgreen
scotus · 2002 · cited in 1 Missouri opinions naming this issue, 2009–2009
11
Sudduth v. City of Pittsburghgreen
scotus · 2002 · cited in 1 Missouri opinions naming this issue, 2009–2009
11
In Re the Care & Treatment of Matthewsgreen
sc · 2001 · cited in 1 Missouri opinions naming this issue, 2009–2009
2 sentences

2009See In Matter of Care and Treatment of Matthews, 345 S.C. 638 , 550 S.E.2d 311, 314-15 (2001), cert. denied, 535 U.S. 1062 , 122 S.Ct. 1928 , 152 L.Ed.2d 834 (2002) (trial within 60 days of a probable cause hearing is mandatory but not jurisdictional; by not filing a motion to dismiss, detainee waived right to challenge the state’s noncompliance with the requisite time period).

2009See In Matter of Care and Treatment of Matthews, 345 S.C. 638 , 550 S.E.2d 311, 314-15 (2001), cert. denied, 535 U.S. 1062 , 122 S.Ct. 1928 , 152 L.Ed.2d 834 (2002) (trial within 60 days of a probable cause hearing is mandatory but not jurisdictional; by not filing a motion to dismiss, detainee waived right to challenge the state’s noncompliance with the requisite time period).

11
In Re Marriage of Hendrixgreen
mo · 2006 · cited in 1 Missouri opinions naming this issue, 2009–2009
11
Martineau v. Stategreen
moctapp · 2007 · cited in 1 Missouri opinions naming this issue, 2008–2008
11
Cavarretta v. Department of Children & Family Servicesgreen
illappct · 1996 · cited in 1 Missouri opinions naming this issue, 2007–2007
11
James W. Sikes v. Teleline, Inc.green
ca11 · 2004 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
Flora v. Floragreen
moctapp · 1992 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
Lynn v. Plumbgreen
moctapp · 1991 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
Page v. Associated Couriers, Inc.green
moctapp · 1993 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
Holder v. Schenherrgreen
moctapp · 2001 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
Bradford v. Director of Revenuegreen
moctapp · 2002 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
Routh Wrecker Service, Inc. v. Washingtongreen
ark · 1998 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
Kelley v. Kelly Residential Group, Inc.green
moctapp · 1997 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
Brancato v. Wholesale Tool Co., Inc.green
moctapp · 1997 · cited in 1 Missouri opinions naming this issue, 2005–2005
11
State v. Smithgreen
moctapp · 1996 · cited in 1 Missouri opinions naming this issue, 2004–2004
11
State v. Willisgreen
moctapp · 2003 · cited in 1 Missouri opinions naming this issue, 2004–2004
11
State v. Hestergreen
mo · 1960 · cited in 1 Missouri opinions naming this issue, 2003–2003
11
Whitworth v. Director of Revenuegreen
moctapp · 1999 · cited in 1 Missouri opinions naming this issue, 2003–2003
11
Oughton v. DIRECTOR OF REVENUE, STATEgreen
moctapp · 1996 · cited in 1 Missouri opinions naming this issue, 1999–1999
11
Richards v. Wisconsingreen
scotus · 1997 · cited in 1 Missouri opinions naming this issue, 1998–1998
11
State v. Lasleygreen
mo · 1979 · cited in 1 Missouri opinions naming this issue, 1997–1997
11
Rose v. State Board of Registration for the Healing Artsgreen
mo · 1965 · cited in 1 Missouri opinions naming this issue, 1996–1996
11
State v. Giffingreen
mo · 1982 · cited in 1 Missouri opinions naming this issue, 1991–1991
11
State v. Sidebottomgreen
mo · 1988 · cited in 1 Missouri opinions naming this issue, 1991–1991
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (38)

CaseCitedYears
Hinnah v. Director of Revenue green
mo · 2002
2 sentences

2010Id.

2010Guhr v. Director of Revenue, 228 S.W.3d 581 , 585 n. 3 (Mo. banc 2007), overruled on other grounds by White, 321 S.W.3d at 301-03 ; Hinnah, 77 S.W.3d at 621 .

32007–2010
Terry v. Ohio green
scotus · 1968
2 sentences

1987Additionally, the state contends that the proper resolution of this case rests not upon a probable cause analysis but upon the stop and frisk doctrine established in Terry v. Ohio, 392 U.S. 1 , 88 S.Ct. 1868 , 20 L.Ed.2d 889 (1968).

1987Additionally, the state contends that the proper resolution of this case rests not upon a probable cause analysis but upon the stop and frisk doctrine established in Terry v. Ohio, 392 U.S. 1 , 88 S.Ct. 1868 , 20 L.Ed.2d 889 (1968).

31987–2009
White v. Director of Revenue green
mo · 2010
2 sentences

2018Ornelas , 517 U.S. at 696 , 116 S.Ct. 1657 , White , 321 S.W.3d at 310 .

2010Guhr v. Director of Revenue, 228 S.W.3d 581 , 585 n. 3 (Mo. banc 2007), overruled on other grounds by White, 321 S.W.3d at 301-03 ; Hinnah, 77 S.W.3d at 621 .

22010–2018
Brown v. Director of Revenue green
mo · 2002
2 sentences

2012“Whether [the arresting officer] had a reasonable suspicion for a lawful stop is irrelevant in a civil driver’s license revocation proceeding.” Jones v. Dir. of Revenue, 291 S.W.3d 340, 344 (Mo.App. 2009); see also Riche v. Dir. of Revenue, 987 S.W.2d 331, 336 (Mo. banc 1999) (holding that the probable-cause requirement for the initial traffic stop and exclusionary rule do not apply to section 302.505 2 proceedings); Brown v. Dir. of Revenue, 85 S.W.3d 1 , 4 n. 4 (Mo. banc 2002) (equating probable-cause determinations in section 302.505 proceedings with reasonable-grounds determinations in sec

2009See Riche v. Dir. of Revenue, 987 S.W.2d 331, 336 (Mo. banc 1999) (holding that the probable cause requirement for the initial stop and the exclusionary rule do not apply in section 302.505 5 proceedings); Brown v. Dir. of Revenue, 85 S.W.3d 1 , 4 n. 4 (Mo. banc 2002) (discussing probable cause determinations in section 302.505 proceedings synonymously with reasonable grounds determinations in section 577.041 proceedings); see also State v. Roark, 229 S.W.3d 216 , 220 n. 2 (Mo.App.

22009–2012
State v. Rushing green
mo · 1996
2 sentences

2003When Officer Wray removed the item, Officer Manlove related that he observed it was a plastic baggie containing “what we believed to be crack cocaine .... ” “The [United States] Supreme Court has equated the requirement that an item in plain view or feel be ‘immediately apparent’ as contraband or other evidence of a crime with the probable cause standard.” Rushing, 935 S.W.2d at 33 .

2003The United States Supreme Court “has equated the requirement that an item in plain view or feel be ‘immediately apparent’ as contraband or other evidence of a crime with the probable cause standard.” Rushing, 935 S.W.2d at 33 .

22003–2003
State v. Clark green
moctapp · 1977
2 sentences

1989Clark, 552 S.W.2d at 261 .” State v. Luleff, 729 S.W.2d 530 , 534 (Mo.App.1987).

1987Clark, 552 S.W.2d at 261 .

21987–1989
Morrissey v. Brewer green
scotus · 1972
2 sentences

2019The probable cause hearing The Morrissey Court conceptualized the revocation probable cause hearing to be one of "minimal inquiry," Morrissey , 408 U.S. at 485 , 487 , 92 S.Ct. 2593 .

2019The probable cause hearing The Morrissey Court conceptualized the revocation probable cause hearing to be one of "minimal inquiry," Morrissey , 408 U.S. at 485 , 487 , 92 S.Ct. 2593 .

12019–2019
Mathews v. Eldridge green
scotus · 1976
2 sentences

2019Because the conclusion that a supervision violation has occurred is one where "a wide variety of information may be deemed relevant, and issues of witness credibility and veracity are often critical to the decisionmaking process," reviewing the administrative record is only minimally reliable and a "wholly unsatisfactory basis for [a revocation] decision." Mathews v. Eldridge, 424 U.S. 319 , 343-44, 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976).

2019Because the conclusion that a supervision violation has occurred is one where "a wide variety of information may be deemed relevant, and issues of witness credibility and veracity are often critical to the decisionmaking process," reviewing the administrative record is only minimally reliable and a "wholly unsatisfactory basis for [a revocation] decision." Mathews v. Eldridge, 424 U.S. 319 , 343-44, 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976).

12019–2019
Ornelas v. United States green
scotus · 1996
2 sentences

2018Ornelas , 517 U.S. at 696 , 116 S.Ct. 1657 , White , 321 S.W.3d at 310 .

2018Ornelas , 517 U.S. at 696 , 116 S.Ct. 1657 , White , 321 S.W.3d at 310 .

12018–2018
Campbell v. Citizens Bank of Edina green
moctapp · 1996
1 sentence

2018Walker v. Mo. State Bd. of Registration for Healing Arts , 926 S.W.2d 148 , 151 (Mo. App. E.D. 1996) (noting in writ proceeding seeking to prevent board from holding probable cause hearing on physician's competency to practice medicine that "the full panoply of due process is not required" "at the probable cause stage of the proceeding").

12018–2018
State v. Turner green
mo · 1962
1 sentence

2018Also, as with a criminal preliminary hearing, the purpose of the probable cause hearing is "merely to determine if the State's evidence raises a triable issue of fact." Tyson , 249 S.W.3d at 852-53 (citations omitted); cf. Turner , 353 S.W.2d at 604 ; see also 544.250.

12018–2018
State v. Aaron green
moctapp · 2007
1 sentence

2018Similar to a criminal preliminary hearing, the right to present evidence and cross-examine witnesses at the probable cause hearing in an SVP case have been granted by the general assembly but are not rights required under the constitution. 16 § 632.489.3; cf. Aaron , 218 S.W.3d at 509 ; see also State ex rel.

12018–2018
Vernonia School District 47J v. Acton green
scotus · 1995
2 sentences

2017In other words, Judge Beam reasoned, the school reduced the extent to which it was acting under its "custodial and tutelary responsibilities” and, instead, brought its actions much closer to "the investigatory role for which the probable-cause standard is intended.” Id. (quoting Earls, 536 U.S. at 830 , 122 S.Ct. 2559 , which was quoting Vernonia, 515 U.S. at 656 , 115 S.Ct. 2386 ). .

2017In other words, Judge Beam reasoned, the school reduced the extent to which it was acting under its "custodial and tutelary responsibilities” and, instead, brought its actions much closer to "the investigatory role for which the probable-cause standard is intended.” Id. (quoting Earls, 536 U.S. at 830 , 122 S.Ct. 2559 , which was quoting Vernonia, 515 U.S. at 656 , 115 S.Ct. 2386 ). .

12017–2017
Board of Education of Independent School District No. 92 of Pottawatomie County v. Earls green
scotus · 2002
2 sentences

2017In other words, Judge Beam reasoned, the school reduced the extent to which it was acting under its "custodial and tutelary responsibilities” and, instead, brought its actions much closer to "the investigatory role for which the probable-cause standard is intended.” Id. (quoting Earls, 536 U.S. at 830 , 122 S.Ct. 2559 , which was quoting Vernonia, 515 U.S. at 656 , 115 S.Ct. 2386 ). .

2017In other words, Judge Beam reasoned, the school reduced the extent to which it was acting under its "custodial and tutelary responsibilities” and, instead, brought its actions much closer to "the investigatory role for which the probable-cause standard is intended.” Id. (quoting Earls, 536 U.S. at 830 , 122 S.Ct. 2559 , which was quoting Vernonia, 515 U.S. at 656 , 115 S.Ct. 2386 ). .

12017–2017
In Re the Care & Treatment of Foster green
kan · 2006
1 sentence

2017In this case, the Judge determined that there was.” Id.

12017–2017
Martin v. Director of Revenue green
moctapp · 2008
12008–2008
Artman v. State Board of Registration for the Healing Arts green
mo · 1996
12008–2008
Santosky v. Kramer green
scotus · 1982
12007–2007
In re Preisendorfer green
nh · 1998
12007–2007
Care and Treatment of Schottel v. State green
mo · 2005
12007–2007
State v. Gant neutral
moctapp · 2003
12007–2007
State v. Lane green
mo · 1997
12006–2006
BMW of North America, Inc. v. Gore green
scotus · 1996
12005–2005
In re the Detention of Petersen green
wash · 2002
12005–2005
Care and Treatment of Schottel v. State green
moctapp · 2003
12005–2005
Ellis v. Farmers Insurance Group green
moctapp · 1983
12005–2005
Detention of Petersen v. State green
wash · 2002
12005–2005
State v. Manley green
moctapp · 2003
12004–2004
Johnson v. State green
mo · 2001
12003–2003
Maryland v. Buie green
scotus · 1990
11997–1997
Minnesota v. Dickerson green
scotus · 1993
11996–1996
Arizona v. Hicks green
scotus · 1987
11996–1996
Texas v. Brown green
scotus · 1983
11996–1996
Missouri v. Presley green
scotus · 1988
11991–1991
State v. Luleff green
moctapp · 1987
11989–1989
State v. Toney green
moctapp · 1984
11989–1989
United States v. Leon green
scotus · 1984
11987–1987
Gerstein v. Pugh green
scotus · 1975
11986–1986

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 302.505 (11) MO § Mo. Rev. Stat. § 632.480 (7) MO § Mo. Rev. Stat. § 302.535 (5) MO § Mo. Rev. Stat. § 577.041 (5) MO § Mo. Rev. Stat. § 302.500 (4) MO § Mo. Rev. Stat. § 210.110 (3) MO § Mo. Rev. Stat. § 302.312 (3) MO § Mo. Rev. Stat. § 577.010 (3) MO § Mo. Rev. Stat. § 632.483 (3) MO § Mo. Rev. Stat. § 632.486 (3) MO § Mo. Rev. Stat. § 632.489 (3) MO § Mo. Rev. Stat. § 632.498 (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 408 (1966–2026) CA 362 (1955–2026) OH 284 (1978–2026) MA 271 (1967–2026) TX 242 (1927–2026) CT 237 (1969–2026) PA 224 (1967–2026) NY 192 (1959–2026) WA 159 (1973–2026) WI 141 (1970–2026) NJ 141 (1978–2026) FL 137 (1973–2025) IN 136 (1971–2025) MI 109 (1972–2026) MD 98 (1973–2026) MN 93 (1975–2026) VA 93 (1975–2026) AL 86 (1937–2024) NC 85 (1974–2026) OR 81 (1976–2026) ID 77 (1978–2026) DC 76 (1970–2026) KS 75 (1975–2024) GA 68 (1969–2026) CO 68 (1971–2025) AZ 61 (1971–2025) MO 57 (1970–2024) UT 56 (1980–2026) IA 54 (1978–2026) ME 53 (1970–2023) LA 51 (1976–2020) TN 51 (1972–2025) NM 51 (1974–2026) MT 50 (1973–2025) AR 41 (1973–2024) ND 37 (1971–2021) KY 36 (1968–2026) NH 34 (1974–2024) RI 31 (1981–2026) WV 30 (1980–2026) MS 29 (1988–2023) DE 27 (1969–2026) SC 26 (2001–2025) AK 26 (1977–2025) NV 24 (1968–2022) VT 20 (1971–2020) WY 19 (1976–2025) NE 18 (1981–2024) SD 17 (1975–2019) HI 17 (1973–2022) VI 11 (1981–2014) OK 9 (1953–2006) MP 2 (2023–2024)

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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