establishment clause (New York) · Go Syfert
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establishment clause in New York

53 New York opinions name it 13 courts 1861–2026 7 in the last five years

The cases below were cited by New York 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 (26)

CaseFollowedCited
Lemon v. Kurtzmanred
scotus · 1971 · cited in 5 New York opinions naming this issue, 1978–1996
2 sentences

1996In apparently concluding that no Establishment Clause violation occurred here because A.A. does not require a participant to adhere to a sectarian belief in God, but permits one to entertain a secular concept of a Higher Power devoid of religious content, the Appellate Division committed a second error by disregarding application of the second prong of the three-part test (the purpose-effect-entanglement test) for primary Establishment Clause analysis articulated in Lemon v Kurtzman ( 403 US 602 , supra).

1996The foregoing opinions of all nine of the Justices in Lee v Weisman dealing with anticoercion as a settled precept of the Establishment Clause either independently or as a prohibited governmental endorsement of religion in violation of the second prong of the three-part Establishment Clause test of Lemon v Kurtzman (supra), effectively dispose of the dissent’s criticism that we have wrongfully interjected a "dominant” coercion element (dissenting opn, at 704; see also, id,., at 703), in a "novel” (id., at 703) or "tenuous” manner (id., at 697) unsupported by precedent, to Establishment Clause

15
Zorach v. Clausongreen
scotus · 1952 · cited in 3 New York opinions naming this issue, 1978–1996
2 sentences

1996Likewise, in Zorach v Clauson ( 343 US 306 ) — a case invoked by the dissent (dissenting opn, at 705, 710, 713) for the proposition that petitioner was not coerced by the threat of lost eligibility for the Family Reunion Program — Justice Douglas, in rejecting the Establishment Clause claim, expressly relied upon the total absence of any influence by school authorities on a student’s election to take religious instruction: "The present record indeed tells us that the school authorities are neutral in this regard and do no more than release students whose parents so request.

1996Likewise, in Zorach v Clauson ( 343 US 306 ) — a case invoked by the dissent (dissenting opn, at 705, 710, 713) for the proposition that petitioner was not coerced by the threat of lost eligibility for the Family Reunion Program — Justice Douglas, in rejecting the Establishment Clause claim, expressly relied upon the total absence of any influence by school authorities on a student’s election to take religious instruction: "The present record indeed tells us that the school authorities are neutral in this regard and do no more than release students whose parents so request.

13
Abington School Dist. v. Schemppgreen
· 1963 · cited in 3 New York opinions naming this issue, 1973–1996
2 sentences

1996This view of the reach of the Establishment Clause is supported by respected constitutional law scholars ( see , 4 Rotunda and Nowak, Constitutional Law — Substance and Procedure § 21.3, at 453 [2d ed]; see also , Abington School Dist. v Schempp , 374 US 203, 216-217 , supra ). [6] The foregoing opinions of all nine of the Justices in Lee v Weisman dealing with anticoercion as a settled precept of the Establishment Clause either independently or as a prohibited governmental endorsement of religion in violation of the second prong of the three-part Establishment Clause test of Lemon v Kurtzman

1996This view of the reach of the Establishment Clause is supported by respected constitutional law scholars ( see , 4 Rotunda and Nowak, Constitutional Law — Substance and Procedure § 21.3, at 453 [2d ed]; see also , Abington School Dist. v Schempp , 374 US 203, 216-217 , supra ). [6] The foregoing opinions of all nine of the Justices in Lee v Weisman dealing with anticoercion as a settled precept of the Establishment Clause either independently or as a prohibited governmental endorsement of religion in violation of the second prong of the three-part Establishment Clause test of Lemon v Kurtzman

13
Illinois Ex Rel. McCollum v. Board of Ed. of School Dist. No. 71, Champaign Cty.green
scotus · 1948 · cited in 3 New York opinions naming this issue, 1969–1978
2 sentences

1978Furthermore, while a school board may encourage sectarian religious instruction by planning its schedule of activities to accommodate an outside program of religious instruction, it may not turn over its own classrooms for this purpose during regular school hours (cf. Zorach v Clauson, 343 US 306 , with McCollum v Board of Educ., 333 US 203 ).

1969See, also, McCollum v. Board of Educ. ( 333 U. S. 203, 211-212 ), where the court said: “ A manifestation of such hostility [toward religion] would be at war with our national tradition as embodied in the First Amendment’s guaranty of the free exercise of religion.” Engel v. Vitale ( 370 U. S. 421, 422 ) involved a constitutional attack on the practice of a New York public school district in commencing the school day by reciting the following prayer composed by the State Board of Regents: “ Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, ou

13
Boston Concessions Group, Inc. v. Criterion Center Corp.green
nyappdiv · 1994 · cited in 2 New York opinions naming this issue, 1995–2013
2 sentences

2013Corp., 200 AD2d 543 , 545 [1st Dept 1994] [“the establishment of a waiver ... is ordinarily a question of fact”]; see also Peck v Peck, 232 AD2d 540, 540 [2d Dept 1996] [“waiver is not created by negligence, oversight, or thoughtlessness, and cannot be inferred from mere silence”].) Then, too, the court cannot reach the issue of whether the City might be estopped from enforcing the free admission requirement, as the court cannot rule on such issue when the City is not a party to this action.

1995Corp. ( 200 AD2d 543, 545 [1st Dept 1994]), argues that under New York law the establishment of a waiver is a question of fact which precludes summary judgment.

12
Matter of Bigdoski v. Bausch & Lombgreen
nyappdiv · 2021 · cited in 1 New York opinions naming this issue, 2026–2026
1 sentence

2026Auth. , 206 AD3d 1418, 1418-1419 [3d Dept 2022]; Matter of Bigdoski v Bausch & Lomb , 197 AD3d 1379, 1380 [3d Dept 2021]).

11
Matter of Brancato v. New York City Tr. Auth.green
nyappdiv · 2022 · cited in 1 New York opinions naming this issue, 2026–2026
1 sentence

2026Auth. , 206 AD3d 1418, 1418-1419 [3d Dept 2022]; Matter of Bigdoski v Bausch & Lomb , 197 AD3d 1379, 1380 [3d Dept 2021]).

11
People v. . Shilitanogreen
ny · 1916 · cited in 1 New York opinions naming this issue, 2025–2025
2 sentences

2025In rejecting the argument that the mere fact of recantation entitles a defendant to a new trial, this Court made the following generalization about the character of violent crime witnesses: "Bearing in mind that the witnesses to crimes of violence are often of a low and degraded character and that after they have given their testimony they are sometimes [*6]influenced by bribery and other improper considerations, it is evident that the establishment of a rule which left the power to grant a new trial to a defendant to depend upon recantation by such witnesses would be subversive of the proper

2025In rejecting the argument that the mere fact of recantation entitles a defendant to a new trial, this Court made the following generalization about the character of violent crime witnesses: "Bearing in mind that the witnesses to crimes of violence are often of a low and degraded character and that after they have given their testimony they are sometimes [*6]influenced by bribery and other improper considerations, it is evident that the establishment of a rule which left the power to grant a new trial to a defendant to depend upon recantation by such witnesses would be subversive of the proper

11
Screen Actors Guild-Producers Health Plan v. State of New York Department of Healthgreen
nysupct · 1999 · cited in 1 New York opinions naming this issue, 2024–2024
1 sentence

2024Nonetheless, an agency’s implementation or application of its interpretation of a law, rule, or policy is not itself a rule (see Matter of Stern v Daines, 2009 NY Slip Op 32836[U] , *17, 2009 NY Misc LEXIS 3670 , *25 [Sup Ct, Queens County, Nov. 23, 2009]; Screen Actors Guild- Producers Health Plan v State of New York Dept. of Health, 180 Misc 2d 709, 713 [Sup Ct, N.Y.

11
Matter of Gaspard v. Queens Party Hall Inc.green
nyappdiv · 2020 · cited in 1 New York opinions naming this issue, 2023–2023
2 sentences

2023Regarding the establishment of the claim, "whether a compensable accident has occurred is a question of fact to be resolved by the Board and its determination will not be disturbed when supported by substantial evidence" ( Matter of Minichino v Amazon.com DEDC LLC , 204 AD3d 1289 , 1291 [3d Dept 2022] [internal quotation marks, brackets and citations omitted]; see Matter of Gaspard v Queens Party Hall Inc. , 189 AD3d 1880, 1880 [3d Dept 2020], lv denied 36 NY3d 912 [2021]). "[A]n injury is compensable only where it 'arises out of and in the course of the employment' [*2]" ( Matter of Scriven v

2023Regarding the establishment of the claim, "whether a compensable accident has occurred is a question of fact to be resolved by the Board and its determination will not be disturbed when supported by substantial evidence" ( Matter of Minichino v Amazon.com DEDC LLC , 204 AD3d 1289 , 1291 [3d Dept 2022] [internal quotation marks, brackets and citations omitted]; see Matter of Gaspard v Queens Party Hall Inc. , 189 AD3d 1880, 1880 [3d Dept 2020], lv denied 36 NY3d 912 [2021]). "[A]n injury is compensable only where it 'arises out of and in the course of the employment' [*2]" ( Matter of Scriven v

11
Matter of Scriven v. Davis Ulmer Sprinkler Co.green
nyappdiv · 2020 · cited in 1 New York opinions naming this issue, 2023–2023
1 sentence

2023Regarding the establishment of the claim, "whether a compensable accident has occurred is a question of fact to be resolved by the Board and its determination will not be disturbed when supported by substantial evidence" ( Matter of Minichino v Amazon.com DEDC LLC , 204 AD3d 1289 , 1291 [3d Dept 2022] [internal quotation marks, brackets and citations omitted]; see Matter of Gaspard v Queens Party Hall Inc. , 189 AD3d 1880, 1880 [3d Dept 2020], lv denied 36 NY3d 912 [2021]). "[A]n injury is compensable only where it 'arises out of and in the course of the employment' [*2]" ( Matter of Scriven v

11
Claim of McGuinness v. John P. Picone, Inc.green
nyappdiv · 2007 · cited in 1 New York opinions naming this issue, 2022–2022
1 sentence

2022Although Liberty contested the establishment of the claim, it was precluded from presenting any witnesses from the employer at the hearing because its scheduled witness did not appear ( compare Matter of McGuinness v John P. Picone, Inc. , 36 AD3d 1032, 1032 [3d Dept 2007]).

11
Matter of McLaughlin v. Sahlen Packing Co., Inc.green
nyappdiv · 2021 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021Board." Accordingly, we further discern no abuse of discretion in the Board's denial of the application for review based upon the carrier's noncompliance with 12 NYCRR 300.13 (b) (2) (ii) ( see Matter of Barber v County of Cortland , 193 AD3d 1202, 1203 [2021]; Matter of McLaughlin v Sahlen Packing Co, Inc. , 192 AD3d 1315, 1316 [2021]). [FN2] The carrier further argues that the Board erred in denying its request — in the first application for review — for a rehearing or reopening of the claim on the issues of employment relationship and coverage, as further development of the record is requir

11
Matter of Barber v. County of Cortlandgreen
nyappdiv · 2021 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021Board." Accordingly, we further discern no abuse of discretion in the Board's denial of the application for review based upon the carrier's noncompliance with 12 NYCRR 300.13 (b) (2) (ii) ( see Matter of Barber v County of Cortland , 193 AD3d 1202, 1203 [2021]; Matter of McLaughlin v Sahlen Packing Co, Inc. , 192 AD3d 1315, 1316 [2021]). [FN2] The carrier further argues that the Board erred in denying its request — in the first application for review — for a rehearing or reopening of the claim on the issues of employment relationship and coverage, as further development of the record is requir

11
Matter of Martinez v. New York Producegreen
nyappdiv · 2020 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021As the employer's response was patently defective by not providing the date on which the objection or exception was made, we cannot say that the Board abused its discretion in deeming the employer's response to be incomplete ( see Matter of Randell v Christie's Inc. , 183 AD3d at 1060 ; Matter of Fadul v Subcontracting Concepts, LLC , 182 AD3d 973, 974 [2020]; Matter of Martinez v New York Produce , 182 AD3d at 967).

11
Matter of Fadul v. Subcontracting Concepts, LLCgreen
nyappdiv · 2020 · cited in 1 New York opinions naming this issue, 2021–2021
1 sentence

2021As the employer's response was patently defective by not providing the date on which the objection or exception was made, we cannot say that the Board abused its discretion in deeming the employer's response to be incomplete ( see Matter of Randell v Christie's Inc. , 183 AD3d at 1060 ; Matter of Fadul v Subcontracting Concepts, LLC , 182 AD3d 973, 974 [2020]; Matter of Martinez v New York Produce , 182 AD3d at 967).

11
Rolleri v. Mastic Beach Ambulance Co.green
nyappdiv · 2013 · cited in 1 New York opinions naming this issue, 2018–2018
1 sentence

2018As to the establishment of the claim, "[w]hether a compensable accident has occurred presents a question of fact for resolution by the Board and its decision will be upheld when supported by substantial evidence" ( Matter of Rolleri v Mastic Beach Ambulance Co., Inc. , 106 AD3d 1292, 1292 [2013], lv denied 21 NY3d 865 [2013]; accord Matter of Oathout v Averill Park Cent.

11
Matter of Oathout v. Averill Park Central Schoolsgreen
nyappdiv · 2016 · cited in 1 New York opinions naming this issue, 2018–2018
1 sentence

2018Sch. , 142 AD3d 749, 750 [2016]).

11
Genger v. Gengergreen
nyappdiv · 2011 · cited in 1 New York opinions naming this issue, 2013–2013
1 sentence

2013(CPLR 1001 [a]; Genger v Genger, 87 AD3d 871, 874 [1st Dept 2011].) In any event, estoppel against the government is “foreclosed ‘in all but the rarest cases.’ ” (Matter of New York State Med.

11
Peck v. Peckgreen
nyappdiv · 1996 · cited in 1 New York opinions naming this issue, 2013–2013
11
Lee v. Weismangreen
scotus · 1992 · cited in 1 New York opinions naming this issue, 1996–1996
11
Zobrest v. Catalina Foothills School Districtgreen
scotus · 1993 · cited in 1 New York opinions naming this issue, 1993–1993
11
Sherrill v. Grayco Builders, Inc.green
ny · 1985 · cited in 1 New York opinions naming this issue, 1993–1993
11
Wallace v. Jaffreegreen
scotus · 1985 · cited in 1 New York opinions naming this issue, 1992–1992
11
Widmar v. Vincentgreen
scotus · 1981 · cited in 1 New York opinions naming this issue, 1985–1985
11
Brownstein v. Brownsteingreen
nyappdiv · 1966 · cited in 1 New York opinions naming this issue, 1972–1972
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (54)

CaseCitedYears
Engel v. Vitale green
scotus · 1962
2 sentences

1978Similarly, the establishment clause forbids a board of education from composing a prayer to be read in its schools even though students are compelled neither to recite nor hear it (Engel v Vitale, 370 US 421 ).

1969See, also, McCollum v. Board of Educ. ( 333 U. S. 203, 211-212 ), where the court said: “ A manifestation of such hostility [toward religion] would be at war with our national tradition as embodied in the First Amendment’s guaranty of the free exercise of religion.” Engel v. Vitale ( 370 U. S. 421, 422 ) involved a constitutional attack on the practice of a New York public school district in commencing the school day by reciting the following prayer composed by the State Board of Regents: “ Almighty God, we acknowledge our dependence upon Thee, and we beg Thy blessings upon us, our parents, ou

31969–1978
Epperson v. Arkansas green
scotus · 1968
2 sentences

1986(Compare, Babbitt v Farm Workers, 442 US 289, 301-302 , supra, and Epperson v Arkansas, 393 US 97 , where statutes were attacked facially for unlawfully restricting speech [Babbitt] and as violative of the establishment clause [Epperson]) What plaintiff must prove to establish its constitutional claim as a charity under the established standard (see, Matter of Society for Ethical Culture v Spatt, 51 NY2d 449, 455 , supra) 7 is neither dependent upon nor peculiar to its religious character.

1973Thus, the Supreme Court has held invalid a system of release time for religious instruction conducted on public school premises (McCollum v. Board of Educ., 333 U. S. 203 ), a program of prayers and Bible-reading in the public schools (Abington School Dist. v. Schempp, 374 U. S. 203 ; Engel v. Vitale, 370 U. S. 421 ), and programs of public school instruction favoring a religious view of life (Epperson v. Arkansas, 393 U. S. 97 ).

21973–1986
Walz v. Tax Comm'n of City of New York green
scotus · 1970
2 sentences

1985Although seemingly contradictory, the two clauses must be interpreted together in that their common purpose is to secure religious freedoms. {See, Choper, The Religion Clauses of the First Amendment: Reconciling the Conflict, 41 U Pitt L Rev 673.) The difficulty faced by courts in interpreting the aforedescribed clauses has been “to find a neutral course between the two Religion Clauses, both of which are cast in absolute terms, and either of which, if expanded to a logical extreme, would tend to clash with the other.” (Walz v Tax Commn., 397 US 664, 668-669 ; see also, Zorach v Clauson, 343 U

1981In support of their contention that the statutory exclusion violates the establishment clause, the tenants cite Walz v Tax Comm. ( 397 US 664 ).

21981–1985
Schuttinger v. Woodruff green
ny · 1932
2 sentences

1957One must assert the validity of Ms claim and the other must in good faith deny all or part of it.” (Schuttinger v. Woodruff, 259 N. Y. 212, 216 ; Eames Vacuum Brake Co. v. Prosser, 157 N. Y. 289, 301 ; Laroe v. Sugar Loaf Dairy Co., 180 N. Y. 367, 371 ; Schnell v. Perlmon, 238 N. Y. 362, 367 .) In the present case however it is apparent that no dispute existed between the parties at the time of the alleged accord and satisfaction.

1933One must assert the validity of his claim and the other must in good faith deny all or part of it.” (Schuttinger v. Woodruff, 259 N. Y. 212, 216 .) The defendant, in its answer, seeks also to offset against the plaintiff rent for the months of March, April and May, 1932, which became due to it from the Decorators Furniture Co., Inc. The difficulty with this is that these rentals matured after the Decorators Furniture Co., Inc., had reassigned the original lease to the plaintiff." This offset, therefore, must fail.

21933–1957
Beebe v. Board of Sup'rs neutral
nysupct · 1892
2 sentences

1913The same rule was applied in Beebe v. Supervisors of Sullivan Co. ( 64 Hun, 377 ; affd. on opinion below, 142 N. Y. 631 ), I consider the enforcement of this rule absolutely necessary for the protection of the public, certainly to the extent that no obligation as against a municipal corporation can be implied because one official consults with another public official as to the performance of his duties or in relation to the public service.

1912The same rule was applied in Beebe v. Supervisors of Sullivan Co., 64 Hun, 377 , 19 N. Y.

21912–1913
McMurray & Thomas v. Gifford green
nysupct · 1850
2 sentences

1884How was the defendant misled by her machinations \ These facts were essential to the establishment of a defense, and yet they were not pleaded, and, therefore, could not be proved (McMurray v. Gifford, 5 How.

1884These facts were essential to the establishment of a defense, and yet they were not pleaded, and, therefore, could not be proved (McMurray v. Gifford, 5 How.

21884–1884
City of Rochester v. . Hart green
ny · 1873
2 sentences

1884Pr. 14 ; Lefler v. Field, 52 N. Y. 621 ; Dubois Hermance, 56 Id. 673 ).

1884Pr. 14 ; Lefler v. Field, 52 N. Y. 621 ; Dubois v. Hermance, 56 N. Y. 673 ).

21884–1884
Finchum v. Colaiacomo green
nyappdiv · 2008
1 sentence

2022Accordingly, the Board's invocation of the doctrine of laches barring Liberty from disputing coverage will not be disturbed ( see Matter of Finchum v Colaiacomo , 55 AD3d at 1086-1087 ).

12022–2022
Matter of Randell v. Christie's Inc. green
nyappdiv · 2020
1 sentence

2021As the employer's response was patently defective by not providing the date on which the objection or exception was made, we cannot say that the Board abused its discretion in deeming the employer's response to be incomplete ( see Matter of Randell v Christie's Inc. , 183 AD3d at 1060 ; Matter of Fadul v Subcontracting Concepts, LLC , 182 AD3d 973, 974 [2020]; Matter of Martinez v New York Produce , 182 AD3d at 967).

12021–2021
People v. Bordowitz green
nycrimct · 1991
1 sentence

2019People v Bordowitz , 155 Misc 2d 128 [Crim Ct, NY County 1991] [while noting that the defense of justification by necessity has typically been rejected by New York courts where protesters demonstrated against existing enacted policies, the Criminal Court, citing to case law from other jurisdictions, found the defense to be applicable in a case where the defendants, who were each charged with criminally possessing a hypodermic instrument, had contended that they were engaged in a needle exchange program justified by the exigencies created by the AIDS epidemic]; People v Gray , 150 Misc 2d 852 [

12019–2019
People v. Gray green
nycrimct · 1991
1 sentence

2019People v Bordowitz , 155 Misc 2d 128 [Crim Ct, NY County 1991] [while noting that the defense of justification by necessity has typically been rejected by New York courts where protesters demonstrated against existing enacted policies, the Criminal Court, citing to case law from other jurisdictions, found the defense to be applicable in a case where the defendants, who were each charged with criminally possessing a hypodermic instrument, had contended that they were engaged in a needle exchange program justified by the exigencies created by the AIDS epidemic]; People v Gray , 150 Misc 2d 852 [

12019–2019
Hunter Highlands I Condominium v. Yolo Equities Corp. green
nyappdiv · 2004
12007–2007
Kirschen v. Marino green
nyappdiv · 2005
12007–2007
Baglio v. St. John's Queens Hospital green
nyappdiv · 2003
12007–2007
Claim of Losurdo v. Asbestos Free, Inc. green
nyappdiv · 2003
12003–2003
Boyd v. Coughlin green
nynd · 1996
11996–1996
Warner v. Orange County Department of Probation green
nysd · 1994
11996–1996
O'Lone v. Estate of Shabazz green
scotus · 1987
11996–1996
Investigation & Determination of an Appropriate Unit & Exclusive Representative Hill-Murray Federation of Teachers, St. Paul v. Hill-Murray High School, Maplewood green
minn · 1992
11995–1995
Hayes v. Crane Hogan Structural Systems green
nyappdiv · 1993
11994–1994
Mendelsohn v. A & D Catering Corp. green
nyappdiv · 1984
11993–1993
In re the Arbitration between Board of Education & Brentwood Teachers Ass'n green
nysupct · 1974
11993–1993
Mendelsohn v. A & D Catering Corp. green
nysupct · 1983
11993–1993
Denihan v. Denihan green
ny · 1974
11993–1993
De Sapio v. Kohlmeyer green
ny · 1974
11993–1993
Van Zandt v. Thompson green
ca7 · 1988
11990–1990
Babbitt v. United Farm Workers National Union green
scotus · 1979
11986–1986
Society for Ethical Culture v. Spatt green
ny · 1980
11986–1986
Everson v. Board of Ed. of Ewing green
scotus · 1947
11985–1985
Scaduto v. State green
nyappdiv · 1982
11985–1985
Roemer v. Board of Public Works of Md. green
scotus · 1976
11985–1985
Committee for Public Education & Religious Liberty v. Regan green
scotus · 1980
11985–1985
Lynch v. Donnelly green
scotus · 1984
11985–1985
Friederwitzer v. Friederwitzer green
ny · 1982
11984–1984
Roe v. Wade red
scotus · 1973
11979–1979
Marsh v. La Marco green
nyappdiv · 1974
11975–1975
In re Clear green
nycfamct · 1969
11974–1974
Arciniega v. Freeman green
scotus · 1971
11973–1973
Goldman v. Goldman green
ny · 1940
11972–1972
Terry v. Ohio green
scotus · 1968
11970–1970

Where else courts name it

CA 89 (1921–2025) NY 53 (1861–2026) FL 43 (1938–2026) OH 42 (1953–2025) WA 42 (1895–2026) MI 39 (1909–2020) IL 39 (1887–2021) PA 39 (1917–2024) NJ 37 (1897–2019) WI 31 (1844–2020) MA 29 (1910–2018) TX 28 (1912–2023) MD 24 (1914–2023) CO 24 (1892–2015) CT 22 (1923–2025) OR 22 (1895–2025) MN 17 (1926–2016) AL 16 (1868–2015) AR 15 (1908–2021) OK 14 (1913–2024) IA 13 (1877–2018) NM 12 (1888–2015) LA 12 (1917–2000) TN 12 (1917–2013) GA 11 (1925–2023) NE 10 (1886–2003) AZ 10 (1960–2016) MO 10 (1906–2011) KS 10 (1901–1996) KY 9 (1899–2023) MS 8 (1950–2005) UT 8 (1986–2022) IN 8 (1942–2005) VA 8 (1925–2015) ME 7 (1844–2006) ID 7 (1890–1996) NC 7 (1874–2011) MT 6 (1878–2012) SC 5 (1846–2021) VT 5 (1979–2017) DC 5 (1982–1997) HI 5 (1987–2020) ND 4 (1895–1986) AK 4 (1979–2022) NV 4 (1959–2022) WV 4 (1950–2014) NH 4 (1967–1995) RI 2 (1919–1980) DE 2 (1974–1990) PR 2 (1942–1956)

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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