exclusion clause (Florida) · Go Syfert
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exclusion clause in Florida

49 Florida opinions name it 3 courts 1955–2024 1 in the last five years

The cases below were cited by Florida 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 (21)

CaseFollowedCited
Alaska Steamship Co. v. Pettersongreen
scotus · 1954 · cited in 5 Florida opinions naming this issue, 1998–2013
2 sentences

2013However, the Supreme Court has held that “[t]here is no general constitutional right to discovery in a criminal case, and Brady did not create one; ... ‘the Due Process Clause has little to say regarding the amount of discovery which the parties must be afforded....’” Weatherford v. Bursey, 429 U.S. 545, 559 , 97 S.Ct. 837 , 51 L.Ed.2d 30 (1977) (quoting Wardius v. Oregon, 412 U.S. 470, 474 , 93 S.Ct. 2208 , 37 L.Ed.2d 82 (1973)); see generally Taylor v. Illinois, 484 U.S. 400, 415 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988) (holding that the exclusion of a defense witness’s testimony as a sanctio

2011See Comer v. State, 730 So.2d 769, 775 (Fla. 1st DCA 1999) (“ ‘In a criminal ease, the exclusion of a defense witness for a discovery violation implicates a defendant’s sixth amendment right to present witnesses as well as the fundamental right to due process.’ M.N. v. State, 724 So.2d 122 [, 124 (Fla. 4th DCA 1998) ]; Taylor v. Illinois, 484 U.S. 400 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988).”).

35
Taylor v. Illinoisgreen
scotus · 1988 · cited in 5 Florida opinions naming this issue, 1998–2013
2 sentences

2013However, the Supreme Court has held that “[t]here is no general constitutional right to discovery in a criminal case, and Brady did not create one; ... ‘the Due Process Clause has little to say regarding the amount of discovery which the parties must be afforded....’” Weatherford v. Bursey, 429 U.S. 545, 559 , 97 S.Ct. 837 , 51 L.Ed.2d 30 (1977) (quoting Wardius v. Oregon, 412 U.S. 470, 474 , 93 S.Ct. 2208 , 37 L.Ed.2d 82 (1973)); see generally Taylor v. Illinois, 484 U.S. 400, 415 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988) (holding that the exclusion of a defense witness’s testimony as a sanctio

2013However, the Supreme Court has held that “[t]here is no general constitutional right to discovery in a criminal case, and Brady did not create one; ... ‘the Due Process Clause has little to say regarding the amount of discovery which the parties must be afforded....’” Weatherford v. Bursey, 429 U.S. 545, 559 , 97 S.Ct. 837 , 51 L.Ed.2d 30 (1977) (quoting Wardius v. Oregon, 412 U.S. 470, 474 , 93 S.Ct. 2208 , 37 L.Ed.2d 82 (1973)); see generally Taylor v. Illinois, 484 U.S. 400, 415 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988) (holding that the exclusion of a defense witness’s testimony as a sanctio

35
Hartford Accident and Indemnity Co. v. Phelpsgreen
fladistctapp · 1974 · cited in 4 Florida opinions naming this issue, 1993–2020
2 sentences

2020Co. v. Phelps, 294 So. 2d 362, 363 (Fla. 1st DCA 1974) (“When we consider the terminology used in the exclusion clause in pari materia with the affirmative statement of coverage from leaks in the plumbing system, we conclude that the exclusion was intended to relate only to damage from water not emanating from the plumbing system.”).

2020Co. v. Phelps, 294 So. 2d 362, 363 (Fla. 1st DCA 1974) (“When we consider the terminology used in the exclusion clause in pari materia with the affirmative statement of coverage from leaks in the plumbing system, we conclude that the exclusion was intended to relate only to damage from water not emanating from the plumbing system.”).

24
MN v. Stategreen
fladistctapp · 1998 · cited in 3 Florida opinions naming this issue, 1999–2011
2 sentences

2011See Comer v. State, 730 So.2d 769, 775 (Fla. 1st DCA 1999) (“ ‘In a criminal ease, the exclusion of a defense witness for a discovery violation implicates a defendant’s sixth amendment right to present witnesses as well as the fundamental right to due process.’ M.N. v. State, 724 So.2d 122 [, 124 (Fla. 4th DCA 1998) ]; Taylor v. Illinois, 484 U.S. 400 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988).”).

2009Rule 3.220(n)(l) provides sanctions for discovery, but “[i]n a criminal case, the exclusion of a defense witness for a discovery violation implicates a defendant’s sixth amendment right to present witnesses as well as the fundamental right to due process.” M.N. v. State, 724 So.2d 122, 124 (Fla. 4th DCA 1998); see also Wessling v. State, 877 So.2d 877, 879 (Fla. 4th DCA 2004) (“Exclusion of exculpatory evidence denies a defendant his fundamental right to defend himself in violation of the Sixth Amendment.”).

23
Richardson v. Stategreen
fla · 1998 · cited in 2 Florida opinions naming this issue, 2010–2017
2 sentences

2017A court must first determine “whether the accused exhibited an actual subjective expectation to negotiate a plea at the time of the discussion.” Id. (quoting Richardson v. State, 706 So.2d 1349, 1353 (Fla. 1998)).

2017A court must first determine “whether the accused exhibited an actual subjective expectation to negotiate a plea at the time of the discussion.” Id. (quoting Richardson v. State, 706 So. 2d 1349, 1353 (Fla. 1998)).

22
Laquila Construction, Inc. v. Travelers Indemnity Co.green
nysd · 1999 · cited in 2 Florida opinions naming this issue, 2003–2005
2 sentences

2005See Laquila Construction, Inc. v. Travelers Indemnity Co. of Illinois, 66 F.Supp.2d 543, 544 (S.D.N.Y. 1999) (involving a policy excluding the “[cjost of making good faulty or defective workmanship or material”).

2003The court rejected the insured's position and determined that the construction company's claim fell "squarely into the exclusion clause simply as a cost incurred to make good the defective concrete." Id. at 545 .

12
Reid v. State Farm Fire & Cas. Co.green
fla · 1977 · cited in 2 Florida opinions naming this issue, 1982–1987
2 sentences

1987See Reid v. State Farm Fire & Casualty Co., 352 So.2d 1172 (Fla. 1977); Linehan v. Alkhabbaz, 398 So.2d 989 (Fla. 4th DCA 1981); Newman v. National Indem.

1982In addition to the policy reasons for such clauses stated in Reid [ v. State Farm Fire and Casualty Co., 352 So.2d 1172 (Fla. 1977)], we also note that insurance premiums may be established in part by reference to potential exposure to liability by insurance companies and may be lower where those most likely to be passengers in the automobile are expressly excluded from coverage. *1070 Florida Farm Bureau Insurance Co. v. Government Employees Insurance Co., 387 So.2d 932, 934 (Fla. 1980).

12
Schoenwetter v. Stategreen
fla · 2010 · cited in 1 Florida opinions naming this issue, 2017–2017
2 sentences

2017“Where a party admission is not clearly part of an attempt to negotiate a plea bargain, this Court has adopted a two-tier analysis for determining whether a statement falls within the exclusion under rule 3.172(i).” Schoenwetter v. State, 46 So.3d 535, 546-47 (Fla. 2010) (citing Calabro v. State, 995 So.2d 307, 313-14 (Fla. 2008)).

2017Florida Rule of Criminal Procedure 3.172(i) provides, “Except as otherwise provided in this rule, evidence of an offer or a plea of guilty or nolo contendere, later withdrawn, or of statements made in connection therewith, is not admissible in any civil or criminal proceeding against the person who made the plea or offer.” -8- “Where a party admission is not clearly part of an attempt to negotiate a plea bargain, this Court has adopted a two-tier analysis for determining whether a statement falls within the exclusion under rule 3.172(i).” Schoenwetter v. State, 46 So. 3d 535, 546-47 (Fla. 2010

11
Calabro v. Stategreen
fla · 2008 · cited in 1 Florida opinions naming this issue, 2017–2017
2 sentences

2017“Where a party admission is not clearly part of an attempt to negotiate a plea bargain, this Court has adopted a two-tier analysis for determining whether a statement falls within the exclusion under rule 3.172(i).” Schoenwetter v. State, 46 So.3d 535, 546-47 (Fla. 2010) (citing Calabro v. State, 995 So.2d 307, 313-14 (Fla. 2008)).

2017Florida Rule of Criminal Procedure 3.172(i) provides, “Except as otherwise provided in this rule, evidence of an offer or a plea of guilty or nolo contendere, later withdrawn, or of statements made in connection therewith, is not admissible in any civil or criminal proceeding against the person who made the plea or offer.” -8- “Where a party admission is not clearly part of an attempt to negotiate a plea bargain, this Court has adopted a two-tier analysis for determining whether a statement falls within the exclusion under rule 3.172(i).” Schoenwetter v. State, 46 So. 3d 535, 546-47 (Fla. 2010

11
Comer v. Stategreen
fladistctapp · 1999 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011See Comer v. State, 730 So.2d 769, 775 (Fla. 1st DCA 1999) (“ ‘In a criminal ease, the exclusion of a defense witness for a discovery violation implicates a defendant’s sixth amendment right to present witnesses as well as the fundamental right to due process.’ M.N. v. State, 724 So.2d 122 [, 124 (Fla. 4th DCA 1998) ]; Taylor v. Illinois, 484 U.S. 400 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988).”).

11
United States v. Andrew Jackson Robertsongreen
ca5 · 1978 · cited in 1 Florida opinions naming this issue, 2010–2010
1 sentence

2010First, a court “must determine ‘whether the accused exhibited an actual subjective expectation to negotiate a plea at the time of the discussion.’” Richardson v. State, 706 So.2d 1349, 1353 (Fla.1998) (quoting United States v. Robertson, 582 F.2d 1356, 1366 (5th Cir.1978)).

11
Wessling v. Stategreen
fladistctapp · 2004 · cited in 1 Florida opinions naming this issue, 2009–2009
1 sentence

2009Rule 3.220(n)(l) provides sanctions for discovery, but “[i]n a criminal case, the exclusion of a defense witness for a discovery violation implicates a defendant’s sixth amendment right to present witnesses as well as the fundamental right to due process.” M.N. v. State, 724 So.2d 122, 124 (Fla. 4th DCA 1998); see also Wessling v. State, 877 So.2d 877, 879 (Fla. 4th DCA 2004) (“Exclusion of exculpatory evidence denies a defendant his fundamental right to defend himself in violation of the Sixth Amendment.”).

11
Johnson v. Stategreen
fladistctapp · 1999 · cited in 1 Florida opinions naming this issue, 2008–2008
1 sentence

2008In reviewing the exclusion of defense evidence, we "must determine whether the erroneously excluded evidence could have had an effect on the jury favorable to the defendant, or, in other words, could the improper exclusion have reasonably affected the outcome of the case." Johnson v. State, 728 So.2d 1204, 1205 (Fla. 3d DCA 1999).

11
Gulf Life Insurance Company v. Nashgreen
fla · 1957 · cited in 1 Florida opinions naming this issue, 2003–2003
1 sentence

2003Co. v. Nash, 97 So.2d 4, 9-10 (Fla. 1957)). [4] Thomas, 673 So.2d at 142-43 . [5] The inclusion of the foreseeability provision in this exclusion clause differentiates this clause significantly from the typical intentional act exclusion clause that has been the subject of so much litigation in the past.

11
United Steelworkers v. Warrior & Gulf Navigation Co.green
scotus · 1960 · cited in 1 Florida opinions naming this issue, 1996–1996
2 sentences

1996See United Steelworkers v. Warrior & Gulf Navigation Co., 363 U.S. 574, 582-83 , 80 S.Ct. 1347, 1352-53 , 4 L.Ed.2d 1409 (1960); United Steelworkers v. American Mfg.

1996See United Steelworkers v. Warrior & Gulf Navigation Co., 363 U.S. 574, 582-83 , 80 S.Ct. 1347, 1352-53 , 4 L.Ed.2d 1409 (1960); United Steelworkers v. American Mfg.

11
Kalell v. Mutual Fire & Automobile Insurance Co.green
iowa · 1991 · cited in 1 Florida opinions naming this issue, 1996–1996
1 sentence

1996Id. at 867 (citations omitted).

11
Protective National Insurance Co. of Omaha v. City of Woodhavengreen
mich · 1991 · cited in 1 Florida opinions naming this issue, 1995–1995
11
SHOALS NAT. BANK OF FLORENCE v. Home Indemnity Co.green
alnd · 1974 · cited in 1 Florida opinions naming this issue, 1985–1985
11
NATIONAL BANK OF COM. IN NEW ORLEANS v. Fidelity & Cas. Co.green
laed · 1970 · cited in 1 Florida opinions naming this issue, 1985–1985
11
Fla. Farm Bureau Ins. v. Government Emp. Ins.green
fla · 1980 · cited in 1 Florida opinions naming this issue, 1982–1982
11
Farrey v. Bettendorfgreen
fla · 1957 · cited in 1 Florida opinions naming this issue, 1979–1979
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (31)

CaseCitedYears
Webb v. American Fire & Casualty Co. green
fla · 1941
2 sentences

2011This Court concluded that if Louis were a named insured, Webb could not recover “because the accident occurred while she was engaged as an employee of the insured.” In the alternative, this Court determined that even if Sophie Davidson were the only named insured on the policy, Webb nevertheless could not recover “because the exclusion clause applies not only to the named insured but also applied to Louis Davidson who was using the automobile with the knowledge and consent of the named insured to transport his employee under his contract of employment with the plaintiff.” Id.

1966In Webb v. American Fire & Casualty Co., Fla. 1941, 5 So.2d 252 , the court noted that an exclusion clause similar to the case at bar with respect to an employee applies not only to the named insured, but also to an omnibus insured using the automobile with the knowledge and consent of the named insured, and held that a claim made by an employee of the additional insured was not covered.

41955–2011
National Surety Corp. v. Windham green
fla · 1954
2 sentences

1985In so doing, the court stated, as dicta, “[o]nly regular employees as distinguished from casual or incidental employees, are within the exclusion clause of the insurance contract.” 74 So.2d at 550 .

1965In the opinion before us for review the district court rejected Mrs. Griffin's contention that the judgment of the trial court was contrary to the decision of this court in National Surety Corp., supra, in which case, by way of obiter dictum, it was said that: "Only regular employees as distinguished from casual or incidental employees, are within the exclusion clause of the insurance contract." In addition to its rejection of this statement from the National Surety Corp. case as authority because it was mere dictum, the district court also concluded that the exclusionary clause involved there

41955–1985
Auto-Owners Ins. Co. v. Anderson green
fla · 2000
2 sentences

2018When the ambiguity arises -8- regarding an exclusion clause, courts construe them "even more strictly against the insurer than coverage clauses." Anderson, 756 So. 2d at 29 .

2001We are not unmindful of our obligation to "read each policy as a whole, endeavoring to give every provision its full meaning and operative effect." Anderson, 756 So.2d at 34 .

22001–2018
Griffin v. Speidel green
fla · 1965
2 sentences

1985Eleven years later, in Griffin v. Speidel, 179 So.2d 569 (Fla.1965), the supreme court expressly receded from its National Surety dicta, stating: Nowhere in the exclusion clauses, or elsewhere, do we find any reasonable basis for construing them to mean that the exclusion applies only to regular employees, but not to casual or incidental employees, as this court said in its dictum in the case of National Surety Corp. supra. 179 So.2d at 571 .

1974In Griffin v. Speidel, supra, wherein this same argument was made as to an identical "employee-exclusion" clause, Mr. Justice O'Connell, writing for the court, stated at 571 of 179 So.2d: "It is our opinion that the exclusion clause is clear and unambiguous.

21974–1985
Oren v. General Accident Fire and Life Assur. Corp. green
fladistctapp · 1965
2 sentences

1969While appellee candidly concedes in its brief that a verdict is not the same as a final judgment, it nonetheless urges us to hold that where a jury verdict has been returned and recorded, the entry of the verdict should be construed by us as the equivalent of a “prosecution to judgment” as such term is used in the policy exclusion, in order to give effect to the intent of the parties, 5 citing us to the case of Oren v. General Accident Fire and Life Assurance Corporation, Fla.App.1965, 175 So.2d 581 .

1967The Third District, in Oren v. General Accident Fire and Life Assurance Corp., Fla.App. 1965, 175 So.2d 581 , held that the exclusion clause was clear and unambiguous, and the insured was denied recovery because of its failure to obtain written consent of the insurer prior to obtaining judgments against an uninsured motorist. [1] *792 In Phoenix Ins.

21967–1969
EMPLOYERS'LIABILITY ASSURANCE CORP. v. Owens green
fla · 1955
2 sentences

1964In Employers’ Liability Assurance Corp. v. Owens, Fla.1955, 78 So.2d 104 , factually similar to the case on review, the Florida Supreme Court distinguished the National Surety Corp. case, supra, by the following language: “In the case of National Surety Corporation v. Windham, Fla., 1954, 74 So.2d 549 , the language of the exclusion clause was before this Court.

1961In the cases of Webb v. American Fire & Casualty Co., 1941, 148 Fla. 714 , 5 So.2d 252 , and Employer's Liability Assurance Corp. v. Owens, Fla. 1955, 78 So.2d 104 , our Supreme Court had before it liability insurance policies containing exclusion provisions similar to sub-paragraphs (f) and (g) of the exclusion clause in the instant policy.

21961–1964
Fabre v. Marin red
fla · 1993
1 sentence

2024We therefore reverse and remand the case for a new trial on liability and damages. 1 Fabre v. Marin, 623 So. 2d 1182 , 1185–87 (Fla. 1993), receded from by Wells v. Tallahassee Mem’l Reg’l Med.

12024–2024
Gore v. State green
fla · 1992
1 sentence

2017“Where the rule has been invoked, a hearing should be conducted to determine whether a witness’ exclusion from the rule will result in prejudice to the accused.” Gore, 599 So.2d at 986 .

12017–2017
Weatherford v. Bursey green
scotus · 1977
2 sentences

2013However, the Supreme Court has held that “[t]here is no general constitutional right to discovery in a criminal case, and Brady did not create one; ... ‘the Due Process Clause has little to say regarding the amount of discovery which the parties must be afforded....’” Weatherford v. Bursey, 429 U.S. 545, 559 , 97 S.Ct. 837 , 51 L.Ed.2d 30 (1977) (quoting Wardius v. Oregon, 412 U.S. 470, 474 , 93 S.Ct. 2208 , 37 L.Ed.2d 82 (1973)); see generally Taylor v. Illinois, 484 U.S. 400, 415 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988) (holding that the exclusion of a defense witness’s testimony as a sanctio

2013However, the Supreme Court has held that “[t]here is no general constitutional right to discovery in a criminal case, and Brady did not create one; ... ‘the Due Process Clause has little to say regarding the amount of discovery which the parties must be afforded....’” Weatherford v. Bursey, 429 U.S. 545, 559 , 97 S.Ct. 837 , 51 L.Ed.2d 30 (1977) (quoting Wardius v. Oregon, 412 U.S. 470, 474 , 93 S.Ct. 2208 , 37 L.Ed.2d 82 (1973)); see generally Taylor v. Illinois, 484 U.S. 400, 415 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988) (holding that the exclusion of a defense witness’s testimony as a sanctio

12013–2013
Wardius v. Oregon green
scotus · 1973
2 sentences

2013However, the Supreme Court has held that “[t]here is no general constitutional right to discovery in a criminal case, and Brady did not create one; ... ‘the Due Process Clause has little to say regarding the amount of discovery which the parties must be afforded....’” Weatherford v. Bursey, 429 U.S. 545, 559 , 97 S.Ct. 837 , 51 L.Ed.2d 30 (1977) (quoting Wardius v. Oregon, 412 U.S. 470, 474 , 93 S.Ct. 2208 , 37 L.Ed.2d 82 (1973)); see generally Taylor v. Illinois, 484 U.S. 400, 415 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988) (holding that the exclusion of a defense witness’s testimony as a sanctio

2013However, the Supreme Court has held that “[t]here is no general constitutional right to discovery in a criminal case, and Brady did not create one; ... ‘the Due Process Clause has little to say regarding the amount of discovery which the parties must be afforded....’” Weatherford v. Bursey, 429 U.S. 545, 559 , 97 S.Ct. 837 , 51 L.Ed.2d 30 (1977) (quoting Wardius v. Oregon, 412 U.S. 470, 474 , 93 S.Ct. 2208 , 37 L.Ed.2d 82 (1973)); see generally Taylor v. Illinois, 484 U.S. 400, 415 , 108 S.Ct. 646 , 98 L.Ed.2d 798 (1988) (holding that the exclusion of a defense witness’s testimony as a sanctio

12013–2013
Castro v. Allstate Ins. Co. green
fladistctapp · 1998
1 sentence

2006Id.

12006–2006
Fabregas v. State green
fladistctapp · 2002
1 sentence

2005Similarly, in Fabregas v. State, 829 So.2d 238 (Fla. 3d DCA 2002), the court disapproved the exclusion of defense witness testimony that went directly to the credibility of the sole prosecution expert witness.

12005–2005
Crump v. State green
fla · 1993
1 sentence

2004Later, in Crump v. State, 622 So.2d 963 (Fla.1993), this Court affirmed a trial court's exclusion of defense questions to a detective witness regarding whether he had been given information that another suspect had committed similar crimes.

12004–2004
Thomas v. Prudential Property and Cas. green
fladistctapp · 1996
1 sentence

2003Co. v. Nash, 97 So.2d 4, 9-10 (Fla. 1957)). [4] Thomas, 673 So.2d at 142-43 . [5] The inclusion of the foreseeability provision in this exclusion clause differentiates this clause significantly from the typical intentional act exclusion clause that has been the subject of so much litigation in the past.

12003–2003
Brower v. Employers' Liability Assurance Co. green
pa · 1935
11996–1996
Richardson v. State green
fla · 1971
11994–1994
United Services Automobile Ass'n v. Elitzky green
pa · 1986
11994–1994
Linehan v. Alkhabbaz neutral
fladistctapp · 1981
11987–1987
The First National Bank Of Decatur v. Insurance Company Of North America green
ca1 · 1970
11985–1985
The National Bank Of Commerce In New Orleans v. Fidelity And Casualty Company Of New York neutral
ca5 · 1971
11985–1985
Volkswagen Insurance Company v. Taylor green
fladistctapp · 1967
11981–1981
cluster 292125 green
ca8 · 1970
11974–1974
King v. Travelers Insurance Company green
nm · 1973
11974–1974
Mullis v. State Farm Mutual Automobile Insurance Co. green
fla · 1971
11974–1974
Travelers Insurance Company v. Elkins green
texapp · 1971
11972–1972
Braswell v. Florida procedural
scotus · 1970
11972–1972
Fox v. Lennon green
scotus · 1970
11972–1972
Feldstein v. United States green
scotus · 1970
11972–1972
Braswell v. State neutral
fladistctapp · 1970
11972–1972
Travelers Indemnity Company v. Powell green
fladistctapp · 1968
11971–1971
Phoenix Insurance Company v. Bowen green
fladistctapp · 1965
11967–1967

Statutes the citing opinions construe

FL § 90.803 (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 175 (1939–2026) TX 96 (1952–2025) IL 88 (1901–2024) LA 86 (1925–2017) NY 78 (1898–2024) PA 62 (1934–2024) MO 59 (1933–2025) NJ 50 (1957–2024) FL 49 (1955–2024) CT 48 (1894–2024) WI 45 (1937–2026) MI 36 (1949–2024) WA 36 (1931–2025) MD 32 (1939–2020) OH 32 (1924–2026) MS 31 (1954–2022) GA 31 (1910–2026) OR 30 (1943–2026) MA 27 (1954–2026) IN 26 (1976–2020) MN 26 (1920–2018) TN 25 (1917–2022) CO 24 (1942–2013) IA 23 (1912–2024) NM 23 (1960–2025) SC 22 (1937–2025) NC 21 (1951–2023) KS 19 (1962–2016) UT 16 (1937–2024) VA 16 (1935–2025) AZ 15 (1970–2023) AL 15 (1903–2015) OK 14 (1952–2011) AR 14 (1945–2025) DC 12 (1986–2026) WY 12 (1971–2025) NH 12 (1963–2023) MT 12 (1967–2023) WV 12 (1982–2023) KY 11 (1958–2025) ID 9 (1981–2014) DE 8 (1962–2024) HI 8 (1992–2021) NV 8 (1952–2014) RI 7 (1958–2007) ND 7 (1965–2020) AK 7 (1981–2007) NE 6 (1943–2015) ME 6 (1952–2019) VT 5 (1894–2012) PR 5 (1949–2023) SD 4 (1963–2012)

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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