exceptions to the general rule in North Carolina

49 North Carolina opinions name it 3 courts 1899–2026 9 in the last five years

The cases below were cited by North Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

Case	Followed	Cited
State v. Greenegreen nc · 1978 · cited in 7 North Carolina opinions naming this issue, 1981–2005 2 sentences 2005Our Supreme Court “has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.” State v. Greene, 294 N.C. 418, 423 , 241 S.E.2d 662, 666 (1978) (citing State v. Arnold, 284 N.C. 41 , 199 S.E.2d 423 (1973); State v. Davis, 229 N.C. 386 , 50 S.E.2d 37 (1948); State v. Biggs, 224 N.C. 722 , 32 S.E.2d 352 (1944)). 2005Our Supreme Court “has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.” State v. Greene, 294 N.C. 418, 423 , 241 S.E.2d 662, 666 (1978) (citing State v. Arnold, 284 N.C. 41 , 199 S.E.2d 423 (1973); State v. Davis, 229 N.C. 386 , 50 S.E.2d 37 (1948); State v. Biggs, 224 N.C. 722 , 32 S.E.2d 352 (1944)).	6	7
State v. Williamsgreen nc · 1981 · cited in 4 North Carolina opinions naming this issue, 1986–1991 2 sentences 1991State v. DeLeonardo, 315 N.C. 762, 769 , 340 S.E.2d 350, 355 (1986). “ ‘Our Court has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.’ ” Id. at 770 , 340 S.E.2d at 356, quoting, State v. Williams, 303 N.C. 507, 513 , 279 S.E.2d 592, 596 (1981). 1991State v. DeLeonardo, 315 N.C. 762, 769 , 340 S.E.2d 350, 355 (1986). “ ‘Our Court has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.’ ” Id. at 770 , 340 S.E.2d at 356, quoting, State v. Williams, 303 N.C. 507, 513 , 279 S.E.2d 592, 596 (1981).	3	4
State v. Thaggardgreen ncctapp · 2005 · cited in 2 North Carolina opinions naming this issue, 2010–2014 2 sentences 2014Our Supreme Court has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule." State v. Thaggard, 168 N.C. 2010"Our Supreme Court has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule." State v. Thaggard, 168 N.C.	2	2
State v. DeLeonardogreen nc · 1986 · cited in 2 North Carolina opinions naming this issue, 1988–1991 2 sentences 1991State v. DeLeonardo, 315 N.C. 762, 769 , 340 S.E.2d 350, 355 (1986). “ ‘Our Court has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.’ ” Id. at 770 , 340 S.E.2d at 356, quoting, State v. Williams, 303 N.C. 507, 513 , 279 S.E.2d 592, 596 (1981). 1991State v. DeLeonardo, 315 N.C. 762, 769 , 340 S.E.2d 350, 355 (1986). “ ‘Our Court has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.’ ” Id. at 770 , 340 S.E.2d at 356, quoting, State v. Williams, 303 N.C. 507, 513 , 279 S.E.2d 592, 596 (1981).	1	2
BODIE ISLAND BEACH CLUB ASS'N, INC. v. Wraygreen ncctapp · 2011 · cited in 1 North Carolina opinions naming this issue, 2017–2017 1 sentence 2017Bodie Island at 289-90, 716 S.E.2d at 74 (internal marks omitted) (citing Lexis-Nexis , 155 N.C.	1	1
State v. Satterfieldgreen nc · 1980 · cited in 1 North Carolina opinions naming this issue, 2012–2012 2 sentences 2012See State v. Satterfield, 300 N.C. 621, 625 , 268 S.E.2d 510, 514 (1980) (“A defendant may move to suppress evidence at trial only if he demonstrates that he did not have a reasonable opportunity to make the motion before trial; or that the State did not give him sufficient advance notice (twenty working days) of its intention to use certain types of evidence; or that additional facts have been discovered after a pretrial determination and denial of the motion which could not have been discovered with reasonable diligence before determination of the motion.”). 2012See State v. Satterfield, 300 N.C. 621, 625 , 268 S.E.2d 510, 514 (1980) (“A defendant may move to suppress evidence at trial only if he demonstrates that he did not have a reasonable opportunity to make the motion before trial; or that the State did not give him sufficient advance notice (twenty working days) of its intention to use certain types of evidence; or that additional facts have been discovered after a pretrial determination and denial of the motion which could not have been discovered with reasonable diligence before determination of the motion.”).	1	1
State v. Hallgreen ncctapp · 1987 · cited in 1 North Carolina opinions naming this issue, 2008–2008 1 sentence 2008App. 447, 450, 355 S.E.2d 250, 252 (1987) (citation omitted).	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (49)

Case	Cited	Years
Jackson v. Jackson green ncctapp · 1984 2 sentences 2021App. 499 , 315 S.E.2d 90 (1984), this Court discussed one of the exceptions to the general rule that a Rule 41(a)(1) dismissal ends the trial court’s jurisdiction to rule on a later motion. 2021App. 499 , 315 S.E.2d 90 (1984), this Court discussed one of the exceptions to the general rule that a Rule 41(a)(1) dismissal ends the trial court’s jurisdiction to rule on a later motion.	4	2021–2021
State v. McClain green nc · 1954 2 sentences 1985The fact that the defendant may have been 571 convicted of reckless driving on another occasion while his driver’s license was suspended and for driving while his driver’s license was suspended does not come within any of the exceptions to the general rule excluding evidence of the commission of other offenses as set out in State v. McClain, 240 N.C. 171 , 81 S.E. 2d 364 (1954). 1985The fact that the defendant may have been 571 convicted of reckless driving on another occasion while his driver’s license was suspended and for driving while his driver’s license was suspended does not come within any of the exceptions to the general rule excluding evidence of the commission of other offenses as set out in State v. McClain, 240 N.C. 171 , 81 S.E. 2d 364 (1954).	4	1972–1987
State v. Fowler green nc · 1949 2 sentences 2022FABIAN 2022-NCCOA-793 Opinion of the Court then citing State v. Fowler, 230 N.C. 470 , 53 S.E.2d 853 (1949)) (noting that evidence of prior bad acts may be admitted into evidence if those acts establish a defendant’s motive, opportunity, or intent to commit the offense charged). ¶ 37 Additionally, “[i]n construing the exceptions to the general rule, our courts have been liberal in admitting evidence of similar sex crimes.” See Sturgis, 74 N.C. 2022FABIAN 2022-NCCOA-793 Opinion of the Court then citing State v. Fowler, 230 N.C. 470 , 53 S.E.2d 853 (1949)) (noting that evidence of prior bad acts may be admitted into evidence if those acts establish a defendant’s motive, opportunity, or intent to commit the offense charged). ¶ 37 Additionally, “[i]n construing the exceptions to the general rule, our courts have been liberal in admitting evidence of similar sex crimes.” See Sturgis, 74 N.C.	3	2022–2022
State v. Patterson green ncctapp · 1984 2 sentences 2022App. at 191-92 , 328 S.E.2d at 458 (citations omitted) (explaining that in State v. Patterson, 66 N.C. 2022App. at 191-92 , 328 S.E.2d at 458 (citations omitted) (explaining that in State v. Patterson, 66 N.C.	3	2022–2022
State v. Sturgis green ncctapp · 1986 2 sentences 2022FABIAN 2022-NCCOA-793 Opinion of the Court then citing State v. Fowler, 230 N.C. 470 , 53 S.E.2d 853 (1949)) (noting that evidence of prior bad acts may be admitted into evidence if those acts establish a defendant’s motive, opportunity, or intent to commit the offense charged). ¶ 37 Additionally, “[i]n construing the exceptions to the general rule, our courts have been liberal in admitting evidence of similar sex crimes.” See Sturgis, 74 N.C. 2022FABIAN 2022-NCCOA-793 Opinion of the Court then citing State v. Fowler, 230 N.C. 470 , 53 S.E.2d 853 (1949)) (noting that evidence of prior bad acts may be admitted into evidence if those acts establish a defendant’s motive, opportunity, or intent to commit the offense charged). ¶ 37 Additionally, “[i]n construing the exceptions to the general rule, our courts have been liberal in admitting evidence of similar sex crimes.” See Sturgis, 74 N.C.	3	2022–2022
State v. . Davis neutral nc · 1948 2 sentences 2005Our Supreme Court “has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.” State v. Greene, 294 N.C. 418, 423 , 241 S.E.2d 662, 666 (1978) (citing State v. Arnold, 284 N.C. 41 , 199 S.E.2d 423 (1973); State v. Davis, 229 N.C. 386 , 50 S.E.2d 37 (1948); State v. Biggs, 224 N.C. 722 , 32 S.E.2d 352 (1944)). 2005Our Supreme Court “has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.” State v. Greene, 294 N.C. 418, 423 , 241 S.E.2d 662, 666 (1978) (citing State v. Arnold, 284 N.C. 41 , 199 S.E.2d 423 (1973); State v. Davis, 229 N.C. 386 , 50 S.E.2d 37 (1948); State v. Biggs, 224 N.C. 722 , 32 S.E.2d 352 (1944)).	3	1978–2005
State v. Arnold green nc · 1973 2 sentences 2005Our Supreme Court “has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.” State v. Greene, 294 N.C. 418, 423 , 241 S.E.2d 662, 666 (1978) (citing State v. Arnold, 284 N.C. 41 , 199 S.E.2d 423 (1973); State v. Davis, 229 N.C. 386 , 50 S.E.2d 37 (1948); State v. Biggs, 224 N.C. 722 , 32 S.E.2d 352 (1944)). 2005Our Supreme Court “has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.” State v. Greene, 294 N.C. 418, 423 , 241 S.E.2d 662, 666 (1978) (citing State v. Arnold, 284 N.C. 41 , 199 S.E.2d 423 (1973); State v. Davis, 229 N.C. 386 , 50 S.E.2d 37 (1948); State v. Biggs, 224 N.C. 722 , 32 S.E.2d 352 (1944)).	2	1978–2005
State v. . Biggs green nc · 1944 2 sentences 2005Our Supreme Court “has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.” State v. Greene, 294 N.C. 418, 423 , 241 S.E.2d 662, 666 (1978) (citing State v. Arnold, 284 N.C. 41 , 199 S.E.2d 423 (1973); State v. Davis, 229 N.C. 386 , 50 S.E.2d 37 (1948); State v. Biggs, 224 N.C. 722 , 32 S.E.2d 352 (1944)). 2005Our Supreme Court “has been very liberal in admitting evidence of similar sex crimes in construing the exceptions to the general rule.” State v. Greene, 294 N.C. 418, 423 , 241 S.E.2d 662, 666 (1978) (citing State v. Arnold, 284 N.C. 41 , 199 S.E.2d 423 (1973); State v. Davis, 229 N.C. 386 , 50 S.E.2d 37 (1948); State v. Biggs, 224 N.C. 722 , 32 S.E.2d 352 (1944)).	2	1978–2005
State v. Cotton green nc · 1987 2 sentences 1987State v. Cotton, 318 N.C. 663 , 351 S.E.2d 277 (1987). 1987State v. Cotton, 318 N.C. 663 , 351 S.E.2d 277 (1987).	2	1987–1987
Mills v. Moore green nc · 1982 1 sentence 2026Love, 305 N.C. at 580 .	1	2026–2026
Wallace v. . Benner green nc · 1931 1 sentence 2024Wallace, 200 N.C. at 131–32 (extraneity omitted) (emphases added).	1	2024–2024
State v. Reavis green ncctapp · 2010 1 sentence 2019Thus, defendant's objection at trial to the admissibility of the evidence is without merit because the objection, treated as a motion to suppress, was not timely made." Id.	1	2019–2019
Lexis-Nexis v. Travishan Corp. green ncctapp · 2002 1 sentence 2017Bodie Island at 289-90, 716 S.E.2d at 74 (internal marks omitted) (citing Lexis-Nexis , 155 N.C.	1	2017–2017
Hunt v. Tender Loving Care Home Care Agency, Inc. green ncctapp · 2002 1 sentence 2007Hunt v. Tender Loving Care Home Care Agency, Inc. , 153 N.C.	1	2007–2007
State v. Barfield green nc · 1979 2 sentences 1983In State v. Barfield, 298 N.C. 306 , 259 S.E.2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed.2d 1137 , reh'g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed.2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted. 1983In State v. Barfield, 298 N.C. 306 , 259 S.E.2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed.2d 1137 , reh'g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed.2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted.	1	1983–1983
Zbaraz v. Miller green scotus · 1980 2 sentences 1983In State v. Barfield, 298 N.C. 306 , 259 S.E.2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed.2d 1137 , reh'g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed.2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted. 1983In State v. Barfield, 298 N.C. 306 , 259 S.E. 2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed. 2d 1137 , reh’g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed. 2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted.	1	1983–1983
Smith v. Hartman green scotus · 1980 2 sentences 1983In State v. Barfield, 298 N.C. 306 , 259 S.E.2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed.2d 1137 , reh'g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed.2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted. 1983In State v. Barfield, 298 N.C. 306 , 259 S.E. 2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed. 2d 1137 , reh’g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed. 2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted.	1	1983–1983
Starr v. Nixon green scotus · 1980 2 sentences 1983In State v. Barfield, 298 N.C. 306 , 259 S.E.2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed.2d 1137 , reh'g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed.2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted. 1983In State v. Barfield, 298 N.C. 306 , 259 S.E. 2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed. 2d 1137 , reh’g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed. 2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted.	1	1983–1983
Celebrezze v. Anderson green scotus · 1980 2 sentences 1983In State v. Barfield, 298 N.C. 306 , 259 S.E.2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed.2d 1137 , reh'g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed.2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted. 1983In State v. Barfield, 298 N.C. 306 , 259 S.E. 2d 510 (1979), cert. denied, 448 U.S. 907 , 100 S.Ct. 3050 , 65 L.Ed. 2d 1137 , reh’g denied, 448 U.S. 918 , 101 S.Ct. 41 , 65 L.Ed. 2d 1181 (1980) our Supreme Court held that in a prosecution for homicide by poisoning, evidence of prior poisonings of other persons was held properly admitted.	1	1983–1983
Kirkrand v. Illinois green scotus · 1958 1 sentence 1982One of the exceptions to the general rule cited in Wiggins is that “[a]n attempted appeal from a non-appealable order is a nullity and does not deprive the tribunal from which the appeal is taken of jurisdiction.” Utilities Comm. v. Edmisten, Attorney General 291 N.C. 361 , 230 S.E. 2d 671 (1976); Bizzell v. Bizzell, 247 N.C. 590 , 101 S.E. 2d 668 (1957), cert. denied, 358 U.S. 888 (1958), reh. denied, 358 U.S. 938 (1959); Cox v. Cox, 246 N.C. 528 , 98 S.E. 2d 879 (1957).	1	1982–1982
Hinkle v. New England Mutual Life Insurance green scotus · 1959	1	1982–1982
State Ex Rel. Utilities Commission v. Edmisten green nc · 1976 2 sentences 1982One of the exceptions to the general rule cited in Wiggins is that “[a]n attempted appeal from a non-appealable order is a nullity and does not deprive the tribunal from which the appeal is taken of jurisdiction.” Utilities Comm. v. Edmisten, Attorney General 291 N.C. 361 , 230 S.E. 2d 671 (1976); Bizzell v. Bizzell, 247 N.C. 590 , 101 S.E. 2d 668 (1957), cert. denied, 358 U.S. 888 (1958), reh. denied, 358 U.S. 938 (1959); Cox v. Cox, 246 N.C. 528 , 98 S.E. 2d 879 (1957). 1982One of the exceptions to the general rule cited in Wiggins is that “[a]n attempted appeal from a non-appealable order is a nullity and does not deprive the tribunal from which the appeal is taken of jurisdiction.” Utilities Comm. v. Edmisten, Attorney General 291 N.C. 361 , 230 S.E. 2d 671 (1976); Bizzell v. Bizzell, 247 N.C. 590 , 101 S.E. 2d 668 (1957), cert. denied, 358 U.S. 888 (1958), reh. denied, 358 U.S. 938 (1959); Cox v. Cox, 246 N.C. 528 , 98 S.E. 2d 879 (1957).	1	1982–1982
Bizzell v. Bizzell green nc · 1958 2 sentences 1982One of the exceptions to the general rule cited in Wiggins is that “[a]n attempted appeal from a non-appealable order is a nullity and does not deprive the tribunal from which the appeal is taken of jurisdiction.” Utilities Comm. v. Edmisten, Attorney General 291 N.C. 361 , 230 S.E. 2d 671 (1976); Bizzell v. Bizzell, 247 N.C. 590 , 101 S.E. 2d 668 (1957), cert. denied, 358 U.S. 888 (1958), reh. denied, 358 U.S. 938 (1959); Cox v. Cox, 246 N.C. 528 , 98 S.E. 2d 879 (1957). 1982One of the exceptions to the general rule cited in Wiggins is that “[a]n attempted appeal from a non-appealable order is a nullity and does not deprive the tribunal from which the appeal is taken of jurisdiction.” Utilities Comm. v. Edmisten, Attorney General 291 N.C. 361 , 230 S.E. 2d 671 (1976); Bizzell v. Bizzell, 247 N.C. 590 , 101 S.E. 2d 668 (1957), cert. denied, 358 U.S. 888 (1958), reh. denied, 358 U.S. 938 (1959); Cox v. Cox, 246 N.C. 528 , 98 S.E. 2d 879 (1957).	1	1982–1982
Cox v. Cox green nc · 1957 2 sentences 1982One of the exceptions to the general rule cited in Wiggins is that “[a]n attempted appeal from a non-appealable order is a nullity and does not deprive the tribunal from which the appeal is taken of jurisdiction.” Utilities Comm. v. Edmisten, Attorney General 291 N.C. 361 , 230 S.E. 2d 671 (1976); Bizzell v. Bizzell, 247 N.C. 590 , 101 S.E. 2d 668 (1957), cert. denied, 358 U.S. 888 (1958), reh. denied, 358 U.S. 938 (1959); Cox v. Cox, 246 N.C. 528 , 98 S.E. 2d 879 (1957). 1982One of the exceptions to the general rule cited in Wiggins is that “[a]n attempted appeal from a non-appealable order is a nullity and does not deprive the tribunal from which the appeal is taken of jurisdiction.” Utilities Comm. v. Edmisten, Attorney General 291 N.C. 361 , 230 S.E. 2d 671 (1976); Bizzell v. Bizzell, 247 N.C. 590 , 101 S.E. 2d 668 (1957), cert. denied, 358 U.S. 888 (1958), reh. denied, 358 U.S. 938 (1959); Cox v. Cox, 246 N.C. 528 , 98 S.E. 2d 879 (1957).	1	1982–1982
State v. Dillard green nc · 1974	1	1976–1976
State v. Allen green · 1973	1	1976–1976
State v. Alford green nc · 1968	1	1973–1973
Corprew v. Geigy Chemical Corporation green nc · 1967	1	1971–1971
Hoke v. Atlantic Greyhound Corp. green nc · 1947	1	1968–1968
Neighbors v. Neighbors green nc · 1952	1	1963–1963
Griffin v. Griffin green nc · 1953	1	1963–1963
In Re Means green nc · 1918	1	1963–1963
Hardee v. Mitchell green nc · 1949	1	1963–1963
Peek v. Wachovia Bank & Trust Company green nc · 1955	1	1957–1957
Moore v. Bezalla neutral nc · 1954	1	1957–1957
Federal Land Bank of Columbia v. Gaines neutral nc · 1933	1	1942–1942
State v. . Stancill green nc · 1919	1	1937–1937
State v. . Ray green nc · 1936	1	1937–1937
State v. . Batts neutral nc · 1936	1	1937–1937
State v. . Simons neutral nc · 1919	1	1937–1937

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 8C-1 (13) NC § N.C. Gen. Stat. § 1A-1 (9) NC § N.C. Gen. Stat. § 15A-1443 (5) NC § N.C. Gen. Stat. § 50-10 (4) NC § N.C. Gen. Stat. § 50-11 (4) NC § N.C. Gen. Stat. § 50-20 (4) NC § N.C. Gen. Stat. § 50-21 (4) NC § N.C. Gen. Stat. § 14-202.1 (3) NC § N.C. Gen. Stat. § 14-27.29 (3) NC § N.C. Gen. Stat. § 15-170 (3) NC § N.C. Gen. Stat. § 15A-926 (3) NC § N.C. Gen. Stat. § 7A-27 (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

NY 92 (1863–2026) TX 72 (1881–2025) CA 57 (1865–2025) NC 49 (1899–2026) PA 44 (1865–2025) AL 40 (1886–2025) MO 36 (1891–2025) GA 35 (1900–2017) IL 30 (1881–2022) VA 30 (1928–2026) KS 28 (1896–2026) IN 28 (1885–2020) OK 26 (1921–2023) MD 25 (1850–2024) NV 19 (1934–2022) KY 17 (1909–2024) WI 16 (1883–2025) IA 16 (1899–1984) MI 16 (1931–2022) LA 16 (1903–2023) FL 15 (1914–2017) WA 15 (1917–2018) CO 15 (1918–2025) OR 12 (1887–2020) CT 12 (1899–2025) UT 11 (1906–2020) AZ 10 (1955–2011) TN 10 (1928–2017) NJ 10 (1896–2025) ID 9 (1905–2009) OH 9 (1929–2025) WV 8 (1908–2022) MN 8 (1909–2011) MA 8 (1878–2021) NE 8 (1888–1979) MS 7 (1924–2021) AR 7 (1914–1963) NM 6 (1902–1992) MT 6 (1981–2015) SC 5 (1925–2023) SD 5 (1912–1993) VT 4 (1879–2025) DE 3 (1913–2019) RI 2 (1978–1981) AK 2 (1979–2026) ME 2 (1984–2001) PR 2 (1907–1932)

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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