aggravating and mitigating factors (Arizona) · Go Syfert
← Arizona issues

aggravating and mitigating factors in Arizona

48 Arizona opinions name it 2 courts 1978–2026 9 in the last five years

The cases below were cited by Arizona 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 (35)

CaseFollowedCited
State v. Roseberrygreen
ariz · 2005 · cited in 3 Arizona opinions naming this issue, 2008–2009
2 sentences

2009III. ¶ 129 Because Dann’s offenses occurred before August 1, 2002, we independently review the aggravating and mitigating factors, as well as the “propriety of the death sentence.” A.R.S. § 13-755.A; see also Roseberry, 210 Ariz. at 373 ¶ 77, 111 P.3d at 415 (stating that this Court “independently reviews the jury’s findings of aggravation and independently determines ‘if the mitigation is sufficiently substantial to warrant leniency in light of existing aggravation’ ” (quoting State v. Greene, 192 Ariz. 431 , 443-44 ¶ 60, 967 P.2d 106, 118-19 (1998))).

2008III. ¶ 72 Because the murders occurred before August 1, 2002, we independently review the aggravating and mitigating factors and the "propriety of the death sentence." A.R.S. § 13-703.04.A; see also State v. Roseberry, 210 Ariz. 360 , 373 ¶ 77, 111 P.3d 402, 415 (2005) ("[The Court] independently determines `if the mitigation is sufficiently substantial to warrant leniency in light of existing aggravation.'" (citation omitted)).

33
State v. Greenegreen
ariz · 1998 · cited in 3 Arizona opinions naming this issue, 2005–2009
2 sentences

2009III. ¶ 129 Because Dann’s offenses occurred before August 1, 2002, we independently review the aggravating and mitigating factors, as well as the “propriety of the death sentence.” A.R.S. § 13-755.A; see also Roseberry, 210 Ariz. at 373 ¶ 77, 111 P.3d at 415 (stating that this Court “independently reviews the jury’s findings of aggravation and independently determines ‘if the mitigation is sufficiently substantial to warrant leniency in light of existing aggravation’ ” (quoting State v. Greene, 192 Ariz. 431 , 443-44 ¶ 60, 967 P.2d 106, 118-19 (1998))).

2009III. ¶ 129 Because Dann’s offenses occurred before August 1, 2002, we independently review the aggravating and mitigating factors, as well as the “propriety of the death sentence.” A.R.S. § 13-755.A; see also Roseberry, 210 Ariz. at 373 ¶ 77, 111 P.3d at 415 (stating that this Court “independently reviews the jury’s findings of aggravation and independently determines ‘if the mitigation is sufficiently substantial to warrant leniency in light of existing aggravation’ ” (quoting State v. Greene, 192 Ariz. 431 , 443-44 ¶ 60, 967 P.2d 106, 118-19 (1998))).

33
State v. Woodgreen
ariz · 1994 · cited in 3 Arizona opinions naming this issue, 1996–2000
2 sentences

2000We independently review both the aggravating and mitigating factors pursuant to A.R.S. § 13-703.01 and State v. Wood, 180 Ariz. 53, 68 , 881 P.2d 1158, 1173 (1994).

2000We independently review both the aggravating and mitigating factors pursuant to A.R.S. § 13-703.01 and State v. Wood, 180 Ariz. 53, 68 , 881 P.2d 1158, 1173 (1994).

33
State v. Smithgreen
ariz · 1983 · cited in 3 Arizona opinions naming this issue, 1984–1985
2 sentences

1985State v. Smith, 138 Ariz. 79, 85 , 673 P.2d 17, 23 (1983); State v. Richmond, 136 Ariz. 312, 317 , 666 P.2d 57, 62 , cert. denied, — U.S. -, 104 S.Ct. 435 , 78 L.Ed.2d 367 (1983).

1985State v. Smith, 138 Ariz. 79, 85 , 673 P.2d 17, 23 (1983); State v. Richmond, 136 Ariz. 312, 317 , 666 P.2d 57, 62 , cert. denied, — U.S. -, 104 S.Ct. 435 , 78 L.Ed.2d 367 (1983).

33
State v. Carbajalgreen
arizctapp · 1994 · cited in 3 Arizona opinions naming this issue, 2020–2024
2 sentences

2024See State v. Carbajal, 177 Ariz. 461, 463 (App. 1994) (‘The trial court is in the best position to determine the evidence surrounding the aggravating and mitigating factors and which factors should be given credence.”).

2023The superior court “is in the best position to determine the evidence surrounding the aggravating and mitigating factors[,]” including “which factors should be given credence,” Carbajal, 177 Ariz. at 463 , and “the weight to be given that evidence,” State v. Gonzales, 181 Ariz. 502, 515 (1995). ¶14 After the jury rendered its verdicts, the superior court granted Hall’s requests to appoint a mental health expert and order a mental examination and evaluation.

23
Attorney Grievance Commission of Maryland v. Weinrauchgreen
md · 2008 · cited in 2 Arizona opinions naming this issue, 2010–2010
2 sentences

2010See In re Galbasini, 163 Ariz. at 121, 125-26 , 786 P.2d at 972, 976-77 (adopting recommended six-month suspension of attorney for knowingly failing to supervise nonlawyer employees who engaged in debt collection and improperly solicited clients in attorney’s name); Davis & Goldberg v. Ala. State Bar, 676 So.2d 306, 307-08 (Ala.1996) (upholding two-month suspension of two partners for implementing policies designed to minimize expenses and maximize profits, to clients’ detriment, when firm’s practices resulted in unmanageable caseloads and permitted nonlawyers to perform legal services); Att’y

2010See In re Galbasini, 163 Ariz. at 121, 125-26 , 786 P.2d at 972, 976-77 (adopting recommended six-month suspension of attorney for knowingly failing to supervise nonlawyer employees who engaged in debt collection and improperly solicited clients in attorney's name); Davis & Goldberg v. Ala. State Bar, 676 So.2d 306, 307-08 (Ala.1996) (upholding two-month suspension of two partners for implementing policies designed to minimize expenses and maximize profits, to clients' detriment, when firm's practices resulted in unmanageable caseloads and permitted nonlawyers to perform legal services); Att'y

22
In Re a Member of the State Bar of Arizona, Galbasinigreen
ariz · 1990 · cited in 2 Arizona opinions naming this issue, 2010–2010
2 sentences

2010See In re Galbasini, 163 Ariz. at 121, 125-26 , 786 P.2d at 972, 976-77 (adopting recommended six-month suspension of attorney for knowingly failing to supervise nonlawyer employees who engaged in debt collection and improperly solicited clients in attorney’s name); Davis & Goldberg v. Ala. State Bar, 676 So.2d 306, 307-08 (Ala.1996) (upholding two-month suspension of two partners for implementing policies designed to minimize expenses and maximize profits, to clients’ detriment, when firm’s practices resulted in unmanageable caseloads and permitted nonlawyers to perform legal services); Att’y

2010See In re Galbasini, 163 Ariz. at 121, 125-26 , 786 P.2d at 972, 976-77 (adopting recommended six-month suspension of attorney for knowingly failing to supervise nonlawyer employees who engaged in debt collection and improperly solicited clients in attorney’s name); Davis & Goldberg v. Ala. State Bar, 676 So.2d 306, 307-08 (Ala.1996) (upholding two-month suspension of two partners for implementing policies designed to minimize expenses and maximize profits, to clients’ detriment, when firm’s practices resulted in unmanageable caseloads and permitted nonlawyers to perform legal services); Att’y

22
Davis v. Alabama State Bargreen
ala · 1996 · cited in 2 Arizona opinions naming this issue, 2010–2010
2 sentences

2010See In re Galbasini, 163 Ariz. at 121, 125-26 , 786 P.2d at 972, 976-77 (adopting recommended six-month suspension of attorney for knowingly failing to supervise nonlawyer employees who engaged in debt collection and improperly solicited clients in attorney’s name); Davis & Goldberg v. Ala. State Bar, 676 So.2d 306, 307-08 (Ala.1996) (upholding two-month suspension of two partners for implementing policies designed to minimize expenses and maximize profits, to clients’ detriment, when firm’s practices resulted in unmanageable caseloads and permitted nonlawyers to perform legal services); Att’y

2010See In re Galbasini, 163 Ariz. at 121, 125-26 , 786 P.2d at 972, 976-77 (adopting recommended six-month suspension of attorney for knowingly failing to supervise nonlawyer employees who engaged in debt collection and improperly solicited clients in attorney's name); Davis & Goldberg v. Ala. State Bar, 676 So.2d 306, 307-08 (Ala.1996) (upholding two-month suspension of two partners for implementing policies designed to minimize expenses and maximize profits, to clients' detriment, when firm's practices resulted in unmanageable caseloads and permitted nonlawyers to perform legal services); Att'y

22
State v. Scottgreen
ariz · 1993 · cited in 2 Arizona opinions naming this issue, 1995–2002
2 sentences

2002Because it is but one fact, it cannot be weighed twice, even though it satisfied two separate aggravating factors. 177 Ariz. 131, 144 , 865 P.2d 792, 805 (1993).

2002Because it is but one fact, it cannot be weighed twice, even though it satisfied two separate aggravating factors. 177 Ariz. 131, 144 , 865 P.2d 792, 805 (1993).

22
State v. Harrisongreen
ariz · 1999 · cited in 2 Arizona opinions naming this issue, 2001–2024
2 sentences

2024See Webb, 164 Ariz. at 354-55 . ¶19 In support of his assertion that the court erred in “fail[ing] to enumerate the aggravating and mitigating factors on the record,” Alvarez cites State v. Bonfiglio, 231 Ariz. 371 (2013), and State v. Harrison, 195 Ariz. 1 (1999).

2001The aggravating circumstances are sufficiently substantial to warrant an aggravated sentence. ¶ 3 In his Rule 32 petition, petitioner challenged the aggravated sentence, arguing (1) that the trial court erred in relying on aggravating factors that were not alleged by the prosecutor in his sentencing memorandum; (2) that the trial court failed to consider and properly weigh mitigating evidence presented by the defense, contrary to State v. Harrison, 195 Ariz. 1 , 985 P.2d 486 (1999); (3) that the trial court erred as a matter of law in finding that the crime was committed in an “especially hein

12
State v. Gomezgreen
arizctapp · 1976 · cited in 1 Arizona opinions naming this issue, 2026–2026
1 sentence

2026See State v. Gomez, 27 Ariz. App. 248, 251 (1976) (citing Ariz. R.

11
State Ex Rel. Thomas v. Granvillegreen
ariz · 2005 · cited in 1 Arizona opinions naming this issue, 2025–2025
1 sentence

2025See id. at 473 ¶ 21 (describing the jury’s assessment of mitigating evidence as based on “[each] juror’s assessment of the quality and significance of the mitigating evidence”). ¶74 Second, the prosecutor did not suggest that jurors must unanimously agree on individual mitigating circumstances.

11
State v. Webbgreen
arizctapp · 1990 · cited in 1 Arizona opinions naming this issue, 2024–2024
2 sentences

2024State v. Webb, 164 Ariz. 348, 355 (App. 1990).

2024See Webb, 164 Ariz. at 354-55 . ¶19 In support of his assertion that the court erred in “fail[ing] to enumerate the aggravating and mitigating factors on the record,” Alvarez cites State v. Bonfiglio, 231 Ariz. 371 (2013), and State v. Harrison, 195 Ariz. 1 (1999).

11
State v. Trujillogreen
arizctapp · 2011 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024See Escalante, 245 Ariz. at 144, ¶ 34; Trujillo, 227 Ariz. at 319, ¶ 21 .

11
State v. Van Adamsgreen
ariz · 1999 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024See State v. Van Adams, 194 Ariz. 408, 421-22, ¶¶48-50 (1999).

11
State of Arizona v. Austin James Bonfigliogreen
ariz · 2013 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024See Webb, 164 Ariz. at 354-55 . ¶19 In support of his assertion that the court erred in “fail[ing] to enumerate the aggravating and mitigating factors on the record,” Alvarez cites State v. Bonfiglio, 231 Ariz. 371 (2013), and State v. Harrison, 195 Ariz. 1 (1999).

11
State v. Gonzalesgreen
ariz · 1995 · cited in 1 Arizona opinions naming this issue, 2023–2023
1 sentence

2023The superior court “is in the best position to determine the evidence surrounding the aggravating and mitigating factors[,]” including “which factors should be given credence,” Carbajal, 177 Ariz. at 463 , and “the weight to be given that evidence,” State v. Gonzales, 181 Ariz. 502, 515 (1995). ¶14 After the jury rendered its verdicts, the superior court granted Hall’s requests to appoint a mental health expert and order a mental examination and evaluation.

11
State v. Sunigagreen
arizctapp · 1985 · cited in 1 Arizona opinions naming this issue, 2023–2023
1 sentence

2023State v. Suniga, 145 Ariz. 389, 395 (App. 1985). ¶13 The record does not show that the trial court used Martin’s lack of remorse to impose consecutive or aggravated sentences.

11
State v. Cidgreen
arizctapp · 1995 · cited in 1 Arizona opinions naming this issue, 2020–2020
1 sentence

2020The record here reflects the court received and therefore considered character letters, mental health records, and information regarding Wallace’s methamphetamine use and history of trauma and made findings on all the relevant statutory mitigating factors before imposing his sentence. 3 See State v. Cid, 181 Ariz. 496, 501 (App. 1995) (“[A]n appellate court presumes that the trial court considered all relevant mitigating factors in rendering its sentencing decision.”).

11
State v. Cazaresgreen
arizctapp · 2003 · cited in 1 Arizona opinions naming this issue, 2020–2020
1 sentence

2020“The trial court is in the best position to determine the evidence surrounding the aggravating and mitigating factors and which factors should be given credence.” State v. Carbajal, 177 Ariz. 461, 463 (App. 1994). 8 STATE v. WALLACE Decision of the Court ¶25 Wallace admits that while the court must consider mitigation evidence, see A.R.S. § 13-701(E), the court “is not required to accept such evidence,” State v. Stokley, 182 Ariz. 505, 519 (1995); see also State v. Cazares, 205 Ariz. 425, 427, ¶ 8 (App. 2003) (“[A] sentencing court is not required to find that mitigating circumstances exist me

11
State v. Stokleygreen
ariz · 1995 · cited in 1 Arizona opinions naming this issue, 2020–2020
1 sentence

2020“The trial court is in the best position to determine the evidence surrounding the aggravating and mitigating factors and which factors should be given credence.” State v. Carbajal, 177 Ariz. 461, 463 (App. 1994). 8 STATE v. WALLACE Decision of the Court ¶25 Wallace admits that while the court must consider mitigation evidence, see A.R.S. § 13-701(E), the court “is not required to accept such evidence,” State v. Stokley, 182 Ariz. 505, 519 (1995); see also State v. Cazares, 205 Ariz. 425, 427, ¶ 8 (App. 2003) (“[A] sentencing court is not required to find that mitigating circumstances exist me

11
In Re Alcorngreen
ariz · 2002 · cited in 1 Arizona opinions naming this issue, 2013–2013
2 sentences

2013The sanction is not intended to punish the disciplined lawyer, In re Alcorn, *16 202 Ariz. 62 , 74 ¶ 41, 41 P.3d 600, 612 (2002), although it may have that effect. ¶ 64 After considering the aggravating and mitigating factors, we conclude that the presumptive sanction of suspension is warranted.

2013The sanction is not intended to punish the disciplined lawyer, In re Alcorn, *16 202 Ariz. 62 , 74 ¶ 41, 41 P.3d 600, 612 (2002), although it may have that effect. ¶ 64 After considering the aggravating and mitigating factors, we conclude that the presumptive sanction of suspension is warranted.

11
State v. Fattygreen
arizctapp · 1986 · cited in 1 Arizona opinions naming this issue, 2010–2010
11
State v. Gilliesgreen
ariz · 1984 · cited in 1 Arizona opinions naming this issue, 2005–2005
11
State v. Hoskinsgreen
ariz · 2003 · cited in 1 Arizona opinions naming this issue, 2004–2004
11
State v. Viramontesgreen
ariz · 2003 · cited in 1 Arizona opinions naming this issue, 2004–2004
11
State v. Guytangreen
arizctapp · 1998 · cited in 1 Arizona opinions naming this issue, 2001–2001
11
State v. McKinneygreen
ariz · 1996 · cited in 1 Arizona opinions naming this issue, 1999–1999
11
State v. Styersgreen
ariz · 1993 · cited in 1 Arizona opinions naming this issue, 1995–1995
11
State v. Milkegreen
ariz · 1993 · cited in 1 Arizona opinions naming this issue, 1995–1995
11
State v. Lopezgreen
ariz · 1992 · cited in 1 Arizona opinions naming this issue, 1993–1993
11
State v. Holstungreen
arizctapp · 1983 · cited in 1 Arizona opinions naming this issue, 1993–1993
11
State v. Libbertongreen
ariz · 1984 · cited in 1 Arizona opinions naming this issue, 1986–1986
11
State v. Gilliesgreen
ariz · 1983 · cited in 1 Arizona opinions naming this issue, 1986–1986
11
State v. Jordangreen
ariz · 1976 · cited in 1 Arizona opinions naming this issue, 1978–1978
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (22)

CaseCitedYears
State v. Richmond green
ariz · 1983
2 sentences

1996Rather, they point to State v. Gretzler, supra, which issued subsequent to the re-sentencing but prior to [State v. Richmond, 136 Ariz. 312 , 666 P.2d 57 (1983) ] (Richmond II), and which provided an adequate narrowing construction of the “especially heinous, cruel or depraved” factor.

1996Rather, they point to State v. Gretzler, supra, which issued subsequent to the re-sentencing but prior to [State v. Richmond, 136 Ariz. 312 , 666 P.2d 57 (1983) ] (Richmond II), and which provided an adequate narrowing construction of the “especially heinous, cruel or depraved” factor.

41984–1996
In the Matter of Rachel R. Alexander green
ariz · 2013
2 sentences

2024“Lawyer discipline also ‘deter[s] the [disciplined] attorney and others from engaging in the same or similar misconduct.’” Id. (quoting In re Alexander, 232 Ariz. at 15 ¶ 63) (alterations in original). ¶56 After having considered the aggravating and mitigating factors involved and the relative weight to give to each, we conclude that a 17 IN THE MATTER OF LISE R.

2014“The sanction to be imposed, however, requires consideration of any pertinent aggravating and mitigating factors.” In re Alexander, 232 Ariz. at 14 ¶ 57, 300 P.3d at 549 . ¶41 After considering the aggravating and mitigating factors, we conclude that disbarment is too severe a sanction.

32014–2024
Hydroculture, Inc. v. Coopers green
scotus · 1983
2 sentences

1985State v. Smith, 138 Ariz. 79, 85 , 673 P.2d 17, 23 (1983); State v. Richmond, 136 Ariz. 312, 317 , 666 P.2d 57, 62 , cert. denied, — U.S. -, 104 S.Ct. 435 , 78 L.Ed.2d 367 (1983).

1985State v. Smith, 138 Ariz. 79, 85 , 673 P.2d 17, 23 (1983), cert. denied, — U.S. -, 104 S.Ct. 1429 , 79 L.Ed.2d 753 (1984); State v. Richmond, 136 Ariz. 312, 317 , 666 P.2d 57, 62 , cert. denied, — U.S. -, 104 S.Ct. 435 , 78 L.Ed.2d 367 (1983).

31984–1985
Burden v. Woodside Cotton Mills green
sc · 1916
2 sentences

1985State v. Smith, 138 Ariz. 79, 85 , 673 P.2d 17, 23 (1983); State v. Richmond, 136 Ariz. 312, 317 , 666 P.2d 57, 62 , cert. denied, — U.S. -, 104 S.Ct. 435 , 78 L.Ed.2d 367 (1983).

1985State v. Smith, 138 Ariz. 79, 85 , 673 P.2d 17, 23 (1983), cert. denied, — U.S. -, 104 S.Ct. 1429 , 79 L.Ed.2d 753 (1984); State v. Richmond, 136 Ariz. 312, 317 , 666 P.2d 57, 62 , cert. denied, — U.S. -, 104 S.Ct. 435 , 78 L.Ed.2d 367 (1983).

31984–1985
Attorney Grievance Commission v. Kimmel green
md · 2008
2 sentences

2010See In re Galbasini, 163 Ariz. at 121, 125-26 , 786 P.2d at 972, 976-77 (adopting recommended six-month suspension of attorney for knowingly failing to supervise nonlawyer employees who engaged in debt collection and improperly solicited clients in attorney’s name); Davis & Goldberg v. Ala. State Bar, 676 So.2d 306, 307-08 (Ala.1996) (upholding two-month suspension of two partners for implementing policies designed to minimize expenses and maximize profits, to clients’ detriment, when firm’s practices resulted in unmanageable caseloads and permitted nonlawyers to perform legal services); Att’y

2010See In re Galbasini, 163 Ariz. at 121, 125-26 , 786 P.2d at 972, 976-77 (adopting recommended six-month suspension of attorney for knowingly failing to supervise nonlawyer employees who engaged in debt collection and improperly solicited clients in attorney's name); Davis & Goldberg v. Ala. State Bar, 676 So.2d 306, 307-08 (Ala.1996) (upholding two-month suspension of two partners for implementing policies designed to minimize expenses and maximize profits, to clients' detriment, when firm's practices resulted in unmanageable caseloads and permitted nonlawyers to perform legal services); Att'y

22010–2010
Matter of Rivkind green
ariz · 1990
2 sentences

1992Considering the ABA-recommended sanctions, and the aggravating and mitigating factors involved, the Commission does not believe suspension would serve the purpose of disciplinary proceedings, which is "... to protect the public and deter similar conduct by other lawyers.” In re Rivkind, 164 Ariz. 154 , 791 P.2d 1037 (1990).

1992Considering the ABA-recommended sanctions, and the aggravating and mitigating factors involved, the Commission does not believe suspension would serve the purpose of disciplinary proceedings, which is "... to protect the public and deter similar conduct by other lawyers.” In re Rivkind, 164 Ariz. 154 , 791 P.2d 1037 (1990).

21992–1992
In Re Zawada green
ariz · 2004
1 sentence

2025Importantly, though, “[t]he sanction is not intended to punish the disciplined lawyer.” Id. ¶113 After considering the aggravating and mitigating factors involved, and comparing similar cases, we conclude that the presumptive sanction of suspension is warranted.

12025–2025
State v. Baum green
arizctapp · 1995
1 sentence

2024Id. at 140 .

12024–2024
State v. Beasley green
arizctapp · 2003
12005–2005
Philip Morris Inc. v. Cabarrus County green
scotus · 1994
11995–1995
Carroll v. Crist green
scotus · 1994
11995–1995
Andrisani v. Saugus Colony Ltd. green
scotus · 1994
11995–1995
In Re Ockrassa green
ariz · 1990
11994–1994
State v. Grier green
ariz · 1985
11991–1991
State v. Patton green
ariz · 1978
11991–1991
State v. Richmond green
ariz · 1976
11990–1990
Marriott Corp. v. Richard green
scotus · 1977
11990–1990
Heublein, Inc. v. Waters green
scotus · 1977
11990–1990
Broncucia v. Colorado green
scotus · 1977
11990–1990
State v. Fulminante green
ariz · 1989
11990–1990
State v. Leslie green
ariz · 1985
11986–1986
Russell v. Texas green
scotus · 1984
11985–1985

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 13-703 (24) AZ § Ariz. Rev. Stat. § 13-4031 (23) AZ § Ariz. Rev. Stat. § 13-1105 (10) AZ § Ariz. Rev. Stat. § 13-702 (10) AZ § Ariz. Rev. Stat. § 13-604 (7) AZ § Ariz. Rev. Stat. § 13-701 (6) AZ § Ariz. Rev. Stat. § 13-1203 (4) AZ § Ariz. Rev. Stat. § 13-1204 (4) AZ § Ariz. Rev. Stat. § 13-1304 (4) AZ § Ariz. Rev. Stat. § 12-120.21 (3) AZ § Ariz. Rev. Stat. § 13-116 (3) AZ § Ariz. Rev. Stat. § 13-1406 (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

NJ 700 (1980–2026) OH 274 (1990–2026) IL 137 (1981–2026) CA 120 (1976–2026) FL 89 (1979–2025) LA 86 (1984–2019) IN 84 (1980–2026) NY 81 (1988–2026) AZ 48 (1978–2026) NC 46 (1981–2026) WA 45 (1984–2026) TN 26 (1993–2018) KS 19 (1993–2021) ME 18 (1994–2026) AK 18 (1982–2025) MD 15 (1983–2024) CO 13 (1990–2012) UT 12 (1994–2020) MS 11 (1993–2023) AL 10 (1994–2016) PA 10 (1998–2024) GA 9 (2014–2025) NV 9 (1990–2019) DE 7 (1985–2023) CT 6 (1994–2025) IA 6 (2010–2023) OR 6 (1992–2022) OK 5 (1994–2017) AR 4 (2009–2025) NH 4 (2010–2015) MT 3 (1993–1996) MN 3 (2007–2014) MI 3 (2000–2009) NE 3 (1993–2023) WY 2 (2003–2017) TX 2 (1996–2020) WI 2 (2020–2026) VT 2 (2019–2022)

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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