Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
48 California opinions name it 2 courts 1991–2026 17 in the last five years
The cases below were cited by California 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.
| Case | Followed | Cited |
|---|---|---|
In Re SBgreen2 sentences2025Applicable Law “At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. [Citation.] If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans. [Citations.] [¶] Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of parental rights would be detrimental to the child under one of the exceptions listed in section 366.26, subdivision (c)(1). [Citations.] Section 366.26, subdivision (c)(1)(B)(i), provides an 2022A. Legal Principles “The sole purpose of the section 366.26 hearing is to select and implement a permanent plan for the child after reunification efforts have failed.” (In re J.D. (2021) 70 Cal.App.5th 833 , 851 (J.D.).) “At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care.” (In re S.B. (2008) 164 Cal.App.4th 289 , 296.) “Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of the parental rights would be detrimental to the child under one of the exceptions | 4 | 17 |
San Francisco Human Services Agency v. Karen R.green2 sentences2016Beneficial Relationship Exception to Termination of Parental Rights Jennifer contends the court erred in finding that there was not a beneficial parent- child relationship between her and N.G. within the meaning of section 366.26, subdivision (c)(1)(B)(i) that precluded the termination of his parental rights.9 " 'At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. [Citation.] If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans.' [Citation.] 'Once the court 2016Relevant Legal Principles " 'At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. [Citation.] If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans.' [Citation.] 'Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of parental rights would be detrimental to the child under one of the exceptions listed in section 366.26, subdivision (c)(1). [Citations.] Section 366.26, subdivision (c)(1)(B)(i), p | 2 | 9 |
Los Angeles County Department of Children & Family Services v. Margaret M.green2 sentences2026(In re Fernando M. (2006) 138 Cal.App.4th 529, 534 ; In re Marilyn H. (1993) 5 Cal.4th 295, 306 .) “The sole purpose of the section 366.26 [permanency plan] hearing is to select and implement a permanent plan for the child after reunification efforts have failed.” (In re J.D. (2021) 69 Cal.App.5th 594 , 612.) At the permanency plan hearing, the court may order one of three alternatives: terminate parental rights and order adoption, appoint a legal guardian, or 12 place children in longterm foster care. 2025“After reunification services have terminated, the focus of a dependency proceeding shifts from family preservation to promoting the best interest of the child including the child’s interest in a placement that is stable, permanent, and that allows the caretaker to make a full emotional commitment to the child.” (In re Fernando M. (2006) 138 Cal.App.4th 529, 534 [cleaned up].) At a permanency plan hearing, the juvenile court may order one of three alternatives: terminate parental rights and order adoption, appoint a legal guardian, or place the child in long-term foster care. | 2 | 8 |
In Re Autumn H.green2 sentences2016(In re Casey D. (1999) 70 Cal.App.4th 38, 53 .) As noted, to overcome the preference for adoption and preclude termination of parental rights at a permanency plan hearing, the evidence must support a finding that "severing the natural parent[-]child relationship would deprive the child of a substantial, positive emotional attachment such that the child would be greatly harmed . . . ." (Autumn H., supra, 27 Cal.App.4th at p. 575 , italics added.) Although Luis argues that Bella would benefit from continuing a parent-child relationship with him and having relationships with her biological relati 2015(In re Casey D. (1999) 70 Cal.App.4th 38, 53 .) As noted, to overcome the preference for adoption and preclude termination of parental rights at a permanency plan hearing, the evidence must support a finding that "severing the natural parent[-]child relationship would deprive the child of a substantial, positive emotional attachment such that the child would be greatly harmed . . . ." (In re Autumn H., supra, 27 Cal.App.4th at p. 575 , italics added.) Even assuming that the evidence shows the existence of a parent-child relationship between Rebecca and Nevaeh that provided some benefit to Neva | 2 | 8 |
San Diego County Department of Social Services v. Lee P.green2 sentences1992There are three types of permanent plans — adoption, long-term foster care and legal guardianship. (§ 366.25; In re Heather P. [1989] 209 Cal. App.3d [886], 889, fn. 5 [ 257 Cal. Rptr. 545 ].) The permanency plan hearing is held no later than 12 months after the original dispositional hearing and it can be combined with a section 366 six-month review. (§ 366.25, subd. (a).) "At the permanency plan hearing, the court first determines if the child should be returned to the physical custody of his or her parent, pursuant to subdivision (e) of section 366.2 [quoted in omitted footnote]. 1992There are three types of permanent plans—adoption, long-term foster care and legal guardianship. (§ 366.25; In re Heather P. [1989] 209 Cal.App.3d [886], 889, fn. 5 [ 257 Cal.Rptr. 545 ].) The permanency plan hearing is held no later than 12 months after the original dispositional hearing and it can be combined with a section 366 six-month review. (§ 366.25, subd. (a).) “At the permanency plan hearing, the court first determines if the child should be returned to the physical custody of his or her parent, pursuant to subdivision (e) of section 366.2 [quoted in omitted footnote]. | 2 | 4 |
In Re Taya C.green2 sentences2008The Agency also argues S.B. did not have a primary attachment to Michael and any evidence to show she would be harmed by termination of parental rights was merely speculative. (1) At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. ( In re Taya C. *297 (1991) 2 Cal.App.4th 1, 7 [ 2 Cal.Rptr.2d 810 ].) If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans. ( San Diego County Dept. of Social Services v. Superior Court (1996) 13 Cal.4th 882, 888 [ 55 Cal.Rptr.2d 2008The Agency also argues S.B. did not have a primary attachment to Michael and any evidence to show she would be harmed by termination of parental rights was merely speculative. (1) At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. ( In re Taya C. *297 (1991) 2 Cal.App.4th 1, 7 [ 2 Cal.Rptr.2d 810 ].) If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans. ( San Diego County Dept. of Social Services v. Superior Court (1996) 13 Cal.4th 882, 888 [ 55 Cal.Rptr.2d | 2 | 2 |
In Re Lorenzo C.green2 sentences2021(In re Lorenzo C. (1997) 54 Cal.App.4th 1330, 1343 .) “[I]t is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement.” (In re Jasmine D., supra, 78 Cal.App.4th at p. 1350 .) The parental benefit exception at issue here applies when (i) the parent has “maintained regular visitation and contact with the child and the child would benefit from continuing the relationship” and (ii) the court finds that the parent-child relationship presents a “compelling reason for determining that termination [of parental rights 2008The Agency also argues S.B. did not have a primary attachment to Michael and any evidence to show she would be harmed by termination of parental rights was merely speculative. (1) At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. ( In re Taya C. *297 (1991) 2 Cal.App.4th 1, 7 [ 2 Cal.Rptr.2d 810 ].) If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans. ( San Diego County Dept. of Social Services v. Superior Court (1996) 13 Cal.4th 882, 888 [ 55 Cal.Rptr.2d | 1 | 4 |
San Diego County Department of Social Services v. Superior Courtgreen2 sentences2008The Agency also argues S.B. did not have a primary attachment to Michael and any evidence to show she would be harmed by termination of parental rights was merely speculative. (1) At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. ( In re Taya C. *297 (1991) 2 Cal.App.4th 1, 7 [ 2 Cal.Rptr.2d 810 ].) If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans. ( San Diego County Dept. of Social Services v. Superior Court (1996) 13 Cal.4th 882, 888 [ 55 Cal.Rptr.2d 2008The Agency also argues S.B. did not have a primary attachment to Michael and any evidence to show she would be harmed by termination of parental rights was merely speculative. (1) At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. ( In re Taya C. *297 (1991) 2 Cal.App.4th 1, 7 [ 2 Cal.Rptr.2d 810 ].) If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans. ( San Diego County Dept. of Social Services v. Superior Court (1996) 13 Cal.4th 882, 888 [ 55 Cal.Rptr.2d | 1 | 2 |
In Re Erik P.green1 sentence2025(Id. at p. 1252; see also In re Erik P. (2002) 104 Cal.App.4th 395 , 402–403.) 2. | 1 | 1 |
In Re Melvin Agreen1 sentence2025Applicable Law “At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. [Citation.] If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans. [Citations.] [¶] Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of parental rights would be detrimental to the child under one of the exceptions listed in section 366.26, subdivision (c)(1). [Citations.] Section 366.26, subdivision (c)(1)(B)(i), provides an | 1 | 1 |
San Diego County Health & Human Services Agency v. Rosi M.green1 sentence2025Applicable Law “At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. [Citation.] If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans. [Citations.] [¶] Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of parental rights would be detrimental to the child under one of the exceptions listed in section 366.26, subdivision (c)(1). [Citations.] Section 366.26, subdivision (c)(1)(B)(i), provides an | 1 | 1 |
Santa Clara County Department of Family & Children's Services v. C.K.green1 sentence2014If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans.’ [Citation.] ‘Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of parental rights would be detrimental to the child under one of the exceptions listed in section 366.26, subdivision (c)(1).’ ” (In re G.B., supra, 227 Cal.App.4th at p. 1165 .) When, as here, reunification services have ceased, “the focus of the proceedings changes from family reunification to the child’s interest in permanence and stability.” ( | 1 | 1 |
Ventura County Human Services Agency v. Frank B.green1 sentence2014If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans.’ [Citation.] ‘Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of parental rights would be detrimental to the child under one of the exceptions listed in section 366.26, subdivision (c)(1).’ ” (In re G.B., supra, 227 Cal.App.4th at p. 1165 .) When, as here, reunification services have ceased, “the focus of the proceedings changes from family reunification to the child’s interest in permanence and stability.” ( | 1 | 1 |
In Re Celine R.green1 sentence2014If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans.’ [Citation.] ‘Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of parental rights would be detrimental to the child under one of the exceptions listed in section 366.26, subdivision (c)(1).’ ” (In re G.B., supra, 227 Cal.App.4th at p. 1165 .) When, as here, reunification services have ceased, “the focus of the proceedings changes from family reunification to the child’s interest in permanence and stability.” ( | 1 | 1 |
| In Re Zachary G.green | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In Re Marilyn H
green
2 sentences2026(In re Fernando M. (2006) 138 Cal.App.4th 529, 534 ; In re Marilyn H. (1993) 5 Cal.4th 295, 306 .) “The sole purpose of the section 366.26 [permanency plan] hearing is to select and implement a permanent plan for the child after reunification efforts have failed.” (In re J.D. (2021) 69 Cal.App.5th 594 , 612.) At the permanency plan hearing, the court may order one of three alternatives: terminate parental rights and order adoption, appoint a legal guardian, or 12 place children in longterm foster care. 2025(See In re Fernando M. (2006) 138 Cal.App.4th 529, 534 ; In re Marilyn H. (1993) 5 Cal.4th 295, 306 .) “The sole purpose of the section 366.26 [permanency plan] hearing is to select and implement a permanent plan for the child after reunification efforts have failed.” (In re J.D. (2021) 70 Cal.App.5th 833 , 851–852.) At the permanency plan hearing, the court may order one of three alternatives: terminate parental rights and order adoption, appoint a legal guardian, or place children in long-term foster care. | 5 | 2006–2026 |
In Re Casey D.
green
2 sentences2016(In re Casey D. (1999) 70 Cal.App.4th 38, 53 .) As noted, to overcome the preference for adoption and preclude termination of parental rights at a permanency plan hearing, the evidence must support a finding that "severing the natural parent[-]child relationship would deprive the child of a substantial, positive emotional attachment such that the child would be greatly harmed . . . ." (Autumn H., supra, 27 Cal.App.4th at p. 575 , italics added.) Although Luis argues that Bella would benefit from continuing a parent-child relationship with him and having relationships with her biological relati 2015(In re Casey D. (1999) 70 Cal.App.4th 38, 53 .) As noted, to overcome the preference for adoption and preclude termination of parental rights at a permanency plan hearing, the evidence must support a finding that "severing the natural parent[-]child relationship would deprive the child of a substantial, positive emotional attachment such that the child would be greatly harmed . . . ." (In re Autumn H., supra, 27 Cal.App.4th at p. 575 , italics added.) Even assuming that the evidence shows the existence of a parent-child relationship between Rebecca and Nevaeh that provided some benefit to Neva | 3 | 2015–2020 |
San Diego County Health & Human Services Agency v. Alejandro G.
green
2 sentences2020(Id. at p. 583.) We stated that section 361.3 generally applies “[a]t the outset of the [dependency] case and during the reunification period.” (Id. at p. 591.) In Maria Q., we distinguished our prior opinion in In re Isabella G. (2016) 246 Cal.App.4th 708 (Isabella G.), noting that case involved a postreunification relative 20 placement, but “did not address whether the [section 361.3] relative placement preference applies after the court has held a permanency plan hearing under section 366.26.” (Maria Q., at p. 593.) Addressing that issue, we stated: “In view of the statutory preferences est 2018The Agency misinformed the relatives about placement policies and did not conduct the assessments required under section 361.3. ( Isabella G ., supra , 246 Cal.App.4th at pp. 722-723, 201 Cal.Rptr.3d 64 .) This court held that the relative placement preference applies after the reunification period where the relative has come forward seeking placement of the child during the reunification period and the agency has ignored the relative's request for placement. ( Id. at p. 723, 201 Cal.Rptr.3d 64 .) Isabella G . , supra, 246 Cal.App.4th 708 , 201 Cal.Rptr.3d 64 did not address whether the relati | 3 | 2018–2020 |
In Re LYL
green
2 sentences2021L. (2002) 101 Cal.App.4th 942 , 947.) “At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long- term foster care. [Citation.] If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans.” (In re S.B. (2008) 164 Cal.App.4th 289 , 296-297.) If the juvenile court finds the child or children adoptable, the parent bears the burden of proving an exception to terminating parental rights applies. 2020L. (2002) 101 Cal.App.4th 942 , 947.) “At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. [Citation.] If the dependent child is adoptable, 11 there is a strong preference for adoption over the alternative permanency plans.” (In re S.B. (2008) 164 Cal.App.4th 289 , 296-297.) Once the juvenile court finds a child is adoptable, the parent bears the burden of proving an exception to terminating parental rights applies. | 2 | 2020–2021 |
In Re Jasmine D.
green
2 sentences2021(In re Lorenzo C. (1997) 54 Cal.App.4th 1330, 1343 .) “[I]t is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement.” (In re Jasmine D., supra, 78 Cal.App.4th at p. 1350 .) The parental benefit exception at issue here applies when (i) the parent has “maintained regular visitation and contact with the child and the child would benefit from continuing the relationship” and (ii) the court finds that the parent-child relationship presents a “compelling reason for determining that termination [of parental rights 2021(In re Lorenzo C. (1997) 54 Cal.App.4th 1330, 1343 .) “[I]t is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement.” (In re Jasmine D., supra, 78 Cal.App.4th at p. 1350 .) The parental benefit exception at issue here applies when (i) the parent has “maintained regular visitation and contact with the child and the child would benefit from continuing the relationship” and (ii) the court finds that the parent-child relationship presents a “compelling reason for determining that termination [of parental rights | 2 | 2020–2021 |
In Re Zeth S.
green
1 sentence2024(In re Zeth S. (2003) 31 Cal.4th 396, 405 .) 6 “‘“At a permanency plan hearing, the [juvenile] court may order one of three alternatives: adoption, guardianship or long- term foster care. [Citation.] If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans.” [Citation.]’” (In re Katherine J. (2022) 75 Cal.App.5th 303 , 316, quoting In re B.D. (2021) 66 Cal.App.5th 1218 , 1224.) If the juvenile court finds the child adoptable, it must terminate parental rights unless one of several statutory exceptions applies. (§ 366.26, subd. (c)(1)( | 1 | 2024–2024 |
In Re Mary G.
green
1 sentence2022At a permanency plan hearing, the juvenile court selects and implements a permanent plan for a dependent child, such as adoption, guardianship, or long-term foster care. (§ 366.26, subd. (b); In re Fernando M. (2006) 138 Cal.App.4th 529, 534 .) If the court finds a child is adoptable, it must terminate parental rights and order the child placed for adoption unless termination would be detrimental under an enumerated statutory exception, such as the parental benefit exception. (§ 366.26, subd. (c)(1); In re Mary G. (2007) 151 Cal.App.4th 184 , 206–207.) A parent establishes this exception by de | 1 | 2022–2022 |
In Re Francisco W.
green
1 sentence2022Mother’s only contention is that the juvenile court was required to follow the directions specified in our disposition in In re S.B.; that is, “to set a new permanency plan hearing for S.B. to determine a permanent plan that does not include the termination of Mother’s parental rights.” (In re S.B., supra, B291059.) Mother relies on the general rule that “[w]hen a judgment is reversed with directions, the appellate court’s order is contained in its remittitur, which revests the jurisdiction of the subject matter in the lower court and defines the scope of the lower court’s jurisdiction.” (In r | 1 | 2022–2022 |
Los Angeles County Department of Children & Family Services v. Darlene F.
green
2 sentences2022Mother’s only contention is that the juvenile court was required to follow the directions specified in our disposition in In re S.B.; that is, “to set a new permanency plan hearing for S.B. to determine a permanent plan that does not include the termination of Mother’s parental rights.” (In re S.B., supra, B291059.) Mother relies on the general rule that “[w]hen a judgment is reversed with directions, the appellate court’s order is contained in its remittitur, which revests the jurisdiction of the subject matter in the lower court and defines the scope of the lower court’s jurisdiction.” (In r 2022(In re Ryan K., supra, 207 Cal.App.4th at pp. 597−599.) In In re Ryan K., the juvenile court gave the father of Ryan legal and physical custody of Ryan, and further granted the father “complete discretion over whether [Ryan’s mother] would have visitation with Ryan.” (Id. at p. 594.) 7 On appeal, the Court of Appeal determined that the court’s order improperly delegated to the father “the power to determine whether visitation would occur at all,” and reversed with a direction “ ‘to formulate an order [regarding visitation] that provides the parties with better and more specific direction.’ ” ( | 1 | 2022–2022 |
In Re Crystal J.
green
1 sentence2015(In re Crystal J. (1993) 12 Cal.App.4th 407, 413 ; c.f., In re Valerie W. (2008) 162 Cal.App.4th 1, 14 .) Here, although the juvenile court had continued the matter to obtain additional information, by the conclusion of the hearing, it was evidently satisfied that it had sufficient information to make its findings and orders. | 1 | 2015–2015 |
In Re Aaliyah R.
green
1 sentence2015“At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. [Citation.] If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans.” (In re S.B. (2008) 164 Cal.App.4th 289 , 296–297.) “Once the court determines the child is likely to be adopted, the burden shifts to the parent to show that termination of parental rights would be detrimental to the child under one of the exceptions listed in section 366.26, subdivision (c)(1).” (Id. at p. 297.) To establish the beneficial | 1 | 2015–2015 |
In Re Valerie W.
green
1 sentence2015(In re Crystal J. (1993) 12 Cal.App.4th 407, 413 ; c.f., In re Valerie W. (2008) 162 Cal.App.4th 1, 14 .) Here, although the juvenile court had continued the matter to obtain additional information, by the conclusion of the hearing, it was evidently satisfied that it had sufficient information to make its findings and orders. | 1 | 2015–2015 |
Los Angeles County Department of Children & Family Services v. Kimberly G.
green
1 sentence2015Day-to-day contact is not necessarily required, although it is typical in a parent-child relationship.’ [Citation.] Moreover, ‘[b]ecause a section 366.26 hearing occurs only after the court has repeatedly found the parent unable to meet the child’s needs, it is only in an extraordinary case that preservation of the parent’s rights will prevail over the Legislature’s preference for adoptive placement.’ ” (In re K.P. (2012) 203 Cal.App.4th 614, 621 .) The parental relationship exception “must be examined on a case-by-case basis, taking into account the many variables which affect a parent/child | 1 | 2015–2015 |
In Re Angel B.
green
1 sentence2014(In re Angel B. (2002) 97 Cal.App.4th 454, 466 .) Mother has not shown her relationship with A.F. rose to a level that outweighs the benefits of adoption. | 1 | 2014–2014 |
San Diego County Health & Human Services Agency v. Tomas L.
green
1 sentence2014(In re D.M. (2012) 205 Cal.App.4th 283, 289 .) “ ‘At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long- term foster care. . . . | 1 | 2014–2014 |
Kern Cty. Dep't of Human Servs. v. Deon C.
green
1 sentence2008The Agency also argues S.B. did not have a primary attachment to Michael and any evidence to show she would be harmed by termination of parental rights was merely speculative. (1) At a permanency plan hearing, the court may order one of three alternatives: adoption, guardianship or long-term foster care. ( In re Taya C. *297 (1991) 2 Cal.App.4th 1, 7 [ 2 Cal.Rptr.2d 810 ].) If the dependent child is adoptable, there is a strong preference for adoption over the alternative permanency plans. ( San Diego County Dept. of Social Services v. Superior Court (1996) 13 Cal.4th 882, 888 [ 55 Cal.Rptr.2d | 1 | 2008–2008 |
| Santosky v. Kramer green | 1 | 1994–1994 |
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.
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.