48 Maryland opinions name it 3 courts 1968–2022 2 in the last five years
The cases below were cited by Maryland 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 |
|---|---|---|
Linton v. Lintongreen2 sentences2011Other scenarios in which Maryland Courts have applied lex loci delicti analysis include: (1) whether a Maryland court would enforce a foreign jurisdiction’s ban on wrongful birth actions, see Hood, 395 Md. 608, 622-24 , 911 A.2d at 849-51 (reaffirming this State’s commitment to lex loci delicti and opining that Maryland would invoke the public policy exception to allow a wrongful birth action to proceed in Maryland courts should the law of the state of injury bar such an action); (2) cases involving the elements required to be established in a negligence action, see, e.g., Chambco v. Urban Mas 2011Other scenarios in which Maryland Courts have applied lex loci delicti analysis include: (1) whether a Maryland court would enforce a foreign jurisdiction’s ban on wrongful birth actions, see Hood, 395 Md. 608, 622-24 , 911 A.2d at 849-51 (reaffirming this State’s commitment to lex loci delicti and opining that Maryland would invoke the public policy exception to allow a wrongful birth action to proceed in Maryland courts should the law of the state of injury bar such an action); (2) cases involving the elements required to be established in a negligence action, see, e.g., Chambco v. Urban Mas | 2 | 2 |
Henderson v. Hendersongreen2 sentences2010Id. at 30 ; see also Henderson , 199 Md. at 459 . 2010Henderson , 199 Md. at 458 -59 . | 2 | 2 |
Jackson v. Jacksongreen2 sentences2010Jackson v. Jackson , 82 Md. 17 , 29-30 33 A. 317 (1895). 2010Jackson v. Jackson , 82 Md. 17 , 29-30 33 A. 317 (1895). | 2 | 2 |
Watkins v. Southcrest Baptist Churchgreen2 sentences1994Our answer today, in response to the contention that a judicially created rule of law based on public policy may be judicially repealed, is found in Watkins v. Southcrest Baptist Church, 399 S.W.2d 530, 533 (Tex.1966), which we quoted in Howard, 249 Md. at 242 , 238 A.2d 863 , with complete approval: “The principle of vicarious liability based upon the rule of respondeat superior is essentially a public policy doctrine. * * *. [We might very well substitute the trust fund theory for respondeat superior,] Courts have applied the rule to certain factual situations and refused to apply it to othe 1968In response to appellant’s contention that a judicially created rule of law based on public policy may be judicially repealed, we need only quote •a portion of the recent case of Watkins v. Southcrest Baptist Church, 399 S. W. 2d 530, 533 (Texas 1966), with which we are in full agreement: “The principle of vicarious liability based upon the rule of respondeat superior is essentially a public policy doctrine * * *. [We might very well substitute the trust fund theory for respondeat superior.] Courts have applied the rule to certain factual situations and refused to apply it to others. | 2 | 2 |
Hutzell v. Boyergreen2 sentences2006In Hutzell v. Boyer, 252 Md. 227 , 249 A.2d 449 (1969) and Hauch v. Connor, supra, 295 Md. 120 , 453 A.2d 1207 , we applied a public policy exception in the context of workers’ compensation statutes, which we recognized had some affinity to contract and tort principles but were sufficiently different from both to be considered separately. 2006In Hutzell v. Boyer, 252 Md. 227 , 249 A.2d 449 (1969) and Hauch v. Connor, supra, 295 Md. 120 , 453 A.2d 1207 , we applied a public policy exception in the context of workers’ compensation statutes, which we recognized had some affinity to contract and tort principles but were sufficiently different from both to be considered separately. | 1 | 2 |
National Glass, Inc. v. J.C. Penney Properties, Inc.green2 sentences2015National Glass, 336 Md. at 614–15, 650 A.2d at 250 . 29 The same strong public policy analysis occurs in discussions of lex loci delicti. 2015National Glass, 336 Md. at 614–15, 650 A.2d at 250 . 29 The same strong public policy analysis occurs in discussions of lex loci delicti. | 1 | 2 |
Estate of Birgreen2 sentences2010For example, in a case involving a native of India who died intestate in the United States, the court held that his two legally wedded wives in India would be allowed to share in the estate, and indicated that the public policy exception would have precluded recognition "only if decedent had attempted to cohabit with his two wives in California." In re Dalip Singh Bir's Estate , 188 P.2d 499 , 502 (Cal. App. 1948); see also Scoles Hay, Conflict of Laws (1984) at 446 ("The courts do recognize the legal existence of and give effect to foreign matrimonial unions that do not conform to requirement 2010A judicial determination 53 (...continued) involving a native of India who died intestate in the United States, the court held that his two legally wedded wives in India would be allowed to share in the estate, and indicated that the public policy exception would have precluded recognition “only if decedent had attempted to cohabit with his two wives in California.” In re Dalip Singh Bir’s Estate, 188 P.2d 499, 502 (Cal. App. 1948); see also Scoles & Hay, Conflict of Laws (1984) at 446 (“The courts do recognize the legal existence of and give effect to foreign matrimonial unions that do not co | 1 | 2 |
Bethlehem Steel Corp. v. G.C. Zarnas & Co.green2 sentences2007Zarnas & Co., 304 Md. 183, 189 , 498 A.2d 605, 608 (1985), we observed that “merely because Maryland law is dissimilar to the law of another jurisdiction does not render the latter contrary to Maryland public policy,” and that, to be unenforceable under the public policy exception, “there must be ‘a strong public policy against its enforcement in Maryland,’ ” quoting from Texaco v. Vanden Bosche, 242 Md. 334, 340-41 , 219 A.2d 80, 83 (1966). 2007Zarnas & Co., 304 Md. 183, 189 , 498 A.2d 605, 608 (1985), we observed that “merely because Maryland law is dissimilar to the law of another jurisdiction does not render the latter contrary to Maryland public policy,” and that, to be unenforceable under the public policy exception, “there must be ‘a strong public policy against its enforcement in Maryland,’ ” quoting from Texaco v. Vanden Bosche, 242 Md. 334, 340-41 , 219 A.2d 80, 83 (1966). | 1 | 2 |
Makovi v. Sherwin-Williams Co.green2 sentences1990In Makovi v. Sherwin-Williams Co., 316 Md. 603 , 561 A.2d 179 (1989), the Court of Appeals referred to a review of the “first round” cases in which the public policy exception to the terminable at-will doctrine was initially adopted in Note, Protecting Employees At Will Against Wrongful Discharge: The Public Policy Exception, 96 Harv.L.Rev. 1931, 1931-37 (1983). 1990In Makovi v. Sherwin-Williams Co., 316 Md. 603 , 561 A.2d 179 (1989), the Court of Appeals referred to a review of the “first round” cases in which the public policy exception to the terminable at-will doctrine was initially adopted in Note, Protecting Employees At Will Against Wrongful Discharge: The Public Policy Exception, 96 Harv.L.Rev. 1931, 1931-37 (1983). | 1 | 2 |
Medex v. McCabegreen2 sentences2015See Peters v. Early Healthcare Giver, Inc., 439 Md. 646, 654-55 , 97 A.3d 621, 626 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld overtime wages); Marshall v. Safeway Inc., 437 Md. 542, 561-62 , 88 A.3d 735, 746 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld wages that result from miscalculating the amount of wages exempt from garnishment); Ocean City, Md., Chamber of Commerce, Inc. v. Barufaldi, 434 Md. 381, 393-94 , 75 A.3d 952, 9 2015See Peters v. Early Healthcare Giver, Inc., 439 Md. 646, 654-55 , 97 A.3d 621, 626 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld overtime wages); Marshall v. Safeway Inc., 437 Md. 542, 561-62 , 88 A.3d 735, 746 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld wages that result from miscalculating the amount of wages exempt from garnishment); Ocean City, Md., Chamber of Commerce, Inc. v. Barufaldi, 434 Md. 381, 393-94 , 75 A.3d 952, 9 | 1 | 1 |
Ocean City, MD., Chamber of Commerce, Inc. v. Barufaldigreen2 sentences2015See Peters v. Early Healthcare Giver, Inc., 439 Md. 646, 654-55 , 97 A.3d 621, 626 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld overtime wages); Marshall v. Safeway Inc., 437 Md. 542, 561-62 , 88 A.3d 735, 746 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld wages that result from miscalculating the amount of wages exempt from garnishment); Ocean City, Md., Chamber of Commerce, Inc. v. Barufaldi, 434 Md. 381, 393-94 , 75 A.3d 952, 9 2015See Peters v. Early Healthcare Giver, Inc., 439 Md. 646, 654-55 , 97 A.3d 621, 626 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld overtime wages); Marshall v. Safeway Inc., 437 Md. 542, 561-62 , 88 A.3d 735, 746 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld wages that result from miscalculating the amount of wages exempt from garnishment); Ocean City, Md., Chamber of Commerce, Inc. v. Barufaldi, 434 Md. 381, 393-94 , 75 A.3d 952, 9 | 1 | 1 |
Marshall v. Safeway, Inc.green2 sentences2015See Peters v. Early Healthcare Giver, Inc., 439 Md. 646, 654-55 , 97 A.3d 621, 626 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld overtime wages); Marshall v. Safeway Inc., 437 Md. 542, 561-62 , 88 A.3d 735, 746 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld wages that result from miscalculating the amount of wages exempt from garnishment); Ocean City, Md., Chamber of Commerce, Inc. v. Barufaldi, 434 Md. 381, 393-94 , 75 A.3d 952, 9 2015See Peters v. Early Healthcare Giver, Inc., 439 Md. 646, 654-55 , 97 A.3d 621, 626 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld overtime wages); Marshall v. Safeway Inc., 437 Md. 542, 561-62 , 88 A.3d 735, 746 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld wages that result from miscalculating the amount of wages exempt from garnishment); Ocean City, Md., Chamber of Commerce, Inc. v. Barufaldi, 434 Md. 381, 393-94 , 75 A.3d 952, 9 | 1 | 1 |
Peters v. Early Healthcare Giver, Inc.green2 sentences2015See Peters v. Early Healthcare Giver, Inc., 439 Md. 646, 654-55 , 97 A.3d 621, 626 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld overtime wages); Marshall v. Safeway Inc., 437 Md. 542, 561-62 , 88 A.3d 735, 746 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld wages that result from miscalculating the amount of wages exempt from garnishment); Ocean City, Md., Chamber of Commerce, Inc. v. Barufaldi, 434 Md. 381, 393-94 , 75 A.3d 952, 9 2015See Peters v. Early Healthcare Giver, Inc., 439 Md. 646, 654-55 , 97 A.3d 621, 626 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld overtime wages); Marshall v. Safeway Inc., 437 Md. 542, 561-62 , 88 A.3d 735, 746 (2014) (concluding that employees have a right to bring a private cause of action under the MWPCL to recover unlawfully withheld wages that result from miscalculating the amount of wages exempt from garnishment); Ocean City, Md., Chamber of Commerce, Inc. v. Barufaldi, 434 Md. 381, 393-94 , 75 A.3d 952, 9 | 1 | 1 |
| Wilson v. Watersgreen | 1 | 1 |
| Cox v. Forrestgreen | 1 | 1 |
| In re McGeegreen | 1 | 1 |
| Laboratory Corp. of America v. Hoodgreen | 1 | 1 |
| Smith v. Mitre Corp.green | 1 | 1 |
| Texaco, Inc. v. Vanden Boschegreen | 1 | 1 |
| Thompto v. Coborn's Inc.green | 1 | 1 |
| Faust v. Ryder Commercial Leasing & Servicesgreen | 1 | 1 |
| Finch v. Holladay-Tyler Printing, Inc.green | 1 | 1 |
| Insignia Residential Corp. v. Ashtongreen | 1 | 1 |
| Teays v. Supreme Concrete Block, Inc.green | 1 | 1 |
| Gerald F. Adler v. American Standard Corporation, Gerald F. Adler v. American Standard Corporationgreen | 1 | 1 |
| Allendale Leasing, Inc. v. Walter Stone, Etc.green | 1 | 1 |
| Wolff v. Wolffgreen | 1 | 1 |
| Hicks v. Resolution Trust Corp.green | 1 | 1 |
| Anthony Prince v. Rescorp Realty, an Illinois Corporationgreen | 1 | 1 |
| Reeder-Baker v. Lincoln National Corp.green | 1 | 1 |
| Ficalora v. Lockheed Corp.green | 1 | 1 |
| Clare R. Bruffett v. Warner Communications, Incgreen | 1 | 1 |
| Napoleon v. Xerox Corp.green | 1 | 1 |
| Donald C. Grubba v. Bay State Abrasives, Division of Dresser Industries, Inc.green | 1 | 1 |
| Lofton v. Wyeth Laboratories, Inc.green | 1 | 1 |
| Wehr v. Burroughs Corp.green | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Md.-Nat'l Cap. P. & P. v. Wash. Nat'l Arena
green
2 sentences2002Judge Levine, writing for Court in Maryland-Nat’l Capital Park and Planning Comm’n v. Washington Nat’l Arena, 282 Md. 588 , 386 A.2d 1216 (1978), discussed the meaning of public policy as follows: “Nearly 150 years ago Lord Truro set forth what has become the classical formulation of the public policy doctrine — that to which we adhere in Maryland: ‘Public policy is that principle of the law which holds that no subject can lawfully do that which has a tendency to be injurious to the public, or against the public good, which may be termed, as it sometimes has been, the policy of the law, or pub 2002Judge Levine, writing for Court in Maryland-Nat’l Capital Park and Planning Comm’n v. Washington Nat’l Arena, 282 Md. 588 , 386 A.2d 1216 (1978), discussed the meaning of public policy as follows: “Nearly 150 years ago Lord Truro set forth what has become the classical formulation of the public policy doctrine — that to which we adhere in Maryland: ‘Public policy is that principle of the law which holds that no subject can lawfully do that which has a tendency to be injurious to the public, or against the public good, which may be termed, as it sometimes has been, the policy of the law, or pub | 5 | 1978–2002 |
Kramer v. Bally's Park Place, Inc.
green
2 sentences2010Cf. Kramer v. Bally Park , 311 Md. 387 , 535 A.2d 466 (1988) (in deciding whether to recognize an out-of-state debt that arguably could not have been *Page 31 contracted in Maryland, the Court reviewed changes in Maryland law to assess public policy exception). 34 B. 2010Cf. Kramer v. Bally Park , 311 Md. 387 , 535 A.2d 466 (1988) (in deciding whether to recognize an out-of-state debt that arguably could not have been *Page 31 contracted in Maryland, the Court reviewed changes in Maryland law to assess public policy exception). 34 B. | 3 | 2007–2010 |
Adler v. American Standard Corp.
green
2 sentences2017According to Maryland law, there is a public policy exception to the at-will employment rule for wrongful termination “when the motivation for the discharge contravenes some clear mandate of public policy!.]” Adler, 291 Md. at 47 , 432 A.2d at 473 . *451 [F]ew courts have flatly rejected the notion that the wrongful discharge of an at will employee may give rise to a cause of action for damages. 2017According to Maryland law, there is a public policy exception to the at-will employment rule for wrongful termination “when the motivation for the discharge contravenes some clear mandate of public policy!.]” Adler, 291 Md. at 47 , 432 A.2d at 473 . *451 [F]ew courts have flatly rejected the notion that the wrongful discharge of an at will employee may give rise to a cause of action for damages. | 2 | 2003–2017 |
Prince George's County Police Civilian Employees Ass'n v. Prince George's County Ex Rel. Prince George's County Police Department
green
2 sentences2016In its petition, the County focused on whether its no-appropriation argument supported a public policy exception to enforcement of the arbitration award. 12 II Discussion As this Court recently reiterated, judicial review of an arbitration decision is “very narrowly limited.” Prince George’s County Police Civilian Employees Ass’n v. Prince George’s County, 447 Md. 180, 192 , 135 A.3d 347 (2016) (interior quotation marks and citation omitted). 2016In its petition, the County focused on whether its no-appropriation argument supported a public policy exception to enforcement of the arbitration award. 12 II Discussion As this Court recently reiterated, judicial review of an arbitration decision is “very narrowly limited.” Prince George’s County Police Civilian Employees Ass’n v. Prince George’s County, 447 Md. 180, 192 , 135 A.3d 347 (2016) (interior quotation marks and citation omitted). | 2 | 2016–2016 |
Hauch v. Connor
green
2 sentences2006In Hutzell v. Boyer, 252 Md. 227 , 249 A.2d 449 (1969) and Hauch v. Connor, supra, 295 Md. 120 , 453 A.2d 1207 , we applied a public policy exception in the context of workers’ compensation statutes, which we recognized had some affinity to contract and tort principles but were sufficiently different from both to be considered separately. 2006In Hutzell v. Boyer, 252 Md. 227 , 249 A.2d 449 (1969) and Hauch v. Connor, supra, 295 Md. 120 , 453 A.2d 1207 , we applied a public policy exception in the context of workers’ compensation statutes, which we recognized had some affinity to contract and tort principles but were sufficiently different from both to be considered separately. | 2 | 2006–2015 |
Wholey v. Roebuck
green
2 sentences2011Id. at 52 , 803 A.2d at 490 . 2011Id. at 52 , 803 A.2d at 490 . | 2 | 2005–2011 |
Conaway v. Deane
green
2 sentences2010Deane , 401 Md. at 304 n. 66. 2010Deane, 401 Md. at 304 n.66. | 2 | 2010–2010 |
Fensterwald v. Burk
green
2 sentences2010Fensterwald v. Burk , 129 Md. 131 , 98 A. 358 (1916). 2010Fensterwald v. Burk , 129 Md. 131 , 98 A. 358 (1916). | 2 | 2010–2010 |
Bushey v. Northern Assurance Co. of America
green
1 sentence2022Therefore, asserted the parents, “the public policy which the immunity is intended to support is non-existent under the circumstances of the instant matter where there is no family relationship to preserve because the alleged tortfeasor is dead.” Id. at 645–46. | 1 | 2022–2022 |
Jones v. Hyatt Insurance Agency, Inc.
green
1 sentence2021May 1, 2018), Chief Judge James Bredar stated that “a sub- strain of third-party beneficiary law apparently exists in Maryland because of a judicially created qualification of the doctrine.” Chief Judge Bredar explained that this “sub-strain of third-party beneficiary law” was apparently based on a public policy exception to contract interpretation whereby liability insurance contracts are interpreted “as expressing the insurer’s and the insured’s intent to make any potential tort claimant against the insureds an intended third-party beneficiary, [Jones, 356 Md. at 646 & n.4] even though the c | 1 | 2021–2021 |
Town of Groton v. United Steelworkers of America
green
2 sentences2019Town of Groton v. United Steelworkers of America, 254 Conn. 35, 46 , 757 A.2d 501 , 508– 09 (2000) (cleaned up and emphasis added). 2019Town of Groton v. United Steelworkers of America, 254 Conn. 35, 46 , 757 A.2d 501 , 508– 09 (2000) (cleaned up and emphasis added). | 1 | 2019–2019 |
Eastern Associated Coal Corp. v. United Mine Workers, District 17
green
1 sentence2019This is because, in the context of a public- policy challenge, the arbitrator’s award is treated as if it represented an agreement between the parties as to the proper meaning of the contract’s words; “the award is not distinguishable from the contractual agreement.” Eastern Associated Coal, 531 U.S. at 62 . | 1 | 2019–2019 |
Amalgamated Transit Union, Division 1300 v. Mass Transit Administration
green
2 sentences2019And “[a]s with any contract, ‘a court may not enforce a collective bargaining agreement that is contrary to public policy.’” MTA-Smith, 305 Md. at 389 ; cf. W.R. 2019In evaluating these challenges, courts are “obliged to take the facts as found by the arbitrator.” Id. | 1 | 2019–2019 |
Suter v. Stuckey
green
2 sentences2018This case, therefore, presents an "existing controversy" because the circuit court's retention of the passport interferes with the Secretary of State's discretion under 42 U.S.C. § 652 (k). 13 Even if the issue of whether the circuit court should have ordered MCOCSE to reverse its certification of Mr. Cohen to the Department of HHS passport was moot, the issue would fall within the public policy exception described in Suter , 402 Md. at 220 , 935 A.2d 731 . 2018This case, therefore, presents an "existing controversy" because the circuit court's retention of the passport interferes with the Secretary of State's discretion under 42 U.S.C. § 652 (k). 13 Even if the issue of whether the circuit court should have ordered MCOCSE to reverse its certification of Mr. Cohen to the Department of HHS passport was moot, the issue would fall within the public policy exception described in Suter , 402 Md. at 220 , 935 A.2d 731 . | 1 | 2018–2018 |
Hunter v. BD. OF EDUC., MONT. CNTY.
green
1 sentence2018The Court *293 concluded that the defendants were entitled to dismissal "[w]ith respect to the contract claim" as well, explaining: "[W]hat we have said in this opinion concerning the uncertainty of damages, the difficulty in determining legal cause, and the public policy factors precluding negligence claims remains true whether the allegations state breach of contract or tort and we discuss it no further." Id. | 1 | 2018–2018 |
Baltimore County v. Baltimore County Fraternal Order of Police, Lodge No. 4
green
1 sentence2016In its petition, the County focused on whether its no-appropriation argument supported a public policy exception to enforcement of the arbitration award.12 II Discussion As this Court recently reiterated, judicial review of an arbitration decision is “very narrowly limited.” Prince George’s County Police Civilian Employees Ass’n v. Prince George’s County, 447 Md. 180, 192 , 135 A.3d 347 (2016) (interior quotation marks and 11 Citing the law of the case doctrine, the Court of Special Appeals also rejected four other issues raised by the County that had been part of the prior appeal. 220 Md. | 1 | 2016–2016 |
William N. Clark v. Modern Group Ltd. John F. Smith
green
1 sentence2015Id. at 331-32 . | 1 | 2015–2015 |
| Chambco, A Division of Chamberlin Waterproofing & Roofing, Inc. v. Urban Masonry Corp. green | 1 | 2011–2011 |
| Erie Insurance Exchange v. Heffernan green | 1 | 2011–2011 |
| cluster 433759 green | 1 | 2008–2008 |
| Kronovet v. Lipchin green | 1 | 2007–2007 |
| Harford Mutual Insurance v. Bruchey green | 1 | 2006–2006 |
| Simonelli v. Anderson Concrete Co. green | 1 | 2003–2003 |
| Gantt v. Sentry Insurance green | 1 | 2002–2002 |
| Ewing v. Koppers Co. green | 1 | 2002–2002 |
| Smith v. Gross green | 1 | 2001–2001 |
| Adler v. American Standard Corp. green | 1 | 2000–2000 |
| Tucker v. Shoemake green | 1 | 2000–2000 |
| Kessler v. Equity Management, Inc. green | 1 | 2000–2000 |
| S.A. Andes v. Versant Corporation First Washington Investments Corporation Thomas F. Herr green | 1 | 1997–1997 |
| Guinness Plc Guinness America, Incorporated v. Thomas Joseph Ward, (Two Cases) green | 1 | 1997–1997 |
| Milhoux v. Linder green | 1 | 1997–1997 |
| McLaughlin v. Barclays American Corp. green | 1 | 1995–1995 |
| McLaughlin v. Barclays American Corp. green | 1 | 1995–1995 |
| Black v. Leatherwood Motor Coach Corp. green | 1 | 1994–1994 |
| Howard v. Bishop Byrne Council Home, Inc. green | 1 | 1994–1994 |
| Travelers Indemnity Co. v. Allied-Signal, Inc. green | 1 | 1993–1993 |
| Allstate Insurance v. Hart green | 1 | 1992–1992 |
| Frye v. Frye green | 1 | 1990–1990 |
| Petermann v. International Brotherhood of Teamsters, Local 396 green | 1 | 1989–1989 |
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.