estoppel doctrine (Georgia) · Go Syfert
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estoppel doctrine in Georgia

46 Georgia opinions name it 2 courts 1914–2021 2 in the last five years

The cases below were cited by Georgia 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 (25)

CaseFollowedCited
Lynch v. Poolegreen
ga · 1912 · cited in 2 Georgia opinions naming this issue, 1923–1951
2 sentences

1951See Fidelity & Deposit Co. v. Nisbet, 119 Ga. 316 ( 46 S. E. 444 ); Lynch v. Poole, 138 Ga. 303, 305 (supra); As kew v. Amos, 147 Ga. 613 ( 95 S. E. 5 ); DeVore v. Baxter, 155 Ga. 109 ( 116 S. E. 610 ); National Land &c.

1923Trice v. Rose, 80 Ga. 408 ( 7 S. E. 109 ); Tuells v. Torras, 113 Ga. 691, 698 ( 39 S. E. 455 ); Askew v. Amos, 147 Ga. 613 ( 95 S. E. 5 ); Irvine v. Wiley, 145 Ga. 867 (3), 868 ( 90 S. E. 69 ); Fidelity & Deposit Co. v. Nisbet, 119 Ga. 316 (7) ( 46 S. E. 444 ); Lynch v. Poole, 138 Ga. 303, 304 ( 75 S. E. 158 ).

22
Hood v. Durengreen
gactapp · 1924 · cited in 2 Georgia opinions naming this issue, 1949–1986
2 sentences

1986Hood v. Duren, 33 Ga. App. 203 ( 125 SE 787 ) (1924). [Appellant] apparently misunderstands the nature of the equitable doctrine of estoppel.

1986Hood v. Duren, 33 Ga. App. 203 ( 125 SE 787 ) (1924). [Appellant] apparently misunderstands the nature of the equitable doctrine of estoppel.

12
Fidelity & Deposit Co. v. Nisbetgreen
ga · 1904 · cited in 2 Georgia opinions naming this issue, 1923–1951
2 sentences

1951See Fidelity & Deposit Co. v. Nisbet, 119 Ga. 316 ( 46 S. E. 444 ); Lynch v. Poole, 138 Ga. 303, 305 (supra); As kew v. Amos, 147 Ga. 613 ( 95 S. E. 5 ); DeVore v. Baxter, 155 Ga. 109 ( 116 S. E. 610 ); National Land &c.

1951See Fidelity & Deposit Co. v. Nisbet, 119 Ga. 316 ( 46 S. E. 444 ); Lynch v. Poole, 138 Ga. 303, 305 (supra); As kew v. Amos, 147 Ga. 613 ( 95 S. E. 5 ); DeVore v. Baxter, 155 Ga. 109 ( 116 S. E. 610 ); National Land &c.

12
Wilhelm v. Houston Countygreen
gactapp · 2011 · cited in 1 Georgia opinions naming this issue, 2021–2021
1 sentence

2021Esener, 240 Ga. App. at 23 ; see also Wilhelm, 310 Ga. App. at 509 (1) (c) (“[A] defendant may be equitably estopped from raising the defense of the statute of repose if the plaintiff reasonably relied on a fraudulent act or statement by the defendant that occurred after the plaintiff’s injury accrued and, as a result of that fraud, the plaintiff did not file suit until after the repose period expired.”) (emphasis omitted).

11
Coley v. Coleygreen
ga · 1907 · cited in 1 Georgia opinions naming this issue, 2007–2007
2 sentences

2007See Coley v. Coley, 128 Ga. 654, 656 (1), 58 S.E. 205 (1907).

2007See Coley v. Coley, 128 Ga. 654, 656 (1), 58 S.E. 205 (1907).

11
Liming v. Liminggreen
neb · 2006 · cited in 1 Georgia opinions naming this issue, 2007–2007
2 sentences

2007See Liming v. Liming, 272 Neb. 534 , 723 N.W.2d 89, 96-97 (2006) (no waiver of right to appeal where spouse's right to benefits accepted is conceded by other spouse; spouse entitled as matter of right to benefits accepted such that outcome of appeal could have no effect on right to those benefits; or benefits accepted pursuant to severable award not subject to appellate review); 5 Am.Jur.2d, Appellate Review, § 636 (rule precluding appeal by party who has accepted benefits of judgment applied less strictly in divorce cases, depending on factors such as whether amount received was small portion

2007See Liming v. Liming, 272 Neb. 534 , 723 N.W.2d 89, 96-97 (2006) (no waiver of right to appeal where spouse's right to benefits accepted is conceded by other spouse; spouse entitled as matter of right to benefits accepted such that outcome of appeal could have no effect on right to those benefits; or benefits accepted pursuant to severable award not subject to appellate review); 5 Am.Jur.2d, Appellate Review, § 636 (rule precluding appeal by party who has accepted benefits of judgment applied less strictly in divorce cases, depending on factors such as whether amount received was small portion

11
Adler's Package Shop, Inc. v. Parkergreen
gactapp · 1989 · cited in 1 Georgia opinions naming this issue, 2000–2000
2 sentences

2000Co. v. Sapp, 223 Ga. App. 443, 445 ( 477 SE2d 869 ) (1996) ("Estoppel requires justifiable reliance on the opposing party’s representations or conduct and a change in position to one’s detriment.”); Adler’s Package Shop v. Parker, 190 Ga. App. 68, 73 (2) ( 378 SE2d 323 ) (1989) (“doctrine of estoppel . . . applies only where the representations of one party cause another to act in reliance thereon to the latter’s detriment”).

2000Co. v. Sapp, 223 Ga. App. 443, 445 ( 477 SE2d 869 ) (1996) ("Estoppel requires justifiable reliance on the opposing party’s representations or conduct and a change in position to one’s detriment.”); Adler’s Package Shop v. Parker, 190 Ga. App. 68, 73 (2) ( 378 SE2d 323 ) (1989) (“doctrine of estoppel . . . applies only where the representations of one party cause another to act in reliance thereon to the latter’s detriment”).

11
Allstate Insurance v. Sappgreen
gactapp · 1996 · cited in 1 Georgia opinions naming this issue, 2000–2000
2 sentences

2000Co. v. Sapp, 223 Ga. App. 443, 445 ( 477 SE2d 869 ) (1996) ("Estoppel requires justifiable reliance on the opposing party’s representations or conduct and a change in position to one’s detriment.”); Adler’s Package Shop v. Parker, 190 Ga. App. 68, 73 (2) ( 378 SE2d 323 ) (1989) (“doctrine of estoppel . . . applies only where the representations of one party cause another to act in reliance thereon to the latter’s detriment”).

2000Co. v. Sapp, 223 Ga. App. 443, 445 ( 477 SE2d 869 ) (1996) ("Estoppel requires justifiable reliance on the opposing party’s representations or conduct and a change in position to one’s detriment.”); Adler’s Package Shop v. Parker, 190 Ga. App. 68, 73 (2) ( 378 SE2d 323 ) (1989) (“doctrine of estoppel . . . applies only where the representations of one party cause another to act in reliance thereon to the latter’s detriment”).

11
Matheson v. DeKalb Countygreen
ga · 1987 · cited in 1 Georgia opinions naming this issue, 1998–1998
2 sentences

1998Matheson v. DeKalb County, 257 Ga. 48, 49 (3) ( 354 SE2d 121 ) (1987).

1998Matheson v. DeKalb County, 257 Ga. 48, 49 (3) ( 354 SE2d 121 ) (1987).

11
Eiberger v. Westgreen
ga · 1981 · cited in 1 Georgia opinions naming this issue, 1996–1996
2 sentences

1996Eiberger v. West, 247 Ga. 767, 769-770 ( 281 SE2d 148 ) (1981). 3.

1996Eiberger v. West, 247 Ga. 767, 769-770 ( 281 SE2d 148 ) (1981). 3.

11
Gainesville Glass Co. v. Don Hammond, Inc.green
gactapp · 1981 · cited in 1 Georgia opinions naming this issue, 1995–1995
2 sentences

1995See Gainesville Glass Co. v. Don Hammond, Inc., 157 Ga. App. 640, 644-645 (2) ( 278 SE2d 182 ) (1981).

1995See Gainesville Glass Co. v. Don Hammond, Inc., 157 Ga. App. 640, 644-645 (2) ( 278 SE2d 182 ) (1981).

11
Mimms v. Sisk Decorating Co.green
gactapp · 1980 · cited in 1 Georgia opinions naming this issue, 1984–1984
2 sentences

1984See Woods v. Delta Air Lines, 237 Ga. 332 , supra; Mimms v. Sisk Decorating Co., 156 Ga. App. 572, 574 (2) ( 275 SE2d 148 ). *432 Again we look to the evidence as to whether or not all or any of the questions involved in the bankruptcy court have been answered so as to bar this action.

1984See Woods v. Delta Air Lines, 237 Ga. 332 , supra; Mimms v. Sisk Decorating Co., 156 Ga. App. 572, 574 (2) ( 275 SE2d 148 ). *432 Again we look to the evidence as to whether or not all or any of the questions involved in the bankruptcy court have been answered so as to bar this action.

11
Woods v. Delta Air Lines, Inc.green
ga · 1976 · cited in 1 Georgia opinions naming this issue, 1984–1984
1 sentence

1984See Woods v. Delta Air Lines, 237 Ga. 332 , supra; Mimms v. Sisk Decorating Co., 156 Ga. App. 572, 574 (2) ( 275 SE2d 148 ). *432 Again we look to the evidence as to whether or not all or any of the questions involved in the bankruptcy court have been answered so as to bar this action.

11
Westwood Place, Ltd. v. Greengreen
gactapp · 1980 · cited in 1 Georgia opinions naming this issue, 1983–1983
2 sentences

1983The quoted code sections and rule make it clear that while the attorney has authority to do many things by virtue of his general retention, he may not compromise the client’s claim unless the same is specially authorized in writing or ratified (Westwood Place v. Green, 153 Ga. App. 595, 596 (2) ( 266 SE2d 242 )) or unless the doctrine of estoppel, or some other special equity, intervenes.

1983The quoted code sections and rule make it clear that while the attorney has authority to do many things by virtue of his general retention, he may not compromise the client’s claim unless the same is specially authorized in writing or ratified (Westwood Place v. Green, 153 Ga. App. 595, 596 (2) ( 266 SE2d 242 )) or unless the doctrine of estoppel, or some other special equity, intervenes.

11
Central Bank & Trust Corp. v. Stategreen
ga · 1912 · cited in 1 Georgia opinions naming this issue, 1966–1966
11
Jackson v. Smithgreen
gactapp · 1955 · cited in 1 Georgia opinions naming this issue, 1959–1959
11
Brown v. Globe & Rutgers Fire Insurancegreen
ga · 1926 · cited in 1 Georgia opinions naming this issue, 1945–1945
11
Morrison v. Whitesidegreen
ga · 1902 · cited in 1 Georgia opinions naming this issue, 1941–1941
11
Dailey v. Springfieldgreen
ga · 1915 · cited in 1 Georgia opinions naming this issue, 1940–1940
11
Southern Manufacturing Co. v. R. L. Moss Manufacturing Co.green
gactapp · 1913 · cited in 1 Georgia opinions naming this issue, 1937–1937
11
Forbes v. Hallgreen
ga · 1897 · cited in 1 Georgia opinions naming this issue, 1935–1935
11
Alston v. Phenix Insurancegreen
ga · 1897 · cited in 1 Georgia opinions naming this issue, 1934–1934
11
Wilkins v. McGeheegreen
ga · 1891 · cited in 1 Georgia opinions naming this issue, 1928–1928
11
Tuells v. Torrasgreen
ga · 1901 · cited in 1 Georgia opinions naming this issue, 1923–1923
11
Smith v. Davisgreen
gactapp · 1908 · cited in 1 Georgia opinions naming this issue, 1914–1914
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (55)

CaseCitedYears
Askew v. Amos green
ga · 1918
2 sentences

1951See Fidelity & Deposit Co. v. Nisbet, 119 Ga. 316 ( 46 S. E. 444 ); Lynch v. Poole, 138 Ga. 303, 305 (supra); As kew v. Amos, 147 Ga. 613 ( 95 S. E. 5 ); DeVore v. Baxter, 155 Ga. 109 ( 116 S. E. 610 ); National Land &c.

1951See Fidelity & Deposit Co. v. Nisbet, 119 Ga. 316 ( 46 S. E. 444 ); Lynch v. Poole, 138 Ga. 303, 305 (supra); As kew v. Amos, 147 Ga. 613 ( 95 S. E. 5 ); DeVore v. Baxter, 155 Ga. 109 ( 116 S. E. 610 ); National Land &c.

31923–1951
Republic Title Co. v. Freeport Title & Guaranty, Inc. neutral
gactapp · 2019
1 sentence

2021“Once the trial court adopts the special master’s findings and enters judgment, the court’s decision is upheld by the appellate court unless clearly erroneous but conclusions of law are reviewed de novo.” Republic Title Co., LLC v. Freeport Title and Guar., 351 Ga. App. 408 , 409 ( 829 SE2d 172 ) (2019) (citation and punctuation omitted). 5 1.

12021–2021
Esener v. Kinsey green
gactapp · 1999
1 sentence

2021Esener, 240 Ga. App. at 23 ; see also Wilhelm, 310 Ga. App. at 509 (1) (c) (“[A] defendant may be equitably estopped from raising the defense of the statute of repose if the plaintiff reasonably relied on a fraudulent act or statement by the defendant that occurred after the plaintiff’s injury accrued and, as a result of that fraud, the plaintiff did not file suit until after the repose period expired.”) (emphasis omitted).

12021–2021
Bowden v. the Medical Center, Inc. green
ga · 2015
2 sentences

2020Ctr., Inc., 297 Ga. 285 ( 773 SE2d 692 ) (2015); see also OCGA §§ 44-14-470, 44-14-471.

2020Ctr., Inc., 297 Ga. 285 ( 773 SE2d 692 ) (2015); see also OCGA §§ 44-14-470, 44-14-471.

12020–2020
Quillian v. Employees' Retirement System green
ga · 1989
2 sentences

2006The trial court granted summary judgment in favor of the board. [2] Dukes urges that his case is controlled in his favor by the estoppel doctrine espoused in Quillian v. Employees' Retirement System of Ga., 259 Ga. 253 , 379 S.E.2d 515 (1989), but although factually very similar, a critical distinguishing factor makes Quillian inapplicable.

2006The trial court granted summary judgment in favor of the board. [2] Dukes urges that his case is controlled in his favor by the estoppel doctrine espoused in Quillian v. Employees' Retirement System of Ga., 259 Ga. 253 , 379 S.E.2d 515 (1989), but although factually very similar, a critical distinguishing factor makes Quillian inapplicable.

12006–2006
D'Oench, Duhme & Co. v. Federal Deposit Insurance green
scotus · 1942
2 sentences

1990The trial court allowed the appellee, Federal Savings and Loan Insurance Corporation (FSLIC) to intervene and held that the estoppel rule established in D’Oench, Duhme & Co. v. FDIC, 315 U. S. 447 (62 SC 676, 86 LE 956) (1942), applied and barred certain defenses raised by the appellants.

1990Since the FSLIC is the real party in interest and a federal corporation, the estoppel rule established in D’Oench, Duhme & Co., supra, 315 U. S. at 459 , controls this case.

11990–1990
Horkan v. City of Moultrie green
ga · 1911
2 sentences

1989At issue in Horkan v. City of Moultrie, 136 Ga. 561 ( 71 SE 785 ) (1911), was whether the estoppel doctrine could be applied in such a manner as to bind the city to contin *844 ued compliance with an agreement to supply free water service to a property owner for an indefinite period of time.

1989At issue in Horkan v. City of Moultrie, 136 Ga. 561 ( 71 SE 785 ) (1911), was whether the estoppel doctrine could be applied in such a manner as to bind the city to contin *844 ued compliance with an agreement to supply free water service to a property owner for an indefinite period of time.

11989–1989
City of Jonesboro v. Shaw-Lightcap, Inc. green
gactapp · 1966
2 sentences

1989Similarly distinguishable are such cases as City of Calhoun v. Holland, supra, 222 Ga. 817 (holding that the estoppel doctrine could not be applied in such a manner as to avoid the statutory ante litem notice arrangement imposed by former Code Ann. § 69-308 [currently OCGA § 36-33-5]); City of Atlanta v. Bull, 161 Ga. App. 648 ( 288 SE2d 335 ) (1982) (holding that an oral commitment made by an ad hoc committee chairman was not contractually binding on the city where its charter specifically required that all city contracts be signed by the mayor or his duly authorized designate); and City of J

1989Similarly distinguishable are such cases as City of Calhoun v. Holland, supra, 222 Ga. 817 (holding that the estoppel doctrine could not be applied in such a manner as to avoid the statutory ante litem notice arrangement imposed by former Code Ann. § 69-308 [currently OCGA § 36-33-5]); City of Atlanta v. Bull, 161 Ga. App. 648 ( 288 SE2d 335 ) (1982) (holding that an oral commitment made by an ad hoc committee chairman was not contractually binding on the city where its charter specifically required that all city contracts be signed by the mayor or his duly authorized designate); and City of J

11989–1989
Corey Outdoor Advertising, Inc. v. Board of Zoning Adjustment green
ga · 1985
2 sentences

1989In Corey Outdoor Advertising v. Bd. of Zoning Adjustment of Atlanta, 254 Ga. 221 (3) ( 327 SE2d 178 ) (1985), the issue before the Court was whether the estoppel doctrine could be employed to validate a sign permit which had been issued by a city official in direct contravention of restrictions appearing in the city’s zoning ordinance.

1989In Corey Outdoor Advertising v. Bd. of Zoning Adjustment of Atlanta, 254 Ga. 221 (3) ( 327 SE2d 178 ) (1985), the issue before the Court was whether the estoppel doctrine could be employed to validate a sign permit which had been issued by a city official in direct contravention of restrictions appearing in the city’s zoning ordinance.

11989–1989
City of Calhoun v. Holland green
ga · 1966
1 sentence

1989Similarly distinguishable are such cases as City of Calhoun v. Holland, supra, 222 Ga. 817 (holding that the estoppel doctrine could not be applied in such a manner as to avoid the statutory ante litem notice arrangement imposed by former Code Ann. § 69-308 [currently OCGA § 36-33-5]); City of Atlanta v. Bull, 161 Ga. App. 648 ( 288 SE2d 335 ) (1982) (holding that an oral commitment made by an ad hoc committee chairman was not contractually binding on the city where its charter specifically required that all city contracts be signed by the mayor or his duly authorized designate); and City of J

11989–1989
City of Atlanta v. Bull green
gactapp · 1982
2 sentences

1989Similarly distinguishable are such cases as City of Calhoun v. Holland, supra, 222 Ga. 817 (holding that the estoppel doctrine could not be applied in such a manner as to avoid the statutory ante litem notice arrangement imposed by former Code Ann. § 69-308 [currently OCGA § 36-33-5]); City of Atlanta v. Bull, 161 Ga. App. 648 ( 288 SE2d 335 ) (1982) (holding that an oral commitment made by an ad hoc committee chairman was not contractually binding on the city where its charter specifically required that all city contracts be signed by the mayor or his duly authorized designate); and City of J

1989Similarly distinguishable are such cases as City of Calhoun v. Holland, supra, 222 Ga. 817 (holding that the estoppel doctrine could not be applied in such a manner as to avoid the statutory ante litem notice arrangement imposed by former Code Ann. § 69-308 [currently OCGA § 36-33-5]); City of Atlanta v. Bull, 161 Ga. App. 648 ( 288 SE2d 335 ) (1982) (holding that an oral commitment made by an ad hoc committee chairman was not contractually binding on the city where its charter specifically required that all city contracts be signed by the mayor or his duly authorized designate); and City of J

11989–1989
Kot v. Richard P. Rita Personnel System International, Inc. green
gactapp · 1975
1 sentence

1988Kot v. Richard P. Rita Personnel System, 134 Ga. App. 438 , supra. Decided October 19, 1988 — Rehearing denied November 2, 1988.

11988–1988
Burke v. First Peoples Bank of NJ green
njsuperctappdiv · 1980
1 sentence

1983Id.; Burke v. First Peoples Bank of N.J., 412 A2d 1089 (N.J.

11983–1983
Spearman v. Jaudon green
gactapp · 1978
2 sentences

1982Nor does the doctrine of res judicata apply: “Before a judgment in a former action will operate as res judicata it must appear that the former action was based on the same cause of action ...” (Emphasis supplied.) Spearman v. Jaudon, 145 Ga. App. 136 ( 243 SE2d 90 ). 3.

1982Nor does the doctrine of res judicata apply: “Before a judgment in a former action will operate as res judicata it must appear that the former action was based on the same cause of action ...” (Emphasis supplied.) Spearman v. Jaudon, 145 Ga. App. 136 ( 243 SE2d 90 ). 3.

11982–1982
State Farm Mutual Automobile Insurance v. Wheeler green
gactapp · 1981
1 sentence

1982Co. v. Wheeler, 160 Ga. App. 523, 527 , supra. Accordingly, there is no viability in an estoppel defense to the instant declaratory judgment action by virtue of the fact that the executed agreement is undated.

11982–1982
Delta Air Lines, Inc. v. Woods green
gactapp · 1976
2 sentences

1982For the same reason, there was no operation of the doctrine of estoppel, for “[e]stoppel by judgment occurs only when the issue determined in the prior proceeding is the same as that in the subsequent proceeding. [Cits.]” Delta Air Lines v. Woods, 137 Ga. App. 693 (1) ( 224 SE2d 763 ).

1982For the same reason, there was no operation of the doctrine of estoppel, for “[e]stoppel by judgment occurs only when the issue determined in the prior proceeding is the same as that in the subsequent proceeding. [Cits.]” Delta Air Lines v. Woods, 137 Ga. App. 693 (1) ( 224 SE2d 763 ).

11982–1982
General Communications Service, Inc. v. Georgia Public Service Commission neutral
gactapp · 1979
11979–1979
Cheney v. Powell green
· 1892
11959–1959
Tanner v. Rosser neutral
· 1892
11959–1959
Lingo v. Swicord green
ark · 1921
11953–1953
Andrews v. Meadow neutral
ala · 1901
11953–1953
DeVore v. Baxter neutral
ga · 1923
11951–1951
Worth County v. Crisp County green
ga · 1912
11949–1949
Alford v. State green
ga · 1900
11946–1946
Oatts v. Wilkins, Neely & Jones green
ga · 1900
11946–1946
Barham v. Weems neutral
ga · 1907
11946–1946
Hamilton v. State green
ga · 1907
11946–1946
Wilson v. Stanford green
ga · 1909
11946–1946
Whitney v. Central Georgia Power Co. green
ga · 1910
11946–1946
Koppe & Steinichen v. Rylander neutral
gactapp · 1925
11945–1945
Miller v. Desverges neutral
ga · 1886
11941–1941
Osburn v. Pritchard green
ga · 1898
11941–1941
Mansfield v. Calhoun green
ga · 1898
11941–1941
Rogers v. Rigell green
ga · 1936
11941–1941
Parsons v. Little neutral
· 1890
11941–1941
Home Owners' Loan Corp. v. Guaranty Title Trust Co. green
tenn · 1934
11941–1941
Southern Marble Co. v. Darnell neutral
· 1894
11938–1938
Barfield v. City of Atlanta green
gactapp · 1936
11938–1938
Petty v. Kennon green
ga · 1873
11936–1936
Moore v. State green
gactapp · 1912
11934–1934

Where else courts name it

CA 370 (1890–2026) IL 282 (1877–2025) TX 227 (1881–2025) NY 226 (1828–2025) PA 136 (1849–2025) FL 84 (1904–2024) MI 73 (1871–2026) NJ 71 (1881–2026) MO 67 (1877–2025) AL 63 (1846–2023) TN 60 (1895–2024) CT 58 (1896–2024) WI 58 (1869–2023) WA 55 (1895–2020) IN 54 (1861–2023) OR 54 (1897–2026) OH 53 (1897–2026) SC 49 (1846–2022) MA 47 (1889–2025) GA 46 (1914–2021) MD 45 (1907–2024) VA 44 (1877–2026) OK 40 (1901–2024) NC 39 (1887–2017) MN 38 (1894–2016) AZ 36 (1924–2024) KY 35 (1876–2024) IA 35 (1864–2024) LA 33 (1910–2016) CO 33 (1891–2025) MS 30 (1893–2024) NE 28 (1884–2025) WV 27 (1888–2020) DC 26 (1953–2015) AR 26 (1896–2012) RI 25 (1877–2011) NM 24 (1912–2022) UT 23 (1921–2025) ND 23 (1912–2023) MT 20 (1924–2019) ID 19 (1895–2022) SD 19 (1894–2021) KS 18 (1900–2012) HI 17 (1952–2015) ME 17 (1889–2021) VT 14 (1902–2024) WY 12 (1923–2008) DE 11 (1947–2024) NH 10 (1932–2019) AK 9 (1983–2015) NV 9 (1947–2017) PR 2 (1916–2003)

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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