invocation bar (Texas) · Go Syfert
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invocation bar in Texas

45 Texas opinions name it 3 courts 1922–2024 3 in the last five years

The cases below were cited by Texas 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 (33)

CaseFollowedCited
Risk Managers International, Inc. v. Stategreen
texapp · 1993 · cited in 6 Texas opinions naming this issue, 2005–2007
2 sentences

2007See Cramer v. Sheppard , 140 Tex. 271 , 167 S.W.2d 147, 155 (1942); Risk Managers Int'l, Inc. v. State , 858 S.W.2d 567, 570 (Tex.App.-Austin 1993, writ denied).

2007See Cramer v. Sheppard, 140 Tex. 271 , 167 S.W.2d 147, 155 (1942); Risk Managers Int’l, Inc. v. State, 858 S.W.2d 567, 570 (Tex.App.-Austin 1993, writ denied).

66
Cramer v. Sheppardgreen
tex · 1942 · cited in 6 Texas opinions naming this issue, 2005–2007
2 sentences

2007See Cramer v. Sheppard, 140 Tex. 271 , 167 S.W.2d 147, 155 (1942); Risk Managers Int’l, Inc. v. State, 858 S.W.2d 567, 570 (Tex.App.-Austin 1993, writ denied).

2007See Cramer v. Sheppard, 140 Tex. 271 , 167 S.W.2d 147, 155 (1942); Risk Managers Int’l, Inc. v. State, 858 S.W.2d 567, 570 (Tex.App.-Austin 1993, writ denied).

66
Oregon v. Kennedygreen
scotus · 1982 · cited in 8 Texas opinions naming this issue, 1994–2009
2 sentences

2006Kennedy, 456 U.S. at 673 , 102 S.Ct. 2083 (explaining that the "intentional goading” standard was designed to protect a defendant whose motion for mistrial could not fairly be considered a result of his own free will; "in such a case, the defendant’s valued right to complete his trial before the first jury would be a hollow shell if the inevitable motion for mistrial were held to prevent a later invocation of the bar of double jeopardy in all circumstances”). .

2006Kennedy, 456 U.S. at 673 , 102 S.Ct. 2083 (explaining that the "intentional goading” standard was designed to protect a defendant whose motion for mistrial could not fairly be considered a result of his own free will; "in such a case, the defendant’s valued right to complete his trial before the first jury would be a hollow shell if the inevitable motion for mistrial were held to prevent a later invocation of the bar of double jeopardy in all circumstances”). .

58
Bauder v. Statered
texcrimapp · 1996 · cited in 4 Texas opinions naming this issue, 1998–2006
2 sentences

2006Kirkpatrick, Federal Evidence § 153 at 176 (2d ed. 1994) (setting out both the relevance theory of insurance inclining a party toward negligence and the prejudice theory that juries will be more likely to find liability because of insurance coverage); see also AccuBanc Mortgage Corp. v. Drummonds, 938 S.W.2d 135, 151-52 (Tex. App.-Fort Worth 1996, writ denied). [41] 146 S.W.3d at 253. [42] Kennedy, 456 U.S. at 673 (explaining that the "intentional goading" standard was designed to protect a defendant whose motion for mistrial could not fairly be considered a result of his own free will; "in su

2003If an appellate court doubts that a mistrial was "required" by the prosecutor's actions, then it may be reasonable to conclude that the prosecutor was not consciously aware of the likelihood that his conduct would require a mistrial. [46] See Kennedy, 456 U.S. at 673 , 102 S.Ct. 2083 (explaining that the "intentional goading" standard was designed to protect a defendant whose motion for mistrial could not fairly be considered a result of his own free will; "[i]n such a case, the defendant's valued right to complete his trial before the first jury would be a hollow shell if the inevitable motio

24
Montejo v. Louisianagreen
scotus · 2009 · cited in 2 Texas opinions naming this issue, 2012–2012
2 sentences

2012See Montejo, 556 U.S. at 787 , 129 S.Ct. at 2086 (stating that “antibadgering” by police officers is the rationale of Edwards), id. at 2087 (rejecting Montejo’s proposed rule that would prevent “police-initiated interrogation entirely once the Sixth Amendment right” to counsel attaches), id. at 2089 (purpose of Jackson rule, like that of Edwards, "is to preclude the State from badgering defendants into waiving their previously asserted rights"). .

2012See Montejo, 556 U.S. at 787 , 129 S.Ct. at 2086 (stating that “antibadgering” by police officers is the rationale of Edwards), id. at 2087 (rejecting Montejo’s proposed rule that would prevent “police-initiated interrogation entirely once the Sixth Amendment right” to counsel attaches), id. at 2089 (purpose of Jackson rule, like that of Edwards, "is to preclude the State from badgering defendants into waiving their previously asserted rights"). .

22
Johnson v. Stategreen
texcrimapp · 1991 · cited in 2 Texas opinions naming this issue, 1999–2011
2 sentences

2011Johnson , 803 S.W.2d at 282 ; see also Benitez , 5 S.W.3d at 920 .

2011See Johnson , 803 S.W.2d at 283 (conducting harm analysis under former Rule of Appellate Procedure 81(b)(2)).

22
Standard Fire Insurance Co. v. Reesegreen
tex · 1979 · cited in 2 Texas opinions naming this issue, 2008–2008
2 sentences

2008See Reese, 584 S.W.2d at 839-40 .

2008See Reese, 584 S.W.2d at 839-40 .

22
Weinbaum v. United Statesgreen
ca9 · 1950 · cited in 2 Texas opinions naming this issue, 2001–2001
2 sentences

2001See United States v. Little, 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards, 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry, 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States, 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez, 852 S.W.2d 596, 615 (Tex. App.—Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was tried

2001See United States v. Little , 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards , 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry , 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States , 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez , 852 S.W.2d 596, 615 (Tex. App.--Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was

22
First Heights Bank, FSB v. Gutierrezgreen
texapp · 1993 · cited in 2 Texas opinions naming this issue, 2001–2001
2 sentences

2001See United States v. Little, 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards, 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry, 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States, 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez, 852 S.W.2d 596, 615 (Tex. App.—Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was tried

2001See United States v. Little , 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards , 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry , 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States , 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez , 852 S.W.2d 596, 615 (Tex. App.--Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was

22
United States v. John Thomas Terrygreen
ca6 · 1966 · cited in 2 Texas opinions naming this issue, 2001–2001
2 sentences

2001See United States v. Little, 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards, 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry, 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States, 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez, 852 S.W.2d 596, 615 (Tex. App.—Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was tried

2001See United States v. Little , 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards , 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry , 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States , 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez , 852 S.W.2d 596, 615 (Tex. App.--Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was

22
United States v. Robert Edwards, Max Jakob, John J. Lombardozzi and Milton Parnessgreen
ca2 · 1966 · cited in 2 Texas opinions naming this issue, 2001–2001
2 sentences

2001See United States v. Little, 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards, 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry, 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States, 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez, 852 S.W.2d 596, 615 (Tex. App.—Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was tried

2001See United States v. Little , 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards , 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry , 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States , 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez , 852 S.W.2d 596, 615 (Tex. App.--Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was

22
United States v. James E. Little, United States of America v. I. L. Vaughngreen
ca8 · 1977 · cited in 2 Texas opinions naming this issue, 2001–2001
2 sentences

2001See United States v. Little, 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards, 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry, 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States, 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez, 852 S.W.2d 596, 615 (Tex. App.—Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was tried

2001See United States v. Little , 567 F.2d 346, 351 (8th Cir. 1977); United States v. Edwards , 366 F.2d 853, 870 (2d Cir. 1966); United States v. Terry , 362 F.2d 914, 917 (6th Cir. 1966 ); Weinbaum v. United States , 184 F.2d 330, 331 (9th Cir. 1950); see also First Heights Bank, FSB v. Gutierrez , 852 S.W.2d 596, 615 (Tex. App.--Corpus Christi 1993, writ denied) (holding that, in civil case, trial court properly instructed jury to disregard invocation of right against self-incrimination in videotaped deposition played before jury by one who invoked privilege but then withdrew his answer and was

22
United States v. Dinitzgreen
scotus · 1976 · cited in 2 Texas opinions naming this issue, 2009–2009
2 sentences

2009Kennedy, 456 U.S. at 673 , 102 S.Ct. 2083 (citing United States v. Dinitz, 424 U.S. 600, 611 , 96 S.Ct. 1075 , 47 L.Ed.2d 267 (1976)).

2009Kennedy, 456 U.S. at 673 , 102 S.Ct. 2083 (citing United States v. Dinitz, 424 U.S. 600, 611 , 96 S.Ct. 1075 , 47 L.Ed.2d 267 (1976)).

12
Ex Parte Petersongreen
texcrimapp · 2003 · cited in 2 Texas opinions naming this issue, 2006–2006
2 sentences

2006Kirkpatrick, Federal Evidence § 153 at 176 (2d ed. 1994) (setting out both the relevance theory of insurance inclining a party toward negligence and the prejudice theory that juries will be more likely to find liability because of insurance coverage); see also AccuBanc Mortgage Corp. v. Drummonds, 938 S.W.2d 135, 151-52 (Tex. App.-Fort Worth 1996, writ denied). [41] 146 S.W.3d at 253. [42] Kennedy, 456 U.S. at 673 (explaining that the "intentional goading" standard was designed to protect a defendant whose motion for mistrial could not fairly be considered a result of his own free will; "in su

2006Ex parte Peterson, 117 S.W.3d at 817 .

12
Texas Capital Securities, Inc. v. Sandefergreen
texapp · 2001 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024Sec., Inc. v. Sandefer, 58 S.W.3d 760, 773 (Tex. App.—Houston [1st Dist.] 2001, pet. denied) (jury was entitled to draw negative inferences from a witness’s invocation of the privilege against self-incrimination and the refusal to answer deposition questions).

11
Evans v. City of Chicagogreen
ca7 · 2008 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024State for the Protection of P.B. v. V.T., 575 S.W.3d 921, 927 (Tex. App.—Austin 2019, no pet.) (citing Evans v. City of Chicago, 513 F.3d 735, 741 (7th Cir. 2008)).

11
Walters, William Kylegreen
texcrimapp · 2011 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024Walters v. State, 359 S.W.3d 212, 215, 216 (Tex. Crim.

11
State for Protection of P. B. v. v. T.green
texapp · 2019 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024State for the Protection of P.B. v. V.T., 575 S.W.3d 921, 927 (Tex. App.—Austin 2019, no pet.) (citing Evans v. City of Chicago, 513 F.3d 735, 741 (7th Cir. 2008)).

11
United States v. Certain Real Property and Premises Known Asgreen
ca2 · 1995 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019Id. at 83. 7 After the FDIC took receivership of a bank that failed after its guarantor refused to pay its claim under a fidelity bond, it stepped into the bank’s place in the three-week jury trial on the fidelity bond. 45 F.3d at 973 .

11
Upton v. Stategreen
texapp · 1995 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018App. 1991) (“[I]n this case, there was no violation of the rule because the evidence showed that the Deuchers had not yet come forward on the first day of trial; they were not known to be witnesses, and were not covered by the invocation of the rule on the first day.”). 7 Even in the absence of a per se rule that a court can never abuse its discretion in permitting the testimony of a witness in violation of the Rule when the witness testifies only at the punishment phase, we agree with our sister courts that, at the very least, “the admission of testimony related to something other than guilt

11
McInnes v. Yamaha Motor Corp., USAgreen
tex · 1984 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015This testimony, adduced by the appellant himself on these topics, militates any claim of harm in this case from Baxter and Oswald testifying on these same matters despite the invocation of the rule. –5– Dist.] 1995), aff’d in part and rev’d in part on other grounds, 937 S.W.2d 444 (Tex. 1996); see also McInnes v. Yahama Motor Corp., U.S.A., 673 S.W.2d 185, 187 (Tex. 1984) (fact that excluded deposition was on file with trial court and part of appellate record not sufficient to make it proper bill of exception).

11
Benitez v. Stategreen
texapp · 1999 · cited in 1 Texas opinions naming this issue, 2011–2011
1 sentence

2011Johnson , 803 S.W.2d at 282 ; see also Benitez , 5 S.W.3d at 920 .

11
AccuBanc Mortgage Corp. v. Drummondsgreen
texapp · 1997 · cited in 1 Texas opinions naming this issue, 2006–2006
1 sentence

2006Kirkpatrick, Federal Evidence § 153 at 176 (2d ed. 1994) (setting out both the relevance theory of insurance inclining a party toward negligence and the prejudice theory that juries will be more likely to find liability because of insurance coverage); see also AccuBanc Mortgage Corp. v. Drummonds, 938 S.W.2d 135, 151-52 (Tex. App.-Fort Worth 1996, writ denied). [41] 146 S.W.3d at 253. [42] Kennedy, 456 U.S. at 673 (explaining that the "intentional goading" standard was designed to protect a defendant whose motion for mistrial could not fairly be considered a result of his own free will; "in su

11
Donnelly v. DeChristoforogreen
scotus · 1974 · cited in 1 Texas opinions naming this issue, 2003–2003
11
Ullmann v. United Statesgreen
scotus · 1956 · cited in 1 Texas opinions naming this issue, 2001–2001
11
General Motors Corp. v. Saenzgreen
texapp · 1992 · cited in 1 Texas opinions naming this issue, 1996–1996
11
GMC v. Saenz on Behalf of Saenzgreen
tex · 1994 · cited in 1 Texas opinions naming this issue, 1996–1996
11
Russell G. Labbe, Sr. v. Louis M. Berman, Etc.green
ca1 · 1980 · cited in 1 Texas opinions naming this issue, 1991–1991
11
John Hugh Melton v. United Statesgreen
ca10 · 1968 · cited in 1 Texas opinions naming this issue, 1991–1991
11
Nixon v. Stategreen
texcrimapp · 1958 · cited in 1 Texas opinions naming this issue, 1991–1991
11
Puga v. Donna Fruit Co., Inc.green
tex · 1982 · cited in 1 Texas opinions naming this issue, 1987–1987
11
Ex Parte Millergreen
texcrimapp · 1922 · cited in 1 Texas opinions naming this issue, 1983–1983
11
Philipowski v. Spencergreen
tex · 1885 · cited in 1 Texas opinions naming this issue, 1977–1977
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
McQuarrie v. Stategreen
texcrimapp · 2012 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015But see McQuarrie v. State, 380 S.W.3d 145, 154 (Tex. Crim.

11

Also cited on this issue (19)

CaseCitedYears
Ex Parte Bauder green
texcrimapp · 1998
2 sentences

2003If an appellate court doubts that a mistrial was "required" by the prosecutor's actions, then it may be reasonable to conclude that the prosecutor was not consciously aware of the likelihood that his conduct would require a mistrial. [46] See Kennedy, 456 U.S. at 673 , 102 S.Ct. 2083 (explaining that the "intentional goading" standard was designed to protect a defendant whose motion for mistrial could not fairly be considered a result of his own free will; "[i]n such a case, the defendant's valued right to complete his trial before the first jury would be a hollow shell if the inevitable motio

2003If an appellate court doubts that a mistrial was "required" by the prosecutor's actions, then it may be reasonable to conclude that the prosecutor was not consciously aware of the likelihood that his conduct would require a mistrial. [46] See Kennedy, 456 U.S. at 673 , 102 S.Ct. 2083 (explaining that the "intentional goading" standard was designed to protect a defendant whose motion for mistrial could not fairly be considered a result of his own free will; "[i]n such a case, the defendant's valued right to complete his trial before the first jury would be a hollow shell if the inevitable motio

22003–2003
Stanford v. Butler green
tex · 1944
2 sentences

2001Nor are we persuaded by the Comptroller's invocation of the rule of departmental construction laid down in Stanford v. Butler , 181 S.W.2d at 273 .

2001Nor are we persuaded by the Comptroller's invocation of the rule of departmental construction laid down in Stanford v. Butler , 181 S.W.2d at 273 .

22001–2001
Federal Deposit Insurance Corporation, in Its Corporate Capacity v. Fidelity & Deposit Company of Maryland green
ca5 · 1995
1 sentence

2019Id. at 83. 7 After the FDIC took receivership of a bank that failed after its guarantor refused to pay its claim under a fidelity bond, it stepped into the bank’s place in the three-week jury trial on the fidelity bond. 45 F.3d at 973 .

12019–2019
Continental Coffee Products Co. v. Cazarez green
tex · 1997
1 sentence

2015This testimony, adduced by the appellant himself on these topics, militates any claim of harm in this case from Baxter and Oswald testifying on these same matters despite the invocation of the rule. –5– Dist.] 1995), aff’d in part and rev’d in part on other grounds, 937 S.W.2d 444 (Tex. 1996); see also McInnes v. Yahama Motor Corp., U.S.A., 673 S.W.2d 185, 187 (Tex. 1984) (fact that excluded deposition was on file with trial court and part of appellate record not sufficient to make it proper bill of exception).

12015–2015
Golden Eagle Archery, Inc. v. Jackson green
tex · 2000
2 sentences

2015Gibbons makes no argument for why the invocation of rule 199.4 was not sufficient to raise an objection under that section or for how she was 88 Id. 89 See id.

2015Gibbons makes no argument for why the invocation of rule 199.4 was not sufficient to raise an objection under that section or for how she was 88 Id. 89 See id.

12015–2015
Thomas, Heather green
texcrimapp · 2013
1 sentence

2015Even if there was in this case a remote possibility that Appellant intended to waive his previously preserved complaints from the voir dire proceedings, or that the trial court understood him to have intended such a waiver, that “contingency is [not] likely enough to justify the absolute and unforgiving application of a rule [requiring the court of appeals to find] that [counsel’s] statement of ‘no objection’ [should] operate to forfeit [any] claim of error that [may have] already been assiduously preserved[.]” Thomas, 408 S.W.3d at 885 .

12015–2015
State v. Lee green
texcrimapp · 2000
12003–2003
Exxon Corp. v. Shuttlesworth green
texapp · 1990
11996–1996
Joseph Gartner San Fratello v. United States green
ca5 · 1965
11991–1991
Miranda v. Arizona green
scotus · 1966
11987–1987
Gertz v. Robert Welch, Inc. green
scotus · 1974
11987–1987
Grunewald v. United States green
scotus · 1957
11983–1983
United States v. Apfelbaum green
scotus · 1980
11983–1983
Cooper v. State neutral
texcrimapp · 1956
11973–1973
United States v. United States Coin & Currency green
scotus · 1971
11972–1972
cluster 297607 green
ca5 · 1971
11972–1972
Sewell v. State green
texcrimapp · 1963
11967–1967
Peter v. First Nat. Bank of La Grange green
texapp · 1936
11938–1938
Bender v. Brooks green
· 1910
11922–1922

Where else courts name it

NY 168 (1895–2025) CA 92 (1899–2026) NJ 52 (1951–2025) TX 45 (1922–2024) MA 44 (1929–2026) CT 37 (1975–2017) PA 34 (1971–2026) IL 33 (1973–2026) MD 32 (1959–2022) FL 26 (1949–2025) LA 19 (1937–2018) OH 18 (1985–2025) MO 17 (1903–2020) AL 16 (1909–2023) GA 15 (1957–2025) MI 12 (1917–2025) VA 10 (1992–2025) MN 9 (1956–2024) RI 9 (1986–2005) DC 9 (1976–2025) TN 9 (1975–2024) WA 9 (1914–2025) ME 8 (1974–2014) CO 8 (1968–2016) OR 8 (1898–2020) DE 8 (1969–2023) ND 8 (1974–2019) AZ 7 (1968–2018) ID 7 (1983–2020) WI 7 (1893–2009) UT 6 (2004–2024) IN 6 (1918–2025) OK 6 (1955–2011) KY 6 (1913–2024) WV 5 (1997–2024) SC 5 (1984–2023) WY 5 (1981–1992) IA 5 (1971–2020) NM 5 (1973–2023) NC 5 (1995–2010) SD 4 (2000–2004) AK 4 (1980–1995) HI 4 (1994–2025) NE 3 (1984–2019) KS 3 (1928–1996) NH 3 (1993–2021) VT 2 (1990–2009) NV 2 (1979–1994) MS 2 (1993–2014) AR 2 (2019–2025)

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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