acceleration clause (Florida) · Go Syfert
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acceleration clause in Florida

44 Florida opinions name it 3 courts 1927–2024 1 in the last five years

The cases below were cited by Florida 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 (19)

CaseFollowedCited
Campbell v. Wernergreen
fladistctapp · 1970 · cited in 4 Florida opinions naming this issue, 1995–2017
2 sentences

2017Sav. & Loan Ass’n, 461 So.2d 93, 95 (Fla. 1984) (citing Campbell v. Werner, 232 So.2d 252, 255 (Fla. 3d DCA 1970)).

2014An acceleration clause contained in a note which by its terms requires payment in installments “confers a contract right upon the mortgagee which he may elect to enforce, upon a default.” Campbell v. Werner, 232 So. 2d 252, 255 (Fla. 3d DCA 1970).

34
Greene v. Burseygreen
fladistctapp · 1999 · cited in 2 Florida opinions naming this issue, 2014–2015
2 sentences

2015See Campbell v. Werner, 232 So.2d 252 , 254 n. 1 (Fla. 3d DCA 1970) (noting that the filing of a suit for foreclosure amounted to the exercise of the option to accelerate and operated as notice to the mortgagor of such election); Rones v. Charlisa, Inc., 948 So.2d 878, 879 (Fla. 4th DCA 2007) (quoting Central Home Trust Co. of Elizabeth v. Lippincott, 392 So.2d 931, 933 (Fla. 5th DCA 1980)) (holding acceleration option was exercised by filing of foreclosure complaint and noting that “to constitute an acceleration after default, where the holder has the option to accelerate, the holder or payee

2014See Greene v. Bursey, 733 So. 2d 1111, 1115 (Fla. 4th DCA 8 1999) (noting that in an installment contract with an optional acceleration clause, “the entire debt does not become due on the mere default of payment; rather, it become[s] due when the creditor takes affirmative action to alert the debtor that he has exercised his option to accelerate.”); Monte v. Tipton, 612 So. 2d 714 (Fla. 2d DCA 1993); Smith v. F.D.I.C., 61 F.3d 1552, 1561 (11th Cir. 1995)(holding, “when the promissory note secured by a mortgage contains an optional acceleration clause, the foreclosure cause of action accrues, a

22
Central Home Trust Co. v. Lippincottgreen
fladistctapp · 1980 · cited in 2 Florida opinions naming this issue, 1993–2015
2 sentences

2015See Campbell v. Werner, 232 So.2d 252 , 254 n. 1 (Fla. 3d DCA 1970) (noting that the filing of a suit for foreclosure amounted to the exercise of the option to accelerate and operated as notice to the mortgagor of such election); Rones v. Charlisa, Inc., 948 So.2d 878, 879 (Fla. 4th DCA 2007) (quoting Central Home Trust Co. of Elizabeth v. Lippincott, 392 So.2d 931, 933 (Fla. 5th DCA 1980)) (holding acceleration option was exercised by filing of foreclosure complaint and noting that “to constitute an acceleration after default, where the holder has the option to accelerate, the holder or payee

1993Rather, the acceleration clause at hand requires after a default that First Union "take some clear and equivocal [sic] action indicating its intent to accelerate all payments under the note, and such action should apprise the maker of the fact that the option to accelerate has been exercised." Central Home Trust Co. v. Lippincott, 392 So.2d 931, 933 (Fla. 5th DCA 1990).

22
Coast Fed. Sav. & Loan Ass'n v. DeLoachgreen
fladistctapp · 1978 · cited in 2 Florida opinions naming this issue, 1980–1990
2 sentences

1990Further, as explained by this court in Coast Federal Savings and Loan Ass'n v. DeLoach, 362 So.2d 982, 984 (Fla. 2d DCA 1978), "[b]y retaking possession either for his own account or for the account of the lessee, a lessor loses the right to recover the full amount of remaining rental due on the basis of an acceleration clause.

1980These alternatives were stated by this court in Coast Federal Savings and Loan Association v. DeLoach, 362 So.2d 982, 984 (Fla. 2d DCA 1978): The lessor may treat the lease as terminated and retake possession for his own account, thus terminating any further liability on the part of the lessee; or the lessor may retake possession of the premises for the account of the lessee, holding the lessee liable for the difference between rental stipulated to be paid under *376 the lease agreement and what, in good faith, the lessor is able to recover from a reletting; or the lessor may stand by and do n

22
Gus' Bath, Inc. v. Lightbowngreen
fla · 1931 · cited in 2 Florida opinions naming this issue, 1962–1966
2 sentences

1966See Gus’ Baths v. Lightbown, 1931, 101 Fla. 1205 , 133 So. 85 , 135 So. 300 .

1966See Gus’ Baths v. Lightbown, 1931, 101 Fla. 1205 , 133 So. 85 , 135 So. 300 .

22
Williams v. Aeroland Oil Companygreen
fla · 1944 · cited in 4 Florida opinions naming this issue, 1978–1981
2 sentences

1981Furthermore, it is well settled that in the absence of an acceleration clause in a lease, “future rent is demandable only in the amounts and at the times named in the lease [and] the total cannot be recovered at law in a lump sum in advance of the accrual of the installments.” Williams v. Aeroland Oil Co., 155 Fla. 114 , 20 So.2d 346, 348 (1944).

1981Furthermore, it is well settled that in the absence of an acceleration clause in a lease, “future rent is demandable only in the amounts and at the times named in the lease [and] the total cannot be recovered at law in a lump sum in advance of the accrual of the installments.” Williams v. Aeroland Oil Co., 155 Fla. 114 , 20 So.2d 346, 348 (1944).

14
In the Matter of Lhd Realty Corporation, Debtor. Appeal of National Life Insurance Companygreen
ca7 · 1984 · cited in 2 Florida opinions naming this issue, 1990–1991
2 sentences

1991In the Matter of LHD Realty Corp., 726 F.2d 327 (7th Cir.1984), the Court specifically limits its ruling to the facts of the case and indeed states that "Courts could deal with the difficulty of [intentional default] by denying the acceleration exception in appropriate cases." Atlantic Federal firmly established here that the borrower willfully defaulted on the loan after being unable to negotiate a waiver of the prepayment penalty with Atlantic Federal officers and as a result of his business plan to sell the apartment building being frustrated when the sale did not close in March 1984 as sch

1990See Matter of LHD Realty Corp., 726 F.2d 327 (7th Cir.1984).

12
Broward County v. Coegreen
fladistctapp · 1979 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024In that sense, a default is an acceleration event. 7 ‘Somewhere the curtain must ring down on litigation.’” (citation omitted) (quoting Broward Cnty v. Coe, 376 So. 2d 1222, 1223 (Fla. 4th DCA 1979))).

11
David v. Sun Federal Sav. & Loan Ass'ngreen
fla · 1984 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017Sav. & Loan Ass’n, 461 So.2d 93, 95 (Fla. 1984) (citing Campbell v. Werner, 232 So.2d 252, 255 (Fla. 3d DCA 1970)).

11
The Travis Co. v. Mayesgreen
fla · 1948 · cited in 1 Florida opinions naming this issue, 2016–2016
1 sentence

2016Even so, Singleton’s pronouncement that an “acceleration and foreclosure [action] predicated upon subsequent and different defaults present[s] a separate and distinct” claim expresses the better reasoned view. 882 So. 2d at 1007 . 3 This analysis of Singleton neither undermines nor contradicts prior Florida Supreme Court or other Florida precedent, including the Supreme Court’s decision in Travis Co. v. Mayes, 36 So. 2d 264, 265-66 (Fla. 1948).

11
U.S. Bank National Ass'n v. Gullottagreen
ohio · 2008 · cited in 1 Florida opinions naming this issue, 2016–2016
2 sentences

2016Assn. v. Gullotta, 120 Ohio St.3d 399, 405 , 899 N.E.2d 987, 992 (2008) (holding Ütat each missed payment under a promissory note and mortgage did not give rise to a new claim because "[o]nce [the borrower] defaulted and [the lender] invoked the acceleration clause of the note, the ... obligations to pay each installment merged into one obligation to pay the entire balance on the note”).

2016Assn. v. Gullotta, 120 Ohio St.3d 399, 405 , 899 N.E.2d 987, 992 (2008) (holding Ütat each missed payment under a promissory note and mortgage did not give rise to a new claim because "[o]nce [the borrower] defaulted and [the lender] invoked the acceleration clause of the note, the ... obligations to pay each installment merged into one obligation to pay the entire balance on the note”).

11
Singleton v. Greymar Associatesgreen
fla · 2004 · cited in 1 Florida opinions naming this issue, 2016–2016
2 sentences

2016Even so, Singleton's pronouncement that an "acceleration and foreclosure [action] predicated upon subsequent and different defaults presents] a separate and distinct” claim expresses the better reasoned view. 882 So.2d at 1007. .

2016Even so, Singleton’s pronouncement that an “acceleration and foreclosure [action] predicated upon subsequent and different defaults present[s] a separate and distinct” claim expresses the better reasoned view. 882 So. 2d at 1007 . 3 This analysis of Singleton neither undermines nor contradicts prior Florida Supreme Court or other Florida precedent, including the Supreme Court’s decision in Travis Co. v. Mayes, 36 So. 2d 264, 265-66 (Fla. 1948).

11
Rones v. Charlisa, Inc.green
fladistctapp · 2007 · cited in 1 Florida opinions naming this issue, 2015–2015
1 sentence

2015See Campbell v. Werner, 232 So.2d 252 , 254 n. 1 (Fla. 3d DCA 1970) (noting that the filing of a suit for foreclosure amounted to the exercise of the option to accelerate and operated as notice to the mortgagor of such election); Rones v. Charlisa, Inc., 948 So.2d 878, 879 (Fla. 4th DCA 2007) (quoting Central Home Trust Co. of Elizabeth v. Lippincott, 392 So.2d 931, 933 (Fla. 5th DCA 1980)) (holding acceleration option was exercised by filing of foreclosure complaint and noting that “to constitute an acceleration after default, where the holder has the option to accelerate, the holder or payee

11
Adkinson v. Nyberggreen
fladistctapp · 1977 · cited in 1 Florida opinions naming this issue, 2015–2015
1 sentence

2015See Adkinson v. Nyberg, 344 So.2d 614, 615-16 (Fla. 2d DCA 1977).

11
Smith v. Federal Deposit Insurance Corporationgreen
ca3 · 1995 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014See Greene v. Bursey, 733 So. 2d 1111, 1115 (Fla. 4th DCA 8 1999) (noting that in an installment contract with an optional acceleration clause, “the entire debt does not become due on the mere default of payment; rather, it become[s] due when the creditor takes affirmative action to alert the debtor that he has exercised his option to accelerate.”); Monte v. Tipton, 612 So. 2d 714 (Fla. 2d DCA 1993); Smith v. F.D.I.C., 61 F.3d 1552, 1561 (11th Cir. 1995)(holding, “when the promissory note secured by a mortgage contains an optional acceleration clause, the foreclosure cause of action accrues, a

11
Dobbs v. Petkogreen
fladistctapp · 1968 · cited in 1 Florida opinions naming this issue, 1997–1997
1 sentence

1997See Dobbs v. Petko, 207 So.2d 11, 13 (Fla. 4th DCA 1968).

11
Chesnel v. Paradisgreen
me · 1983 · cited in 1 Florida opinions naming this issue, 1989–1989
11
Hulley v. Cape Kennedy Leasing Corp.green
fladistctapp · 1979 · cited in 1 Florida opinions naming this issue, 1981–1981
11
Pompano Paint Co. v. Pompano Beach Bank & Trust Co.green
fladistctapp · 1968 · cited in 1 Florida opinions naming this issue, 1979–1979
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (42)

CaseCitedYears
Smith v. Midcoast Investment Co. green
fla · 1937
2 sentences

1965Co., 127 Fla. 455 , 173 So. 348, 350 , in which it was stated that "* * * if the note and mortgage contained an acceleration clause of which the lender takes advantage, then the bonus or excess will be prorated only over the period of time for which the lender has elected to allow the obligation to run"; but we are not persuaded that *862 this rule should be applied to make criminally usurious that which was only civilly usurious in its inception and where the lender is not seeking to recover the full face value of the note, but only the amount actually loaned.' We feel that under Shorr v. Sha

1965Co., 127 Fla. 455 , 173 So. 348, 350 , in which it was stated that "* * * if the note and mortgage contained an acceleration clause of which the lender takes advantage, then the bonus or excess will be prorated only over the period of time for which the lender has elected to allow the obligation to run"; but we are not persuaded that *862 this rule should be applied to make criminally usurious that which was only civilly usurious in its inception and where the lender is not seeking to recover the full face value of the note, but only the amount actually loaned.' We feel that under Shorr v. Sha

51952–1965
Ayvas v. Green green
fla · 1952
2 sentences

1965Even if not, however, it became so under the proscription set out in the quoted portion of Ayvas v. Green, supra, when Home Credit sought to recover the full face value of the two notes as exhibited by the face of its complaint.

1953In the case of Alabama-Florida Co. v. Mays, 111 Fla. 100 , 149 So. 61, 64 , 91 A.L.R. 139 , this Court said: “ * * * The ground of the grantee’s liability adopted by this court is that of contract, an application of the now prevailing American doctrine that the grantee’s assumption of the mortgage debt is a contract made and intended by the formal parties thereto, not alone for their own benefit, but also for the direct benefit of a third party, the mortgagee, who may sue upon it"at law as the real party in interest (see section 4201, C.G.L.1927), even though the agreement to assume is contain

31953–1965
Baader v. Walker green
fladistctapp · 1963
2 sentences

1999In Baader v. Walker, 153 So.2d 51 (Fla. 2d DCA), cert. denied, 156 So.2d 858 (Fla.1963), the court construed an acceleration clause in a promissory note as being “self-executing” or “absolute. ” The note provided: Upon default in the payment of principal and/or interest due on any note, secured by said mortgage, all notes so secured and remaining unpaid shall forthwith be come due and payable notwithstanding their tenor.

1989Appellee relies on Baader v. Walker, 153 So.2d 51 (Fla. 2d DCA), cert. denied, 156 So.2d 858 (Fla. 1963), in which the court held that an acceleration clause identical to the clause in the note here was automatic.

21989–1999
Andrade v. Dade County green
fla · 1963
2 sentences

1999In Baader v. Walker, 153 So.2d 51 (Fla. 2d DCA), cert. denied, 156 So.2d 858 (Fla.1963), the court construed an acceleration clause in a promissory note as being “self-executing” or “absolute. ” The note provided: Upon default in the payment of principal and/or interest due on any note, secured by said mortgage, all notes so secured and remaining unpaid shall forthwith be come due and payable notwithstanding their tenor.

1989Appellee relies on Baader v. Walker, 153 So.2d 51 (Fla. 2d DCA), cert. denied, 156 So.2d 858 (Fla. 1963), in which the court held that an acceleration clause identical to the clause in the note here was automatic.

21989–1999
Quiring v. Plackard green
fladistctapp · 1982
2 sentences

1996In Quiring v. Plackard, 412 So.2d 415 (Fla. 3d DCA 1982), this court affirmed the exclusion of extrinsic evidence regarding an acceleration clause and a discount clause within a mortgage, finding no ambiguity.

1996In Quiring v. Plackard, 412 So.2d 415 (Fla. 3d DCA 1982), this court affirmed the exclusion of extrinsic evidence regarding an acceleration clause and a discount clause within a mortgage, finding no ambiguity.

21996–1996
Jimmy Hall's Morningside v. Blackburn & Peck Enter. green
fladistctapp · 1970
2 sentences

1980Williams v. Aeroland Oil Co., 155 Fla. 114 , 20 So.2d 346 (1944); Jimmy Hall's Morningside, Inc. v. Blackburn & Peck Enter., Inc., 235 So.2d 344 (Fla. 2d DCA 1970).

1978Williams v. Aeroland Oil Co., 155 Fla. 114 , 20 So.2d 346 (1944); Jimmy Hall's Morningside, Inc. v. Blackburn & Peck Enter., Inc., 235 So.2d 344 (Fla.2d DCA 1970).

21978–1980
Treb Trading Co. v. Green neutral
fla · 1931
2 sentences

1971Treb Trading Co. v. Green, 102 Fla. 238 , 135 So. 510 , and 102 Fla. 238 , 136 So. 688 (Fla. 1931).

1971Treb Trading Co. v. Green, 102 Fla. 238 , 135 So. 510 , and 102 Fla. 238 , 136 So. 688 (Fla. 1931).

21970–1971
Cone Et Ux. v. Armstrong neutral
fla · 1931
2 sentences

1971Treb Trading Co. v. Green, 102 Fla. 238 , 135 So. 510 , and 102 Fla. 238 , 136 So. 688 (Fla. 1931).

1970In the case of Treb Trading Co. v. Green, 102 Fla. 238 , 135 So. 510 , 136 So. 688 , after holding that foreclosure can be had for an entire mortgage indebtedness upon election to accelerate for a default consisting of nonpayment of taxes, required to be paid by a mortgage which contains a clause authorizing acceleration for default therein, the Supreme Court said: "* * * Such an agreement is not prohibited by statute, nor is it against public policy; it is not in the nature of a forfeiture nor a hard contract which it would be unconscionable to enforce, because an investor may very properly i

21970–1971
Shorr v. Skafte green
fla · 1956
2 sentences

1965Co., 127 Fla. 455 , 173 So. 348, 350 , in which it was stated that "* * * if the note and mortgage contained an acceleration clause of which the lender takes advantage, then the bonus or excess will be prorated only over the period of time for which the lender has elected to allow the obligation to run"; but we are not persuaded that *862 this rule should be applied to make criminally usurious that which was only civilly usurious in its inception and where the lender is not seeking to recover the full face value of the note, but only the amount actually loaned.' We feel that under Shorr v. Sha

1962Co., 127 Fla. 455 , 173 So. 348, 350 , in which it was stated that `* * * if the note and mortgage contained an acceleration clause of which the lender takes advantage, then the bonus or excess will be prorated only over the period of time for which the lender has elected to allow the obligation to run'; but we are not persuaded that this rule should be applied to make criminally usurious that which was only civilly usurious in its inception and where the lender is not seeking to recover the full face value of the note, but only the amount actually loaned." We feel that under Shorr v. Shafte,

21962–1965
Monte v. Tipton green
fladistctapp · 1993
1 sentence

2014See Greene v. Bursey, 733 So. 2d 1111, 1115 (Fla. 4th DCA 8 1999) (noting that in an installment contract with an optional acceleration clause, “the entire debt does not become due on the mere default of payment; rather, it become[s] due when the creditor takes affirmative action to alert the debtor that he has exercised his option to accelerate.”); Monte v. Tipton, 612 So. 2d 714 (Fla. 2d DCA 1993); Smith v. F.D.I.C., 61 F.3d 1552, 1561 (11th Cir. 1995)(holding, “when the promissory note secured by a mortgage contains an optional acceleration clause, the foreclosure cause of action accrues, a

12014–2014
Barnes v. Resolution Trust Corp. green
fladistctapp · 1995
1 sentence

2012In Barnes v. Resolution Trust Corp., 664 So.2d 1171 (Fla. 4th DCA 1996), this court held: An acceleration clause in a mortgage confers upon the mortgagee a contract right of constitutional dimensions.

12012–2012
Cook v. Merrifield green
fladistctapp · 1976
1 sentence

1999In the first case, Cook v. Merri-field, 335 So.2d 297 (Fla. 1st DCA 1976), the installment instrument provided: Failure to pay any installment herein promptly when due shall cause the entire indebtedness to become immediately due and payable.

11999–1999
Rohrt v. Kelley Manufacturing Company green
tex · 1961
2 sentences

1989Co. [ 162 Tex. 534 ], 349 S.W.2d 95 (Tex. 1961); Pirkle & Williams v. Shreveport Jitney Jungle, 140 So. 837 (La.

1989Co. [ 162 Tex. 534 ], 349 S.W.2d 95 (Tex. 1961); Pirkle & Williams v. Shreveport Jitney Jungle, 140 So. 837 (La.

11989–1989
Geiger Mutual Agency, Inc. v. Wright green
fladistctapp · 1970
2 sentences

1989This would in effect be a double remedy, which is conflicting and antagonistic."4 2 For purposes of this decision the court does not find it necessary to determine whether such a clause really is an acceleration clause. 3 Geiger Mutual Agency, Inc. v. Wright, 233 So.2d 444 (Fla. 4th DCA 1970); see also Chesnel v. Paradis, 453 A.2d 1184 (Me. 1983); Rohrt v. Kelly [Kelley] Mfg.

1989This would in effect be a double remedy, which is conflicting and antagonistic."4 2 For purposes of this decision the court does not find it necessary to determine whether such a clause really is an acceleration clause. 3 Geiger Mutual Agency, Inc. v. Wright, 233 So.2d 444 (Fla. 4th DCA 1970); see also Chesnel v. Paradis, 453 A.2d 1184 (Me. 1983); Rohrt v. Kelly [Kelley] Mfg.

11989–1989
Pirkle & Williams, Inc. v. Shreveport Jitney Jungle, Inc. green
lactapp · 1932
11989–1989
Clark v. Lachenmeier green
fladistctapp · 1970
11983–1983
The Trenton Banking Co. v. Hawley green
njsuperctappdiv · 1950
11982–1982
Financial Fed. S. & L. Ass'n v. Continental Ent. green
fladistctapp · 1976
11982–1982
Windowmaster Corporation v. Jefferson Const. Co. green
fladistctapp · 1959
11982–1982
Yeaton v. Roberts neutral
nhsuperct · 1854
11982–1982
In Re Estate of Rentz green
fladistctapp · 1963
11982–1982
Neill Ex Rel. Neill v. Bach neutral
nc · 1950
11982–1982
Carlon, Inc. v. Southland Diversified Co. green
fladistctapp · 1980
11982–1982
Gray Corp. of North Miami v. Cisky neutral
fla · 1963
11982–1982
Aldridge v. Liberty Air, Inc. neutral
fladistctapp · 1968
11981–1981
Meredith v. Long green
fla · 1928
11979–1979
Kirk v. VanPetten green
fla · 1896
11979–1979
Home Credit Company v. Brown green
fla · 1962
11964–1964
Kreiss Potassium Phosphate Co. v. Knight green
fla · 1929
11963–1963
Hoefer v. Fortmann neutral
iowa · 1935
11963–1963
Groner-Youngerman, Inc. v. Denison green
fladistctapp · 1959
11963–1963
Lieberbaum v. Surfcomber Hotel Corp. green
fladistctapp · 1960
11963–1963
River Holding Co. v. Nickel green
fla · 1952
11963–1963
Perry v. Beckerman green
fla · 1957
11962–1962
Benson v. First Tr. Svgs. Bk., as Trustee green
fla · 1931
11962–1962
Alabama-Florida Co. v. Mays green
fla · 1933
11953–1953
Clay v. Girdner green
fla · 1931
11939–1939
Land v. May neutral
ark · 1904
11934–1934
Blood v. Hunt green
fla · 1929
11931–1931
Taylor v. American National Bank green
fla · 1912
11929–1929

Statutes the citing opinions construe

FL § 95.11 (5) FL § 687.03 (3) FL § 687.04 (3) FL § 95.281 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 100 (1910–2025) TX 54 (1925–2025) CA 45 (1927–2025) FL 44 (1927–2024) GA 34 (1934–2003) MI 33 (1930–2025) PA 24 (1928–2019) LA 23 (1933–2025) IL 22 (1904–2025) OH 22 (1912–2017) MA 21 (1956–2022) NJ 19 (1929–2024) IA 17 (1925–2022) AZ 16 (1969–2022) KS 16 (1915–2022) OK 15 (1936–2024) MO 14 (1927–2016) IN 13 (1936–2020) TN 13 (1915–2018) CT 12 (1933–2002) AR 11 (1924–1982) AL 11 (1929–2017) CO 10 (1954–2020) NC 10 (1948–2024) MD 10 (1954–2002) WA 10 (1929–2026) ND 10 (1918–1997) VA 9 (1919–2025) MS 9 (1955–2021) ME 8 (1973–2024) MN 7 (1924–1986) WI 7 (1929–2018) NM 7 (1941–2024) OR 7 (1919–1999) NE 7 (1926–2022) UT 7 (1935–2019) SD 6 (1927–1982) DE 6 (1930–2017) RI 4 (1974–2018) ID 3 (1922–1988) KY 3 (1937–1998) VT 3 (1993–2005) MT 3 (1923–1962) HI 3 (1997–2013) SC 2 (1940–1984) WY 2 (1933–1981)

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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