motor vehicle exception (Minnesota) · Go Syfert
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motor vehicle exception in Minnesota

44 Minnesota opinions name it 2 courts 1975–2025 2 in the last five years

The cases below were cited by Minnesota 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 (26)

CaseFollowedCited
State v. Duesterhoeftgreen
minn · 1981 · cited in 4 Minnesota opinions naming this issue, 1997–2024
2 sentences

2024An investigatory stop of a vehicle is valid if an officer has “specific and articulable facts establishing reasonable suspicion of a motor vehicle violation or criminal activity.” State v. Duesterhoeft, 311 N.W.2d 866, 867 (Minn. 1981) (quotation omitted).

2016An investigatory stop of a vehicle is valid if an officer has “specific and articulable facts establishing reasonable suspicion of a motor vehicle violation or criminal activity.” State v. Duesterhoeft, 311 N.W.2d 866, 867 (Minn. 1981) (quotation omitted).

44
State v. Johnsongreen
minnctapp · 2002 · cited in 4 Minnesota opinions naming this issue, 2014–2016
2 sentences

2016But “[l]imited investigatory stops are allowed if police have reasonable articulable suspicion of a motor vehicle violation or of criminal activity.” State v. Johnson, 645 N.W.2d 505, 508 (Minn. App. 2002).

2015But “[l]imited investigatory stops are allowed if police have reasonable articulable suspicion of a motor vehicle violation or of criminal activity.” State v. Johnson, 645 N.W.2d 505, 508 (Minn. App. 2002).

44
State v. Georgegreen
minn · 1997 · cited in 3 Minnesota opinions naming this issue, 2015–2016
2 sentences

2016To justify an investigatory traffic stop, “the police must only show that the stop was not the product of mere whim, caprice or idle curiosity, but was based upon 5 specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.” State v. Anderson, 683 N.W.2d 818, 823 (Minn. 2004) (quotations omitted). “[I]f an officer observes a violation of a traffic law, however insignificant, the officer has an objective basis for stopping the vehicle.” State v. George, 557 N.W.2d 575, 578 (Minn. 1997).

2016Suspicion must be based on more than a “mere hunch.” State v. Battleson, 567 N.W.2d 69, 71 (Minn. App. 1997). “[I]f an officer observes a violation of a traffic law, however insignificant, the officer has an objective basis for stopping the vehicle.” State v. George, 557 N.W.2d 575, 578 (Minn. 1997).

33
State v. Olsongreen
minnctapp · 1984 · cited in 3 Minnesota opinions naming this issue, 1984–1984
2 sentences

1984The test may be required of a person when an officer has reasonable and probable grounds to believe the person was driving, operating, or in physical control of a motor vehicle in violation of section 169.-121 [the DWI statute] and one of the following conditions exist: (1) the person has been lawfully placed under arrest for violation of section 169.121, or an ordinance in conformity with it * * * “Reasonable and probable grounds” to believe a person has been driving while under the influence of alcohol has been equated with the term “probable cause.” State v. Olson, 342 N.W.2d 638, 640 (Minn

1984The test may be required of a person when an officer has reasonable and probable grounds to believe the person was driving, operating, or in physical control of a motor vehicle in violation of section 169.121 [the DWI statute] and one of the following conditions exist: * * * (2) the person has been involved in a motor vehicle accident or collision resulting in property damage, personal injury, or death (Emphasis supplied.) “Reasonable and probable grounds” to believe a person was driving while under the influence of alcohol has been equated with the term “probable cause,” State v. Olson, 342 N

23
State v. Bigelowgreen
minn · 1990 · cited in 2 Minnesota opinions naming this issue, 1999–2016
2 sentences

2016Probable cause to search a vehicle “justifies a search of every part of the vehicle and its contents that may conceal the object of the search.” State v. Bigelow, 451 N.W.2d 311, 311 (Minn. 1990).

1999The U.S. Supreme Court has held that “[i]f probable cause justifies the search of a lawfully stopped vehicle, it justifies the search of every part of the vehicle and its contents that may conceal the object of the search.” Ross, 456 U.S. at 825 , 102 S.Ct. 2157 ; see also Carroll, 267 U.S. at 136 , 45 S.Ct. 280 (upholding, under the motor vehicle exception, a search in which the police found and seized illegal alcohol only by tearing open the seat covers of the car); State v. Bigelow, 451 N.W.2d 311, 312 (Minn.1990).

22
State v. Andersongreen
minn · 2004 · cited in 2 Minnesota opinions naming this issue, 2015–2016
2 sentences

2016To justify an investigatory traffic stop, “the police must only show that the stop was not the product of mere whim, caprice or idle curiosity, but was based upon 5 specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.” State v. Anderson, 683 N.W.2d 818, 823 (Minn. 2004) (quotations omitted). “[I]f an officer observes a violation of a traffic law, however insignificant, the officer has an objective basis for stopping the vehicle.” State v. George, 557 N.W.2d 575, 578 (Minn. 1997).

2015To justify an investigatory traffic stop, “the police must only show that the stop was not the product of mere whim, caprice or idle curiosity, but was based upon specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant that intrusion.” State v. Anderson, 683 N.W.2d 818, 823 (Minn. 2004) (quotation omitted). 3 “[I]f an officer observes a violation of a traffic law, however insignificant, the officer has an objective basis for stopping the vehicle.” State v. George, 557 N.W.2d 575, 578 (Minn. 1997).

22
State v. Crippsgreen
minn · 1995 · cited in 2 Minnesota opinions naming this issue, 2014–2014
2 sentences

2014A reasonable articulable suspicion exists if the police officer can present “a particularized and objective basis for suspecting the seized person of criminal activity.” State v. Cripps, 533 N.W.2d 388, 391 (Minn. 1995).

2014A reasonable, articulable suspicion exists if the police officer can present “a particularized and objective basis for suspecting the seized person of criminal activity.” State v. Cripps, 533 N.W.2d 388, 391 (Minn. 1995).

22
Garske v. United Statesgreen
ca8 · 1924 · cited in 2 Minnesota opinions naming this issue, 1984–1984
2 sentences

1984Probable cause has been defined as “a reasonable ground of suspicion supported by circumstances sufficiently strong in themselves to warrant a cautious man in believing the accused to be guilty.” Id. at 640 , quoting Garske v. United States, 1 F.2d 620, 623 (8th Cir.1924).

1984The test may be required of a person when an officer has reasonable and probable grounds to believe the person was driving, operating, or in physical control of a motor vehicle in violation of section 169.121 [the DWI statute] and one of the following conditions exist: * * * (2) the person has been involved in a motor vehicle accident or collision resulting in property damage, personal injury, or death (Emphasis supplied.) “Reasonable and probable grounds” to believe a person was driving while under the influence of alcohol has been equated with the term “probable cause,” State v. Olson, 342 N

22
State v. Schultzgreen
minn · 1978 · cited in 3 Minnesota opinions naming this issue, 1980–2025
2 sentences

2025We noted that, at the time Wicklund was 4 See, e.g., State v. Schultz, 271 N.W.2d 836, 837 (Minn. 1978) (citing Wicklund for the proposition that “the odor of marijuana” justified a “warrantless search of the passenger compartment for marijuana pursuant to the so-called motor vehicle exception to the warrant requirement”); State v. Hodgman, 257 N.W.2d 313, 315 (Minn. 1977) (citing Wicklund for the proposition that the odor of marijuana gave the officer “probable cause to arrest defendant and conduct a full search of both defendant and the car” (emphasis added)); State v. Veigel, 304 N.W.2d 900

1981State v. Armstrong, 291 N.W.2d 918 (Minn.1980); State v. Johnson, 277 N.W.2d 346 (Minn.1979); State v. Schultz, 271 N.W.2d 836 (Minn.1978); City of St.

13
State v. Munsongreen
minn · 1999 · cited in 3 Minnesota opinions naming this issue, 2004–2016
2 sentences

2016The supreme court held “that the corroborated details of the [informant’s] tip, together with the past reliability of the [informant], gave the police probable cause to believe that the Blazer was carrying illegal drugs and thus justified the search of the Blazer under the motor vehicle exception.” Id. at 136-37 .

2016“Under this motor vehicle exception, the police may search an automobile without a warrant if they have probable cause for believing that the vehicles are carrying contraband or illegal merchandise.” Id. (quotation omitted).

13
State v. Hodgmangreen
minn · 1977 · cited in 1 Minnesota opinions naming this issue, 2025–2025
1 sentence

2025We noted that, at the time Wicklund was 4 See, e.g., State v. Schultz, 271 N.W.2d 836, 837 (Minn. 1978) (citing Wicklund for the proposition that “the odor of marijuana” justified a “warrantless search of the passenger compartment for marijuana pursuant to the so-called motor vehicle exception to the warrant requirement”); State v. Hodgman, 257 N.W.2d 313, 315 (Minn. 1977) (citing Wicklund for the proposition that the odor of marijuana gave the officer “probable cause to arrest defendant and conduct a full search of both defendant and the car” (emphasis added)); State v. Veigel, 304 N.W.2d 900

11
State v. Bourkegreen
minn · 2006 · cited in 1 Minnesota opinions naming this issue, 2024–2024
1 sentence

2024The reasonable suspicion standard is “not high.” State v. Bourke, 718 N.W.2d 922, 927 (Minn. 2006) (quotation omitted).

11
Dutcher v. Commissioner of Public Safetygreen
minnctapp · 1987 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016Safety, 406 N.W.2d 333, 336 (Minn. App. 1987) (“The Commissioner’s burden extends only to the concentration at 4 the time of testing, insofar as implied consent is concerned.” (citation omitted)).

11
State v. Koppigreen
minn · 2011 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016Such probable cause exists “whenever there 4 are facts and circumstances known to the officer which would warrant a prudent man in believing that the individual was driving or was operating or was in physical control of a motor vehicle while impaired.” State v. Koppi, 798 N.W.2d 358, 362 (Minn. 2011) (quotation omitted).

11
State v. Battlesongreen
minnctapp · 1997 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016Suspicion must be based on more than a “mere hunch.” State v. Battleson, 567 N.W.2d 69, 71 (Minn. App. 1997). “[I]f an officer observes a violation of a traffic law, however insignificant, the officer has an objective basis for stopping the vehicle.” State v. George, 557 N.W.2d 575, 578 (Minn. 1997).

11
Llona v. Commissioner of Public Safetygreen
minnctapp · 1986 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015Safety, 389 N.W.2d 210, 211 (Minn. App. 1986); Roberts v. Comm’r of Pub.

11
Frost & Frost Trucking Co. v. Railroad Comm'n of Cal.green
scotus · 1926 · cited in 1 Minnesota opinions naming this issue, 2014–2014
2 sentences

2014Camara 2 Poitra does not rely on Frost, 271 U.S. at 593-94 , 46 S. Ct. at 607 (discussing the unconstitutional-conditions doctrine). 3 Unlike the regulation in Camara, Minnesota’s implied-consent law does not authorize chemical testing unless “an officer has probable cause to believe the person [to be tested] was driving, operating, or in physical control of a motor vehicle in violation of section 169A.20 (driving while impaired).” Minn. Stat. § 169A.51, subd. 1(b) (2012); see also Minn. Stat. § 169A.51, subd. 1(c) (2012) (“The test may also be required of a person 5 contended that he could no

2014Camara 2 Poitra does not rely on Frost, 271 U.S. at 593-94 , 46 S. Ct. at 607 (discussing the unconstitutional-conditions doctrine). 3 Unlike the regulation in Camara, Minnesota’s implied-consent law does not authorize chemical testing unless “an officer has probable cause to believe the person [to be tested] was driving, operating, or in physical control of a motor vehicle in violation of section 169A.20 (driving while impaired).” Minn. Stat. § 169A.51, subd. 1(b) (2012); see also Minn. Stat. § 169A.51, subd. 1(c) (2012) (“The test may also be required of a person 5 contended that he could no

11
Illinois Farmers Insurance Co. v. Duffygreen
minnctapp · 2000 · cited in 1 Minnesota opinions naming this issue, 2002–2002
1 sentence

2002See Duffy, 618 N.W.2d at 616 .

11
Carroll v. United Statesgreen
scotus · 1925 · cited in 1 Minnesota opinions naming this issue, 1999–1999
2 sentences

1999The U.S. Supreme Court has held that “[i]f probable cause justifies the search of a lawfully stopped vehicle, it justifies the search of every part of the vehicle and its contents that may conceal the object of the search.” Ross, 456 U.S. at 825 , 102 S.Ct. 2157 ; see also Carroll, 267 U.S. at 136 , 45 S.Ct. 280 (upholding, under the motor vehicle exception, a search in which the police found and seized illegal alcohol only by tearing open the seat covers of the car); State v. Bigelow, 451 N.W.2d 311, 312 (Minn.1990).

1999The U.S. Supreme Court has held that “[i]f probable cause justifies the search of a lawfully stopped vehicle, it justifies the search of every part of the vehicle and its contents that may conceal the object of the search.” Ross, 456 U.S. at 825 , 102 S.Ct. 2157 ; see also Carroll, 267 U.S. at 136 , 45 S.Ct. 280 (upholding, under the motor vehicle exception, a search in which the police found and seized illegal alcohol only by tearing open the seat covers of the car); State v. Bigelow, 451 N.W.2d 311, 312 (Minn.1990).

11
State v. Harrisgreen
minn · 1972 · cited in 1 Minnesota opinions naming this issue, 1989–1989
11
State v. Richardsgreen
minn · 1979 · cited in 1 Minnesota opinions naming this issue, 1988–1988
11
Byrd v. O'NEILLgreen
minn · 1976 · cited in 1 Minnesota opinions naming this issue, 1986–1986
11
Sammie Jackson, Jr. v. United Statesgreen
cadc · 1962 · cited in 1 Minnesota opinions naming this issue, 1984–1984
11
State v. Fraziergreen
minn · 1982 · cited in 1 Minnesota opinions naming this issue, 1984–1984
11
State v. Harrisgreen
minn · 1963 · cited in 1 Minnesota opinions naming this issue, 1984–1984
11
State v. Alessogreen
minn · 1982 · cited in 1 Minnesota opinions naming this issue, 1984–1984
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (41)

CaseCitedYears
United States v. Ross green
scotus · 1982
2 sentences

2014In that case the Court held that, under the motor vehicle exception to the warrant requirement, police officers “may conduct a search of a vehicle that is as thorough as a magistrate could authorize in a warrant ‘particularly describing the place to be searched.’” 456 U.S. at 800 , 102 S. Ct. at 2159 .

2014In that case the Court held that, under the motor vehicle exception to the warrant requirement, police officers “may conduct a search of a vehicle that is as thorough as a magistrate could authorize in a warrant ‘particularly describing the place to be searched.’” 456 U.S. at 800 , 102 S. Ct. at 2159 .

51982–2014
State v. Veigel green
minn · 1981
2 sentences

2025We noted that, at the time Wicklund was 4 See, e.g., State v. Schultz, 271 N.W.2d 836, 837 (Minn. 1978) (citing Wicklund for the proposition that “the odor of marijuana” justified a “warrantless search of the passenger compartment for marijuana pursuant to the so-called motor vehicle exception to the warrant requirement”); State v. Hodgman, 257 N.W.2d 313, 315 (Minn. 1977) (citing Wicklund for the proposition that the odor of marijuana gave the officer “probable cause to arrest defendant and conduct a full search of both defendant and the car” (emphasis added)); State v. Veigel, 304 N.W.2d 900

1984United States v. Ross, 456 U.S. 798 , 102 S.Ct. 2157 , 72 L.Ed.2d 572 (1982); New York v. Belton, 453 U.S. 454 , 101 S.Ct. 2860 , 69 L.Ed.2d 768 (1981); State v. Schinzing, 342 N.W.2d at 110 ; State v. Frazier, 318 N.W.2d 42, 43 (Minn.1982); State v. Veigel, 304 N.W.2d 900 (Minn.1981).

31983–2025
Terry v. Ohio green
scotus · 1968
2 sentences

2002State v. Duesterhoeft, 311 N.W.2d 866, 867 (Minn.1981); Terry v. Ohio, 392 U.S. 1, 30 , 88 S.Ct. 1868, 1884 , 20 L.Ed.2d 889 (1968).

2002Id.

31996–2002
State v. McKinley green
minn · 1975
2 sentences

1981In State v. McKinley, 305 Minn. 297 , 232 N.W.2d 906 (1975), relied on in Vaughn , we held that police may not make investigatory stops of motor vehicles without first having “specific and articulable facts” establishing “reasonable suspicion” of a motor vehicle violation or criminal activity.

1979We do not need to decide this issue because (a) they clearly had reasonable grounds for stopping the truck for minimally intrusive investigative questioning, see, Delaware v. Prouse, 440 U.S. 648 , 99 S.Ct. 1391 , 59 L.Ed.2d 660 (1979), and State v. McKinley, 305 Minn. 297 , 232 N.W.2d 906 (1975); (b) upon doing this and before they ever actually entered the vehicle one of the officers saw through the window and in open view a partially uncased gun; 2 (c) this observation provided them with all they needed in the way of probable cause; and (d) under the motor vehicle exception they at that poi

31979–1996
State v. Schinzing green
minn · 1983
2 sentences

1988After detecting the odor of alcohol, pursuant to the motor vehicle exception to the warrant requirement, the officer is “justified in searching anywhere in the passenger compartment where those open bottles or cans might be found.” Id.

1984Schinzing, 342 N.W.2d at 109 ; State v. Alesso, 328 N.W.2d 685, 688 (Minn.1982); State v. Veigel, 304 N.W.2d *415 900 (Minn.1981).

21984–1988
State v. McKinley green
minn · 1975
2 sentences

1981In State v. McKinley, 305 Minn. 297 , 232 N.W.2d 906 (1975), relied on in Vaughn , we held that police may not make investigatory stops of motor vehicles without first having “specific and articulable facts” establishing “reasonable suspicion” of a motor vehicle violation or criminal activity.

1979We do not need to decide this issue because (a) they clearly had reasonable grounds for stopping the truck for minimally intrusive investigative questioning, see, Delaware v. Prouse, 440 U.S. 648 , 99 S.Ct. 1391 , 59 L.Ed.2d 660 (1979), and State v. McKinley, 305 Minn. 297 , 232 N.W.2d 906 (1975); (b) upon doing this and before they ever actually entered the vehicle one of the officers saw through the window and in open view a partially uncased gun; 2 (c) this observation provided them with all they needed in the way of probable cause; and (d) under the motor vehicle exception they at that poi

21979–1981
Delaware v. Prouse green
scotus · 1979
2 sentences

1979We do not need to decide this issue because (a) they clearly had reasonable grounds for stopping the truck for minimally intrusive investigative questioning, see, Delaware v. Prouse, 440 U.S. 648 , 99 S.Ct. 1391 , 59 L.Ed.2d 660 (1979), and State v. McKinley, 305 Minn. 297 , 232 N.W.2d 906 (1975); (b) upon doing this and before they ever actually entered the vehicle one of the officers saw through the window and in open view a partially uncased gun; 2 (c) this observation provided them with all they needed in the way of probable cause; and (d) under the motor vehicle exception they at that poi

1979We do not need to decide this issue because (a) they clearly had reasonable grounds for stopping the truck for minimally intrusive investigative questioning, see, Delaware v. Prouse, 440 U.S. 648 , 99 S.Ct. 1391 , 59 L.Ed.2d 660 (1979), and State v. McKinley, 305 Minn. 297 , 232 N.W.2d 906 (1975); (b) upon doing this and before they ever actually entered the vehicle one of the officers saw through the window and in open view a partially uncased gun; 2 (c) this observation provided them with all they needed in the way of probable cause; and (d) under the motor vehicle exception they at that poi

21979–1981
State v. Johnson green
minn · 1979
2 sentences

1981State v. Armstrong, 291 N.W.2d 918 (Minn.1980); State v. Johnson, 277 N.W.2d 346 (Minn.1979); State v. Schultz, 271 N.W.2d 836 (Minn.1978); City of St.

1980State v. Johnson, 277 N.W.2d 346 (Minn.1979); State v. Schultz, 271 N.W.2d 836 (Minn.1978); City of St.

21980–1981
McDonnell v. Commissioner of Public Safety green
minn · 1991
1 sentence

2018Based on the parties' presentation of this case, we assume, without deciding, that Johnson's claim is best analyzed as a challenge under McDonnell . 473 N.W.2d 848 .

12018–2018
State v. Flowers green
minn · 2007
1 sentence

2016McIntosh asserts that this case is like State v. Flowers, 734 N.W.2d 239 (Minn. 2007).

12016–2016
State Farm Insurance Companies v. Seefeld green
minn · 1992
1 sentence

2000Id. at 65 .

12000–2000
State v. Moseng green
minn · 1959
11997–1997
State v. Lothenbach green
minn · 1980
11993–1993
Schneckloth v. Bustamonte green
scotus · 1973
11988–1988
Dietrich v. Commissioner of Public Safety green
minnctapp · 1985
11986–1986
In re Turner green
pacommwct · 1979
11985–1985
New York v. Belton red
scotus · 1981
11984–1984
United States v. Johnny Williams, Gregory Leon Murchison, Lawrence Daniels, Charged as Paul Abrams green
ca9 · 1980
11984–1984
United States v. Jozsef Tibor Wiga, United States of America v. Jozsef Tibor Wiga green
ca9 · 1981
11984–1984
United States v. Darrell Combs, and Steven Brown, A/K/A Steve Newman green
ca6 · 1982
11984–1984
State v. Francoeur yellow
fladistctapp · 1980
11984–1984
United States v. Bowles green
dc · 1973
11984–1984
State v. Mower green
me · 1979
11984–1984
The United States of America v. Aubrey Westley Miller green
ca10 · 1972
11984–1984
United States v. Johnnie Hudson and Michael Dean Johnson neutral
ca5 · 1979
11984–1984
Hunter v. Wainwright green
scotus · 1980
11984–1984
Tarkowski v. Scott green
scotus · 1980
11984–1984
Garrett v. Director, Department of Corrections of Virginia green
scotus · 1980
11984–1984
Pennington v. Housewright green
scotus · 1982
11984–1984
Taylor v. United States green
scotus · 1982
11984–1984
Trimmer v. Van Bomel green
scotus · 1982
11984–1984
Troy v. United States green
scotus · 1982
11984–1984
Spencer v. American Consulting Ass'n green
scotus · 1982
11984–1984
State v. Armstrong neutral
minn · 1980
11981–1981
State v. Tungland green
minn · 1979
11979–1979
Cooper v. California green
scotus · 1967
11979–1979
State v. Landon neutral
minn · 1977
11979–1979
State v. Yaeger green
minn · 1979
11979–1979
State v. Lee green
minn · 1975
11979–1979
State v. Wicklund green
minn · 1973
11978–1978

Statutes the citing opinions construe

MN § Minn. Stat. § 480A.08 (12) MN § Minn. Stat. § 169A.20 (5) MN § Minn. Stat. § 169A.51 (5) MN § Minn. Stat. § 169A.52 (5) MN § Minn. Stat. § 169.122 (4) MN § Minn. Stat. § 152.021 (3) MN § Minn. Stat. § 624.713 (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

MI 216 (1947–2026) NJ 165 (1950–2026) PA 107 (1938–2025) CT 91 (1964–2026) OH 72 (1965–2026) MN 44 (1975–2025) MA 35 (1977–2026) CA 33 (1935–2026) VT 27 (1987–2020) NY 25 (1945–2026) IA 24 (1974–2022) NC 21 (1956–2026) NE 14 (1950–2022) TX 13 (1939–2025) CO 12 (1986–2022) MO 11 (1971–2017) VA 10 (1983–2021) ID 9 (1978–2021) FL 8 (1978–2013) GA 8 (1990–2014) WI 8 (1953–2018) IL 7 (1970–2013) ME 6 (1975–2022) OR 5 (1974–2015) SD 5 (1990–2005) RI 5 (1979–2013) WA 5 (1981–2014) DE 5 (1983–2025) MD 4 (1980–2018) AK 4 (1981–1997) NH 4 (1981–2015) KS 4 (2012–2024) AZ 3 (1977–2007) MS 3 (1958–1993) LA 3 (2003–2013) KY 3 (1951–2022) WV 2 (1979–2007) WY 2 (1977–1982) IN 2 (1999–2000) UT 2 (2009–2013)

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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