deliberate violation in Idaho

43 Idaho opinions name it 1 courts 1953–2024 1 in the last five years

The cases below were cited by Idaho 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 (14)

Case	Followed	Cited
Johns v. SH Kress & Companygreen idaho · 1957 · cited in 24 Idaho opinions naming this issue, 1959–2011 2 sentences 1996Kress & Co.: While the term “discharged for misconduct” ... has been variously defined, we think the term should be interpreted as meaning willful, intentional disregard of the employer’s interest; a deliberate violation of the employer’s rules; or a disregard of standards of behavior which the employer has a right to expect of his employees. 78 Idaho at 548 , 307 P.2d at 219 . 1996Kress & Co.: While the term “discharged for misconduct” ... has been variously defined, we think the term should be interpreted as meaning willful, intentional disregard of the employer’s interest; a deliberate violation of the employer’s rules; or a disregard of standards of behavior which the employer has a right to expect of his employees. 78 Idaho at 548 , 307 P.2d at 219 .	13	24
Puckett v. Idaho Department of Correctionsgreen idaho · 1985 · cited in 5 Idaho opinions naming this issue, 1991–2003 2 sentences 1995This Court has articulated a test for three types of conduct to determine whether an employee is ineligible for unemployment benefits due to a discharge based on “misconduct” as used in I.C. § 72-1366(e) by defining misconduct as “willful, intentional disregard of the employer’s interest; a deliberate violation of the employer’s rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.” Puckett v. Idaho Dep’t of Corrections, 107 Idaho 1022, 1023 , 695 P.2d 407, 408 (1985) (quotations omitted). 1995This Court has articulated a test for three types of conduct to determine whether an employee is ineligible for unemployment benefits due to a discharge based on “misconduct” as used in I.C. § 72-1366(e) by defining misconduct as “willful, intentional disregard of the employer’s interest; a deliberate violation of the employer’s rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.” Puckett v. Idaho Dep’t of Corrections, 107 Idaho 1022, 1023 , 695 P.2d 407, 408 (1985) (quotations omitted).	3	5
Matthews v. Bucyrus-Erie Co.green idaho · 1980 · cited in 4 Idaho opinions naming this issue, 1984–1991 2 sentences 1991Kress & Co., 78 Idaho 544 , 307 P.2d 217 (1957); Puckett v. Idaho Dep’t of Corrections, 107 Idaho 1022 , 695 P.2d 407 (1985); Goolsby v. Life Savers, 107 Idaho 456 , 690 P.2d 911 (1984); Roll v. City of Middleton, 105 Idaho 22 , 665 P.2d 721 (1983); Matthews v. Bucyrus-Erie Co., 101 Idaho 657 , 619 P.2d 1110 (1980). 1991Kress & Co., 78 Idaho 544 , 307 P.2d 217 (1957); Puckett v. Idaho Dep’t of Corrections, 107 Idaho 1022 , 695 P.2d 407 (1985); Goolsby v. Life Savers, 107 Idaho 456 , 690 P.2d 911 (1984); Roll v. City of Middleton, 105 Idaho 22 , 665 P.2d 721 (1983); Matthews v. Bucyrus-Erie Co., 101 Idaho 657 , 619 P.2d 1110 (1980).	3	4
Kivalu v. Life Care Centers of Americagreen idaho · 2005 · cited in 3 Idaho opinions naming this issue, 2009–2011 2 sentences 2011Employment-related misconduct includes any of the following: “(1) a willful, intentional disregard of the employer’s interest; (2) a deliberate violation of the employer’s reasonable rules; or (3) a disregard of a standard of behavior which the employer has a right to expect of his employees.” Kivalu v. Life Care Centers of America, 142 Idaho 262, 264 , 127 P.3d 165, 167 (2005); IDAPA 09.01.30.275.02. 2011Employment-related misconduct includes any of the following: “(1) a willful, intentional disregard of the employer’s interest; (2) a deliberate violation of the employer’s reasonable rules; or (3) a disregard of a standard of behavior which the employer has a right to expect of his employees.” Kivalu v. Life Care Centers of America, 142 Idaho 262, 264 , 127 P.3d 165, 167 (2005); IDAPA 09.01.30.275.02.	3	3
Wroble v. Bonners Ferry Ranger Stationgreen idaho · 1976 · cited in 5 Idaho opinions naming this issue, 1979–1984 2 sentences 1983"Misconduct is an `act of wanton or willful disregard of the employer's interest, a deliberate violation of the employer's rules, a disregard of standards of behavior which the employer has the right to expect of his employee, an intentional and substantial disregard of the employer's interest or of the employee's duties and obligations to the employer.' See Wroble v. Bonners Ferry Ranger Station, 97 Idaho 900 , 556 P.2d 859 (1976); Watts v. Employment Security Agency, 80 Idaho 529 , 335 P.2d 533 (1959); Johns v. S.H. 1983"Misconduct is an `act of wanton or willful disregard of the employer's interest, a deliberate violation of the employer's rules, a disregard of standards of behavior which the employer has the right to expect of his employee, an intentional and substantial disregard of the employer's interest or of the employee's duties and obligations to the employer.' See Wroble v. Bonners Ferry Ranger Station, 97 Idaho 900 , 556 P.2d 859 (1976); Watts v. Employment Security Agency, 80 Idaho 529 , 335 P.2d 533 (1959); Johns v. S.H.	2	5
Oliver v. Creamer Heating & Appliancegreen idaho · 1966 · cited in 3 Idaho opinions naming this issue, 1976–1984 2 sentences 1978“Misconduct” within the meaning of I.C. § 72-1366(e) must amount to “wilful, intentional disregard of the employer’s interests; a deliberate violation of the employer’s rules ; or a disregard of the standards of behavior which the employer has a right to expect of his employees.” (Emphasis added in Wroble.) Id. (quoting from Oliver v. Creamer Heating & Appliance Co., 91 Idaho 312, 317 , 420 P.2d 795, 800 (1966). 1978“Misconduct” within the meaning of I.C. § 72-1366(e) must amount to “wilful, intentional disregard of the employer’s interests; a deliberate violation of the employer’s rules ; or a disregard of the standards of behavior which the employer has a right to expect of his employees.” (Emphasis added in Wroble.) Id. (quoting from Oliver v. Creamer Heating & Appliance Co., 91 Idaho 312, 317 , 420 P.2d 795, 800 (1966).	2	3
Quinn v. J.R. Simplot Co.green idaho · 1998 · cited in 2 Idaho opinions naming this issue, 2009–2010 2 sentences 2010Simplot Co., 131 Idaho 318, 321 , 955 P.2d 1097, 1100 (1998)); IDAPA 09.01.30.275.02 (2010). 2010Simplot Co., 131 Idaho 318, 321 , 955 P.2d 1097, 1100 (1998)); IDAPA 09.01.30.275.02 (2010).	2	2
Campbell v. Bonneville County Board of Commissionersgreen idaho · 1994 · cited in 2 Idaho opinions naming this issue, 1995–2003 2 sentences 2003Campbell v. Bonneville County Brd. of Comm’rs, 126 Idaho 222, 225 , 880 P.2d 252, 255 (1994) (citing Puckett v. Idaho Department of Corrections, 107 Idaho 1022 , 695 P.2d 407 (1985)). 2003Campbell v. Bonneville County Brd. of Comm’rs, 126 Idaho 222, 225 , 880 P.2d 252, 255 (1994) (citing Puckett v. Idaho Department of Corrections, 107 Idaho 1022 , 695 P.2d 407 (1985)).	2	2
Laundry v. Franciscan Health Care Centergreen idaho · 1994 · cited in 2 Idaho opinions naming this issue, 1995–1998 2 sentences 1998Laundry v. Franciscan Health Care Center, 125 Idaho 279, 282 , 869 P.2d 1374, 1377 (1994) (citing Johns v. S.H. 1998Laundry v. Franciscan Health Care Center, 125 Idaho 279, 282 , 869 P.2d 1374, 1377 (1994) (citing Johns v. S.H.	2	2
Mandes v. Employment SEC. Agencygreen idaho · 1953 · cited in 5 Idaho opinions naming this issue, 1959–1991 2 sentences 1991Both lines of cases base their definition upon the following language which first appeared in Mandes v. Employment Security Agency, 74 Idaho 23, 25 , 255 P.2d 1049, 1050 (1953): Misconduct within the meaning of an unemployment compensation act excluding from its benefits an employee discharged for misconduct must be an act of wanton or wilful disregard of the employers interest, a deliberate violation of the employers rules, a disregard of standards of behavior which the employer has the right to expect of his employee, or negligence in such degree or recurrence as to manifest culpability, wro 1991Both lines of cases base their definition upon the following language which first appeared in Mandes v. Employment Security Agency, 74 Idaho 23, 25 , 255 P.2d 1049, 1050 (1953): Misconduct within the meaning of an unemployment compensation act excluding from its benefits an employee discharged for misconduct must be an act of wanton or wilful disregard of the employers interest, a deliberate violation of the employers rules, a disregard of standards of behavior which the employer has the right to expect of his employee, or negligence in such degree or recurrence as to manifest culpability, wro	1	5
Claim of Watts v. Employment Security Agencygreen idaho · 1959 · cited in 5 Idaho opinions naming this issue, 1961–1984 2 sentences 1983"Misconduct is an `act of wanton or willful disregard of the employer's interest, a deliberate violation of the employer's rules, a disregard of standards of behavior which the employer has the right to expect of his employee, an intentional and substantial disregard of the employer's interest or of the employee's duties and obligations to the employer.' See Wroble v. Bonners Ferry Ranger Station, 97 Idaho 900 , 556 P.2d 859 (1976); Watts v. Employment Security Agency, 80 Idaho 529 , 335 P.2d 533 (1959); Johns v. S.H. 1983"Misconduct is an `act of wanton or willful disregard of the employer's interest, a deliberate violation of the employer's rules, a disregard of standards of behavior which the employer has the right to expect of his employee, an intentional and substantial disregard of the employer's interest or of the employee's duties and obligations to the employer.' See Wroble v. Bonners Ferry Ranger Station, 97 Idaho 900 , 556 P.2d 859 (1976); Watts v. Employment Security Agency, 80 Idaho 529 , 335 P.2d 533 (1959); Johns v. S.H.	1	5
Roll v. City of Middletongreen idaho · 1983 · cited in 2 Idaho opinions naming this issue, 1991–1995 2 sentences 1995“Idaho case law discloses no requirement that there be a precipitating act of misconduct immediately prior to the termination of employment before a claimant may be denied unemployment benefits for employment-related misconduct.” Roll v. City of Middleton, 105 Idaho 22, 26 , 665 P.2d 721, 725 (1983). 1995“Idaho case law discloses no requirement that there be a precipitating act of misconduct immediately prior to the termination of employment before a claimant may be denied unemployment benefits for employment-related misconduct.” Roll v. City of Middleton, 105 Idaho 22, 26 , 665 P.2d 721, 725 (1983).	1	2
Chapman v. NYK LINE NORTH AMERICA, INC.green idaho · 2009 · cited in 1 Idaho opinions naming this issue, 2010–2010 2 sentences 2010Both the Idaho Administrative Code and this Court define misconduct as “(1) a willful, intentional disregard of the employer’s interest; (2) a deliberate violation of the employer’s rules; or (3) a disregard of standards of behavior which the employer has a right to expect of its employees.” Chapman v. NYK Line N.A., Inc., 147 Idaho 178, 182 , 207 P.3d 154, 158 (2009) (quoting Quinn v. J.R. 2010Both the Idaho Administrative Code and this Court define misconduct as “(1) a willful, intentional disregard of the employer’s interest; (2) a deliberate violation of the employer’s rules; or (3) a disregard of standards of behavior which the employer has a right to expect of its employees.” Chapman v. NYK Line N.A., Inc., 147 Idaho 178, 182 , 207 P.3d 154, 158 (2009) (quoting Quinn v. J.R.	1	1
Wulff v. Sun Valley Co.green idaho · 1995 · cited in 1 Idaho opinions naming this issue, 2010–2010 2 sentences 2010In order to prove misconduct under this test, the employer must demonstrate that the “employee acted deliberately, violating a known rule.” Wulff v. Sun Valley Co., 127 Idaho 71, 76 , 896 P.2d 979, 983 (1995). 2010In order to prove misconduct under this test, the employer must demonstrate that the “employee acted deliberately, violating a known rule.” Wulff v. Sun Valley Co., 127 Idaho 71, 76 , 896 P.2d 979, 983 (1995).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (13)

Case	Cited	Years
Jenkins v. Agri-Lines Corp. green idaho · 1979 2 sentences 1980Kress & Co., 78 Idaho 544 , 307 P.2d 217 (1957): "While the term `discharged for misconduct, as used in Sec. 72-1366(f), I.C. [now I.C. § 72-1366(e)] has been variously defined, we think the term should be interpreted as meaning willful, intentional disregard of the employer's interest; a deliberate violation of the employer's rules; or a disregard of standards of behavior which the employer has a right to expect of his employees. " 78 Idaho at 548 , 307 P.2d at 219 . (emphasis added) This definition was recently reaffirmed as the law in Idaho in Jenkins v. Agri-Lines Corp., 100 Idaho 549 , 60 1980Kress & Co., 78 Idaho 544 , 307 P.2d 217 (1957): "While the term `discharged for misconduct, as used in Sec. 72-1366(f), I.C. [now I.C. § 72-1366(e)] has been variously defined, we think the term should be interpreted as meaning willful, intentional disregard of the employer's interest; a deliberate violation of the employer's rules; or a disregard of standards of behavior which the employer has a right to expect of his employees. " 78 Idaho at 548 , 307 P.2d at 219 . (emphasis added) This definition was recently reaffirmed as the law in Idaho in Jenkins v. Agri-Lines Corp., 100 Idaho 549 , 60	4	1980–1991
Harris v. Electrical Wholesale green idaho · 2004 2 sentences 2006“Misconduct is defined as a willful, intentional disregard of the employer’s interests; a deliberate violation of the employer’s rules; or a disregard of the standards of behavior which the employer has a right to expect of its employees.” Harris, 141 Idaho at 3 , 105 P.3d at 269 . 2006“Misconduct is defined as a willful, intentional disregard of the employer’s interests; a deliberate violation of the employer’s rules; or a disregard of the standards of behavior which the employer has a right to expect of its employees.” Harris, 141 Idaho at 3 , 105 P.3d at 269 .	3	2006–2011
Adams v. Aspen Water, Inc. green idaho · 2011 2 sentences 2024“Misconduct is defined in three ways: (1) a willful, intentional disregard of the employer’s interest; (2) a deliberate violation of the employer’s reasonable rules; or (3) a disregard of a standard of behavior which the employer has a right to expect of its employees.” Id. (citing IDAPA 09.01.30.275.02.a– c). 2018Misconduct in connection with employment includes the following: "(1) a willful, intentional disregard of the employer's interest; or (2) a deliberate violation of the employer's reasonable rules; or (3) a disregard of a standard of behavior which the employer has a right to expect of his employees." Adams v. Aspen Water, Inc ., 150 Idaho 408 , 413, 247 P.3d 635 , 640 (2011) ; IDAPA 9.01.30.275.02.	2	2018–2024
Folks v. Moscow School District No. 281 green idaho · 1997 1 sentence 2002The statute relevant to unemployment benefits, I.C. § 72-1366(e), provides that an employee who has been discharged is eligible for unemployment benefits so long as his discharge was not for “misconduct in connection with his employment.” “Misconduct in connection with employment,” defined at IDAPA 09.01.30.275.01 (formerly IDAPA 09.01.30.331.01-03), is: “1) A willful, intentional disregard of the employer’s interest; 2) A deliberate violation of the employer’s reasonable rules; or 3) A disregard of the standards of behavior which the employer has a right to expect of his or her employees.” Fo	1	2002–2002
Goolsby v. Life Savers, Inc. green idaho · 1984 2 sentences 1991Kress & Co., 78 Idaho 544 , 307 P.2d 217 (1957); Puckett v. Idaho Dep’t of Corrections, 107 Idaho 1022 , 695 P.2d 407 (1985); Goolsby v. Life Savers, 107 Idaho 456 , 690 P.2d 911 (1984); Roll v. City of Middleton, 105 Idaho 22 , 665 P.2d 721 (1983); Matthews v. Bucyrus-Erie Co., 101 Idaho 657 , 619 P.2d 1110 (1980). 1991Kress & Co., 78 Idaho 544 , 307 P.2d 217 (1957); Puckett v. Idaho Dep’t of Corrections, 107 Idaho 1022 , 695 P.2d 407 (1985); Goolsby v. Life Savers, 107 Idaho 456 , 690 P.2d 911 (1984); Roll v. City of Middleton, 105 Idaho 22 , 665 P.2d 721 (1983); Matthews v. Bucyrus-Erie Co., 101 Idaho 657 , 619 P.2d 1110 (1980).	1	1991–1991
Spruell v. Allied Meadows Corp. green idaho · 1990 2 sentences 1991Misconduct has been defined in our prior cases to mean “willful, intentional disregard of the employer’s interest; a deliberate violation of the employer’s rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.” Jensen v. Siemsen, 118 Idaho 1 , 794 P.2d 271 (1990); Spruell v. Allied Meadows Corp., 117 Idaho 277 , 787 P.2d 263 (1990); Johns v. S.H. 1991Misconduct has been defined in our prior cases to mean “willful, intentional disregard of the employer’s interest; a deliberate violation of the employer’s rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.” Jensen v. Siemsen, 118 Idaho 1 , 794 P.2d 271 (1990); Spruell v. Allied Meadows Corp., 117 Idaho 277 , 787 P.2d 263 (1990); Johns v. S.H.	1	1991–1991
Jensen v. Siemsen green idaho · 1990 2 sentences 1991Misconduct has been defined in our prior cases to mean “willful, intentional disregard of the employer’s interest; a deliberate violation of the employer’s rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.” Jensen v. Siemsen, 118 Idaho 1 , 794 P.2d 271 (1990); Spruell v. Allied Meadows Corp., 117 Idaho 277 , 787 P.2d 263 (1990); Johns v. S.H. 1991Misconduct has been defined in our prior cases to mean “willful, intentional disregard of the employer’s interest; a deliberate violation of the employer’s rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.” Jensen v. Siemsen, 118 Idaho 1 , 794 P.2d 271 (1990); Spruell v. Allied Meadows Corp., 117 Idaho 277 , 787 P.2d 263 (1990); Johns v. S.H.	1	1991–1991
Parker v. St. Maries Plywood green idaho · 1980 2 sentences 1985Maries Plywood, 101 Idaho 415 , 614 P.2d 955 (1980); Ortiz v. Armour & Co., 100 Idaho 363 , 597 P.2d 606 (1979). 1985Maries Plywood, 101 Idaho 415 , 614 P.2d 955 (1980); Ortiz v. Armour & Co., 100 Idaho 363 , 597 P.2d 606 (1979).	1	1985–1985
Bullock v. Cit Co. Federal Credit Union neutral idaho · 1984 2 sentences 1985Kress & Co., 78 Idaho 544, 548 , 307 P.2d 217, 219 (1957), this Court interpreted the statutory phrase "discharged for misconduct" as follows: "While the term `discharged for misconduct' as used in Sec. 72-1366(f) [now (e)], I.C. has been variously defined, we think the term should be interpreted as meaning wilful, intentional disregard of the employer's interest; a deliberate violation of the employer's rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.'" Cited with approval in Cornwell v. Kootenai County Sheriff, 106 Idaho 823 , 683 P.2d 1985Kress & Co., 78 Idaho 544, 548 , 307 P.2d 217, 219 (1957), this Court interpreted the statutory phrase "discharged for misconduct" as follows: "While the term `discharged for misconduct' as used in Sec. 72-1366(f) [now (e)], I.C. has been variously defined, we think the term should be interpreted as meaning wilful, intentional disregard of the employer's interest; a deliberate violation of the employer's rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.'" Cited with approval in Cornwell v. Kootenai County Sheriff, 106 Idaho 823 , 683 P.2d	1	1985–1985
Cornwell v. Kootenai County Sheriff green idaho · 1984 2 sentences 1985Kress & Co., 78 Idaho 544, 548 , 307 P.2d 217, 219 (1957), this Court interpreted the statutory phrase "discharged for misconduct" as follows: "While the term `discharged for misconduct' as used in Sec. 72-1366(f) [now (e)], I.C. has been variously defined, we think the term should be interpreted as meaning wilful, intentional disregard of the employer's interest; a deliberate violation of the employer's rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.'" Cited with approval in Cornwell v. Kootenai County Sheriff, 106 Idaho 823 , 683 P.2d 1985Kress & Co., 78 Idaho 544, 548 , 307 P.2d 217, 219 (1957), this Court interpreted the statutory phrase "discharged for misconduct" as follows: "While the term `discharged for misconduct' as used in Sec. 72-1366(f) [now (e)], I.C. has been variously defined, we think the term should be interpreted as meaning wilful, intentional disregard of the employer's interest; a deliberate violation of the employer's rules; or a disregard of standards of behavior which the employer has a right to expect of his employees.'" Cited with approval in Cornwell v. Kootenai County Sheriff, 106 Idaho 823 , 683 P.2d	1	1985–1985
Ortiz v. Armour & Co. green idaho · 1979 2 sentences 1985Maries Plywood, 101 Idaho 415 , 614 P.2d 955 (1980); Ortiz v. Armour & Co., 100 Idaho 363 , 597 P.2d 606 (1979). 1985Maries Plywood, 101 Idaho 415 , 614 P.2d 955 (1980); Ortiz v. Armour & Co., 100 Idaho 363 , 597 P.2d 606 (1979).	1	1985–1985
Brown v. Iowa Beef Processors green idaho · 1984 2 sentences 1984That was appellant’s main argument, and as recently as the case of Brown v. Iowa Beef Processors, 107 Idaho 558 , 691 P.2d 1173 (1984), we have consistently held that the filing of a false application is grounds for discharge for cause. 1984That was appellant’s main argument, and as recently as the case of Brown v. Iowa Beef Processors, 107 Idaho 558 , 691 P.2d 1173 (1984), we have consistently held that the filing of a false application is grounds for discharge for cause.	1	1984–1984
Merkle v. Review Board of Indiana Employment Security Division green indctapp · 1950 2 sentences 1953Merkle v. Review Board of Indiana Employment Security Division, 120 Ind.App. 108 , 90 N.E. 2d 524 ; 146 A.L.R. 243 ; 58 C.J.S., Misconduct, page 817. 1953Merkle v. Review Board of Indiana Employment Security Division, 120 Ind.App. 108 , 90 N.E. 2d 524 ; 146 A.L.R. 243 ; 58 C.J.S., Misconduct, page 817.	1	1953–1953

Statutes the citing opinions construe

ID § Idaho Code § 72-1366 (42) ID § Idaho Code § 72-1368 (12) ID § Idaho Code § 72-1302 (7) ID § Idaho Code § 72-1301 (5) ID § Idaho Code § 72-732 (5)

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

PA 522 (1909–2026) LA 132 (1955–2015) MO 71 (1954–2025) ID 43 (1953–2024) AR 22 (1934–2008) FL 21 (1980–2015) IN 17 (1950–2014) IL 14 (1875–2021) VA 13 (1989–2018) CA 13 (1973–2020) DC 12 (1972–2015) NV 12 (1986–2016) MI 11 (1946–1978) NJ 11 (1965–2019) KS 11 (1989–2021) NC 10 (1973–2026) NM 8 (1980–2020) MD 7 (1958–2019) OR 7 (1947–1978) TX 6 (1981–2024) AZ 6 (1972–1996) IA 5 (1991–2019) NH 5 (2003–2011) OH 4 (2006–2024) CT 4 (1961–2008) MN 4 (1984–2015) MA 4 (1921–2020) MS 4 (2000–2016) AL 4 (1987–2015) MT 3 (1984–2013) SC 3 (1982–2012) UT 3 (1983–2023) WA 3 (1970–2004) CO 3 (1982–2019) NY 3 (1985–2018) WV 2 (1997–2003) VI 2 (1994–2001) KY 2 (1995–2009)

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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