party alleging error (Georgia) · Go Syfert
← Georgia issues

party alleging error in Georgia

259 Georgia opinions name it 2 courts 1950–2026 53 in the last five years

The cases below were cited by Georgia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (70)

CaseFollowedCited
Boles v. Leegreen
ga · 1999 · cited in 17 Georgia opinions naming this issue, 2001–2020
2 sentences

2020See generally Boles v. Lee, 270 Ga. 454, 455 (1) ( 511 SE2d 177 ) (1999) ( “A party alleging error carries the burden of showing it affirmatively by the record, and when that burden is not met, the judgment is assumed to be correct and will be affirmed.”).

2020See generally Boles v. Lee, 270 Ga. 454, 455 (1) ( 511 SE2d 177 ) (1999) ( “A party alleging error carries the burden of showing it affirmatively by the record, and when that burden is not met, the judgment is assumed to be correct and will be affirmed.”).

1517
Bennett v. Quickgreen
gactapp · 2010 · cited in 12 Georgia opinions naming this issue, 2013–2024
2 sentences

2024In addition, “[t]he burden is upon the party alleging error to show it affirmatively in the record,” and “[a]ppellate judges should not be expected to take pilgrimages into records in search of error without the compass of citation and argument.” Bennett, 305 Ga. App. at 416 (citations and punctuation omitted).

2023Of course, “[t]he burden is upon the party alleging error to show it affirmatively in the record.” Bennett v. Quick, 305 Ga. App. 415, 416 ( 699 SE2d 539 ) (2010) (punctuation omitted).

1212
Guilford v. Marriott International, Inc.green
gactapp · 2009 · cited in 10 Georgia opinions naming this issue, 2010–2025
2 sentences

2025The burden is upon the party alleging error to show it affirmatively in the record.” (Citation and punctuation omitted.) Guilford v. Marriott Intl., 296 Ga. App. 503, 504 ( 675 SE2d 247 ) (2009). “[I]f we have omitted any facts or failed to locate some evidence in the record, the responsibility rests with [the appellant].” (Citation and punctuation omitted.) Sadler v. Rigsby, 343 Ga. App. 269, 273 (2), n. 3 ( 808 SE2d 11 ) (2017). 3 an e-mail in which Spencer asked to copy the PSEAE curriculum and cited to part of the ORA, OCGA § 50-18-72.

2025The burden is upon the party alleging error to show it affirmatively in the record.” (Citation and punctuation omitted.) Guilford v. Marriott Intl., 296 Ga. App. 503, 504 ( 675 SE2d 247 ) (2009). “[I]f we have omitted any facts or failed to locate some evidence in the record, the responsibility rests with [the appellant].” (Citation and punctuation omitted.) Sadler v. Rigsby, 343 Ga. App. 269, 273 (2), n. 3 ( 808 SE2d 11 ) (2017). 3 an e-mail in which Spencer asked to copy the PSEAE curriculum and cited to part of the ORA, OCGA § 50-18-72.

910
Shepherd v. Shepherdgreen
ga · 1969 · cited in 10 Georgia opinions naming this issue, 1972–1990
2 sentences

1990“The burden is on the party alleging error to show it affirmatively by the record. [Cits.]” Shepherd v. Shepherd, 225 Ga. 455 (3) ( 169 SE2d 314 ) (1969).

1990“The burden is on the party alleging error to show it affirmatively by the record. [Cits.]” Shepherd v. Shepherd, 225 Ga. 455 (3) ( 169 SE2d 314 ) (1969).

910
Roberson v. Stategreen
ga · 2017 · cited in 8 Georgia opinions naming this issue, 2021–2026
2 sentences

2026See Roberson v. State, 300 Ga. 632, 636 (2017) (holding that “[i]t is well established that the burden is on the party alleging error to show it by the record” (cleaned up)). 3.

2025See Roberson v. State, 300 Ga. 632, 636 (III) ( 797 SE2d 104 ) (2017) (holding that “[i]t is well established that the burden is on the party alleging error to show it by the record”) (citation and punctuation omitted). 15 Finally, James does not point to any authority – and we have found none – supporting the proposition that the Sixth Amendment Confrontation Clause applies to a party’s own witness on direct- examination.

88
Campbell v. Powellgreen
ga · 1950 · cited in 10 Georgia opinions naming this issue, 1962–1997
2 sentences

1997“The burden is on the party alleging error to show it affirmatively by the record.” Campbell v. Powell, 206 Ga. 768, 770 ( 58 SE2d 829 ) (1950).

1997“The burden is on the party alleging error to show it affirmatively by the record.” Campbell v. Powell, 206 Ga. 768, 770 ( 58 SE2d 829 ) (1950).

610
Fleming v. Advanced Stores Co.green
gactapp · 2009 · cited in 7 Georgia opinions naming this issue, 2015–2025
2 sentences

2025See, e.g., Fine, 281 Ga. at 852 (2); Fleming v. Advanced Stores, 301 Ga. App. 734, 736 ( 688 SE2d 414 ) (2009) (“[T]he burden is on the party alleging error to show it affirmatively by the record.

2025See, e.g., Fine, 281 Ga. at 852 (2); Fleming v. Advanced Stores, 301 Ga. App. 734, 736 ( 688 SE2d 414 ) (2009) (“[T]he burden is on the party alleging error to show it affirmatively by the record.

67
Zellars v. Stategreen
gactapp · 2012 · cited in 4 Georgia opinions naming this issue, 2018–2026
2 sentences

2026“A party alleging error carries the burden of showing it affirmatively by the record, and when that burden is not met, the judgment is assumed to be correct and will be affirmed.” Zellars v. State, 314 Ga. App. 88, 89 (1) ( 723 SE2d 319 ) (2012) (quotation marks omitted).

2026“A party alleging error carries the burden of showing it affirmatively by the record, and when that burden is not met, the judgment is assumed to be correct and will be affirmed.” Zellars v. State, 314 Ga. App. 88, 89 (1) ( 723 SE2d 319 ) (2012) (quotation marks omitted).

44
Resource Life Insurance Co. v. Bucknergreen
gactapp · 2010 · cited in 4 Georgia opinions naming this issue, 2012–2014
2 sentences

2014Co. v. Buckner, 304 Ga. App. 719, 740 (7) ( 698 SE2d 19 ) (2010).

2014Co. v. Buckner, 304 Ga. App. 719, 740 (7) ( 698 SE2d 19 ) (2010).

44
Jackson v. Department of Transportationgreen
gactapp · 1991 · cited in 4 Georgia opinions naming this issue, 1993–1999
2 sentences

1999Brown v. Frachiseur, 247 Ga. 463 ( 277 SE2d 16 ); Jackson v. Dept. of Transp., 201 Ga. App. 863, 865 ( 412 SE2d 847 ); Transport Indem.

1999Brown v. Frachiseur, 247 Ga. 463 ( 277 SE2d 16 ); Jackson v. Dept. of Transp., 201 Ga. App. 863, 865 ( 412 SE2d 847 ); Transport Indem.

44
Fletcher v. Estesgreen
gactapp · 2004 · cited in 4 Georgia opinions naming this issue, 2010–2019
2 sentences

2019This [C]ourt cannot determine the propriety of the trial court's ruling without a proffer of the excluded evidence or testimony." (Citation and punctuation omitted.) Fletcher v. Estes , 268 Ga. App. 596 , 597 (1), 602 S.E.2d 164 (2004) ; see also Dent v. Candler Hospital, Inc ., 236 Ga. App. 540 , 541 (2), 512 S.E.2d 392 (1999).

2019This [C]ourt cannot determine the propriety of the trial court's ruling without a proffer of the excluded evidence or testimony." (Citation and punctuation omitted.) Fletcher v. Estes , 268 Ga. App. 596 , 597 (1), 602 S.E.2d 164 (2004) ; see also Dent v. Candler Hospital, Inc ., 236 Ga. App. 540 , 541 (2), 512 S.E.2d 392 (1999).

34
Moye v. Stategreen
gactapp · 1972 · cited in 4 Georgia opinions naming this issue, 1974–1993
2 sentences

1991“The burden is on the party alleging error to show it affirmatively by the record. [Cits.]” Moye v. State, 127 Ga. App. 338, 341 ( 193 SE2d 562 ) (1972); Rambo v. Fulton Financial Corp., 145 Ga. App. 791 ( 245 SE2d 12 ) (1978).

1991“The burden is on the party alleging error to show it affirmatively by the record. [Cits.]” Moye v. State, 127 Ga. App. 338, 341 ( 193 SE2d 562 ) (1972); Rambo v. Fulton Financial Corp., 145 Ga. App. 791 ( 245 SE2d 12 ) (1978).

34
Coffee v. Silvergreen
gactapp · 1990 · cited in 4 Georgia opinions naming this issue, 1990–1992
2 sentences

1991Appellant raises five enumerations of error, contending that the trial court erred in failing to consider the evidence that the county did not maintain the easement, in concluding that appellant’s pond incurred siltation as a result of the owner’s negligence, in concluding that there was no evidence of a continuing nuisance, in finding that the widow was not the owner of the property in 1974 and in barring *150 the action pursuant to the county notice requirement. “ ‘ “(T)he burden is on the party alleging error to show it affirmatively by the record, and . . . when the burden is not met, the

1991Appellant raises five enumerations of error, contending that the trial court erred in failing to consider the evidence that the county did not maintain the easement, in concluding that appellant’s pond incurred siltation as a result of the owner’s negligence, in concluding that there was no evidence of a continuing nuisance, in finding that the widow was not the owner of the property in 1974 and in barring *150 the action pursuant to the county notice requirement. “ ‘ “(T)he burden is on the party alleging error to show it affirmatively by the record, and . . . when the burden is not met, the

34
Suggs v. Stategreen
ga · 2021 · cited in 3 Georgia opinions naming this issue, 2022–2026
2 sentences

2026See Suggs v. State, 310 Ga. 762, 767 (2021) (“[T]he burden is on the party alleging error to show it by the record.” (quotation marks omitted)); Soto v. State, 303 Ga. 517, 523 (2018) (“[I]t is not this Court’s responsibility to cull the record in search of support for the appellant’s claims[.]”).

2023See Suggs v. State, 310 Ga. 762, 767 (5) (854 SE2d 674) (2021) (“It is well established that the burden is on the party alleging error to show it by the record.” (citation and punctuation omitted)).

33
Enchanted Valley RV Park Resort, Ltd. v. Weesegreen
gactapp · 1999 · cited in 3 Georgia opinions naming this issue, 2005–2025
2 sentences

2025To the extent that any omission has hampered our review to Ramey’s detriment, he “‘bore the burden of ensuring an accurate and complete record on appeal’ so that this Court could objectively and fully review the trial court’s ruling.” Gajaanan Inv., LLC v. Shahil & Sohail Corp. Inc., 323 Ga. App. 694, 698 (1) ( 747 SE2d 713 ) (2013) (quoting Griffin Builders, LLC v. Synovus Bank, 320 Ga. App. 307, 309 ( 739 SE2d 760 ) (2013)). “‘It is well established that the burden is on the party alleging error to show it by the record and that where the proof necessary for determination of the issues on ap

2025To the extent that any omission has hampered our review to Ramey’s detriment, he “‘bore the burden of ensuring an accurate and complete record on appeal’ so that this Court could objectively and fully review the trial court’s ruling.” Gajaanan Inv., LLC v. Shahil & Sohail Corp. Inc., 323 Ga. App. 694, 698 (1) ( 747 SE2d 713 ) (2013) (quoting Griffin Builders, LLC v. Synovus Bank, 320 Ga. App. 307, 309 ( 739 SE2d 760 ) (2013)). “‘It is well established that the burden is on the party alleging error to show it by the record and that where the proof necessary for determination of the issues on ap

33
Quarterman v. Leegreen
gactapp · 2008 · cited in 3 Georgia opinions naming this issue, 2019–2024
2 sentences

2024See Quarterman v. Lee, 291 Ga. App. 603, 603-604 ( 662 SE2d 234 ) (2008) (“The burden is on the party alleging error to show it affirmatively by the record.”) (citation and punctuation omitted). 2.

2024See Quarterman v. Lee, 291 Ga. App. 603, 603-604 ( 662 SE2d 234 ) (2008) (“The burden is on the party alleging error to show it affirmatively by the record.”) (citation and punctuation omitted). 2.

33
Wilson v. Mallard Creek Holdingsgreen
gactapp · 1999 · cited in 3 Georgia opinions naming this issue, 2010–2024
2 sentences

2024A23A1728 (Oct. 4, 2023), available at https://vimeo.com/871883408?share=copy. 2 Fleming v. Advanced Stores Co., 301 Ga. App. 734, 735 ( 688 SE2d 414 ) (2009) (punctuation omitted); see Wilson v. Mallard Creek Holdings, 238 Ga. App. 746, 747 ( 519 SE2d 925 ) (1999) ( “It is not the function of appellate judges to engage in the . . . search for support of alleged error without citation to relevant parts of the record.” (punctuation omitted)); CT.

2024A23A1728 (Oct. 4, 2023), available at https://vimeo.com/871883408?share=copy. 2 Fleming v. Advanced Stores Co., 301 Ga. App. 734, 735 ( 688 SE2d 414 ) (2009) (punctuation omitted); see Wilson v. Mallard Creek Holdings, 238 Ga. App. 746, 747 ( 519 SE2d 925 ) (1999) ( “It is not the function of appellate judges to engage in the . . . search for support of alleged error without citation to relevant parts of the record.” (punctuation omitted)); CT.

33
Henderson v. Stategreen
ga · 2018 · cited in 3 Georgia opinions naming this issue, 2021–2023
2 sentences

2023See Henderson v. State, 304 Ga. 733, 739 (4) (822 SE2d 228) (2018) (“It is not this Court’s job to cull the record on behalf of Appellant to find alleged errors, as appellate judges are not like pigs, hunting for truffles buried in briefs.” (citation and punctuation omitted)); Roberson v. State, 300 Ga. 632, 636 (III) (797 SE2d 104) (2017) (“It is well established that the burden is on the party alleging error to show it by the record[.]” (citation and punctuation omitted)). 11 evidence showed that crimes, which occurred over course of several days, arose from appellant’s “continuing course of

2023See Henderson v. State, 304 Ga. 733, 739 (4) (822 SE2d 228) (2018) (“It is not this Court’s job to cull the record on behalf of Appellant to find alleged errors, as appellate judges are not like pigs, hunting for truffles buried in briefs.” (citation and punctuation omitted)); Roberson v. State, 300 Ga. 632, 636 (III) (797 SE2d 104) (2017) (“It is well established that the burden is on the party alleging error to show it by the record[.]” (citation and punctuation omitted)). 11 evidence showed that crimes, which occurred over course of several days, arose from appellant’s “continuing course of

33
McClarity v. Stategreen
gactapp · 1998 · cited in 3 Georgia opinions naming this issue, 1999–2022
2 sentences

2022See McClarity v. State, 234 Ga. App. 348, 351 (3) ( 506 SE2d 392 ) (1998) (“The burden is on the party alleging error to show it affirmatively by the record[.]”) (citation and punctuation omitted).

2022See McClarity v. State, 234 Ga. App. 348, 351 (3) ( 506 SE2d 392 ) (1998) (“The burden is on the party alleging error to show it affirmatively by the record[.]”) (citation and punctuation omitted).

33
Stout v. Cincinnati Insurancegreen
gactapp · 1999 · cited in 3 Georgia opinions naming this issue, 2004–2019
2 sentences

2019This [C]ourt cannot determine the propriety of the trial court's ruling without a proffer of the excluded evidence or testimony." (Citation and punctuation omitted.) Fletcher v. Estes , 268 Ga. App. 596 , 597 (1), 602 S.E.2d 164 (2004) ; see also Dent v. Candler Hospital, Inc ., 236 Ga. App. 540 , 541 (2), 512 S.E.2d 392 (1999).

2004“The burden is on the party alleging error to show it affirmatively by the record.” (Citation and punctuation omitted.) Dent v. Candler Hosp., 236 Ga. App. 540, 541 (1) ( 512 SE2d 392 ) (1999).

33
Dent v. Candler Hospital, Inc.green
gactapp · 1999 · cited in 3 Georgia opinions naming this issue, 2004–2019
2 sentences

2019This [C]ourt cannot determine the propriety of the trial court's ruling without a proffer of the excluded evidence or testimony." (Citation and punctuation omitted.) Fletcher v. Estes , 268 Ga. App. 596 , 597 (1), 602 S.E.2d 164 (2004) ; see also Dent v. Candler Hospital, Inc ., 236 Ga. App. 540 , 541 (2), 512 S.E.2d 392 (1999).

2004“The burden is on the party alleging error to show it affirmatively by the record.” (Citation and punctuation omitted.) Dent v. Candler Hosp., 236 Ga. App. 540, 541 (1) ( 512 SE2d 392 ) (1999).

33
Adamson v. Sandersgreen
ga · 2005 · cited in 3 Georgia opinions naming this issue, 2005–2017
2 sentences

2017“It is well established that the burden is on the party alleging error to show it by the record and that where the proof necessary for determination of the issues on appeal is omitted from the record, an appellate court must assume that the judgment below was correct and affirm.” Adamson v. Sanders, 279 Ga. 187, 188 ( 611 SE2d 44 ) (2005) (citations and punctuation omitted).

2017“It is well established that the burden is on the party alleging error to show it by the record and that where the proof necessary for determination of the issues on appeal is omitted from the record, an appellate court must assume that the judgment below was correct and affirm.” Adamson v. Sanders, 279 Ga. 187, 188 ( 611 SE2d 44 ) (2005) (citations and punctuation omitted).

33
Hooks v. Humphriesgreen
gactapp · 2010 · cited in 3 Georgia opinions naming this issue, 2013–2016
33
Hayes v. Stategreen
gactapp · 1999 · cited in 3 Georgia opinions naming this issue, 2000–2004
33
Bergmann v. McCulloughgreen
gactapp · 1995 · cited in 3 Georgia opinions naming this issue, 2000–2002
33
Maloy v. Dixongreen
gactapp · 1972 · cited in 3 Georgia opinions naming this issue, 1974–1979
33
Bennett v. Executive Benefits, Inc.green
gactapp · 1993 · cited in 6 Georgia opinions naming this issue, 1998–2011
2 sentences

2011It is, of course, “well established that the burden is on the party alleging error to show it by the record.” Bennett v. Executive Benefits, Inc., 210 Ga. App. 429, 429 ( 436 SE2d 544 ) (1993) (citation omitted).

2011It is, of course, “well established that the burden is on the party alleging error to show it by the record.” Bennett v. Executive Benefits, Inc., 210 Ga. App. 429, 429 ( 436 SE2d 544 ) (1993) (citation omitted).

26
Tahamtan v. Sawnee Electric Membership Corp.green
gactapp · 1997 · cited in 4 Georgia opinions naming this issue, 2003–2025
2 sentences

2025Membership Corp., 228 Ga. App. 485 ( 491 SE2d 918 ) 1 The trial court entered a separate order reviving the dormant judgment. (1997) (“It is well established that the burden is on the party alleging error to show it affirmatively by the record.”) (citation omitted).

2025Membership Corp., 228 Ga. App. 485 ( 491 SE2d 918 ) 1 The trial court entered a separate order reviving the dormant judgment. (1997) (“It is well established that the burden is on the party alleging error to show it affirmatively by the record.”) (citation omitted).

24
Rice v. Bakergreen
gactapp · 2003 · cited in 4 Georgia opinions naming this issue, 2005–2006
2 sentences

2006See Rice v. Baker, 264 Ga. App. 704 ( 592 SE2d 186 ) (2003) (burden is on the party alleging error to show it affirmatively by the record and assertions of evidence in briefs or enumerations of error cannot satisfy this burden).

2006See Rice v. Baker, 264 Ga. App. 704 ( 592 SE2d 186 ) (2003) (burden is on the party alleging error to show it affirmatively by the record and assertions of evidence in briefs or enumerations of error cannot satisfy this burden).

24
Patterson v. Stategreen
gactapp · 2014 · cited in 3 Georgia opinions naming this issue, 2018–2025
2 sentences

2018It is not the function of this Court to "cull the record on behalf of a party in search of instances of error[,] [and] [t]he burden is upon the party alleging error to show it affirmatively in the record." Patterson v. State , 327 Ga. App. 695 , 696 (1), 761 S.E.2d 101 (2014) (punctuation omitted).

2018It is not the function of this Court to "cull the record on behalf of a party in search of instances of error[,] [and] [t]he burden is upon the party alleging error to show it affirmatively in the record." Patterson v. State , 327 Ga. App. 695 , 696 (1), 761 S.E.2d 101 (2014) (punctuation omitted).

23
Cawthon v. Stategreen
gactapp · 2019 · cited in 3 Georgia opinions naming this issue, 2020–2024
2 sentences

2024Instead, the burden is upon the party alleging error to show it affirmatively in the record.” (Punctuation and footnote omitted.) Cawthon v. State, 350 Ga. App. 741, 743 ( 830 SE2d 270 ) (2019).

2024Instead, the burden is upon the party alleging error to show it affirmatively in the record.” (Punctuation and footnote omitted.) Cawthon v. State, 350 Ga. App. 741, 743 ( 830 SE2d 270 ) (2019).

23
Sycamore Pellet Systems, Inc. v. Southeastern Steam, Inc.green
gactapp · 1990 · cited in 3 Georgia opinions naming this issue, 1991–1999
23
Foreman v. Stategreen
gactapp · 1991 · cited in 3 Georgia opinions naming this issue, 1994–1999
23
In Re Hollygreen
gactapp · 1988 · cited in 3 Georgia opinions naming this issue, 1989–1990
23
Fortson v. Browngreen
gactapp · 2010 · cited in 2 Georgia opinions naming this issue, 2016–2026
22
Sadler v. Rigsbygreen
gactapp · 2017 · cited in 2 Georgia opinions naming this issue, 2021–2025
22
Wheeling-Culligan v. Allengreen
gactapp · 2000 · cited in 2 Georgia opinions naming this issue, 2004–2025
22
Farmer v. Georgia Department of Corrections.green
gactapp · 2018 · cited in 2 Georgia opinions naming this issue, 2019–2024
22
Simmons v. Simmonsgreen
ga · 2011 · cited in 2 Georgia opinions naming this issue, 2020–2021
22
Mashburn Construction, L.P. v. CharterBankgreen
gactapp · 2017 · cited in 2 Georgia opinions naming this issue, 2019–2019
22

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
Griner v. State green
gactapp · 1989
2 sentences

2000Griner v. State, 192 Ga. App. 283 ( 384 SE2d 398 ) (1990).

2000Griner v. State, 192 Ga. App. 283 ( 384 SE2d 398 ) (1990).

51990–2000
Moulton v. Wood green
gactapp · 2004
2 sentences

2024“It is well established that the burden is on the party alleging error to show it affirmatively by the record and where the proof necessary for determination of the issues on appeal is omitted from the record, an appellate court must assume that the judgment below was correct and affirm.” (Citation and punctuation omitted.) Moulton v. Wood, 265 Ga. App. 389 ( 593 SE2d 911 ) (2004).

2024“It is well established that the burden is on the party alleging error to show it affirmatively by the record and where the proof necessary for determination of the issues on appeal is omitted from the record, an appellate court must assume that the judgment below was correct and affirm.” (Citation and punctuation omitted.) Moulton v. Wood, 265 Ga. App. 389 ( 593 SE2d 911 ) (2004).

32007–2024
Gillespie v. Gillespie green
ga · 1990
31991–1998
Helms v. Franklin Builders, Inc. green
gactapp · 2010
22010–2015
White v. Arthur Enterprises, Inc. green
gactapp · 1995
21996–2003
Wilson v. Walker neutral
gactapp · 1976
21983–1999
Smith v. Forrester green
gactapp · 1974
21985–1988
Baldwin v. Grimes neutral
ga · 1963
21972–1986
Tift County v. Smith green
ga · 1963
21972–1986
Richmond Hosiery Mills v. Hayes neutral
ga · 1916
21950–1969

Statutes the citing opinions construe

GA § 9-11-56 (27) GA § 5-6-41 (14) GA § 9-15-14 (14) GA § 5-6-37 (13) GA § 24-4-403 (10) GA § 16-5-21 (9) GA § 5-6-34 (9)

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

GA 259 (1950–2026) ID 34 (2004–2026) LA 26 (1984–2015) KS 26 (1952–2026) MN 21 (1889–2017) NY 19 (1852–2024) SD 19 (1896–2010) WI 16 (1962–2026) OH 16 (1999–2026) MO 15 (1894–2023) MI 15 (1899–2025) IL 14 (1902–2026) TX 13 (1891–2024) AL 13 (1893–2007) ND 12 (1904–2001) CA 11 (1867–2019) NC 10 (1876–2013) MT 10 (1907–2011) WA 8 (2014–2025) IN 7 (1979–2012) MD 7 (2011–2023) WY 7 (1996–2020) NJ 6 (1955–2026) NE 6 (1892–2026) TN 5 (1993–2002) ME 5 (1997–2008) RI 5 (1996–2023) UT 4 (1989–2005) NM 4 (1913–1966) IA 4 (1943–2023) VT 4 (1981–2010) AK 4 (1991–2023) AR 4 (1982–1989) OK 3 (1911–2011) CO 3 (1926–2017) KY 2 (1995–2019) HI 2 (1980–1999) PA 2 (1983–1984) MS 2 (2004–2005) MA 2 (2014–2016)

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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