43 Washington opinions name it 2 courts 2000–2025 7 in the last five years
The cases below were cited by Washington 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.
| Case | Followed | Cited |
|---|---|---|
New Hampshire v. Mainegreen2 sentences2025Three core factors guide a trial court’s determination of whether to apply the judicial estoppel doctrine: (1) whether “a party’s later position” is “clearly inconsistent with its earlier position”; (2) whether “judicial acceptance of an inconsistent position in a later proceeding would create the perception that either the first or the second court was misled”; and (3) “whether the party seeking to assert an inconsistent position would derive an unfair advantage or impose an unfair detriment on the opposing party if not estopped.” Arkison, 160 Wn.2d at 538-39 (internal quotation marks omitted 2024In Arkison, our Supreme Court set forth the following three factors to “guide a trial court’s determination of whether to apply the judicial estoppel doctrine”: (1) whether “a party’s later position” is “clearly inconsistent with its earlier position”; (2) whether “judicial acceptance of an inconsistent position in a later proceeding would create ‘the perception that either the first or the second court was misled’”; and (3) “whether the party seeking to assert an inconsistent position would derive an unfair advantage or impose an unfair detriment on the opposing party if not estopped.” 160 Wn | 4 | 15 |
Arkison v. Ethan Allen, Inc.green2 sentences2025We disagree. 20 No. 59466-8-II The equitable doctrine of judicial estoppel “‘precludes a party from asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.’” Anfinson v. FedEx Ground Package Sys., Inc., 174 Wn.2d 851, 861 , 281 P.3d 289 (2012) (internal quotation marks omitted) (quoting Arkison v. Ethan Allen, Inc., 160 Wn.2d 535, 538 , 160 P.3d 13 (2007)). 2025Three core factors guide a trial court’s determination of whether to apply the judicial estoppel doctrine: (1) whether “a party’s later position” is “clearly inconsistent with its earlier position”; (2) whether “judicial acceptance of an inconsistent position in a later proceeding would create the perception that either the first or the second court was misled”; and (3) “whether the party seeking to assert an inconsistent position would derive an unfair advantage or impose an unfair detriment on the opposing party if not estopped.” Arkison, 160 Wn.2d at 538-39 (internal quotation marks omitted | 2 | 15 |
Lawrence Hamilton v. State Farm Fire & Casualty Company, an Illinois Corporation David's Restaurant Supplygreen2 sentences2007Co., 270 F.3d 778, 785 (9th Cir.2001) (emphasis omitted) (quoting In re Coastal Plains, 179 F.3d 197, 208 (5th Cir.1999)). ¶ 8 So a debtor's failure to disclose a personal injury claim in a bankruptcy proceeding generally precludes a later lawsuit on the same claim under the doctrine of judicial estoppel. 2007Co., 270 F.3d 778, 785 (9th Cir. 2001) (emphasis omitted) (quoting In re Coastal Plains, 179 F.3d 197, 208 (5th Cir. 1999)). ¶8 So a debtor’s failure to disclose a personal injury claim in a bankruptcy proceeding generally precludes a later lawsuit on the same claim under the doctrine of judicial estoppel. | 2 | 4 |
United States v. George C. Hookgreen2 sentences2023Ed. 2d 968 (2001) (quoting United States v. Hook, 17 No. 84660-4-I/18 195 F.3d 299, 306 (7th Cir. 1999); Edwards v. Aetna Life Ins. 2007Ed. 2d 968 (2001) (quoting United States v. Hook, 195 F.3d 299, 306 (7th Cir. 1999) and Edwards v. Aetna Life Ins. | 2 | 2 |
Skinner v. Holgategreen2 sentences2008The judicial estoppel doctrine “protect[s] the integrity of the judicial process by prohibiting parties from deliberately changing positions according to the exigencies of the moment.” Skinner, 141 Wn. 2008App. at 849 . [Although not exclusive, t]hree core factors guide a trial court’s determination of whether to apply the judicial estoppel doctrine: (1) whether “a party’s later position” is “clearly inconsistent with its earlier position”; (2) whether “judicial acceptance of an inconsistent position in a later proceeding would create the perception that either the first or the second court was misled”; and (3) “whether the party seeking to assert an inconsistent position would derive an unfair advantage or impose an unfair detriment on the opposing party if not estopped.” Arkison, 160 Wn.2d at | 2 | 2 |
Browning Manufacturing v. Mims (In Re Coastal Plains, Inc.)green2 sentences2007Co., 270 F.3d 778, 785 (9th Cir.2001) (emphasis omitted) (quoting In re Coastal Plains, 179 F.3d 197, 208 (5th Cir.1999)). ¶ 8 So a debtor's failure to disclose a personal injury claim in a bankruptcy proceeding generally precludes a later lawsuit on the same claim under the doctrine of judicial estoppel. 2007Co., 270 F.3d 778, 785 (9th Cir. 2001) (emphasis omitted) (quoting In re Coastal Plains, 179 F.3d 197, 208 (5th Cir. 1999)). ¶8 So a debtor’s failure to disclose a personal injury claim in a bankruptcy proceeding generally precludes a later lawsuit on the same claim under the doctrine of judicial estoppel. | 2 | 2 |
Markley v. Markleygreen2 sentences2005See, e.g., Markley v. Markley, 31 Wn.2d 605, 614-15 , 198 P.2d 486 (1948); Johnson v. Si-Cor, Inc., 107 Wn. 2005See, e.g., Markley v. Markley, 31 Wn.2d 605, 614-15 , 198 P.2d 486 (1948); Johnson v. Si-Cor, Inc., 107 Wn. | 2 | 2 |
cluster 507099green2 sentences2000Oneida Motor Freight, Inc. v. United Jersey Bank, 848 F.2d 414, 419 (3d Cir.) (“Oneida’s failure to list its claim against the bank worked in opposition to preservation of the integrity of the system which the doctrine of judicial estoppel seeks to protect”), cert. denied, 488 U.S. 967 (1988); Payless Wholesale Distribs., Inc. v. Alberto Culver, Inc., 989 F.2d 570, 571 (1st Cir. 1993) (“Payless, having obtained judicial relief on the representation that no claims existed, can not now .. . obtain relief on the opposite basis [;] . .. [this] is an unacceptable abuse of judicial proceedings”); Lu 2000Oneida Motor Freight, Inc. v. United Jersey Bank, 848 F.2d 414, 419 (3d Cir.) (“Oneida’s failure to list its claim against the bank worked in opposition to preservation of the integrity of the system which the doctrine of judicial estoppel seeks to protect”), cert. denied, 488 U.S. 967 (1988); Payless Wholesale Distribs., Inc. v. Alberto Culver, Inc., 989 F.2d 570, 571 (1st Cir. 1993) (“Payless, having obtained judicial relief on the representation that no claims existed, can not now .. . obtain relief on the opposite basis [;] . .. [this] is an unacceptable abuse of judicial proceedings”); Lu | 2 | 2 |
Luna v. Dominion Bankgreen2 sentences2000Oneida Motor Freight, Inc. v. United Jersey Bank, 848 F.2d 414, 419 (3d Cir.) (“Oneida’s failure to list its claim against the bank worked in opposition to preservation of the integrity of the system which the doctrine of judicial estoppel seeks to protect”), cert. denied, 488 U.S. 967 (1988); Payless Wholesale Distribs., Inc. v. Alberto Culver, Inc., 989 F.2d 570, 571 (1st Cir. 1993) (“Payless, having obtained judicial relief on the representation that no claims existed, can not now .. . obtain relief on the opposite basis [;] . .. [this] is an unacceptable abuse of judicial proceedings”); Lu 2000L.Rev. at 805. [10] Oneida Motor Freight, Inc. v. United Jersey Bank, 848 F.2d 414, 419 (3rd Cir.) ("Oneida's failure to list its claim against the bank worked in opposition to preservation of the integrity of the system which the doctrine of judicial estoppel seeks to protect"), cert. denied, 488 U.S. 967 , 109 S.Ct. 495 , 102 L.Ed.2d 532 (1988); Payless Wholesale Distribs., Inc. v. Alberto Culver, Inc., 989 F.2d 570, 571 (1st Cir.1993) ("Payless, having obtained judicial relief on the representation that no claims existed, can not now ... obtain relief on the opposite basis[;] ... [this] is | 2 | 2 |
1993-1 Trade Cases P 70,178, Bankr. L. Rep. P 75,211 Payless Wholesale Distributors, Inc. v. Alberto Culver (p.r.) Inc.green2 sentences2000Oneida Motor Freight, Inc. v. United Jersey Bank, 848 F.2d 414, 419 (3d Cir.) (“Oneida’s failure to list its claim against the bank worked in opposition to preservation of the integrity of the system which the doctrine of judicial estoppel seeks to protect”), cert. denied, 488 U.S. 967 (1988); Payless Wholesale Distribs., Inc. v. Alberto Culver, Inc., 989 F.2d 570, 571 (1st Cir. 1993) (“Payless, having obtained judicial relief on the representation that no claims existed, can not now .. . obtain relief on the opposite basis [;] . .. [this] is an unacceptable abuse of judicial proceedings”); Lu 2000L.Rev. at 805. [10] Oneida Motor Freight, Inc. v. United Jersey Bank, 848 F.2d 414, 419 (3rd Cir.) ("Oneida's failure to list its claim against the bank worked in opposition to preservation of the integrity of the system which the doctrine of judicial estoppel seeks to protect"), cert. denied, 488 U.S. 967 , 109 S.Ct. 495 , 102 L.Ed.2d 532 (1988); Payless Wholesale Distribs., Inc. v. Alberto Culver, Inc., 989 F.2d 570, 571 (1st Cir.1993) ("Payless, having obtained judicial relief on the representation that no claims existed, can not now ... obtain relief on the opposite basis[;] ... [this] is | 2 | 2 |
Sprague v. Sysco Corp.green2 sentences2000See also Sprague v. Sysco Corp., 97 Wn. 2000See also Sprague v. Sysco Corp., 97 Wash.App. 169 , 180 n. 4, 982 P.2d 1202 (1999) (noting but declining to apply judicial estoppel), review denied, 140 Wash.2d 1004 , 999 P.2d 1262 (2000). [11] Oneida, 848 F.2d at 417 ("The result of a failure to disclose such claims triggers application of the doctrine of equitable estoppel, operating against a subsequent attempt to prosecute the actions."); Heritage Hotel, 160 B.R. at 379 ("We hold that the failure to disclose any potential lender liability claims ... during the pendency of the bankruptcy case equitably estops [the debtor] from subsequently | 2 | 2 |
Taylor v. Bellgreen2 sentences2018Taylor, 185 Wn. 2015See, e^, Tavlor v. Bell. 185 Wn. | 1 | 2 |
Michaelson v. Employment Security Departmentgreen1 sentence2021Robbins v. Department of Labor & Industries, 187 Wn. | 1 | 1 |
Skinner v. Holgategreen2 sentences2008Alternatively, Judicial Estoppel Should Apply ¶ 37 Notwithstanding that the majority's holding creates a result incompatible with legislative intent, thereby dictating that the trial court's ruling be affirmed, I would alternatively invoke the doctrine of judicial estoppel, an equitable doctrine that we may invoke at our discretion, to prevent Hapner from "`asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.'" Arkison v. Ethan Allen, Inc., 160 Wash.2d 535, 538 , 160 P.3d 13 (2007) (quoting Bartley-Williams v. Kendall, 134 Wash. 2008Alternatively, Judicial Estoppel Should Apply ¶ 37 Notwithstanding that the majority's holding creates a result incompatible with legislative intent, thereby dictating that the trial court's ruling be affirmed, I would alternatively invoke the doctrine of judicial estoppel, an equitable doctrine that we may invoke at our discretion, to prevent Hapner from "`asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.'" Arkison v. Ethan Allen, Inc., 160 Wash.2d 535, 538 , 160 P.3d 13 (2007) (quoting Bartley-Williams v. Kendall, 134 Wash. | 1 | 1 |
William Edwards v. Aetna Life Insurance Companygreen1 sentence2007Co., 690 F.2d 595, 599 (6th Cir.1982)). | 1 | 1 |
| Conrad v. Bank of Americagreen | 1 | 1 |
| Billmeyer v. Plaza Bank of Commercegreen | 1 | 1 |
| Heritage Hotel Ltd. Partnership I v. Valley Bank of Nevada (In Re Heritage Hotel Partnership I)green | 1 | 1 |
| Wright v. Stategreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Arkison v. Ethan Allen, Inc.
green
2 sentences2025We disagree. 20 No. 59466-8-II The equitable doctrine of judicial estoppel “‘precludes a party from asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.’” Anfinson v. FedEx Ground Package Sys., Inc., 174 Wn.2d 851, 861 , 281 P.3d 289 (2012) (internal quotation marks omitted) (quoting Arkison v. Ethan Allen, Inc., 160 Wn.2d 535, 538 , 160 P.3d 13 (2007)). 2017Under the doctrine of judicial estoppel, we generally "'precluded a party from asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.'" Miller v. Campbell, 164 Wn.2d 529, 539 , 192 P.3d 352 (2008)(quoting Arkison v. Ethan Allen, Inc., 160 Wn.2d 535, 538 , 160 P.3d 13 (2007)). | 7 | 2007–2025 |
Miller v. Campbell
green
2 sentences2017Under the doctrine of judicial estoppel, we generally "'precluded a party from asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.'" Miller v. Campbell, 164 Wn.2d 529, 539 , 192 P.3d 352 (2008)(quoting Arkison v. Ethan Allen, Inc., 160 Wn.2d 535, 538 , 160 P.3d 13 (2007)). 2011A court focuses on three core factors when deciding whether to apply the doctrine of judicial estoppel: “(1) whether a party’s later position is clearly inconsistent with its earlier position; (2) whether judicial acceptance of an inconsistent position in a later proceeding would create the perception that either the first or the second court was misled; and (3) whether the party seeking to assert an inconsistent position would derive an unfair advantage or impose an unfair detriment on the opposing party if not estopped.” Miller v. Campbell, 164 Wn.2d 529, 539 , 192 P.3d 352 (2008) (quoting A | 6 | 2009–2017 |
Johnson v. Si-Cor, Inc.
green
2 sentences2013The law firm also argues that this court's denial of discretionary review in the previous proceedings demonstrates that Smith, Guarino, and Yarmuth 36 107 Wn. 2007Johnson, 107 Wn. | 5 | 2005–2013 |
Miller v. Campbell
green
2 sentences2017Under the doctrine of judicial estoppel, we generally "'precluded a party from asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.'" Miller v. Campbell, 164 Wn.2d 529, 539 , 192 P.3d 352 (2008)(quoting Arkison v. Ethan Allen, Inc., 160 Wn.2d 535, 538 , 160 P.3d 13 (2007)). 2011A court focuses on three core factors when deciding whether to apply the doctrine of judicial estoppel: “(1) whether a party’s later position is clearly inconsistent with its earlier position; (2) whether judicial acceptance of an inconsistent position in a later proceeding would create the perception that either the first or the second court was misled; and (3) whether the party seeking to assert an inconsistent position would derive an unfair advantage or impose an unfair detriment on the opposing party if not estopped.” Miller v. Campbell, 164 Wn.2d 529, 539 , 192 P.3d 352 (2008) (quoting A | 4 | 2011–2017 |
Bartley-Williams v. Kendall
green
2 sentences2008Alternatively, Judicial Estoppel Should Apply ¶37 Notwithstanding that the majority’s holding creates a result incompatible with legislative intent, thereby dictating that the trial court’s ruling be affirmed, I would alternatively invoke the doctrine of judicial estoppel, an equitable doctrine that we may invoke at our discretion, to prevent Hapner from “ ‘asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.’ ” Arkison v. Ethan Allen, Inc., 160 Wn.2d 535, 538 , 160 P.3d 13 (2007) (quoting BartleyWilliams v. Kendall, 134 Wn. 2008Alternatively, Judicial Estoppel Should Apply ¶ 37 Notwithstanding that the majority's holding creates a result incompatible with legislative intent, thereby dictating that the trial court's ruling be affirmed, I would alternatively invoke the doctrine of judicial estoppel, an equitable doctrine that we may invoke at our discretion, to prevent Hapner from "`asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.'" Arkison v. Ethan Allen, Inc., 160 Wash.2d 535, 538 , 160 P.3d 13 (2007) (quoting Bartley-Williams v. Kendall, 134 Wash. | 4 | 2007–2014 |
Bartley-Williams v. Kendall
green
2 sentences2012Id. “[A] trial court’s determination of whether to apply the judicial estoppel doctrine” is guided by three core factors: (1) whether the party’s later position is “ ‘clearly inconsistent with its earlier position,’ ” (2) whether acceptance of the later inconsistent position “ ‘would create the perception that either the first or the second court was misled,’ ” and (3) whether the assertion of the inconsistent position would create an unfair advantage for the asserting party or an unfair detriment to the opposing party. 2008Alternatively, Judicial Estoppel Should Apply ¶ 37 Notwithstanding that the majority's holding creates a result incompatible with legislative intent, thereby dictating that the trial court's ruling be affirmed, I would alternatively invoke the doctrine of judicial estoppel, an equitable doctrine that we may invoke at our discretion, to prevent Hapner from "`asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.'" Arkison v. Ethan Allen, Inc., 160 Wash.2d 535, 538 , 160 P.3d 13 (2007) (quoting Bartley-Williams v. Kendall, 134 Wash. | 4 | 2007–2012 |
Anfinson v. FedEx Ground Package System, Inc.
green
2 sentences2025We disagree. 20 No. 59466-8-II The equitable doctrine of judicial estoppel “‘precludes a party from asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.’” Anfinson v. FedEx Ground Package Sys., Inc., 174 Wn.2d 851, 861 , 281 P.3d 289 (2012) (internal quotation marks omitted) (quoting Arkison v. Ethan Allen, Inc., 160 Wn.2d 535, 538 , 160 P.3d 13 (2007)). 2025We disagree. 20 No. 59466-8-II The equitable doctrine of judicial estoppel “‘precludes a party from asserting one position in a court proceeding and later seeking an advantage by taking a clearly inconsistent position.’” Anfinson v. FedEx Ground Package Sys., Inc., 174 Wn.2d 851, 861 , 281 P.3d 289 (2012) (internal quotation marks omitted) (quoting Arkison v. Ethan Allen, Inc., 160 Wn.2d 535, 538 , 160 P.3d 13 (2007)). | 2 | 2024–2025 |
Cunningham v. Reliable Concrete Pumping, Inc.
green
2 sentences2018In Cunningham, Cunningham filed a bankruptcy petition without disclosing his personal injury claim against his former employer. 126 Wn. 2007Cunningham, 126 Wash.App. at 230 , 108 P.3d 147 . ¶ 24 Skinner relies heavily on New Hampshire in his argument that the trial court erroneously applied the doctrine of judicial estoppel. | 2 | 2007–2018 |
City of Spokane v. Marr
green
2 sentences2014City of Spokane v. Marr, 129 Wn. 2014City ofSpokane v. Marr, 129 Wn. | 2 | 2014–2014 |
Hangman Ridge Training Stables, Inc. v. Safeco Title Insurance
green
2 sentences2008Co., 105 Wn.2d 778, 793 , 719 P.2d 531 (1986). ¶16 The equitable doctrine of judicial estoppel does not apply here. 2008Co., 105 Wn.2d 778, 793 , 719 P.2d 531 (1986). ¶16 The equitable doctrine of judicial estoppel does not apply here. | 2 | 2008–2008 |
Johnson v. Si-Cor Inc.
green
2 sentences2007Johnson, 107 Wash.App. at 906 , 28 P.3d 832 ; Boyers, supra, at 1248. 2005See, e.g., Markley v. Markley, 31 Wash.2d 605, 614-15 , 198 P.2d 486 (1948); Johnson v. Si-Cor, Inc., 107 Wash.App. 902, 906 , 28 P.3d 832 (2001). ¶ 13 Nonexclusive factors promote court discretion in applying judicial estoppel: "(1) The inconsistent position first asserted must have been successfully maintained; (2) a judgment must have been rendered; (3) the positions must be clearly inconsistent; (4) the parties and questions must be the same; (5) the party claiming estoppel must have been misled and have changed his position; (6) it must appear unjust to one party to permit the other to ch | 2 | 2005–2007 |
Barbizon Corp. v. ILGWU National Retirement Fund
green
2 sentences2000Oneida Motor Freight, Inc. v. United Jersey Bank, 848 F.2d 414, 419 (3d Cir.) (“Oneida’s failure to list its claim against the bank worked in opposition to preservation of the integrity of the system which the doctrine of judicial estoppel seeks to protect”), cert. denied, 488 U.S. 967 (1988); Payless Wholesale Distribs., Inc. v. Alberto Culver, Inc., 989 F.2d 570, 571 (1st Cir. 1993) (“Payless, having obtained judicial relief on the representation that no claims existed, can not now .. . obtain relief on the opposite basis [;] . .. [this] is an unacceptable abuse of judicial proceedings”); Lu 2000L.Rev. at 805. [10] Oneida Motor Freight, Inc. v. United Jersey Bank, 848 F.2d 414, 419 (3rd Cir.) ("Oneida's failure to list its claim against the bank worked in opposition to preservation of the integrity of the system which the doctrine of judicial estoppel seeks to protect"), cert. denied, 488 U.S. 967 , 109 S.Ct. 495 , 102 L.Ed.2d 532 (1988); Payless Wholesale Distribs., Inc. v. Alberto Culver, Inc., 989 F.2d 570, 571 (1st Cir.1993) ("Payless, having obtained judicial relief on the representation that no claims existed, can not now ... obtain relief on the opposite basis[;] ... [this] is | 2 | 2000–2000 |
Davis v. Microsoft Corp.
green
1 sentence2025Three factors guide a court’s determination of whether to apply the doctrine of judicial estoppel: (1) whether the party’s later position is “clearly inconsistent with its earlier position[;]” (2) whether acceptance of the “inconsistent position in a later 3 “‘The term “qualified individual with a disability” means an individual with a disability who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.’” Davis, 149 Wn.2d at 533 n.5 (quoting 42 U.S.C. § 12111 (8)). 9 No. 40060-3-III Bogardus v. City of Y | 1 | 2025–2025 |
Cunningham v. Reliable Concrete Pumping, Inc.
green
1 sentence2007Cunningham, 126 Wash.App. at 230 , 108 P.3d 147 . ¶ 24 Skinner relies heavily on New Hampshire in his argument that the trial court erroneously applied the doctrine of judicial estoppel. | 1 | 2007–2007 |
| Garrett v. Morgan green | 1 | 2007–2007 |
Garrett v. Morgan
green
1 sentence2007Garrett v. Morgan, 127 Wash.App. 375, 379 , 112 P.3d 531 (2005) (overruled in Arkison only on grounds that judicial estoppel cannot be applied to bankruptcy trustees); see also New Hampshire v. Maine, 532 U.S. 742 , 121 S.Ct. 1808 , 149 L.Ed.2d 968 (2001) (judicial estoppel may be inappropriate when a party's prior position was based on inadvertence or mistake). ¶ 22 Although not an exhaustive formula, a trial court generally considers three factors when deciding to apply the doctrine of judicial estoppel: (1) whether the party's later position is clearly inconsistent with its earlier position | 1 | 2007–2007 |
| Raymond v. Ingram green | 1 | 2005–2005 |
| Falkner v. Foshaug green | 1 | 2005–2005 |
| Falkner v. Foshaug green | 1 | 2005–2005 |
| Hay v. First Interstate Bank of Kalispell green | 1 | 2000–2000 |
| Oneida Motor Freight, Inc. v. United Jersey green | 1 | 2000–2000 |
| Phillips v. Totco green | 1 | 2000–2000 |
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.
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.