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for the reasons that follow, we approve the first district in the instant case and disapprove the decisions of the fourth district.
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we disapprove cooper and craven to the extent that they may be read to conflict.
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to the extent that this dictum is inconsistent with our holding here, we expressly overrule it.
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876 f.3d at 1306.
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the analysis below is included to satisfy our own, independent obligation to ensure that we have jurisdiction.
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my colleagues argue that their imposition of sua sponte estoppel avoids ""unnecessary judicial waste.""
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