harshness rule (North Dakota) · Go Syfert
← North Dakota issues

harshness rule in North Dakota

5 North Dakota opinions name it 1 courts 1974–2012 0 in the last five years

The cases below were cited by North Dakota 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 (4)

CaseFollowedCited
Runcorn v. Shearer Lumber Products, Inc.green
idaho · 1984 · cited in 2 North Dakota opinions naming this issue, 2012–2012
2 sentences

2012Other courts have recognized that “[m]ueh of the harshness of the rule has been eliminated with the advent of comparative negligence in which slight contributory negligence does not act as a complete bar to recovery,” Runcorn v. Shearer Lumber Prods., Inc., 107 Idaho 389 , 690 P.2d 324, 329 (1984), and that “[m]ost of the criticism targeted at the ‘derivative liability principle’ originated prior to the advent of the comparative negligence doctrine.” Mist v. Westin Hotels, Inc., 69 Haw. 192 , 738 P.2d 85, 90 (1987) (footnote omitted).

2012Other courts have recognized that “[m]ueh of the harshness of the rule has been eliminated with the advent of comparative negligence in which slight contributory negligence does not act as a complete bar to recovery,” Runcorn v. Shearer Lumber Prods., Inc., 107 Idaho 389 , 690 P.2d 324, 329 (1984), and that “[m]ost of the criticism targeted at the ‘derivative liability principle’ originated prior to the advent of the comparative negligence doctrine.” Mist v. Westin Hotels, Inc., 69 Haw. 192 , 738 P.2d 85, 90 (1987) (footnote omitted).

22
Schobinger v. Iveygreen
nd · 1991 · cited in 2 North Dakota opinions naming this issue, 2012–2012
2 sentences

2012The Mist court noted that criticism by some commentators in their earlier works “has been apparently significantly retracted in their later works.” Id. at 90 n. 6; cf. Schobinger v. Ivey, 467 N.W.2d 728, 730 (N.D.1991) (reexamining imputation of negligence after adoption of comparative negligence “due to the fact that we no longer have the harsh result that would occur under the prior contributory negligence law”).

2012The Mist court noted that criticism by some commentators in their earlier works “has been apparently significantly retracted in their later works.” Id. at 90 n.6; cf. Schobinger v. Ivey , 467 N.W.2d 728, 730 (N.D. 1991) (re-examining imputation of negligence after adoption of comparative negligence “due to the fact that we no longer have the harsh result that would occur under the prior contributory negligence law”).

22
Mist v. Westin Hotels, Inc.green
haw · 1987 · cited in 2 North Dakota opinions naming this issue, 2012–2012
2 sentences

2012Other courts have recognized that “[m]ueh of the harshness of the rule has been eliminated with the advent of comparative negligence in which slight contributory negligence does not act as a complete bar to recovery,” Runcorn v. Shearer Lumber Prods., Inc., 107 Idaho 389 , 690 P.2d 324, 329 (1984), and that “[m]ost of the criticism targeted at the ‘derivative liability principle’ originated prior to the advent of the comparative negligence doctrine.” Mist v. Westin Hotels, Inc., 69 Haw. 192 , 738 P.2d 85, 90 (1987) (footnote omitted).

2012Other courts have recognized that “[m]ueh of the harshness of the rule has been eliminated with the advent of comparative negligence in which slight contributory negligence does not act as a complete bar to recovery,” Runcorn v. Shearer Lumber Prods., Inc., 107 Idaho 389 , 690 P.2d 324, 329 (1984), and that “[m]ost of the criticism targeted at the ‘derivative liability principle’ originated prior to the advent of the comparative negligence doctrine.” Mist v. Westin Hotels, Inc., 69 Haw. 192 , 738 P.2d 85, 90 (1987) (footnote omitted).

22
Hillesland v. Federal Land Bank Ass'n of Grand Forksgreen
nd · 1987 · cited in 1 North Dakota opinions naming this issue, 1994–1994
1 sentence

1994See Hillesland, supra. In Hillesland , we declined to follow those states which have recognized a bad-faith exception to the at-will doctrine.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
Thompson v. St. Regis Paper Company green
wash · 1984
2 sentences

1987Regis Paper Co., supra, 685 P.2d at 1086 -1087: “A number of courts have utilized a contract theory as a means of ameliorating the harshness of the rule.

1987Regis Paper Co., supra, 685 P.2d at 1086 -1087: "A number of courts have utilized a contract theory as a means of ameliorating the harshness of the rule.

11987–1987
Spanel v. Mounds View School District No. 621 green
minn · 1962
2 sentences

1974However, we do not share the view that a court-made rule, however unjust or outmoded, becomes with age invulnerable to judicial attack and cannot be discarded except by legislative action.” Spanel v. Mounds View School District No. 621, 264 Minn. 279 , 118 N.W.2d 795, 803 . 13 .

1974However, we do not share the view that a court-made rule, however unjust or outmoded, becomes with age invulnerable to judicial attack and cannot be discarded except by legislative action.” Spanel v. Mounds View School District No. 621, 264 Minn. 279 , 118 N.W.2d 795, 803 . 13 .

11974–1974

Where else courts name it

CA 32 (1927–2021) NY 27 (1891–2018) TX 17 (1940–2023) IL 15 (1964–2023) TN 15 (1965–2016) WA 13 (1936–2007) PA 8 (1940–2005) MI 8 (1938–2020) OH 8 (1992–2017) NJ 7 (1954–2022) MS 6 (1992–2001) KS 6 (1967–2005) MO 6 (1958–2006) AR 6 (1937–2006) NC 6 (1925–2021) MD 6 (1915–2005) FL 5 (1968–2021) MN 5 (1953–2016) ND 5 (1974–2012) GA 5 (1983–2018) KY 4 (1936–2024) DC 4 (1987–1996) UT 4 (1940–2006) LA 4 (1970–1994) CT 4 (1927–1999) IN 4 (1979–1995) RI 3 (1975–2010) AZ 3 (1963–1995) WI 3 (1961–2012) IA 3 (1964–2000) AL 3 (1931–2008) MA 3 (1970–2000) WV 2 (1977–1992) NM 2 (1990–1994) NV 2 (1910–1949) SD 2 (1928–1976)

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.

← Caselaw search · G Cite Topics · Brief Check