employer may rebut presumption (North Carolina) · Go Syfert
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employer may rebut presumption in North Carolina

29 North Carolina opinions name it 3 courts 1996–2022 2 in the last five years

The cases below were cited by North Carolina 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 (12)

CaseFollowedCited
Perez v. American Airlines/AMR Corp.green
ncctapp · 2005 · cited in 10 North Carolina opinions naming this issue, 2010–2022
2 sentences

2017"The employer may rebut the presumption with evidence that the medical treatment is not directly related to the compensable injury." Perez , 174 N.C.App. at 135 , 620 S.E.2d at 292 .

2017"The employer may rebut the presumption with evidence that the medical treatment is not directly related to the compensable injury." Perez , 174 N.C.App. at 135 , 620 S.E.2d at 292 .

110
Franklin v. Broyhill Furniture Industriesgreen
ncctapp · 1996 · cited in 10 North Carolina opinions naming this issue, 1996–2011
2 sentences

2011Regarding Plaintiff's attempts to return to work and her disability subsequent to the admittedly compensable injury, an employer may rebut the presumption of continuing *Page 9 disability through evidence "that suitable jobs are available to the employee and that the employee is capable of getting one, taking into account the employee's physical and vocational limitations." Franklin v. Broyhill Furniture Industries , 123 N.C.

2011Regarding Plaintiff's attempts to return to work and her disability subsequent to the admittedly compensable injury, an employer may rebut the presumption of continuing disability through evidence "that suitable jobs are available to the employee and that the employee is capable of getting one, taking into account the employee's physical and vocational limitations." Franklin v. Broyhill Furniture Industries , 123 N.C.

110
Stamey v. N.C. Self-Insurance Guaranty Ass'ngreen
ncctapp · 1998 · cited in 2 North Carolina opinions naming this issue, 2001–2002
2 sentences

2001App. 662, 665 , 507 S.E.2d 596, 599 (1998) (“The employer may rebut the presumption of continuing disability ‘through medical and other evidence,’ including evidence ‘that suitable jobs are available to the employee ....’”) Id. (citation omitted).

2001App. 662, 665 , 507 S.E.2d 596, 599 (1998) (“The employer may rebut the presumption of continuing disability ‘through medical and other evidence,’ including evidence ‘that suitable jobs are available to the employee ....’”) Id. (citation omitted).

12
Parsons v. Pantry, Inc.green
ncctapp · 1997 · cited in 1 North Carolina opinions naming this issue, 2017–2017
2 sentences

2017Airlines/AMR Corp. , 174 N.C.App. 128 , 135, 620 S.E.2d 288 , 292 (2005) (citations omitted) (citing Parsons , 126 N.C.App. at 542 , 485 S.E.2d at 869 ); see also id. at 136 n.1, 620 S.E.2d at 293 n.1 ("We can conceive of a situation where an employee seeks medical compensation for symptoms completely unrelated to the compensable injury.

2017Airlines/AMR Corp. , 174 N.C.App. 128 , 135, 620 S.E.2d 288 , 292 (2005) (citations omitted) (citing Parsons , 126 N.C.App. at 542 , 485 S.E.2d at 869 ); see also id. at 136 n.1, 620 S.E.2d at 293 n.1 ("We can conceive of a situation where an employee seeks medical compensation for symptoms completely unrelated to the compensable injury.

11
Miller v. Mission Hospital, Inc.green
ncctapp · 2014 · cited in 1 North Carolina opinions naming this issue, 2015–2015
1 sentence

2015See Miller v. Mission Hosp., Inc., --- N.C.App. ----, ----, 760 S.E.2d 31 , 35 (2014) ("The employer may rebut the presumption with evidence that the medical treatment is not directly related to the compensable injury.

11
Frazier v. Coopergreen
nc · 2002 · cited in 1 North Carolina opinions naming this issue, 2005–2005
2 sentences

2005App. 913, 918 , 563 S.E.2d 235, 239 (stating an employer may rebut the presumption of ongoing disability “by showing that suitable jobs are available, taking into consideration the employee’s physical and vocational limitations, and taking into consideration whether the employee is capable of obtaining a suitable job”), disc. review denied, 356 N.C. 299 , 570 S.E.2d 505 (2002).

2005See Foster v. U.S. Airways, Inc., 149 N.C.App. 913, 918 , 563 S.E.2d 235, 239 (stating an employer may rebut the presumption of ongoing disability "by showing that suitable jobs are available, taking into consideration the employee's physical and vocational limitations, and taking into consideration whether the employee is capable of obtaining a suitable job"), disc. review denied, 356 N.C. 299 , 570 S.E.2d 505 (2002).

11
Futrell v. Resinall Corp.green
nc · 2002 · cited in 1 North Carolina opinions naming this issue, 2005–2005
2 sentences

2005App. 913, 918 , 563 S.E.2d 235, 239 (stating an employer may rebut the presumption of ongoing disability “by showing that suitable jobs are available, taking into consideration the employee’s physical and vocational limitations, and taking into consideration whether the employee is capable of obtaining a suitable job”), disc. review denied, 356 N.C. 299 , 570 S.E.2d 505 (2002).

2005See Foster v. U.S. Airways, Inc., 149 N.C.App. 913, 918 , 563 S.E.2d 235, 239 (stating an employer may rebut the presumption of ongoing disability "by showing that suitable jobs are available, taking into consideration the employee's physical and vocational limitations, and taking into consideration whether the employee is capable of obtaining a suitable job"), disc. review denied, 356 N.C. 299 , 570 S.E.2d 505 (2002).

11
Foster v. U.S. Airways, Inc.green
ncctapp · 2002 · cited in 1 North Carolina opinions naming this issue, 2005–2005
2 sentences

2005See Foster v. U.S. Airways, Inc., 149 N.C.App. 913, 918 , 563 S.E.2d 235, 239 (stating an employer may rebut the presumption of ongoing disability "by showing that suitable jobs are available, taking into consideration the employee's physical and vocational limitations, and taking into consideration whether the employee is capable of obtaining a suitable job"), disc. review denied, 356 N.C. 299 , 570 S.E.2d 505 (2002).

2005See Foster v. U.S. Airways, Inc., 149 N.C.App. 913, 918 , 563 S.E.2d 235, 239 (stating an employer may rebut the presumption of ongoing disability "by showing that suitable jobs are available, taking into consideration the employee's physical and vocational limitations, and taking into consideration whether the employee is capable of obtaining a suitable job"), disc. review denied, 356 N.C. 299 , 570 S.E.2d 505 (2002).

11
Saums v. Raleigh Community Hospitalgreen
nc · 1997 · cited in 1 North Carolina opinions naming this issue, 2002–2002
2 sentences

2002Saums v. Raleigh Community Hospital, 346 N.C. 760, 763-64 , 487 S.E.2d 746, 750 (1997).

2002Saums v. Raleigh Community Hospital, 346 N.C. 760, 763-64 , 487 S.E.2d 746, 750 (1997).

11
Kennedy v. Duke University Medical Centergreen
ncctapp · 1990 · cited in 1 North Carolina opinions naming this issue, 2001–2001
2 sentences

2001Alternatively, the employer can "come forward with evidence to show not only that suitable jobs are available, but also that the plaintiff is capable of getting one, taking into account both physical and vocational limitations." Kennedy v. Duke Univ.Med.Center, 101 N.C.App. 24, 33 , 398 S.E.2d 677, 682 (1990).

2001Alternatively, the employer can "come forward with evidence to show not only that suitable jobs are available, but also that the plaintiff is capable of getting one, taking into account both physical and vocational limitations." Kennedy v. Duke Univ.Med.Center, 101 N.C.App. 24, 33 , 398 S.E.2d 677, 682 (1990).

11
In Re Stone v. G G Buildersgreen
nc · 1997 · cited in 1 North Carolina opinions naming this issue, 1998–1998
2 sentences

1998The employer may rebut the presumption of continuing disability “through medical and other evidence,” In re Stone v. G & G Builders, 346 N.C. 154, 157 , 484 S.E.2d 365, 368 (1997); Harrington v. Adams-Robinson Enterprises, 349 N.C. 218 , 504 S.E.2d 786 (1998) (per curiam), including evidence “that suitable jobs are available to the employee and ‘that the [employee] is capable of *666 getting one,’ taking into account the employee’s ‘age, education, physical limitations, vocational skills, and experience,’ ” Smith, 127 N.C.

1998The employer may rebut the presumption of continuing disability “through medical and other evidence,” In re Stone v. G & G Builders, 346 N.C. 154, 157 , 484 S.E.2d 365, 368 (1997); Harrington v. Adams-Robinson Enterprises, 349 N.C. 218 , 504 S.E.2d 786 (1998) (per curiam), including evidence “that suitable jobs are available to the employee and ‘that the [employee] is capable of *666 getting one,’ taking into account the employee’s ‘age, education, physical limitations, vocational skills, and experience,’ ” Smith, 127 N.C.

11
Radica v. Carolina Millsgreen
ncctapp · 1994 · cited in 1 North Carolina opinions naming this issue, 1996–1996
2 sentences

1996Radica v. Carolina Mills, 113 N.C.App. 440, 447 , 439 S.E.2d 185, 190 (1994).

1996Radica v. Carolina Mills, 113 N.C.App. 440, 447 , 439 S.E.2d 185, 190 (1994).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
Reinninger v. Prestige Fabricators, Inc. green
ncctapp · 1999
2 sentences

2016"The employer may rebut the presumption with evidence that the medical treatment is not directly related to the compensable injury." Id. at 135, 620 S.E.2d at 292 (citing Reinninger v. Prestige Fabricators, Inc. , 136 N.C.App. 255 , 259, 523 S.E.2d 720 , 723 (1999) ).

2016"The employer may rebut the presumption with evidence that the medical treatment is not directly related to the compensable injury." Id. at 135, 620 S.E.2d at 292 (citing Reinninger v. Prestige Fabricators, Inc. , 136 N.C.App. 255 , 259, 523 S.E.2d 720 , 723 (1999) ).

42005–2016
Dorsey v. UNC-WILMINGTON green
nc · 1996
2 sentences

2011App. 200 , 206 , cert. denied , 344 N.C. 629 (1996). "[M]ere proof of a return to work is insufficient to rebut the . . . presumption," because "capacity to earn is the benchmark test of disability." Kisiah v. W.R.

2011App. 200 , 206 , cert. denied , 344 N.C. 629 (1996). "[M]ere proof of a return to work is insufficient to rebut the . . . presumption," because "capacity to earn is the benchmark test of disability." Kisiah v. W.R.

42007–2011
Franklin v. Broyhill Furniture Industries green
nc · 1996
2 sentences

2008App. 200 , 206 , 472 S.E.2d 382 , 386 , cert. denied , 344 N.C. 629 , 477 S.E.2d 39 (1996). "[M]ere proof of a return to work is insufficient to rebut the . . . presumption," because "capacity to earn is the benchmark test of disability." Kisiah v. W.R.

2007App. 200 , 206 , 472 S.E.2d 382 , 386 , cert. denied , 344 N.C. 629 , 477 S.E.2d 39 (1996). "[M]ere proof of a return to work is insufficient to rebut the . . . presumption," because "capacity to earn is the benchmark test of disability." Kisiah v. W.R.

22007–2008
Fletcher v. Dana Corp. neutral
nc · 1995
1 sentence

1999Id.

11999–1999
In Re Harrington v. Adams-Robinson Enterprises green
nc · 1998
2 sentences

1998The employer may rebut the presumption of continuing disability “through medical and other evidence,” In re Stone v. G & G Builders, 346 N.C. 154, 157 , 484 S.E.2d 365, 368 (1997); Harrington v. Adams-Robinson Enterprises, 349 N.C. 218 , 504 S.E.2d 786 (1998) (per curiam), including evidence “that suitable jobs are available to the employee and ‘that the [employee] is capable of *666 getting one,’ taking into account the employee’s ‘age, education, physical limitations, vocational skills, and experience,’ ” Smith, 127 N.C.

1998The employer may rebut the presumption of continuing disability “through medical and other evidence,” In re Stone v. G & G Builders, 346 N.C. 154, 157 , 484 S.E.2d 365, 368 (1997); Harrington v. Adams-Robinson Enterprises, 349 N.C. 218 , 504 S.E.2d 786 (1998) (per curiam), including evidence “that suitable jobs are available to the employee and ‘that the [employee] is capable of *666 getting one,’ taking into account the employee’s ‘age, education, physical limitations, vocational skills, and experience,’ ” Smith, 127 N.C.

11998–1998
Smith v. Sealed Air Corp. green
ncctapp · 1997
2 sentences

1998The employer may rebut the presumption of continuing disability “through medical and other evidence,” In re Stone v. G & G Builders, 346 N.C. 154, 157 , 484 S.E.2d 365, 368 (1997); Harrington v. Adams-Robinson Enterprises, 349 N.C. 218 , 504 S.E.2d 786 (1998) (per curiam), including evidence “that suitable jobs are available to the employee and ‘that the [employee] is capable of *666 getting one,’ taking into account the employee’s ‘age, education, physical limitations, vocational skills, and experience,’ ” Smith, 127 N.C.

1998App. at 361 , 489 S.E.2d at 447 (quoting Franklin v. Broyhill Furniture Industries, 123 N.C.

11998–1998

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 97-2 (14) NC § N.C. Gen. Stat. § 97-25 (8) NC § N.C. Gen. Stat. § 97-29 (7) NC § N.C. Gen. Stat. § 97-18 (6) NC § N.C. Gen. Stat. § 97-31 (5) NC § N.C. Gen. Stat. § 97-82 (5) NC § N.C. Gen. Stat. § 97-25.1 (4) NC § N.C. Gen. Stat. § 97-30 (4) NC § N.C. Gen. Stat. § 97-86 (4) NC § N.C. Gen. Stat. § 97-32 (3) NC § N.C. Gen. Stat. § 97-88.1 (3)

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

NC 29 (1996–2022) IL 7 (2003–2023) MA 6 (1995–2026) AK 6 (1992–2022) PA 6 (2004–2024) CA 5 (1985–2025) TX 5 (1995–2024) DC 4 (1997–2021) MI 3 (2021–2026) WA 3 (2014–2015) NY 3 (2009–2016) ME 2 (1992–2001) VA 2 (1999–2001)

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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