clear and convincing standard (North Carolina) · Go Syfert
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clear and convincing standard in North Carolina

28 North Carolina opinions name it 3 courts 1987–2026 10 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 (14)

CaseFollowedCited
Scarborough v. Dillard's, Inc.green
nc · 2009 · cited in 9 North Carolina opinions naming this issue, 2016–2026
2 sentences

2026“The clear and convincing standard requires evidence that “’should fully convince.’” Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (2009) (citation omitted).

2026“The clear and convincing standard requires evidence that “’should fully convince.’” Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (2009) (citation omitted).

79
Williams v. Blue Ridge Building & Loan Ass'ngreen
nc · 1934 · cited in 6 North Carolina opinions naming this issue, 2009–2024
2 sentences

2020Cooper v. Mitchell Bros.’ Santa Ana Theater, 454 U.S. 90, 93 (1981) (per curiam) (footnote omitted) (“Three standards of proof are generally recognized, ranging from the ‘preponderance of the evidence’ standard employed in most civil cases, to the ‘clear and convincing’ standard reserved to protect particularly important interests in a limited number of civil cases, to the requirement that guilt be proved ‘beyond a reasonable doubt’ in a criminal prosecution.” (citing Addington v. Texas, 441 U.S. 418 , 423–44 (1979))); Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (20

2020Cooper v. Mitchell Bros.’ Santa Ana Theater, 454 U.S. 90, 93 (1981) (per curiam) (footnote omitted) (“Three standards of proof are generally recognized, ranging from the ‘preponderance of the evidence’ standard employed in most civil cases, to the ‘clear and convincing’ standard reserved to protect particularly important interests in a limited number of civil cases, to the requirement that guilt be proved ‘beyond a reasonable doubt’ in a criminal prosecution.” (citing Addington v. Texas, 441 U.S. 418 , 423–44 (1979))); Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (20

46
In Re the Will of McCauleygreen
nc · 2002 · cited in 4 North Carolina opinions naming this issue, 2009–2024
2 sentences

2024“The clear and convincing standard requires evidence that ‘should fully convince.’” Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (2009) (quoting In re Will of McCauley, 356 N.C. 91, 101 , 565 S.E.2d 88, 95 (2002)).

2024“The clear and convincing standard requires evidence that ‘should fully convince.’” Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (2009) (quoting In re Will of McCauley, 356 N.C. 91, 101 , 565 S.E.2d 88, 95 (2002)).

44
Bennett v. Hawksgreen
ncctapp · 2005 · cited in 4 North Carolina opinions naming this issue, 2006–2026
2 sentences

2019"Absent an indication that the trial court applied the clear and convincing standard in this case, we reverse the order of the trial court and remand this case for findings of fact consistent therewith." Bennett , 170 N.C.

2019App. at 429 , 613 S.E.2d at 42 ; see also David N. , 359 N.C. at 307 , 608 S.E.2d at 754 (reversing and remanding for finding consistent *420 with the clear and convincing standard, where the trial court "failed to apply the clear and convincing evidence standard as set forth in Adams in making th[e] determination" that the defendant's conduct was inconsistent with a natural parent's constitutionally protected interest).

24
In Re AKgreen
ncctapp · 2006 · cited in 4 North Carolina opinions naming this issue, 2007–2008
2 sentences

2008The Court carefully limited its holding in reversing the adjudication of neglect: "Consequently, where the trial court did not accept any formal evidence in addition to its consideration of the prior court orders concerning C.A.K., and the only order concerning C.A.K. that contained findings by the clear and convincing standard of proof was from a hearing occurring many months earlier, the trial court could not, on this record, conclude that `the minor child would be at substantial risk of neglect if placed in the custody of the . . . parents at this time.'" Id. at 732 , 637 S.E.2d at 230 (emp

2008The Court carefully limited its holding in reversing the adjudication of neglect: "Consequently, where the trial court did not accept any formal evidence in addition to its consideration of the prior court orders concerning C.A.K., and the only order concerning C.A.K. that contained findings by the clear and convincing standard of proof was from a hearing occurring many months earlier, the trial court could not, on this record, conclude that `the minor child would be at substantial risk of neglect if placed in the custody of the . . . parents at this time.'" Id. at 732 , 637 S.E.2d at 230 (emp

24
California Ex Rel. Cooper v. Mitchell Brothers' Santa Ana Theatergreen
scotus · 1982 · cited in 2 North Carolina opinions naming this issue, 2020–2020
2 sentences

2020Cooper v. Mitchell Bros.’ Santa Ana Theater, 454 U.S. 90, 93 (1981) (per curiam) (footnote omitted) (“Three standards of proof are generally recognized, ranging from the ‘preponderance of the evidence’ standard employed in most civil cases, to the ‘clear and convincing’ standard reserved to protect particularly important interests in a limited number of civil cases, to the requirement that guilt be proved ‘beyond a reasonable doubt’ in a criminal prosecution.” (citing Addington v. Texas, 441 U.S. 418 , 423–44 (1979))); Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (20

2020Cooper v. Mitchell Bros.’ Santa Ana Theater, 454 U.S. 90, 93 (1981) (per curiam) (footnote omitted) (“Three standards of proof are generally recognized, ranging from the ‘preponderance of the evidence’ standard employed in most civil cases, to the ‘clear and convincing’ standard reserved to protect particularly important interests in a limited number of civil cases, to the requirement that guilt be proved ‘beyond a reasonable doubt’ in a criminal prosecution.” (citing Addington v. Texas, 441 U.S. 418 , 423–44 (1979))); Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (20

22
Adams v. Tessenergreen
nc · 2001 · cited in 2 North Carolina opinions naming this issue, 2006–2026
2 sentences

2026Adams v. Tessener, 354 N.C. 57, 63 (2001) (determining whether a parent has acted inconsistent with her constitutionally protected status must be reviewed under a clear, cogent, and convincing standard); Bennett v. Hawks, 170 N.C.

2006See, e.g., Petersen v. Rogers, 337 N.C. 397 , 445 S.E.2d 901 (1994) 3 ; David N. v. Jason N., 359 N.C. 303 , 608 S.E.2d 751 (2005); Adams v. Tessener, 354 N.C. 57 , 550 S.E.2d 499 (2001); Bennett v. Hawks, 170 N.C.

12
David N. v. Jason N.green
nc · 2005 · cited in 2 North Carolina opinions naming this issue, 2006–2019
2 sentences

2019App. at 429 , 613 S.E.2d at 42 ; see also David N. , 359 N.C. at 307 , 608 S.E.2d at 754 (reversing and remanding for finding consistent *420 with the clear and convincing standard, where the trial court "failed to apply the clear and convincing evidence standard as set forth in Adams in making th[e] determination" that the defendant's conduct was inconsistent with a natural parent's constitutionally protected interest).

2019App. at 429 , 613 S.E.2d at 42 ; see also David N. , 359 N.C. at 307 , 608 S.E.2d at 754 (reversing and remanding for finding consistent *420 with the clear and convincing standard, where the trial court "failed to apply the clear and convincing evidence standard as set forth in Adams in making th[e] determination" that the defendant's conduct was inconsistent with a natural parent's constitutionally protected interest).

12
Schenk v. HNA Holdings, Inc.green
ncctapp · 2005 · cited in 2 North Carolina opinions naming this issue, 2005–2008
2 sentences

2008Id. at 560-61 , 613 S.E.2d at 507-08 .

2005The clear and convincing standard is greater than the general preponderance of the evidence standard—it requires evidence “which should ‘fully convince.’” Schenk v. HNA Holdings, Inc., 613 S.E.2d 503, 508 (2005) (quoting In re Smith, 146 N.C.

12
United States v. Bushgreen
ca4 · 2009 · cited in 1 North Carolina opinions naming this issue, 2025–2025
1 sentence

2025United States v. Bush, 585 F.3d 806, 814 (4th Cir. 2009) (collecting cases as to the clear and convincing standard for Sell hearings).

11
Scarborough v. Dillard's, Inc.green
ncctapp · 2006 · cited in 1 North Carolina opinions naming this issue, 2008–2008
2 sentences

2008NOTES [1] Scarborough v. Dillard's, Inc., 179 N.C.App. 127, 132 , 632 S.E.2d 800, 803 (2006); N.C.

2008NOTES [1] Scarborough v. Dillard's, Inc., 179 N.C.App. 127, 132 , 632 S.E.2d 800, 803 (2006); N.C.

11
Petersen v. Rogersgreen
nc · 1994 · cited in 1 North Carolina opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., Petersen v. Rogers, 337 N.C. 397 , 445 S.E.2d 901 (1994) 3 ; David N. v. Jason N., 359 N.C. 303 , 608 S.E.2d 751 (2005); Adams v. Tessener, 354 N.C. 57 , 550 S.E.2d 499 (2001); Bennett v. Hawks, 170 N.C.

2006See, e.g., Petersen v. Rogers, 337 N.C. 397 , 445 S.E.2d 901 (1994) 3 ; David N. v. Jason N., 359 N.C. 303 , 608 S.E.2d 751 (2005); Adams v. Tessener, 354 N.C. 57 , 550 S.E.2d 499 (2001); Bennett v. Hawks, 170 N.C.

11
Price v. Howardgreen
nc · 1997 · cited in 1 North Carolina opinions naming this issue, 2005–2005
2 sentences

2005Because the trial court’s order is unclear about the standard of proof, we reverse and remand the trial court’s order. “[N]atural parents have a constitutionally protected interest in the companionship, custody, care, and control of their children.” Price v. Howard, 346 N.C. 68, 72 , 484 S.E.2d 528, 530 (1997).

2005Because the trial court’s order is unclear about the standard of proof, we reverse and remand the trial court’s order. “[N]atural parents have a constitutionally protected interest in the companionship, custody, care, and control of their children.” Price v. Howard, 346 N.C. 68, 72 , 484 S.E.2d 528, 530 (1997).

11
In Re Smithgreen
ncctapp · 2001 · cited in 1 North Carolina opinions naming this issue, 2005–2005
2 sentences

2005The clear and convincing standard is greater than the general preponderance of the evidence standard—it requires evidence “which should ‘fully convince.’” Schenk v. HNA Holdings, Inc., 613 S.E.2d 503, 508 (2005) (quoting In re Smith, 146 N.C.

2005App. 302, 204 , 552 S.E.2d 184, 184 (2001)). {79} Here, the jury found that the evidence of fraud on the part of Andre Boisvert warranted an award of punitive damages in this case.

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 (10)

CaseCitedYears
Slater v. New Jersey green
scotus · 2011
2 sentences

2021This burden is more exacting than the preponderance of the evidence standard generally applied in civil cases, but less than the beyond a reasonable doubt standard applied in criminal matters.” Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 (2009) (cleaned up) (first quoting In re Will of McCauley, 356 N.C. 91, 101 (2002); then quoting Williams v. Blue Ridge Bldg. & Loan Ass’n, 207 N.C. 362 , 363–64 (1934)), cert. denied, 563 U.S. 988 (2011). ¶ 20 The trial court’s legal conclusion that a parent acted inconsistently with his constitutionally protected status as a parent is reviewed de novo

2021This burden is more exacting than the preponderance of the evidence standard generally applied in civil cases, but less than the beyond a reasonable doubt standard applied in criminal matters.” Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 (2009) (cleaned up) (first quoting In re Will of McCauley, 356 N.C. 91, 101 (2002); then quoting Williams v. Blue Ridge Bldg. & Loan Ass’n, 207 N.C. 362 , 363–64 (1934)), cert. denied, 563 U.S. 988 (2011). ¶ 20 The trial court’s legal conclusion that a parent acted inconsistently with his constitutionally protected status as a parent is reviewed de novo

42016–2021
In re T.H.T. green
ncctapp · 2007
2 sentences

2022App. 30 , 36 (2020)). “‘If such evidence exists, the findings of the trial court are binding on appeal, even if the evidence would support a finding to the contrary.’” Id. (quoting In re T.H.T., 185 N.C.

2022App. 30 , 36 (2020)). “‘If such evidence exists, the findings of the trial court are binding on appeal, even if the evidence would support a finding to the contrary.’” Id. (quoting In re T.H.T., 185 N.C.

22022–2022
In re T.H.T. green
nc · 2008
2 sentences

2022App. 337, 343 (2007) (cleaned up in original), aff’d in part, modified in part, 362 N.C. 446 (2008)). “‘The clear and convincing standard is greater than the preponderance of the evidence standard required in most civil cases.’” Id. (quoting In re K.L., 272 N.C.

2022App. 337, 343 (2007) (cleaned up in original), aff’d in part, modified in part, 362 N.C. 446 (2008)). “‘The clear and convincing standard is greater than the preponderance of the evidence standard required in most civil cases.’” Id. (quoting In re K.L., 272 N.C.

22022–2022
Addington v. Texas green
scotus · 1979
2 sentences

2020Cooper v. Mitchell Bros.’ Santa Ana Theater, 454 U.S. 90, 93 (1981) (per curiam) (footnote omitted) (“Three standards of proof are generally recognized, ranging from the ‘preponderance of the evidence’ standard employed in most civil cases, to the ‘clear and convincing’ standard reserved to protect particularly important interests in a limited number of civil cases, to the requirement that guilt be proved ‘beyond a reasonable doubt’ in a criminal prosecution.” (citing Addington v. Texas, 441 U.S. 418 , 423–44 (1979))); Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (20

2020Cooper v. Mitchell Bros.’ Santa Ana Theater, 454 U.S. 90, 93 (1981) (per curiam) (footnote omitted) (“Three standards of proof are generally recognized, ranging from the ‘preponderance of the evidence’ standard employed in most civil cases, to the ‘clear and convincing’ standard reserved to protect particularly important interests in a limited number of civil cases, to the requirement that guilt be proved ‘beyond a reasonable doubt’ in a criminal prosecution.” (citing Addington v. Texas, 441 U.S. 418 , 423–44 (1979))); Scarborough v. Dillard’s, Inc., 363 N.C. 715, 721 , 693 S.E.2d 640, 643 (20

22020–2020
Owenby v. Young green
nc · 2003
2 sentences

2020As our Supreme Court held in Owenby, “the trial court may employ the ‘best interest of the child’ test only when the movant first shows, by clear and convincing evidence, that the natural parent has forfeited [] her constitutionally protected status.” Owenby, 357 N.C. at 148 , 579 S.E.2d at 268 .

2020As our Supreme Court held in Owenby, “the trial court may employ the ‘best interest of the child’ test only when the movant first shows, by clear and convincing evidence, that the natural parent has forfeited [] her constitutionally protected status.” Owenby, 357 N.C. at 148 , 579 S.E.2d at 268 .

22020–2020
Scarborough v. Dillard's, Inc. green
scotus · 2011
2 sentences

2017This burden is more exacting than the preponderance of the evidence standard generally applied in civil cases, but less than the beyond a reasonable doubt standard applied in criminal matters." In re A.C. , --- N.C. at ----, 786 S.E.2d at 734 (citing Scarborough v. Dillard's, Inc., 363 N.C. 715 , 721, 693 S.E.2d 640 , 643 (2009), cert. denied, 563 U.S. 988 , 131 S.Ct. 2456 , 179 L.Ed.2d 1211 (2011) ).

2016This burden is more exacting than the preponderance of the evidence standard generally applied in civil cases, but less than the beyond a reasonable doubt standard applied in criminal matters." Scarborough v. Dillard's, Inc., 363 N.C. 715 , 721, 693 S.E.2d 640 , 643 (2009) (citations and quotation marks omitted), cert. denied, 563 U.S. 988 , 131 S.Ct. 2456 , 179 L.Ed.2d 1211 (2011).

22016–2017
Chien v. Skystar Bio Pharmaceutical Co. green
scotus · 2011
2 sentences

2017This burden is more exacting than the preponderance of the evidence standard generally applied in civil cases, but less than the beyond a reasonable doubt standard applied in criminal matters." In re A.C. , --- N.C. at ----, 786 S.E.2d at 734 (citing Scarborough v. Dillard's, Inc., 363 N.C. 715 , 721, 693 S.E.2d 640 , 643 (2009), cert. denied, 563 U.S. 988 , 131 S.Ct. 2456 , 179 L.Ed.2d 1211 (2011) ).

2016This burden is more exacting than the preponderance of the evidence standard generally applied in civil cases, but less than the beyond a reasonable doubt standard applied in criminal matters." Scarborough v. Dillard's, Inc., 363 N.C. 715 , 721, 693 S.E.2d 640 , 643 (2009) (citations and quotation marks omitted), cert. denied, 563 U.S. 988 , 131 S.Ct. 2456 , 179 L.Ed.2d 1211 (2011).

22016–2017
In re: K.L. & R.E. green
ncctapp · 2017
1 sentence

2025This burden is more exacting than the preponderance of the evidence standard generally applied in civil cases, but less than the beyond a reasonable doubt standard applied in criminal matters.” In re K.L., 254 N.C.

12025–2025
In re: A.C. green
ncctapp · 2016
1 sentence

2017This burden is more exacting than the preponderance of the evidence standard generally applied in civil cases, but less than the beyond a reasonable doubt standard applied in criminal matters." In re A.C. , --- N.C. at ----, 786 S.E.2d at 734 (citing Scarborough v. Dillard's, Inc., 363 N.C. 715 , 721, 693 S.E.2d 640 , 643 (2009), cert. denied, 563 U.S. 988 , 131 S.Ct. 2456 , 179 L.Ed.2d 1211 (2011) ).

12017–2017
Spering v. Sullivan green
ded · 1973
1 sentence

1987Spering v. Sullivan, 361 F. Supp. 282 (D.

11987–1987

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 7B-101 (9) NC § N.C. Gen. Stat. § 1D-15 (5) NC § N.C. Gen. Stat. § 7B-906.2 (5) NC § N.C. Gen. Stat. § 1D-5 (4) NC § N.C. Gen. Stat. § 7A-30 (4) NC § N.C. Gen. Stat. § 7B-1001 (4) NC § N.C. Gen. Stat. § 7B-507 (4) NC § N.C. Gen. Stat. § 7B-805 (4) NC § N.C. Gen. Stat. § 7B-807 (4) NC § N.C. Gen. Stat. § 7B-906.1 (4) NC § N.C. Gen. Stat. § 7A-31 (3) NC § N.C. Gen. Stat. § 7B-901 (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

TX 880 (1960–2026) OH 475 (1983–2026) CA 448 (1978–2026) TN 341 (1990–2026) PA 181 (1983–2026) IL 171 (1975–2026) CT 138 (1982–2026) LA 110 (1985–2026) WV 103 (1984–2026) ND 85 (1979–2025) NJ 81 (1966–2026) FL 81 (1982–2026) MN 77 (1985–2025) NM 73 (1988–2025) WA 66 (1980–2026) MD 63 (1982–2023) NY 60 (1979–2026) AZ 58 (1962–2026) DC 51 (1982–2025) CO 51 (1980–2025) OK 50 (1982–2024) UT 50 (1951–2026) ME 49 (1991–2021) IN 47 (1982–2024) ID 45 (1989–2025) MO 45 (1982–2025) MI 36 (1978–2025) VA 36 (1988–2026) OR 35 (1959–2026) SD 34 (1956–2026) GA 31 (1984–2024) KS 30 (1983–2024) NC 28 (1987–2026) RI 25 (1990–2024) SC 24 (1985–2026) AK 24 (1979–2025) WI 23 (1981–2025) HI 21 (1992–2025) MA 21 (1983–2025) DE 20 (1988–2026) MS 19 (1987–2023) IA 18 (1984–2025) AL 16 (1985–2017) NE 14 (1981–2024) VT 14 (1986–2024) NV 13 (1999–2026) WY 11 (1984–2015) AR 10 (1943–2022) NH 8 (1988–2013) KY 8 (1983–2025) VI 3 (2008–2010) MT 2 (1991–2010)

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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