special duty exception (North Carolina) · Go Syfert
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special duty exception in North Carolina

28 North Carolina opinions name it 3 courts 1994–2022 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 (6)

CaseFollowedCited
Barger v. McCoy Hillard & Parksgreen
nc · 1997 · cited in 13 North Carolina opinions naming this issue, 1999–2022
2 sentences

2022Under the special duty exception, “the duty must be one that the alleged wrongdoer owed directly to the shareholder as an individual.” Barger, 346 N.C. at 659 .

2022In Green, however, the Supreme Court explained that [t]o recover under the special duty exception, there must be a special duty “that defendant[ ] owed . . . to plaintiffs that was personal to plaintiffs as [creditors] and was separate and distinct from the duty defendant[ ] owed the corporation.” Barger, 346 N.C. at 661 .

213
Braswell v. Braswellgreen
nc · 1991 · cited in 8 North Carolina opinions naming this issue, 1996–2009
2 sentences

1996Moreover, to make out a prima facie case under the special duty exception, “plaintiff must show that an actual promise was made by *548 the police to create a special duty, that this promise was reasonably relied upon by the plaintiff, and that this reliance was causally related to the injury ultimately suffered by plaintiff.” Braswell, 330 N.C. at 371 , 410 S.E.2d at 902 .

1996Moreover, to make out a prima facie case under the special duty exception, “plaintiff must show that an actual promise was made by *548 the police to create a special duty, that this promise was reasonably relied upon by the plaintiff, and that this reliance was causally related to the injury ultimately suffered by plaintiff.” Braswell, 330 N.C. at 371 , 410 S.E.2d at 902 .

28
Cockerham-Ellerbee v. Town of Jonesvillegreen
ncctapp · 2006 · cited in 2 North Carolina opinions naming this issue, 2007–2008
2 sentences

2008Most significantly, this' Court held that the allegations in Ms. Cockerham-Ellerbee’s complaint “are sufficient to state a claim falling under the special duty exception to the public duty doctrine.” Id. at 379 , 626 S.E.2d at 690 .

2008Most significantly, this' Court held that the allegations in Ms. Cockerham-Ellerbee’s complaint “are sufficient to state a claim falling under the special duty exception to the public duty doctrine.” Id. at 379 , 626 S.E.2d at 690 .

12
Myers v. McGradygreen
nc · 2006 · cited in 1 North Carolina opinions naming this issue, 2014–2014
2 sentences

2014See Myers v. McGrady, 360 N.C. 460, 468-69 , 628 S.E.2d 761, 767 (2006) (declining to address exceptions to public duty doctrine where plaintiffs did not raise them); Rev O, Inc. v. Woo, _ N.C.

2014See Myers v. McGrady, 360 N.C. 460, 468-69 , 628 S.E.2d 761, 767 (2006) (declining to address exceptions to public duty doctrine where plaintiffs did not raise them); Rev O, Inc. v. Woo, _ N.C.

11
Lassiter v. Cohngreen
ncctapp · 2005 · cited in 1 North Carolina opinions naming this issue, 2014–2014
1 sentence

2014App. at 321 , 607 S.E.2d at 695 (concluding that officer’s management of accident scene “fell completely within Durham’s immunization of performing a public duty”). *308 Finally, because Plaintiff has not alleged the applicability of either the special relationship exception or the special duty exception to the public duty doctrine, we decline to address the potential applicability of these exceptions.

11
Davis v. Messergreen
ncctapp · 1995 · cited in 1 North Carolina opinions naming this issue, 2000–2000
2 sentences

2000Cf. Davis v. Messer, 119 N.C.

2000App. 44, 56 , 457 S.E.2d 902, 910 (holding the following allegations stated a claim for relief under the special duty exception: “the Town .. . promised it would provide fire-fighting assistance and protection; the promised protection never arrived; and plaintiffs relied upon the promise to respond to the fire as their exclusive source of aid, resulting in the complete destruction of their home”), disc. rev. denied, 341 N.C. 647 , 462 S.E.2d 508 (1995).

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 (8)

CaseCitedYears
Raymond James Capital Partners, L.P. v. Hayes green
ncctapp · 2016
2 sentences

2019Although Barger did not purport to identify an exhaustive list, our Court of Appeals has concluded that “the special duty exception clearly requires an articulation of some duty owed to a plaintiff that is distinct from the general fiduciary duties directors and officers owe to the corporation.” Id. at 580, 789 S.E.2d at 701 . 16.

2016Although Barger did not purport to identify an exhaustive list, the Court of Appeals has concluded that “the special duty exception clearly requires an articulation of some duty owed to a plaintiff that is distinct from the general fiduciary duties directors and officers owe to the corporation.” Hayes, 789 S.E.2d at 701 . 48.

22016–2019
Howell v. Fisher green
ncctapp · 1980
1 sentence

2011Separate Injury Exception to Barger [34] For the "separate injury" exception to Barger to apply, the alleged injury must be "peculiar or personal to the shareholder" and "separate and distinct from any damage suffered by the corporation." Id. (quoting Howell v. Fisher, 49 N.C.

12011–2011
Stone v. North Carolina Department of Labor green
nc · 1998
2 sentences

2007Id. at 482 , 495 S.E.2d at 717 (citing Braswell, 330 N.C. at 371 , 410 S.E.2d at 902 ); see also Cockerham-Ellerbee v. Town of Jonesville, 176 N.C.App. 372, 377 , 626 S.E.2d 685, 689 (2006) (quoting Braswell, 330 N.C. at 371 , 410 S.E.2d at 902 ). "[T]he `special duty' exception . . . is a very narrow one; it should be applied only when the promise, reliance, and causation are manifestly present." Braswell, 330 N.C. at 372 , 410 S.E.2d at 902 .

2007Id. at 482 , 495 S.E.2d at 717 (citing Braswell, 330 N.C. at 371 , 410 S.E.2d at 902 ); see also Cockerham-Ellerbee v. Town of Jonesville, 176 N.C.

12007–2007
Meyer v. Walls green
nc · 1997
1 sentence

2005Id. at 372 , 410 S.E.2d at 902 . 3 Here, as the school defendants have observed, there is no statutory requirement that a sheriff provide a school resource officer.

12005–2005
Norman v. Nash Johnson & Sons' Farms, Inc. green
ncctapp · 2000
1 sentence

2000However, while our Court held in Norman v. Nash Johnson & Sons' Farms, supra, that the fiduciary duty owed to a minority shareholder by a majority shareholder may satisfy the special duty requirement of Barger, plaintiff was a fifty percent owner of A & B and hence was not a minority shareholder.

12000–2000
Davis v. Messer green
nc · 1995
1 sentence

2000App. 44, 56 , 457 S.E.2d 902, 910 (holding the following allegations stated a claim for relief under the special duty exception: “the Town .. . promised it would provide fire-fighting assistance and protection; the promised protection never arrived; and plaintiffs relied upon the promise to respond to the fire as their exclusive source of aid, resulting in the complete destruction of their home”), disc. rev. denied, 341 N.C. 647 , 462 S.E.2d 508 (1995).

12000–2000
Corn v. Nesbitt green
nc · 1995
1 sentence

2000App. 44, 56 , 457 S.E.2d 902, 910 (holding the following allegations stated a claim for relief under the special duty exception: “the Town .. . promised it would provide fire-fighting assistance and protection; the promised protection never arrived; and plaintiffs relied upon the promise to respond to the fire as their exclusive source of aid, resulting in the complete destruction of their home”), disc. rev. denied, 341 N.C. 647 , 462 S.E.2d 508 (1995).

12000–2000
Coleman v. Cooper green
ncctapp · 1988
1 sentence

1994Plaintiff cites Coleman v. Cooper, 89 N.C.

11994–1994

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 1A-1 (12) NC § N.C. Gen. Stat. § 55-8-30 (4) NC § N.C. Gen. Stat. § 57D-3-21 (4) NC § N.C. Gen. Stat. § 57D-8-01 (4) NC § N.C. Gen. Stat. § 75-1.1 (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

IL 87 (1982–2023) NY 58 (1962–2026) NC 28 (1994–2022) RI 24 (1989–2010) TN 20 (1967–2026) OH 14 (1989–2016) SD 6 (1997–2020) WV 6 (1997–2014) SC 5 (1991–2022) MD 4 (2001–2021) WA 3 (1988–2019) DC 3 (1985–2022) GA 3 (1992–2004) MN 2 (1985–1996)

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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