distinct requirement (North Carolina) · Go Syfert
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distinct requirement in North Carolina

26 North Carolina opinions name it 3 courts 1906–2026 8 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 (9)

CaseFollowedCited
Thigpen v. Ngogreen
nc · 2002 · cited in 6 North Carolina opinions naming this issue, 2006–2026
2 sentences

2026P. 9(j); see also Thigpen, 355 N.C. at 202 , 558 S.E.2d at 165 (emphasizing “no other subsection [of Rule 9] contains the mandatory language ‘shall be dismissed[]’” and “[Rule 9(j)] indicates that medical malpractice complaints have a distinct requirement of expert certification with which plaintiffs must comply”).

2026P. 9(j); see also Thigpen, 355 N.C. at 202 , 558 S.E.2d at 165 (emphasizing “no other subsection [of Rule 9] contains the mandatory language ‘shall be dismissed[]’” and “[Rule 9(j)] indicates that medical malpractice complaints have a distinct requirement of expert certification with which plaintiffs must comply”).

56
Pait v. Southeastern General Hospitalgreen
ncctapp · 2012 · cited in 2 North Carolina opinions naming this issue, 2021–2021
2 sentences

2021App. 403, 414 , 724 S.E.2d 618, 627 (2012) (A death benefits claim under the Workers’ Compensation Act is a distinct claim to those beneficiaries upon the death of the injured worker.).

2021App. 403, 414 , 724 S.E.2d 618, 627 (2012) (A death benefits claim under the Workers’ Compensation Act is a distinct claim to those beneficiaries upon the death of the injured worker.).

22
Maines v. City of Greensborogreen
· 1980 · cited in 2 North Carolina opinions naming this issue, 2005–2007
2 sentences

2007See Maines v. City of Greensboro, 300 N.C. 126, 130 , 265 S.E.2d 155, 158 (1980) (discussing the two types of claims where plaintiff “first contends that the ordinance is unconstitutional on its face . . . alternative [ly], plaintiff argues that the ordinance is unconstitutional as applied”).

2007See Maines v. City of Greensboro, 300 N.C. 126, 130 , 265 S.E.2d 155, 158 (1980) (discussing the two types of claims where plaintiff “first contends that the ordinance is unconstitutional on its face . . . alternative [ly], plaintiff argues that the ordinance is unconstitutional as applied”).

22
Rent-A-Center, West, Inc. v. Jacksongreen
scotus · 2010 · cited in 1 North Carolina opinions naming this issue, 2026–2026
1 sentence

2026See, e.g., Rent-A- Center, W., Inc. v. Jackson, 561 U.S. 63 , 70–71 (2010); Howell, 2020 NCBC LEXIS 105 , at *20–23 (suggesting that a party must make a distinct challenge to the provision’s delegation clause to avoid its effect). 3 To be clear, as set forth below, the Court makes no determination as to whether the Operating Agreements are binding or valid.

11
Moore v. Propergreen
nc · 2012 · cited in 1 North Carolina opinions naming this issue, 2024–2024
2 sentences

2024The Supreme Court of North Carolina has held Rule 9(j) imposes “a distinct requirement of expert certification.” Moore v. Proper, 366 N.C. 25, 30 , 726 S.E.2d 812, 816 (2012) (citation omitted).

2024The Supreme Court of North Carolina has held Rule 9(j) imposes “a distinct requirement of expert certification.” Moore v. Proper, 366 N.C. 25, 30 , 726 S.E.2d 812, 816 (2012) (citation omitted).

11
John MacDonald v. Cashcall Incgreen
ca3 · 2018 · cited in 1 North Carolina opinions naming this issue, 2020–2020
1 sentence

2020See, e.g., Gibbs v. Haynes Invs., LLC, 2020 U.S. App. LEXIS 22736 , at *12 (4th Cir. July 21, 2020) (“[I]n specifically challenging a delegation clause, a party may rely on the same arguments that it employs to contest the enforceability of other arbitration provisions.” (quoting MacDonald v. CashCall, Inc., 883 F.3d 220 , 226–27 (3d Cir. 2018))); see also, e.g., Parm v. Nat’l Bank of Cal., N.A., 835 F.3d 1331 , 1335 n.1 (11th Cir. 2016) (“Because [the plaintiff] directly challenged the delegation clause in her opposition to the motion to compel, there is no waiver and we have jurisdiction to

11
Jessica Parm v. National Bank of California, N.A.green
ca11 · 2016 · cited in 1 North Carolina opinions naming this issue, 2020–2020
1 sentence

2020See, e.g., Gibbs v. Haynes Invs., LLC, 2020 U.S. App. LEXIS 22736 , at *12 (4th Cir. July 21, 2020) (“[I]n specifically challenging a delegation clause, a party may rely on the same arguments that it employs to contest the enforceability of other arbitration provisions.” (quoting MacDonald v. CashCall, Inc., 883 F.3d 220 , 226–27 (3d Cir. 2018))); see also, e.g., Parm v. Nat’l Bank of Cal., N.A., 835 F.3d 1331 , 1335 n.1 (11th Cir. 2016) (“Because [the plaintiff] directly challenged the delegation clause in her opposition to the motion to compel, there is no waiver and we have jurisdiction to

11
State v. Stevensongreen
ncctapp · 1986 · cited in 1 North Carolina opinions naming this issue, 2017–2017
2 sentences

2017App. 409 , 412, 344 S.E.2d 334 , 335 (1986) ("The 'castle doctrine' is derived from the principle that one's home is one's castle and is based on the theory that if a person is bound to become a fugitive from her own home, there would be no refuge for her anywhere in the world.") While the castle doctrine is a legal theory in the nature of self-defense, it is a separate and distinct analysis from simple self-defense against a threat of serious or deadly force because under the castle doctrine the person is not just defending himself but also defending himself in the place he has the right to b

2017App. 409, 412 , 344 S.E.2d 334, 335 (1986) (“The ‘castle doctrine’ is derived from the principle that one’s home is one’s castle and is based on the theory that if a person is bound to become a fugitive from her own home, there would be no refuge for her anywhere in the world.”) While the castle doctrine is a legal theory in the nature of self-defense, it is a separate and distinct analysis from simple self- defense against a threat of serious or deadly force because under the castle doctrine the person is not just defending himself but also defending himself in the place he has the right to b

11
Duncan v. Ohio Blow Pipe Co.green
ohioctapp · 1998 · cited in 1 North Carolina opinions naming this issue, 2006–2006
2 sentences

2006Ct. App. 2000) (“[T]he traveling-employee rule recognizes that the conditions faced by employees working ‘on the road,’ away from home and away from their employer’s home office, are sufficiently different from the conditions faced by employees merely going to or from their local place of employment on a daily basis to warrant a distinct rule.”); Duncan v. Ohio Blow Pipe Co., 130 Ohio App. 3d 228, 235 , 719 N.E.2d 1029, 1034 (1998) (holding that the fact that the employee had fixed hours and a fixed work location for purposes of the “coming- and-going” rule “does not end the inquiry,” and the

2006Ct. App. 2000) (“[T]he traveling-employee rule recognizes that the conditions faced by employees working ‘on the road,’ away from home and away from their employer’s home office, are sufficiently different from the conditions faced by employees merely going to or from their local place of employment on a daily basis to warrant a distinct rule.”); Duncan v. Ohio Blow Pipe Co., 130 Ohio App. 3d 228, 235 , 719 N.E.2d 1029, 1034 (1998) (holding that the fact that the employee had fixed hours and a fixed work location for purposes of the “coming- and-going” rule “does not end the inquiry,” and the

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 (15)

CaseCitedYears
State v. Batiste neutral
ncctapp · 2017
2 sentences

2022Ct. App. Sept. 5, 2017) (holding that defendant’s actions, without more, did not violate N.C.G.S. § 15A–1343(b)(3a) when those actions violated the explicit language of “a wholly separate” regular condition of probation which did not allow probation revocation and activation of a suspended sentence); State v. Batiste, No. COA16-1186, 2017 WL 3863538 (N.C.

2022Ct. App. Sept. 5, 2017) (holding that defendant’s actions, without more, did not violate N.C.G.S. § 15A–1343(b)(3a) when those actions violated the explicit language of “a wholly separate” regular condition of probation which did not allow probation revocation and activation of a suspended sentence); State v. Batiste, No. COA16-1186, 2017 WL 3863538 (N.C.

32022–2022
State v. Booker neutral
ncctapp · 2017
2 sentences

2022App. 111 (2018) (reasoning that the State’s allegations and supporting evidence were very similar to those rejected in Williams because defendant’s actions only amounted to a violation of N.C.G.S. § 15A-1343(b)(3) and did not rise to the distinct violation of absconding supervision); State v. Booker, No. COA 16-1142, 2017 WL 3863881 (N.C.

2022App. 111 (2018) (reasoning that the State’s allegations and supporting evidence were very similar to those rejected in Williams because defendant’s actions only amounted to a violation of N.C.G.S. § 15A-1343(b)(3) and did not rise to the distinct violation of absconding supervision); State v. Booker, No. COA 16-1142, 2017 WL 3863881 (N.C.

32022–2022
In Re Redmond Ex Rel. Nichols green
nc · 2017
2 sentences

2021Stat. § 97-24 (a), a dependent is not required to file a separate and distinct claim within the two-year statutory period, so long as an initial claim satisfies the limitation period. ¶ 20 “Where the language of a statute is clear and unambiguous, there is no room for judicial construction[,] and the courts must give [the statute] its plain and definite meaning, and are without power to interpolate, or superimpose, provisions and limitations not contained therein.” Matter of Redmond by & through Nichols, 369 N.C. 490, 495 , 797 S.E.2d 275 , 279 (2017) (citation and quotation marks omitted; alt

2021Stat. § 97-24 (a), a dependent is not required to file a separate and distinct claim within the two-year statutory period, so long as an initial claim satisfies the limitation period. ¶ 20 “Where the language of a statute is clear and unambiguous, there is no room for judicial construction[,] and the courts must give [the statute] its plain and definite meaning, and are without power to interpolate, or superimpose, provisions and limitations not contained therein.” Matter of Redmond by & through Nichols, 369 N.C. 490, 495 , 797 S.E.2d 275 , 279 (2017) (citation and quotation marks omitted; alt

22021–2021
Purcell v. Friday Staffing green
ncctapp · 2014
2 sentences

2021“When, however, a statute is ambiguous, judicial construction must be used to ascertain the legislative will.” Purcell v. Friday Staffing, 235 N.C.

2021“When, however, a statute is ambiguous, judicial construction must be used to ascertain the legislative will.” Purcell v. Friday Staffing, 235 N.C.

22021–2021
Matter of White green
ncctapp · 1986
2 sentences

2007White, 81 N.C.App. at 85 , 344 S.E.2d at 38 .

2007White, 81 N.C.App. at 85 , 344 S.E.2d at 38 .

22007–2007
Phillips v. a Triangle Women's Health Clinic, Inc. green
ncctapp · 2002
1 sentence

2026“When ruling on [a motion to dismiss pursuant to Rule 9(j)], a court must consider the facts relevant to Rule 9(j) and apply the law to them.” Phillips v. A Triangle Women’s Health Clinic, Inc., 155 N.C.

12026–2026
State v. Jackson green
ncctapp · 2012
1 sentence

2016MARTIN Opinion of the Court Jackson, 220 N.C.

12016–2016
Bank v. Cooper, Paroff, Cooper & Cook green
scotus · 2010
1 sentence

2012Cir.) (“Presumably, the ‘reasonable to believe’ standard requires less than probable cause, because otherwise Gant’s evidentiary rationale would merely duplicate the ‘automobile exception,’ which the Court [in Gant] specifically identified as a distinct exception to the warrant requirement.”), cert. denied, _ U.S. _, 131 S. Ct. 93 , 178 L.

12012–2012
DeSantiago v. McCollum green
scotus · 2010
1 sentence

2012Cir.) (“Presumably, the ‘reasonable to believe’ standard requires less than probable cause, because otherwise Gant’s evidentiary rationale would merely duplicate the ‘automobile exception,’ which the Court [in Gant] specifically identified as a distinct exception to the warrant requirement.”), cert. denied, _ U.S. _, 131 S. Ct. 93 , 178 L.

12012–2012
Wray v. . Woolen Mills green
nc · 1934
2 sentences

2012Id. at 783-84 , 172 S.E. at 488 .

2012Id. at 783-84 , 172 S.E. at 488 .

12012–2012
Ebeling v. Morgan green
scotus · 1915
2 sentences

1950However, the decided weight of authority supports the view that in cases of factual similarity with the one under review the power of the Legislature, when it so intends, to make punishable as a distinct violation of statute law each offense denounced by the statute, although occurring in the same transaction, must be given effect. 22 C.J.S., Criminal Law, sec. 9, and authorities assembled in notes 39, 40, and 42; 15 A. J., Criminal Law, sec. 389; Ebelling v. Morgan, 237 U.S. 625 , 59 L.

1950However, the decided weight of authority supports the view that in cases of factual similarity with the one under review the power of the Legislature, when it so intends, to make punishable as a distinct violation of statute law each offense denounced by the statute, although occurring in the same transaction, must be given effect. 22 C.J.S., Criminal Law, sec. 9, and authorities assembled in notes 39, 40, and 42; 15 A. J., Criminal Law, sec. 389; Ebelling v. Morgan, 237 U.S. 625 , 59 L.

11950–1950
Florida v. Mellon green
scotus · 1927
1 sentence

1950Ed. 1151 ; Ruark v. U. S., 17 Fed. 2d 570 (C.C.A. 8); 51 A.L.R. 87 ; Albrecht v. U. S., 273 U.S. 1 , 71 L.

11950–1950
Albrecht v. United States green
scotus · 1927
1 sentence

1950Ed. 1151 ; Ruark v. U. S., 17 Fed. 2d 570 (C.C.A. 8); 51 A.L.R. 87 ; Albrecht v. U. S., 273 U.S. 1 , 71 L.

11950–1950
Dorsett v. Clement-Ross Manufacturing Co. neutral
nc · 1902
1 sentence

1914Dorsett v. Manufacturing Co., 131 N. C., 254 ; Eplee v. R.

11914–1914
Nagel v. Missouri Pacific Railway Co. green
· 1882
1 sentence

1906Such act may have been the immediate intervening cause, but the unlawful employment, continuing, was in combination with the intervening act a proximate cause of the injury.” The principle" was applied in Nagel v. Railway, 75 Mo., 653 : “The defendant owned or had control of a turntable located in a portion of the town where children were in the habit of playing.

11906–1906

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 1A-1 (8) NC § N.C. Gen. Stat. § 90-21.11 (4) NC § N.C. Gen. Stat. § 15A-1343 (3) NC § N.C. Gen. Stat. § 15A-1344 (3) NC § N.C. Gen. Stat. § 15A-1345 (3) NC § N.C. Gen. Stat. § 7A-30 (3) NC § N.C. Gen. Stat. § 8C-1 (3) NC § N.C. Gen. Stat. § 90-21.12 (3) NC § N.C. Gen. Stat. § 97-2 (3) NC § N.C. Gen. Stat. § 97-38 (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

CA 128 (1871–2026) PA 103 (1897–2024) CT 100 (1895–2026) NY 75 (1874–2026) OH 64 (1898–2025) TX 57 (1916–2026) IL 55 (1886–2025) MI 35 (1922–2026) MO 30 (1875–2025) GA 30 (1895–2025) AZ 29 (1947–2025) NC 26 (1906–2026) FL 25 (1935–2018) AL 24 (1877–2026) WA 24 (1911–2026) LA 22 (1911–2022) MA 20 (1886–2026) NJ 19 (1896–2026) UT 18 (1968–2025) MD 17 (1910–2021) IN 16 (1906–2020) OR 15 (1940–2026) KY 15 (1880–2025) WI 15 (1873–2020) DC 14 (1987–2023) TN 13 (1924–2026) WV 13 (1946–2025) CO 13 (1923–2024) VA 12 (1882–2025) NM 11 (1981–2025) MN 8 (1904–2013) IA 8 (1900–2020) VT 7 (1921–2021) KS 7 (1926–2026) ID 6 (1985–2012) MS 6 (1934–2007) DE 6 (1946–2022) OK 6 (1907–2014) RI 5 (1915–2010) NE 5 (1894–2020) NV 5 (1979–2024) SC 5 (1926–1939) HI 5 (1923–2010) AK 4 (1971–2024) NH 4 (2018–2025) MT 4 (2000–2025) AR 3 (1959–2024) ME 3 (1864–2018) PR 2 (1934–1950) WY 2 (1931–2023)

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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