state law claim (North Carolina) · Go Syfert
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state law claim in North Carolina

20 North Carolina opinions name it 2 courts 1987–2025 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 (14)

CaseFollowedCited
Allis-Chalmers Corp. v. Lueckgreen
scotus · 1985 · cited in 2 North Carolina opinions naming this issue, 1989–2009
2 sentences

2009Under Section 301, when the resolution of a state law claim is “substantially dependent” upon the interpretation or application of the provisions in a collective bargaining agreement, “that claim must either be treated as a § 301 claim or dismissed as pre-empted by federal labor-contract law.” Allis-Chalmers Corp. v. Lueck, 471 U.S. 202, 220 , 85 L.

2009Under Section 301, when the resolution of a state law claim is “substantially dependent” upon the interpretation or application of the provisions in a collective bargaining agreement, “that claim must either be treated as a § 301 claim or dismissed as pre-empted by federal labor-contract law.” Allis-Chalmers Corp. v. Lueck, 471 U.S. 202, 220 , 85 L.

22
Gunn v. Mintongreen
scotus · 2013 · cited in 2 North Carolina opinions naming this issue, 2017–2021
2 sentences

2021As the United States Supreme Court recently reaffirmed, “federal jurisdiction over a state law claim will lie if a federal issue is: (1) necessarily raised, (2) actually disputed, (3) substantial, and (4) capable of resolution in federal court without disrupting the federal-state balance approved by Congress.” Gunn, 568 U.S. at 258 ; see also Grable & Sons Metal Prods., Inc. v. Darue Eng’g & Mgf., 545 U.S. 308 , 312–14 (2005) (addressing federal arising under jurisdiction in the context of 28 U.S.C. § 1331 ).

2017Operating Corp., 486 U.S. 800, 809 (1988); see also Gunn v. Minton, 133 S. Ct. 1059, 1065 (2013) (clarifying the standard to determine whether a state law claim arises under federal law by articulating a four-part inquiry.) The mere existence of a patent law issue does not necessarily mean that the claim arises under federal patent law.

12
Tire Engineering & Distribution, LLC v. Shandong Linglong Rubber Co.green
ca4 · 2012 · cited in 1 North Carolina opinions naming this issue, 2025–2025
1 sentence

2025See Tire Eng’g & Distrib., LLC v. Shandong Linglong Rubber Co., 682 F.3d 292, 309 (4th Cir. 2012). 81.

11
Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturinggreen
scotus · 2005 · cited in 1 North Carolina opinions naming this issue, 2021–2021
1 sentence

2021As the United States Supreme Court recently reaffirmed, “federal jurisdiction over a state law claim will lie if a federal issue is: (1) necessarily raised, (2) actually disputed, (3) substantial, and (4) capable of resolution in federal court without disrupting the federal-state balance approved by Congress.” Gunn, 568 U.S. at 258 ; see also Grable & Sons Metal Prods., Inc. v. Darue Eng’g & Mgf., 545 U.S. 308 , 312–14 (2005) (addressing federal arising under jurisdiction in the context of 28 U.S.C. § 1331 ).

11
Rosciszewski v. Arete Associatesgreen
ca4 · 1993 · cited in 1 North Carolina opinions naming this issue, 2018–2018
1 sentence

2018Rosciszewski, 1 F.3d at 230; see also Out of the Box Developers, 2012 NCBC LEXIS 55 , at *20–21.

11
Christianson v. Colt Industries Operating Corp.green
scotus · 1988 · cited in 1 North Carolina opinions naming this issue, 2017–2017
1 sentence

2017Operating Corp., 486 U.S. 800, 809 (1988); see also Gunn v. Minton, 133 S. Ct. 1059, 1065 (2013) (clarifying the standard to determine whether a state law claim arises under federal law by articulating a four-part inquiry.) The mere existence of a patent law issue does not necessarily mean that the claim arises under federal patent law.

11
Atlantic & East Carolina Railway Co. v. Wheatly Oil Co.green
ncctapp · 2004 · cited in 1 North Carolina opinions naming this issue, 2016–2016
1 sentence

2016App. 748, 753 , 594 S.E.2d 425, 429 (2004). {58} In addition, where, as here, “the state law claim for breach of contract remains viable, it is unnecessary to address the claim for unjust enrichment [on a Rule 12(b)(6) motion].” Forest2Market, Inc. v. Am.

11
Person Earth Movers, Inc. v. Bucklandgreen
ncctapp · 2000 · cited in 1 North Carolina opinions naming this issue, 2012–2012
2 sentences

2012Specifically, plaintiffs cite the following passage from Person Earth Movers, Inc. v. Buckland: “[t]he statute of limitations for a state law claim ... expires at the end of the limitations period described by the appropriate state law, and is extended only by that amount of time the debtor is in bankruptcy.” 136 N.C.

2012App. 658, 660 , 525 S.E.2d 239, 240 (2000).

11
Southland Corp. v. Keatinggreen
scotus · 1984 · cited in 1 North Carolina opinions naming this issue, 2010–2010
1 sentence

2010See also Southland Corp. v. Keating, 465 U.S. 1, 16 (1984). 76 Pl. 2nd Resp.

11
Glen Kermit Till and Bettie F. Till v. Unifirst Federal Savings and Loan Association and Wortman & Mann, Inc.green
ca1 · 1981 · cited in 1 North Carolina opinions naming this issue, 2009–2009
2 sentences

2009However, the Ford court acknowledged that “[m]ost . . . federal courts . . . have determined that whether a state law claim based on the violation of a federal statute may be brought is a matter of state law for state courts to decide[.]” Id.; see also Hofbauer, 700 F.2d at 1201 (holding that, although a federal statute may create a standard of conduct the violation of which suffices to support a claim arising under state law, whether such a claim exists is a question best left entirely to state courts); Till, 653 F.2d at 161-62 (holding that the existence of state law claims depends upon stat

2009As a result of the fact that the absence of a federal private right of action under the NFIA does not inherently preclude the recognition of a state law claim that encompasses conduct prohibited by 42 U.S.C. § 4104a(a)(1), we are now called upon to decide whether a lender is liable under North Carolina law for damages resulting from a failure to disclose the fact that property is located in a flood plain. *40 In determining whether such a state law claim should be recognized in North Carolina, we find the analysis of the United States Court of Appeals for the Fifth Circuit in Till, 653 F.2d 15

11
cluster 414495green
ca8 · 1983 · cited in 1 North Carolina opinions naming this issue, 2009–2009
1 sentence

2009However, the Ford court acknowledged that “[m]ost . . . federal courts . . . have determined that whether a state law claim based on the violation of a federal statute may be brought is a matter of state law for state courts to decide[.]” Id.; see also Hofbauer, 700 F.2d at 1201 (holding that, although a federal statute may create a standard of conduct the violation of which suffices to support a claim arising under state law, whether such a claim exists is a question best left entirely to state courts); Till, 653 F.2d at 161-62 (holding that the existence of state law claims depends upon stat

11
Midgett v. North Carolina State Highway Commissiongreen
nc · 1963 · cited in 1 North Carolina opinions naming this issue, 2007–2007
2 sentences

2007However, the term "adequate" in Corum is not used to mean "potentially successful." Just before the above-quoted statement in Corum , the Court quotes this from Midgett v. Highway Commission: "`And where the Constitution points out no remedy and no statute affords an adequate remedy under a particular fact situation, the common law will furnish the appropriate action for adequate redress of such grievance.'" Id. (quoting Midgett v. North Carolina State Highway Commission, 260 N.C. 241, 249-50 , 132 S.E.2d 599, 608 (1963)).

2007However, the term "adequate" in Corum is not used to mean "potentially successful." Just before the above-quoted statement in Corum , the Court quotes this from Midgett v. Highway Commission: "`And where the Constitution points out no remedy and no statute affords an adequate remedy under a particular fact situation, the common law will furnish the appropriate action for adequate redress of such grievance.'" Id. (quoting Midgett v. North Carolina State Highway Commission, 260 N.C. 241, 249-50 , 132 S.E.2d 599, 608 (1963)).

11
Pizlo v. Bethlehem Steel Corporationgreen
ca4 · 1989 · cited in 1 North Carolina opinions naming this issue, 1992–1992
1 sentence

1992Pizlo v. Bethlehem Steel Corp., 884 F.2d 116, 120 (4th Cir. 1989).

11
Chiplin Enterprises, Inc. v. City of Lebanongreen
ca1 · 1983 · cited in 1 North Carolina opinions naming this issue, 1987–1987
1 sentence

1987See Chiplin Enterprises, Inc. v. City of Lebanon, 712 F. 2d 1524 (1st Cir. 1983).

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 (9)

CaseCitedYears
Corum v. University of North Carolina green
· 1992
2 sentences

2016Constitutional Claims Plaintiff's sole argument regarding his constitutional claims is that he does not have an adequate remedy under state law due to defendant's assertion of governmental immunity, citing Craig v. New Hanover County Board of Education, 363 N.C. 334 , 340, 678 S.E.2d 351 , 355 (2009), for the proposition that "if 'governmental immunity stands as an absolute bar,' the state law claim 'does not provide an adequate remedy.' " In Corum v. University of North Carolina, our Supreme Court stated, "[I]n the absence of an adequate state remedy, one whose state constitutional rights hav

2016Constitutional Claims Plaintiff's sole argument regarding his constitutional claims is that he does not have an adequate remedy under state law due to defendant's assertion of governmental immunity, citing Craig v. New Hanover County Board of Education, 363 N.C. 334 , 340, 678 S.E.2d 351 , 355 (2009), for the proposition that "if 'governmental immunity stands as an absolute bar,' the state law claim 'does not provide an adequate remedy.' " In Corum v. University of North Carolina, our Supreme Court stated, "[I]n the absence of an adequate state remedy, one whose state constitutional rights hav

22007–2016
Rousselo v. Starling green
ncctapp · 1998
2 sentences

2018We next addressed the adequacy of a state law claim in Rousselo v. Starling , 128 N.C.

2018App. 439 , 495 S.E.2d 725 (1998), in which the plaintiff sued a State Highway Patrolman in both his official and individual capacities for, inter alia , an unreasonable search.

12018–2018
American Telephone And Telegraph Company v. Integrated Network Corporation green
cafc · 1992
1 sentence

2017AT&T Co. v. Integrated Network Corp., 972 F.2d 1321 , 1325 (Fed.

12017–2017
Craig Ex Rel. Craig v. New Hanover County Board of Education green
nc · 2009
2 sentences

2016Constitutional Claims Plaintiff's sole argument regarding his constitutional claims is that he does not have an adequate remedy under state law due to defendant's assertion of governmental immunity, citing Craig v. New Hanover County Board of Education, 363 N.C. 334 , 340, 678 S.E.2d 351 , 355 (2009), for the proposition that "if 'governmental immunity stands as an absolute bar,' the state law claim 'does not provide an adequate remedy.' " In Corum v. University of North Carolina, our Supreme Court stated, "[I]n the absence of an adequate state remedy, one whose state constitutional rights hav

2016Constitutional Claims Plaintiff's sole argument regarding his constitutional claims is that he does not have an adequate remedy under state law due to defendant's assertion of governmental immunity, citing Craig v. New Hanover County Board of Education, 363 N.C. 334 , 340, 678 S.E.2d 351 , 355 (2009), for the proposition that "if 'governmental immunity stands as an absolute bar,' the state law claim 'does not provide an adequate remedy.' " In Corum v. University of North Carolina, our Supreme Court stated, "[I]n the absence of an adequate state remedy, one whose state constitutional rights hav

12016–2016
Cipollone v. Liggett Group, Inc. green
scotus · 1992
2 sentences

2015Auth. v. Lofton, ---N.C.App. ----, ----, 767 S.E.2d 63 , 69 (2014) (citing Cipollone v. Liggett Grp., Inc., 505 U.S. 504 , 516, 112 S.Ct. 2608 , 2617, 120 L.Ed.2d 407 (1992) ).

2015Auth. v. Lofton, ---N.C.App. ----, ----, 767 S.E.2d 63 , 69 (2014) (citing Cipollone v. Liggett Grp., Inc., 505 U.S. 504 , 516, 112 S.Ct. 2608 , 2617, 120 L.Ed.2d 407 (1992) ).

12015–2015
Harter v. Vernon green
ncctapp · 2000
2 sentences

2014Harter, 139 N.C.

2014Harter, 139 N.C.

12014–2014
Beneficial National Bank v. Anderson green
scotus · 2003
1 sentence

2007In fact, “[b]ecause [Sections] 85 and 86 provide the exclusive cause of action for such claims, there is, in short, no such thing as a state-law claim of usury against a national bank.” Id. 12 C.F.R. § 7.4001 (2007) provides: “The term ‘interest’ as used in 12 U.S.C. 85 includes any payment compensating a creditor or prospective creditor for an extension of credit, making available of a line of credit, or any default or breach by a borrower of a condition upon which credit was extended.” Moreover, 12 C.F.R. § 7.4008 identifies the types of state laws that are preempted with respect to national

12007–2007
cluster 728735 green
ca4 · 1996
1 sentence

2001In considering whether a particular state law claim falls within this category, it is important to determine whether the claim is “aimed at obtaining ERISA benefits.” Coyne & Delany Co., 98 F.3d at 1471 .

12001–2001
Lumber Co. v. Brooks, Comr. of Labor green
ncctapp · 1981
1 sentence

1990Ward Lumber Co. v. Brooks, 50 N.C.

11990–1990

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 1-52 (5) NC § N.C. Gen. Stat. § 1A-1 (5) NC § N.C. Gen. Stat. § 75-1.1 (3) USC § 17u.s.c.301 (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 514 (1944–2026) TX 133 (1983–2025) IL 100 (1985–2026) OH 61 (1983–2026) NY 44 (1987–2026) WA 33 (1988–2025) MI 33 (1928–2025) IN 32 (1986–2026) NJ 31 (1989–2024) AL 29 (1981–2023) MA 27 (1978–2024) PA 26 (1982–2026) MD 26 (1984–2025) FL 24 (1987–2025) CO 23 (1989–2025) GA 23 (1982–2023) MO 21 (1903–2025) CT 20 (1991–2022) NC 20 (1987–2025) WI 20 (1980–2025) LA 19 (1974–2025) MT 19 (1987–2020) OR 19 (1982–2026) OK 18 (1991–2025) NM 18 (1990–2022) MN 17 (1961–2014) AZ 17 (1984–2025) KS 16 (1993–2022) VA 16 (1993–2026) SC 14 (1987–2019) KY 13 (1989–2020) IA 13 (1988–2018) WV 11 (1985–2020) TN 11 (1991–2025) ID 11 (1986–2025) MS 10 (1997–2018) DC 10 (1992–2024) ME 9 (1983–2021) NE 8 (1993–2023) HI 8 (1992–2016) AR 7 (1993–2011) AK 7 (1994–2025) UT 7 (1983–2017) WY 6 (1997–2023) SD 5 (1990–2008) ND 5 (1993–2013) DE 4 (2009–2023) VI 3 (2012–2026) VT 3 (1990–2013) RI 2 (1986–1986) NV 2 (1990–2019)

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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