disputable presumption (North Dakota) · Go Syfert
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disputable presumption in North Dakota

20 North Dakota opinions name it 2 courts 1954–2026 1 in the last five years

The cases below were cited by North Dakota 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
Willman v. Harty Co.green
nd · 1981 · cited in 3 North Dakota opinions naming this issue, 2012–2015
2 sentences

2015(Emphasis added.) [¶ 30] Although Aggregate suggests its leases were renewed as a matter of law *865 under this statute, “our Court has held section 47-16-06, N.D.C.C., does not automatically renew a lease for up to one year when a tenant holds over and a landlord accepts a rent payment; rather, the ‘section only raises a disputable presumption that the lease was renewed on the same terms.’” Working Capital # 1, LLC v. Quality Auto Body, Inc., 2012 ND 115, ¶ 8 , 817 N.W.2d 346 (quoting Willman v. Harty Co., 305 N.W.2d 909, 911 (N.D.1981)). [¶ 31] Here, in construing the relevant lease provisio

2012However, our Court has held section 47-16-06, N.D.C.C., does not automatically renew a lease for up to one year when a tenant holds over and a landlord accepts a rent payment; rather, the “section only raises a disputable presumption that the lease was renewed on the same terms.” Willman v. Harty Co., 305 N.W.2d 909, 911 (N.D.1981) (citing Foster v. Nat’l Tea Co., 74 N.D. 37 , 19 N.W.2d 760, 763 (1945)). [¶ 9] The trial court specifically found that the presumption was rebutted by the evidence and entered specific findings of fact.

33
Foster v. National Tea Co.green
nd · 1945 · cited in 3 North Dakota opinions naming this issue, 1981–2012
2 sentences

2012However, our Court has held section 47-16-06, N.D.C.C., does not automatically renew a lease for up to one year when a tenant holds over and a landlord accepts a rent payment; rather, the “section only raises a disputable presumption that the lease was renewed on the same terms.” Willman v. Harty Co., 305 N.W.2d 909, 911 (N.D.1981) (citing Foster v. Nat’l Tea Co., 74 N.D. 37 , 19 N.W.2d 760, 763 (1945)). [¶ 9] The trial court specifically found that the presumption was rebutted by the evidence and entered specific findings of fact.

2012However, our Court has held section 47-16-06, N.D.C.C., does not automatically renew a lease for up to one year when a tenant holds over and a landlord accepts a rent payment; rather, the “section only raises a disputable presumption that the lease was renewed on the same terms.” Willman v. Harty Co., 305 N.W.2d 909, 911 (N.D.1981) (citing Foster v. Nat’l Tea Co., 74 N.D. 37 , 19 N.W.2d 760, 763 (1945)). [¶ 9] The trial court specifically found that the presumption was rebutted by the evidence and entered specific findings of fact.

23
Haugland v. City of Bismarckgreen
nd · 2014 · cited in 2 North Dakota opinions naming this issue, 2020–2020
2 sentences

2020No. 24 v. Porter, 130 N.W.2d 76, 80 (N.D. 1964); see also Haugland v. City of Bismarck, 2014 ND 51, ¶ 12 , 843 N.W.2d 840 (“Under N.D.C.C. § 31-11-03(15), there is a disputable presumption that an official duty has been performed regularly, which may be contradicted.”). [¶13] “A party against whom a presumption is directed has the burden of rebutting the presumption by proving the nonexistence of the presumed fact is more probable than its existence.” Stenehjem ex rel State v. Nat’l Audubon Soc’y, Inc., 2014 ND 71, ¶ 25 , 844 N.W.2d 892 .

2020No. 24 v. Porter, 130 N.W.2d 76, 80 (N.D. 1964); see also Haugland v. City of Bismarck, 2014 ND 51, ¶ 12 , 843 N.W.2d 840 (“Under N.D.C.C. § 31-11-03(15), there is a disputable presumption that an official duty has been performed regularly, which may be contradicted.”). [¶13] “A party against whom a presumption is directed has the burden of rebutting the presumption by proving the nonexistence of the presumed fact is more probable than its existence.” Stenehjem ex rel State v. Nat’l Audubon Soc’y, Inc., 2014 ND 71, ¶ 25 , 844 N.W.2d 892 .

22
Linden School District No. 24 v. Portergreen
nd · 1964 · cited in 2 North Dakota opinions naming this issue, 2020–2026
2 sentences

2026Dist. case, we emphasized the disputable presumption means “where there is evidence that official duty has not been regularly performed, the burden of going forward with the evidence is cast upon the officials whose acts are challenged.” Id. [¶56] The presumption of regularity has been applied to when public bodies engage in an executive session.

2020No. 24 v. Porter, 130 N.W.2d 76, 80 (N.D. 1964); see also Haugland v. City of Bismarck, 2014 ND 51, ¶ 12 , 843 N.W.2d 840 (“Under N.D.C.C. § 31-11-03(15), there is a disputable presumption that an official duty has been performed regularly, which may be contradicted.”). [¶13] “A party against whom a presumption is directed has the burden of rebutting the presumption by proving the nonexistence of the presumed fact is more probable than its existence.” Stenehjem ex rel State v. Nat’l Audubon Soc’y, Inc., 2014 ND 71, ¶ 25 , 844 N.W.2d 892 .

12
Stenehjem, ex rel. v. National Audubon Society, Inc.green
nd · 2014 · cited in 2 North Dakota opinions naming this issue, 2020–2020
2 sentences

2020No. 24 v. Porter, 130 N.W.2d 76, 80 (N.D. 1964); see also Haugland v. City of Bismarck, 2014 ND 51, ¶ 12 , 843 N.W.2d 840 (“Under N.D.C.C. § 31-11-03(15), there is a disputable presumption that an official duty has been performed regularly, which may be contradicted.”). [¶13] “A party against whom a presumption is directed has the burden of rebutting the presumption by proving the nonexistence of the presumed fact is more probable than its existence.” Stenehjem ex rel State v. Nat’l Audubon Soc’y, Inc., 2014 ND 71, ¶ 25 , 844 N.W.2d 892 .

2020No. 24 v. Porter, 130 N.W.2d 76, 80 (N.D. 1964); see also Haugland v. City of Bismarck, 2014 ND 51, ¶ 12 , 843 N.W.2d 840 (“Under N.D.C.C. § 31-11-03(15), there is a disputable presumption that an official duty has been performed regularly, which may be contradicted.”). [¶13] “A party against whom a presumption is directed has the burden of rebutting the presumption by proving the nonexistence of the presumed fact is more probable than its existence.” Stenehjem ex rel State v. Nat’l Audubon Soc’y, Inc., 2014 ND 71, ¶ 25 , 844 N.W.2d 892 .

12
State v. Ericksongreen
nd · 1976 · cited in 2 North Dakota opinions naming this issue, 1984–1986
2 sentences

1986Erickson, supra. VandeHoven also argues that pursuant to § 39-20-07(6) (1983) (since amended but applicable here), the method, equipment, and persons used by the State Toxicologist to perform the blood test must be approved by the State Toxicologist and that such approval must be filed with the clerk of the district court in each County.

1984In State v. Erickson, 241 N.W.2d 854, 865 (N.D.1976), we said that a laboratory technician performing a service under the supervision and direction of the State Toxicologist is performing an official act which is entitled to a disputable presumption of regularity pursuant to Section 31-11-03(15), N.D.C.C.

12
Wilson v. Divide Countygreen
nd · 1956 · cited in 1 North Dakota opinions naming this issue, 2014–2014
2 sentences

2014See Wilson v. Divide Cnty., 76 N.W.2d 896, 900-01 (N.D.1956); Coulter v. Ramberg, 79 N.D. 208, 213-14 , 55 N.W.2d 516, 518 (1952). [¶ 13] The district court granted Bismarck summary judgment, meaning Haugland was entitled to all inferences favorable to him, including all inferences unfavorable to Bismarck, in relation to Bismarck’s claim it cannot find the crucial page of its official public record.

2014See Wilson v. Divide Cnty. , 76 N.W.2d 896, 900-01 (N.D. 1956); Coulter v. Ramberg , 79 N.D. 208 , 213- 14, 55 N.W.2d 516, 518 (1952). [¶13] The district court granted Bismarck summary judgment, meaning Haugland was entitled to all inferences favorable to him, including all inferences unfavorable to Bismarck, in relation to Bismarck’s claim it cannot find the crucial page of its official public record.

11
Thompson v. Nettumgreen
nd · 1968 · cited in 1 North Dakota opinions naming this issue, 2014–2014
2 sentences

2014Section 31-11-03(15), N.D.C.C., establishes as a disputable presumption that an “official duty has been performed regularly.” This Court has previously held that “identical conflicting presumptions balance and cancel each other.” Thompson v. Nettum, 163 N.W.2d 91, 97 (N.D.1968).

2014Section 31-11-03(15), N.D.C.C., establishes as a disputable presumption that an “official duty has been performed regularly.” This Court has previously held that “identical conflicting presumptions balance and cancel each other.” Thompson v. Nettum , 163 N.W.2d 91, 97 (N.D. 1968).

11
Coulter v. Ramberggreen
nd · 1952 · cited in 1 North Dakota opinions naming this issue, 2014–2014
2 sentences

2014See Wilson v. Divide Cnty. , 76 N.W.2d 896, 900-01 (N.D. 1956); Coulter v. Ramberg , 79 N.D. 208 , 213- 14, 55 N.W.2d 516, 518 (1952). [¶13] The district court granted Bismarck summary judgment, meaning Haugland was entitled to all inferences favorable to him, including all inferences unfavorable to Bismarck, in relation to Bismarck’s claim it cannot find the crucial page of its official public record.

2014See Wilson v. Divide Cnty. , 76 N.W.2d 896, 900-01 (N.D. 1956); Coulter v. Ramberg , 79 N.D. 208 , 213- 14, 55 N.W.2d 516, 518 (1952). [¶13] The district court granted Bismarck summary judgment, meaning Haugland was entitled to all inferences favorable to him, including all inferences unfavorable to Bismarck, in relation to Bismarck’s claim it cannot find the crucial page of its official public record.

11
Myra Foundation v. Harveygreen
nd · 1959 · cited in 1 North Dakota opinions naming this issue, 1998–1998
1 sentence

1998Myra Found. v. Harvey, 100 N.W.2d 435, 438 (N.D.1959).

11
Erickson v. Director, North Dakota Department of Transportationgreen
nd · 1993 · cited in 1 North Dakota opinions naming this issue, 1993–1993
1 sentence

1993See Erickson, 507 N.W.2d at 589 .

11
State v. VandeHovengreen
nd · 1986 · cited in 1 North Dakota opinions naming this issue, 1990–1990
1 sentence

1990See State v. VandeHoven, 388 N.W.2d 857, 859 (N.D.1986).

11
Auto-Owners Insurance Co. v. State Farm Mutual Automobile Insurance Co.green
nd · 1989 · cited in 1 North Dakota opinions naming this issue, 1990–1990
1 sentence

1990NDCC 31 — 11— 03(24); Auto-Owners Insurance Company v. State Farm Mutual Automobile Insurance Company, 434 N.W.2d 348, 350 (N.D.1989).

11
Newell v. McMurraygreen
nd · 1924 · cited in 1 North Dakota opinions naming this issue, 1986–1986
2 sentences

1986Parties may by agreement “give to fixtures the legal character of realty or personalty at their option.” Newell v. McMurray, 51 N.D. 901 , 201 N.W. 845, 847 (1924).

1986Parties may by agreement “give to fixtures the legal character of realty or personalty at their option.” Newell v. McMurray, 51 N.D. 901 , 201 N.W. 845, 847 (1924).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
Working Capital 1, LLC v. Quality Auto Body, Inc. green
nd · 2012
2 sentences

2015(Emphasis added.) [¶ 30] Although Aggregate suggests its leases were renewed as a matter of law *865 under this statute, “our Court has held section 47-16-06, N.D.C.C., does not automatically renew a lease for up to one year when a tenant holds over and a landlord accepts a rent payment; rather, the ‘section only raises a disputable presumption that the lease was renewed on the same terms.’” Working Capital # 1, LLC v. Quality Auto Body, Inc., 2012 ND 115, ¶ 8 , 817 N.W.2d 346 (quoting Willman v. Harty Co., 305 N.W.2d 909, 911 (N.D.1981)). [¶ 31] Here, in construing the relevant lease provisio

2015(Emphasis added.) [¶ 30] Although Aggregate suggests its leases were renewed as a matter of law *865 under this statute, “our Court has held section 47-16-06, N.D.C.C., does not automatically renew a lease for up to one year when a tenant holds over and a landlord accepts a rent payment; rather, the ‘section only raises a disputable presumption that the lease was renewed on the same terms.’” Working Capital # 1, LLC v. Quality Auto Body, Inc., 2012 ND 115, ¶ 8 , 817 N.W.2d 346 (quoting Willman v. Harty Co., 305 N.W.2d 909, 911 (N.D.1981)). [¶ 31] Here, in construing the relevant lease provisio

12015–2015
Working Capital 1 v. Quality Auto Body green
nd · 2012
2 sentences

2015(Emphasis added.) [¶ 30] Although Aggregate suggests its leases were renewed as a matter of law *865 under this statute, “our Court has held section 47-16-06, N.D.C.C., does not automatically renew a lease for up to one year when a tenant holds over and a landlord accepts a rent payment; rather, the ‘section only raises a disputable presumption that the lease was renewed on the same terms.’” Working Capital # 1, LLC v. Quality Auto Body, Inc., 2012 ND 115, ¶ 8 , 817 N.W.2d 346 (quoting Willman v. Harty Co., 305 N.W.2d 909, 911 (N.D.1981)). [¶ 31] Here, in construing the relevant lease provisio

2015(Emphasis added.) [¶ 30] Although Aggregate suggests its leases were renewed as a matter of law *865 under this statute, “our Court has held section 47-16-06, N.D.C.C., does not automatically renew a lease for up to one year when a tenant holds over and a landlord accepts a rent payment; rather, the ‘section only raises a disputable presumption that the lease was renewed on the same terms.’” Working Capital # 1, LLC v. Quality Auto Body, Inc., 2012 ND 115, ¶ 8 , 817 N.W.2d 346 (quoting Willman v. Harty Co., 305 N.W.2d 909, 911 (N.D.1981)). [¶ 31] Here, in construing the relevant lease provisio

12015–2015
Sprague v. Evanson green
nd · 2012
2 sentences

2014“Whether a presumption arises, and whether a presumption has been rebutted, are questions of fact governed by the clearly erroneous standard of review under N.D.R.Civ.P. 52(a).” In re Estate of Clemetson, 2012 ND 28, ¶ 11 , 812 N.W.2d 388 . [¶ 26] The district court found that Audubon filed the deed in question with the Stutsman County Recorder in November, 1988.

2014“Whether a presumption arises, and whether a presumption has been rebutted, are questions of fact governed by the clearly erroneous standard of review under N.D.R.Civ.P. 52(a).” In re Estate of Clemetson , 2012 ND 28, ¶ 11 , 812 N.W.2d 388 . [¶26] The district court found that Audubon filed the deed in question with the Stutsman County Recorder in November, 1988.

12014–2014
Estate of Clemetson green
nd · 2012
2 sentences

2014“Whether a presumption arises, and whether a presumption has been rebutted, are questions of fact governed by the clearly erroneous standard of review under N.D.R.Civ.P. 52(a).” In re Estate of Clemetson, 2012 ND 28, ¶ 11 , 812 N.W.2d 388 . [¶ 26] The district court found that Audubon filed the deed in question with the Stutsman County Recorder in November, 1988.

2014“Whether a presumption arises, and whether a presumption has been rebutted, are questions of fact governed by the clearly erroneous standard of review under N.D.R.Civ.P. 52(a).” In re Estate of Clemetson , 2012 ND 28, ¶ 11 , 812 N.W.2d 388 . [¶26] The district court found that Audubon filed the deed in question with the Stutsman County Recorder in November, 1988.

12014–2014
McManus v. Commow green
nd · 1901
2 sentences

1986Since the purpose of the statute was to abrogate the common-law requirement of proof of execution by testimony of subscribing witnesses [McManus v. Commow, 10 N.D. 340 , 87 N.W. 8 (1901) ], it is questionable whether use of the word "not” in the second sentence resulted from intention or oversight. 6 .

1986Since the purpose of the statute was to abrogate the common-law requirement of proof of execution by testimony of subscribing witnesses [McManus v. Commow, 10 N.D. 340 , 87 N.W. 8 (1901) ], it is questionable whether use of the word "not” in the second sentence resulted from intention or oversight. 6 .

11986–1986
Fancher v. North Dakota Workmen's Compensation Bureau neutral
nd · 1963
1 sentence

1976State v. Berger, 148 N.W.2d 331 (N.D.1966); Fancher v. North Dakota Workmen’s Compensation Bureau, 123 N.W.2d 105 (N.D.1963).

11976–1976
State v. Berger green
nd · 1966
1 sentence

1976State v. Berger, 148 N.W.2d 331 (N.D.1966); Fancher v. North Dakota Workmen’s Compensation Bureau, 123 N.W.2d 105 (N.D.1963).

11976–1976
Cameron v. Great Northern Railway Co. neutral
nd · 1898
2 sentences

1968Cameron v. Great Northern Railway Co., 8 N.D. 124 , 77 N.W. 1016 (1898); Kunkel et al. v. Minneapolis, St.

1968Cameron v. Great Northern Railway Co., 8 N.D. 124 , 77 N.W. 1016 (1898); Kunkel et al. v. Minneapolis, St.

11968–1968
St. Leger's Appeal from Probate green
conn · 1867
2 sentences

1954Leger's Appeal, 34 Conn. 434 , 91 Am.Dec. 735, it is held that when the relation of attorney and client subsists between the testator and legatee and the will is drawn by the latter, undue influence will be presumed but this presumption is one of fact which may be rebutted by proper evidence that satisfies the jury.

1954Leger’s Appeal, 34 Conn. 434 , 91 Am.Dec. 735, it is held that when the relation of attorney and client subsists between the testator and legatee and the will is drawn by the latter, undue influence will be presumed but this presumption is one of fact which may be rebutted by proper evidence that satisfies the jury.

11954–1954
Mar Shee v. Maryland Assurance Corp. green
cal · 1922
2 sentences

1954In Mar Shee v. Maryland Assurance Corp., 190 Cal. 1 , 210 P. 269 , cited by plaintiff, it is held that a disputable presumption has no weight as against a fact proved by the uncontra-dicted testimony of a party or of his witnesses under circumstances which afford no indication that the testimony is the product of mistake or inadvertence and when the fact so proved is wholly irreconcilable with the presumption.

1954In Mar Shee v. Maryland Assurance Corp., 190 Cal. 1 , 210 P. 269 , cited by plaintiff, it is held that a disputable presumption has no weight as against a fact proved by the uncontra-dicted testimony of a party or of his witnesses under circumstances which afford no indication that the testimony is the product of mistake or inadvertence and when the fact so proved is wholly irreconcilable with the presumption.

11954–1954

Statutes the citing opinions construe

ND § N.D. Cent. Code § 31-11-03 (11) ND § N.D. Cent. Code § 39-20-07 (4) ND § N.D. Cent. Code § 47-16-06 (4) ND § N.D. Cent. Code § 31-09-10 (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 100 (1913–2014) OR 63 (1897–2016) MT 34 (1915–2023) ND 20 (1954–2026) VT 4 (1938–2005) MO 4 (1898–1909) NV 3 (1910–2019) NY 3 (1912–1940) NM 3 (1916–1953) ME 3 (1963–1971)

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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