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18 North Carolina opinions name it 2 courts 1956–2025 4 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.
| Case | Followed | Cited |
|---|---|---|
State v. Paynegreen2 sentences2025See e.g., State v. Payne, 280 N.C. 170, 171 , 185 S.E.2d 101, 102 (1971) (“Ordinarily one who causes . . . the court to commit error is not in a position to repudiate his action or assign it as ground for a new trial.”); Frugard v. Pritchard, 338 N.C. 508, 512 , 450 S.E.2d 744, 746 (1994) (“A party may not complain of action which he induced.” (citations omitted)). -4- MCPHERSON V. 2025See e.g., State v. Payne, 280 N.C. 170, 171 , 185 S.E.2d 101, 102 (1971) (“Ordinarily one who causes . . . the court to commit error is not in a position to repudiate his action or assign it as ground for a new trial.”); Frugard v. Pritchard, 338 N.C. 508, 512 , 450 S.E.2d 744, 746 (1994) (“A party may not complain of action which he induced.” (citations omitted)). -4- MCPHERSON V. | 13 | 15 |
Frugard v. Pritchardgreen2 sentences2025See e.g., State v. Payne, 280 N.C. 170, 171 , 185 S.E.2d 101, 102 (1971) (“Ordinarily one who causes . . . the court to commit error is not in a position to repudiate his action or assign it as ground for a new trial.”); Frugard v. Pritchard, 338 N.C. 508, 512 , 450 S.E.2d 744, 746 (1994) (“A party may not complain of action which he induced.” (citations omitted)). -4- MCPHERSON V. 2025See e.g., State v. Payne, 280 N.C. 170, 171 , 185 S.E.2d 101, 102 (1971) (“Ordinarily one who causes . . . the court to commit error is not in a position to repudiate his action or assign it as ground for a new trial.”); Frugard v. Pritchard, 338 N.C. 508, 512 , 450 S.E.2d 744, 746 (1994) (“A party may not complain of action which he induced.” (citations omitted)). -4- MCPHERSON V. | 2 | 2 |
Overton v. Overtongreen2 sentences2009Invited error is not ground for a new trial."); Overton v. Overton, 260 N.C. 139, 144-45 , 132 S.E.2d 349, 353 (1963) ("However, in this case respondents may not assert the objection that the court wrongfully placed the burden of proof of the issue upon them" since "[t]hey requested in their prayer for instructions that the burden of proof be so placed, and the court complied."). 2009Invited error is not ground for a new trial."); Overton v. Overton, 260 N.C. 139, 144-45 , 132 S.E.2d 349, 353 (1963) ("However, in this case respondents may not assert the objection that the court wrongfully placed the burden of proof of the issue upon them" since "[t]hey requested in their prayer for instructions that the burden of proof be so placed, and the court complied."). | 2 | 2 |
Sumner v. . Sumnergreen2 sentences2023MILLER Opinion of the Court redactions to the video were for the benefit of Defendant; and (3) Defendant agreed to the admission of the redacted video and its publication to the jury.” “[U]nder the doctrine of invited error, a party cannot complain of a charge given at his request, or which is in substance the same as one asked by him[.]” Sumner v. Sumner, 227 N.C. 610, 613 , 44 S.E.2d 40, 41 (1947) (citations omitted); see also State v. Payne, 280 N.C. 170, 171 , 185 S.E.2d 101, 102 (1971) (“Ordinarily one who causes . . . the court to commit error is not in a position to repudiate his action 2023MILLER Opinion of the Court redactions to the video were for the benefit of Defendant; and (3) Defendant agreed to the admission of the redacted video and its publication to the jury.” “[U]nder the doctrine of invited error, a party cannot complain of a charge given at his request, or which is in substance the same as one asked by him[.]” Sumner v. Sumner, 227 N.C. 610, 613 , 44 S.E.2d 40, 41 (1947) (citations omitted); see also State v. Payne, 280 N.C. 170, 171 , 185 S.E.2d 101, 102 (1971) (“Ordinarily one who causes . . . the court to commit error is not in a position to repudiate his action | 1 | 1 |
State v. Gaineygreen2 sentences2018See State v. Gainey , 355 N.C. 73 , 93, 558 S.E.2d 463 , 477 (2002) ("Constitutional questions not raised and passed upon at trial will not be considered on appeal." (citation omitted) ); State v. Sharpe , 344 N.C. 190 , 194, 473 S.E.2d 3 , 5 (1996) ("[W]here a theory argued on appeal was not raised before the trial court, the law does not permit parties to swap horses between courts ... [for] a better mount ...." (citation and internal quotation marks omitted) ); State v. Payne , 280 N.C. 170 , 171, 185 S.E.2d 101 , 102 (1971) (explaining that where a defendant "causes (or ... joins in causin 2018See State v. Gainey , 355 N.C. 73 , 93, 558 S.E.2d 463 , 477 (2002) ("Constitutional questions not raised and passed upon at trial will not be considered on appeal." (citation omitted) ); State v. Sharpe , 344 N.C. 190 , 194, 473 S.E.2d 3 , 5 (1996) ("[W]here a theory argued on appeal was not raised before the trial court, the law does not permit parties to swap horses between courts ... [for] a better mount ...." (citation and internal quotation marks omitted) ); State v. Payne , 280 N.C. 170 , 171, 185 S.E.2d 101 , 102 (1971) (explaining that where a defendant "causes (or ... joins in causin | 1 | 1 |
State v. Gobalgreen1 sentence2014App. 308 , 319—20, 651 S.E.2d 279, 287 (2007) (“Statements elicited by a defendant on cross-examination are, even if error, invited error, by which a defendant cannot -12- be prejudiced as a matter of law.” (citations omitted)); State v. Payne, 280 N.C. 170, 171 , 185 S.E.2d 101, 102 (1971) (“[O]ne who causes . . . the court to commit error is not in a position to repudiate his action and assign it as ground for a new trial. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in North Carolina. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Sharpe
green
2 sentences2018See State v. Gainey , 355 N.C. 73 , 93, 558 S.E.2d 463 , 477 (2002) ("Constitutional questions not raised and passed upon at trial will not be considered on appeal." (citation omitted) ); State v. Sharpe , 344 N.C. 190 , 194, 473 S.E.2d 3 , 5 (1996) ("[W]here a theory argued on appeal was not raised before the trial court, the law does not permit parties to swap horses between courts ... [for] a better mount ...." (citation and internal quotation marks omitted) ); State v. Payne , 280 N.C. 170 , 171, 185 S.E.2d 101 , 102 (1971) (explaining that where a defendant "causes (or ... joins in causin 2018See State v. Gainey , 355 N.C. 73 , 93, 558 S.E.2d 463 , 477 (2002) ("Constitutional questions not raised and passed upon at trial will not be considered on appeal." (citation omitted) ); State v. Sharpe , 344 N.C. 190 , 194, 473 S.E.2d 3 , 5 (1996) ("[W]here a theory argued on appeal was not raised before the trial court, the law does not permit parties to swap horses between courts ... [for] a better mount ...." (citation and internal quotation marks omitted) ); State v. Payne , 280 N.C. 170 , 171, 185 S.E.2d 101 , 102 (1971) (explaining that where a defendant "causes (or ... joins in causin | 1 | 2018–2018 |
State v. Jones
green
2 sentences2015"It is well established that a defendant who causes or joins in causing the trial court to commit error is not in a position to repudiate his action and assign it as ground for a new trial." State v. Jones, 213 N.C.App. 59 , 67, 711 S.E.2d 791 , 796 (2011) (marks omitted). 2015"It is well established that a defendant who causes or joins in causing the trial court to commit error is not in a position to repudiate his action and assign it as ground for a new trial." State v. Jones, 213 N.C.App. 59 , 67, 711 S.E.2d 791 , 796 (2011) (marks omitted). | 1 | 2015–2015 |
State v. Barber
green
2 sentences2015In State v. Barber, 147 N.C.App. 69 , 74, 554 S.E.2d 413 , 416 (2001) (marks omitted), we further recognized that pursuant to North Carolina General Statutes § 15A-1443(c) "a defendant is not prejudiced ... by error resulting from his own conduct. 2015In State v. Barber, 147 N.C.App. 69 , 74, 554 S.E.2d 413 , 416 (2001) (marks omitted), we further recognized that pursuant to North Carolina General Statutes § 15A-1443(c) "a defendant is not prejudiced ... by error resulting from his own conduct. | 1 | 2015–2015 |
Medford v. Davis
green
1 sentence2001See State v. Payne, 280 N.C. 170, 185 , S.E.2d 101 (1971); Medford v. Davis, 62 N.C. | 1 | 2001–2001 |
Erickson v. Starling
green
2 sentences1968Ervin, J., stated in Erickson v. Starling, 235 N.C. 643 , 71 S.E. 2d 384 : “A motion for judgment on the pleadings is in the nature of a demurrer. ... 1968Ervin, J., stated in Erickson v. Starling, 235 N.C. 643 , 71 S.E. 2d 384 : “A motion for judgment on the pleadings is in the nature of a demurrer. ... | 1 | 1968–1968 |
State v. McIver
green
2 sentences1956In S. v. McIver, 231 N.C. 313 , 56 S.E. 2d 604 , the facts were as follows: On 7 January about 7:00 a.m. 1956In S. v. McIver, 231 N.C. 313 , 56 S.E. 2d 604 , the facts were as follows: On 7 January about 7:00 a.m. | 1 | 1956–1956 |
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.
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.