added claim (North Dakota) · Go Syfert
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added claim in North Dakota

15 North Dakota opinions name it 1 courts 1994–2018 0 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 (9)

CaseFollowedCited
Darby v. SWENSON, INC.green
nd · 2009 · cited in 1 North Dakota opinions naming this issue, 2018–2018
2 sentences

2018See Darby , 2009 ND 103 , ¶¶ 12-13, 767 N.W.2d 147 .

2018See Darby , 2009 ND 103 , ¶¶ 12-13, 767 N.W.2d 147 .

11
Hovden v. Lindgreen
nd · 1981 · cited in 1 North Dakota opinions naming this issue, 2012–2012
1 sentence

2012III [¶9] The Georges argue the district court erred in granting summary judgment to quiet title in Veeder’s favor on the basis of evidence presented and the court erred in denying amendment of their complaint to allow consideration of reformation of the deed. [¶10] In Hovden v. Lind , 301 N.W.2d 374, 378 (N.D. 1981), this Court held the term “minerals,” used in reservation language in a land sale contract, excludes gravel, clay, and scoria.

11
Cockrell v. Sparksgreen
ca11 · 2007 · cited in 1 North Dakota opinions naming this issue, 2009–2009
1 sentence

2009Cockrell v. Sparks, 510 F.3d 1307, 1310 (11th Cir.2007); Watson ex rel.

11
Olson v. City of West Fargogreen
nd · 1981 · cited in 1 North Dakota opinions naming this issue, 2007–2007
1 sentence

2007Olson , at 824-27, relied extensively on the United States Supreme Court’s decision in California v. LaRue, 409 U.S. 109, 118-19 , 93 S.Ct. 390 , 34 L.Ed.2d 342 (1972), which held that the conclusion embodied in a statute prohibiting nude dancing where liquor was sold “was not an irrational one,” and “[g]iven the added presumption in favor of the validity of the *135 state regulation in this area that the Twenty-first Amendment requires,” the challenged regulations passed constitutional muster.

11
Hagel v. Hagelgreen
nd · 1994 · cited in 1 North Dakota opinions naming this issue, 1997–1997
1 sentence

1997As we explained in Hagel v. Hagel, 512 N.W.2d 465, 467 (N.D.1994) (quoting Orke v. Olson, 411 N.W.2d 97, 100 (N.D.1987)), the added requirement of showing a change of custody is “compelled” or “required” “gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents ‘as the scales settle slightly toward first one parent and then the other.’ ” [¶ 18] We have described the burden facing a noncustodial parent seeking a change of custody as “ ‘a daunting, arduous task.’ ” Alvarez, 524 N.W.2d at 590 (quoting Johnson, 502

11
Johnson v. Schlotmangreen
nd · 1993 · cited in 1 North Dakota opinions naming this issue, 1997–1997
1 sentence

1997As we explained in Hagel v. Hagel, 512 N.W.2d 465, 467 (N.D.1994) (quoting Orke v. Olson, 411 N.W.2d 97, 100 (N.D.1987)), the added requirement of showing a change of custody is “compelled” or “required” “gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents ‘as the scales settle slightly toward first one parent and then the other.’ ” [¶ 18] We have described the burden facing a noncustodial parent seeking a change of custody as “ ‘a daunting, arduous task.’ ” Alvarez, 524 N.W.2d at 590 (quoting Johnson, 502

11
Blotske v. Leidholmgreen
nd · 1992 · cited in 1 North Dakota opinions naming this issue, 1997–1997
1 sentence

1997The heavy burden has a “deterrent effect on continuous litigation of custody which, left unchecked, generates cruel emotional and economic strain on all participants to the ultimate detriment of a child’s best interests.” Blotske v. Leidholm, 487 N.W.2d 607, 609 (N.D.1992).

11
Orke v. Olsongreen
nd · 1987 · cited in 1 North Dakota opinions naming this issue, 1997–1997
1 sentence

1997As we explained in Hagel v. Hagel, 512 N.W.2d 465, 467 (N.D.1994) (quoting Orke v. Olson, 411 N.W.2d 97, 100 (N.D.1987)), the added requirement of showing a change of custody is “compelled” or “required” “gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents ‘as the scales settle slightly toward first one parent and then the other.’ ” [¶ 18] We have described the burden facing a noncustodial parent seeking a change of custody as “ ‘a daunting, arduous task.’ ” Alvarez, 524 N.W.2d at 590 (quoting Johnson, 502

11
State v. Kreigergreen
nd · 1965 · cited in 1 North Dakota opinions naming this issue, 1994–1994
2 sentences

1994While the trial court gave an added instruction defining “recklessly,” State v. Kreiger, 138 N.W.2d 597, 600 (N.D.1965), clarifies that “a driver need not be proved guilty under both subsections.” Yet, I see small difference between the reckless conduct element in subsection 1, “disregard of the ... safety of others,” and the recklessness in subsection 2, “at a speed or in a manner ... likely to endanger any person.” I believe the endangerment element defines a degree of culpability significantly greater than the ordinary negligence element, “without due caution.” After all, a basic rule of st

1994While the trial court gave an added instruction defining "recklessly," State v. Kreiger, 138 N.W.2d 597, 600 (N.D.1965), clarifies that "a driver need not be proved guilty under both subsections." Yet, I see small difference between the reckless conduct element in subsection 1, "disregard of the ... safety of others," and the recklessness in subsection 2, "at a speed or in a manner ... likely to endanger any person." I believe the endangerment element defines a degree of culpability significantly greater than the ordinary negligence element, "without due caution." After all, a basic rule of st

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 (11)

CaseCitedYears
Johnson v. Hovland green
nd · 2011
2 sentences

2012Courts have said that “an amendment is futile for purposes of determining whether leave to amend should be granted, if the added claim would not survive a motion for summary judgment.” Id. (quotations omitted).

2012Courts have said that “an amendment is futile for purposes of determining whether leave to amend should be granted, if the added claim would not survive a motion for summary judgment.” Id. (quotations omitted).

42011–2012
Benz Farm, LLP v. Cavendish Farms, Inc. green
nd · 2011
2 sentences

2018Benz Farm, LLP v. Cavendish Farms, Inc., 2011 ND 184, ¶ 26 , 803 N.W.2d 818 . [¶18] The district court denied Bakke’s request to amend the complaint after determining the amendment would be futile.

2018Benz Farm, LLP v. Cavendish Farms, Inc. , 2011 ND 184 , ¶ 26, 803 N.W.2d 818 . [¶ 18] The district court denied Bakke's request to amend the complaint after determining the amendment would be futile.

32018–2018
Benz Farm, LLP v. Cavendish Farms, Inc. green
nd · 2011
2 sentences

2018Benz Farm, LLP v. Cavendish Farms, Inc., 2011 ND 184, ¶ 26 , 803 N.W.2d 818 . [¶18] The district court denied Bakke’s request to amend the complaint after determining the amendment would be futile.

2018Benz Farm, LLP v. Cavendish Farms, Inc. , 2011 ND 184 , ¶ 26, 803 N.W.2d 818 . [¶ 18] The district court denied Bakke's request to amend the complaint after determining the amendment would be futile.

32018–2018
Lovin v. Lovin green
nd · 1997
2 sentences

2012Myers v. Myers, 1999 ND 194, ¶ 10 , 601 N.W.2d 264 (citations and quotations omitted). “ ‘The added requirement of showing a change of primary residential responsibility is compelled or required gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents as the scales settle slightly toward first one parent and then the other.’ ” Neustel, at ¶ 12 (quoting Lovin v. Lovin, 1997 ND 55, ¶ 17 , 561 N.W.2d 612 ). [¶ 26] The district court considered and made findings about each of the best interest factors, finding that

2012Myers v. Myers, 1999 ND 194, ¶ 10 , 601 N.W.2d 264 (citations and quotations omitted). “ ‘The added requirement of showing a change of primary residential responsibility is compelled or required gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents as the scales settle slightly toward first one parent and then the other.’ ” Neustel, at ¶ 12 (quoting Lovin v. Lovin, 1997 ND 55, ¶ 17 , 561 N.W.2d 612 ). [¶ 26] The district court considered and made findings about each of the best interest factors, finding that

22012–2012
Myers v. Myers green
nd · 1999
2 sentences

2012Myers v. Myers, 1999 ND 194, ¶ 10 , 601 N.W.2d 264 (citations and quotations omitted). “ ‘The added requirement of showing a change of primary residential responsibility is compelled or required gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents as the scales settle slightly toward first one parent and then the other.’ ” Neustel, at ¶ 12 (quoting Lovin v. Lovin, 1997 ND 55, ¶ 17 , 561 N.W.2d 612 ). [¶ 26] The district court considered and made findings about each of the best interest factors, finding that

2012Myers v. Myers, 1999 ND 194, ¶ 10 , 601 N.W.2d 264 (citations and quotations omitted). “ ‘The added requirement of showing a change of primary residential responsibility is compelled or required gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents as the scales settle slightly toward first one parent and then the other.’ ” Neustel, at ¶ 12 (quoting Lovin v. Lovin, 1997 ND 55, ¶ 17 , 561 N.W.2d 612 ). [¶ 26] The district court considered and made findings about each of the best interest factors, finding that

22012–2012
Johnson v. Hovland green
nd · 2011
2 sentences

2011Johnson, 2011 ND 64, ¶ 9 , 795 N.W.2d 294 . [¶ 27] The district court provided a thorough analysis of its reasoning for denying the motion to amend the complaint, explaining that the motion was untimely, the amendment at such a late date would have been unfairly prejudicial to Cavendish, the proposed new claims were not supported by substantial evidence, and the amendments would have been futile.

2011Johnson , 2011 ND 64, ¶ 9 , 795 N.W.2d 294 . [¶27] The district court provided a thorough analysis of its reasoning for denying the motion to amend the complaint, explaining that the motion was untimely, the amendment at such a late date would have been unfairly prejudicial to Cavendish, the proposed new claims were not supported by substantial evidence, and the amendments would have been futile.

22011–2011
State v. Neustel green
nd · 2010
1 sentence

2014“The added requirement of showing a change of primary residential responsibility is ‘compelled’ or ‘required’ gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents as the scales settle slightly toward first one parent and then the other.” Gussiaas v. Neustel, 2010 ND 216, ¶ 12 , 790 N.W.2d 476 (quotation marks omitted) (citation omitted).

12014–2014
Gussiaas v. Neustel green
nd · 2010
1 sentence

2014“The added requirement of showing a change of primary residential responsibility is ‘compelled’ or ‘required’ gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents as the scales settle slightly toward first one parent and then the other.” Gussiaas v. Neustel, 2010 ND 216, ¶ 12 , 790 N.W.2d 476 (quotation marks omitted) (citation omitted).

12014–2014
44 Liquormart, Inc. v. Rhode Island green
scotus · 1996
2 sentences

2007However, in 44 Liquormart, Inc. v. Rhode Island, 517 U.S. 484, 515-16 , 116 S.Ct. 1495 , 134 L.Ed.2d 711 (1996), the Supreme Court disavowed LaRue’s reliance on the Twenty-first Amendment, but otherwise upheld the precedential value of the case because “the Court’s analysis in LaRue would have led to precisely the same result if it had placed no reliance on the Twenty-first Amendment.” Since then, courts have “struggled in deciding whether adult entertainment liquor regulations should fall under the analytical framework of zoning regulations or public indecency regulations” and have devised va

2007However, in 44 Liquormart, Inc. v. Rhode Island, 517 U.S. 484, 515-16 , 116 S.Ct. 1495 , 134 L.Ed.2d 711 (1996), the Supreme Court disavowed LaRue’s reliance on the Twenty-first Amendment, but otherwise upheld the precedential value of the case because “the Court’s analysis in LaRue would have led to precisely the same result if it had placed no reliance on the Twenty-first Amendment.” Since then, courts have “struggled in deciding whether adult entertainment liquor regulations should fall under the analytical framework of zoning regulations or public indecency regulations” and have devised va

12007–2007
California v. LaRue green
scotus · 1973
2 sentences

2007Olson , at 824-27, relied extensively on the United States Supreme Court’s decision in California v. LaRue, 409 U.S. 109, 118-19 , 93 S.Ct. 390 , 34 L.Ed.2d 342 (1972), which held that the conclusion embodied in a statute prohibiting nude dancing where liquor was sold “was not an irrational one,” and “[g]iven the added presumption in favor of the validity of the *135 state regulation in this area that the Twenty-first Amendment requires,” the challenged regulations passed constitutional muster.

2007Olson , at 824-27, relied extensively on the United States Supreme Court’s decision in California v. LaRue, 409 U.S. 109, 118-19 , 93 S.Ct. 390 , 34 L.Ed.2d 342 (1972), which held that the conclusion embodied in a statute prohibiting nude dancing where liquor was sold “was not an irrational one,” and “[g]iven the added presumption in favor of the validity of the *135 state regulation in this area that the Twenty-first Amendment requires,” the challenged regulations passed constitutional muster.

12007–2007
Alvarez v. Carlson green
nd · 1994
1 sentence

1997As we explained in Hagel v. Hagel, 512 N.W.2d 465, 467 (N.D.1994) (quoting Orke v. Olson, 411 N.W.2d 97, 100 (N.D.1987)), the added requirement of showing a change of custody is “compelled” or “required” “gives some finality to a trial court’s original custody decision and helps ensure that a child is not bounced back and forth between parents ‘as the scales settle slightly toward first one parent and then the other.’ ” [¶ 18] We have described the burden facing a noncustodial parent seeking a change of custody as “ ‘a daunting, arduous task.’ ” Alvarez, 524 N.W.2d at 590 (quoting Johnson, 502

11997–1997

Statutes the citing opinions construe

ND § N.D. Cent. Code § 51-15-02 (5) ND § N.D. Cent. Code § 32-03-09 (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

PA 36 (1908–2026) CA 29 (1861–2025) NJ 27 (1942–2023) NY 22 (1876–2018) TX 21 (1916–2021) ND 15 (1994–2018) LA 12 (1914–2015) CT 11 (1963–2004) MI 10 (1897–2024) WA 10 (1932–2017) DC 9 (1984–2009) FL 8 (1930–2014) WI 8 (1969–2018) IA 7 (1917–2026) MO 7 (1916–2017) IL 7 (1914–2024) OH 6 (2005–2026) IN 6 (1875–1987) MD 6 (1938–2013) AK 6 (1983–2021) AL 5 (1934–2017) DE 4 (1986–2022) AR 4 (1944–2017) OK 4 (1975–2017) CO 4 (1981–2017) OR 3 (1977–2025) NC 3 (1904–1990) VA 3 (1941–2000) GA 3 (1981–2004) KS 3 (1923–1979) MA 3 (2000–2019) WV 3 (1893–1989) KY 3 (1928–2015) UT 2 (2007–2024) VT 2 (1996–2006) TN 2 (1924–1982) RI 2 (2000–2010) ME 2 (2006–2014) SD 2 (1934–2000) MN 2 (1983–1990) AZ 2 (1996–1999)

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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