futility exception (North Carolina) · Go Syfert
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futility exception in North Carolina

12 North Carolina opinions name it 2 courts 2000–2025 1 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 (6)

CaseFollowedCited
Norman v. Nash Johnson & Sons' Farms, Inc.green
ncctapp · 2000 · cited in 6 North Carolina opinions naming this issue, 2000–2025
2 sentences

2017App. at 409 , 537 S.E.2d at 261 (holding that the futility exception under the pre- 1995 BCA arises when “corporate management is under control of the guilty parties . . . since the guilty parties would not comply with the request” (quoting Murphy v. City of Greensboro, 190 N.C. 268 , 275–76, 129 S.E. 614 , 617–19 (1925))). 28.

2017The court observed that the futility exception was “grounded in the ancient principle that the law does not require a person to do a vain, or futile, act.” Id. at 408, 537 S.E.2d at 261 (citing Seaboard Air Line R.R. v. Atl.

26
Seaboard Air Line Railroad v. Atlantic Coast Line Railroadgreen
nc · 1954 · cited in 2 North Carolina opinions naming this issue, 2000–2017
2 sentences

2017Coast Line R.R., 240 N.C. 495, 515 , 82 S.E.2d 771, 785 (1954)). 27.

2017Coast Line R.R., 240 N.C. 495, 515 , 82 S.E.2d 771, 785 (1954)). 27.

22
Dunn v. Ceccarelligreen
gactapp · 1997 · cited in 2 North Carolina opinions naming this issue, 2000–2000
2 sentences

2000Gen.Stat. § 55-7-42 "has eliminated the futility exception to the demand requirement." Norman v. Nash Johnson & Sons' Farms, Inc., ___ N.C.App. ____, 537 S.E.2d 248 (2000); accord Dunn v. Ceccarelli, 227 Ga.App. 505 , 489 S.E.2d 563 (1997) (considering OCGA § 14-2-742, a statute virtually identical to N.C.

2000Gen.Stat. § 55-7-42 "has eliminated the futility exception to the demand requirement." Norman v. Nash Johnson & Sons' Farms, Inc., ___ N.C.App. ____, 537 S.E.2d 248 (2000); accord Dunn v. Ceccarelli, 227 Ga.App. 505 , 489 S.E.2d 563 (1997) (considering OCGA § 14-2-742, a statute virtually identical to N.C.

22
Allen v. Ferreragreen
ncctapp · 2000 · cited in 2 North Carolina opinions naming this issue, 2014–2015
2 sentences

2015Allen & Brock Const. Co., Inc. v. Ferrera, 141 N.C.App. 284 , 288, 540 S.E.2d 761 , 765 (2000) (noting that section 55-7-40(b) allowed for a futility exception to the demand requirement where the directors in control of the corporation were alleged of wrongdoing).

2014See Allen v. Ferrera, 141 N.C.

12
Roney v. Joynergreen
ncctapp · 1987 · cited in 1 North Carolina opinions naming this issue, 2017–2017
1 sentence

2017The court observed that the futility exception was “grounded in the ancient principle that the law does not require a person to do a vain, or futile, act.” Id. at 408, 537 S.E.2d at 261 (citing Seaboard Air Line R.R. v. Atl.

11
Winters v. First Union Corp.green
ncbizct · 2001 · cited in 1 North Carolina opinions naming this issue, 2003–2003
1 sentence

2003“Derivative actions are also subject to several procedural protections against litigation agency costs, including: the contemporaneous ownership requirement, posting security for expense statutes, and most importantly, the demand requirement.” North Carolina has elected to eliminate the futility test and require demand under all circumstances and does not require posting security for expenses. [12] Winters v. First Union, 2001 NCBC 8 n.1 (No. 01 CVS 5362, Mecklenburg Super Ct. July 13, 2002) (Tennille, J.). [13] First Union Corp. v. SunTrust, Inc., 2001 NCBC 9 (No. 01 CVS 10075, Mecklenburg Su

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 (6)

CaseCitedYears
Greene v. Shoemaker green
ncbizct · 1998
2 sentences

2008Id. at ¶¶ 41–81.

2000Id. at 19- 22.

22000–2008
Murphy v. City of Greensboro green
nc · 1925
2 sentences

2017App. at 409 , 537 S.E.2d at 261 (holding that the futility exception under the pre- 1995 BCA arises when “corporate management is under control of the guilty parties . . . since the guilty parties would not comply with the request” (quoting Murphy v. City of Greensboro, 190 N.C. 268 , 275–76, 129 S.E. 614 , 617–19 (1925))). 28.

2017App. at 409 , 537 S.E.2d at 261 (holding that the futility exception under the pre- 1995 BCA arises when “corporate management is under control of the guilty parties . . . since the guilty parties would not comply with the request” (quoting Murphy v. City of Greensboro, 190 N.C. 268 , 275–76, 129 S.E. 614 , 617–19 (1925))). 28.

12017–2017
Barger v. McCoy Hillard & Parks green
nc · 1997
2 sentences

2015Given our ruling that the POA, and not plaintiffs, has standing to pursue these claims against the third parties because of the POA's actions following plaintiffs' demands, we need not address: (1) whether plaintiffs' derivative claims were rendered moot upon the filing of the POA's intervenor complaint; (2) the Developers' argument that some plaintiffs were not members of the POA at the time of the alleged wrongdoing; or (3) arguments pertaining to the rule in Barger v. McCoy Hillard & Parks, 346 N.C. 650 , 488 S.E.2d 215 (1997).

2015Given our ruling that the POA, and not plaintiffs, has standing to pursue these claims against the third parties because of the POA's actions following plaintiffs' demands, we need not address: (1) whether plaintiffs' derivative claims were rendered moot upon the filing of the POA's intervenor complaint; (2) the Developers' argument that some plaintiffs were not members of the POA at the time of the alleged wrongdoing; or (3) arguments pertaining to the rule in Barger v. McCoy Hillard & Parks, 346 N.C. 650 , 488 S.E.2d 215 (1997).

12015–2015
Allen Ex Rel. Allen & Brock v. Ferrera green
ncctapp · 2000
1 sentence

2015Allen & Brock Const. Co., Inc. v. Ferrera, 141 N.C.App. 284 , 288, 540 S.E.2d 761 , 765 (2000) (noting that section 55-7-40(b) allowed for a futility exception to the demand requirement where the directors in control of the corporation were alleged of wrongdoing).

12015–2015
Bovis Constr. Corp. v. Western Mass. Life Care Corp. neutral
nc · 2000
1 sentence

2000"The general rule in statutory construction is that `[a] statute must be construed as written.'" Carrington v. Brown, 136 N.C.App. 554, 558 , 525 S.E.2d 230, 234 , disc. review denied, 352 N.C. 147 , ___ S.E.2d ___ (2000).

12000–2000
Carrington v. Brown green
ncctapp · 2000
2 sentences

2000"The general rule in statutory construction is that `[a] statute must be construed as written.'" Carrington v. Brown, 136 N.C.App. 554, 558 , 525 S.E.2d 230, 234 , disc. review denied, 352 N.C. 147 , ___ S.E.2d ___ (2000).

2000"The general rule in statutory construction is that `[a] statute must be construed as written.'" Carrington v. Brown, 136 N.C.App. 554, 558 , 525 S.E.2d 230, 234 , disc. review denied, 352 N.C. 147 , ___ S.E.2d ___ (2000).

12000–2000

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 55-7-40 (9) NC § N.C. Gen. Stat. § 55-7-42 (9) NC § N.C. Gen. Stat. § 1A-1 (5) NC § N.C. Gen. Stat. § 75-1.1 (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 116 (1974–2026) TX 29 (1995–2025) PA 17 (1917–2020) WA 17 (1989–2026) CT 15 (1949–2020) IL 13 (1989–2020) NC 12 (2000–2025) MA 12 (1956–2026) NM 11 (1981–2022) MI 11 (1976–2021) UT 10 (2006–2024) FL 9 (1929–2021) DC 9 (1986–2026) NY 9 (2012–2022) NV 8 (2006–2021) AK 7 (1988–2022) GA 7 (2011–2017) TN 6 (1995–2013) MD 6 (2001–2025) RI 6 (2004–2026) OH 6 (2010–2025) CO 6 (2005–2026) IA 5 (1975–2016) OR 5 (1978–2025) SC 4 (2005–2017) VA 3 (2018–2025) MO 3 (1987–2020) MT 3 (2004–2006) NJ 3 (2007–2025) HI 3 (1995–2025) AR 3 (2005–2017) AL 2 (1988–2011) IN 2 (2005–2007) VT 2 (2009–2015) OK 2 (2004–2013) MS 2 (2003–2006) WI 2 (2001–2002) DE 2 (1993–1993) WY 2 (1996–2022)

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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