Williams factors (North Carolina) · Go Syfert
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Williams factors in North Carolina

12 North Carolina opinions name it 2 courts 1983–2025 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 (6)

CaseFollowedCited
Hunt v. Huntgreen
ncctapp · 1993 · cited in 3 North Carolina opinions naming this issue, 2006–2025
2 sentences

2019In making a dependency determination, the relevant Williams factors include: (1) the accustomed standard of living of the parties prior to the separation, (2) the income and expenses of each of the parties at the time of the trial, (3) the value of the estates, if any, of both spouses at the time of the hearing, and (4) “the length of [the] marriage and the contribution each party has made to the financial status of the family over the years.” Hunt v. Hunt, 112 N.C. App. 722, 726-27 , 436 S.E.2d 856, 859 (1993) (quoting Williams, 299 N.C. at 183-85 , 261 S.E.2d at 856-57 ).

2019In making a dependency determination, the relevant Williams factors include: (1) the accustomed standard of living of the parties prior to the separation, (2) the income and expenses of each of the parties at the time of the trial, (3) the value of the estates, if any, of both spouses at the time of the hearing, and (4) “the length of [the] marriage and the contribution each party has made to the financial status of the family over the years.” Hunt v. Hunt, 112 N.C. App. 722, 726-27 , 436 S.E.2d 856, 859 (1993) (quoting Williams, 299 N.C. at 183-85 , 261 S.E.2d at 856-57 ).

23
Wise v. Wisegreen
ncctapp · 2019 · cited in 1 North Carolina opinions naming this issue, 2025–2025
2 sentences

2025See Helms, 191 N.C. App. at 24 ; Hunt, 112 N.C. App. at 726-27; see also Wise, 264 N.C. App. at 739 ; N.C.G.S. § 50-16.3(A)(b).

2025See Helms, 191 N.C. App. at 24 ; Hunt, 112 N.C. App. at 726-27; see also Wise, 264 N.C. App. at 739 ; N.C.G.S. § 50-16.3(A)(b).

11
Helms v. Helmsgreen
ncctapp · 2008 · cited in 1 North Carolina opinions naming this issue, 2025–2025
2 sentences

2025See Helms, 191 N.C. App. at 24 ; Hunt, 112 N.C. App. at 726-27; see also Wise, 264 N.C. App. at 739 ; N.C.G.S. § 50-16.3(A)(b).

2025See Helms, 191 N.C. App. at 24 ; Hunt, 112 N.C. App. at 726-27; see also Wise, 264 N.C. App. at 739 ; N.C.G.S. § 50-16.3(A)(b).

11
Talent v. Talentred
ncctapp · 1985 · cited in 1 North Carolina opinions naming this issue, 2019–2019
2 sentences

2019“The conclusions made by the court as to whether a spouse is ‘dependent’ or ‘supporting’ must be based on findings of fact sufficiently specific to indicate that the court properly considered the factors set out in Williams.” Talent v. Talent, 76 N.C. App. 545, 548 , 334 S.E.2d 256, 259 (1985).

2019“The conclusions made by the court as to whether a spouse is ‘dependent’ or ‘supporting’ must be based on findings of fact sufficiently specific to indicate that the court properly considered the factors set out in Williams.” Talent v. Talent, 76 N.C. App. 545, 548 , 334 S.E.2d 256, 259 (1985).

11
Griner v. Smithgreen
ncctapp · 1979 · cited in 1 North Carolina opinions naming this issue, 2001–2001
2 sentences

2001See id.

2001See id.

11
McClanahan v. Arizona State Tax Commissiongreen
scotus · 1973 · cited in 1 North Carolina opinions naming this issue, 1987–1987
2 sentences

1987The Williams test is principally applicable in situations involving a non-Indian party. 6 McClanahan v. Arizona State Tax *59 Commission, 411 U.S. 164, 179 , 36 L.Ed. 2d 129, 140 (1973).

1987The Williams test is principally applicable in situations involving a non-Indian party. 6 McClanahan v. Arizona State Tax *59 Commission, 411 U.S. 164, 179 , 36 L.Ed. 2d 129, 140 (1973).

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 (8)

CaseCitedYears
Williams v. Williams green
nc · 1980
2 sentences

2019In making a dependency determination, the relevant Williams factors include: (1) the accustomed standard of living of the parties prior to the separation, (2) the income and expenses of each of the parties at the time of the trial, (3) the value of the estates, if any, of both spouses at the time of the hearing, and (4) “the length of [the] marriage and the contribution each party has made to the financial status of the family over the years.” Hunt v. Hunt, 112 N.C. App. 722, 726-27 , 436 S.E.2d 856, 859 (1993) (quoting Williams, 299 N.C. at 183-85 , 261 S.E.2d at 856-57 ).

2019In making a dependency determination, the relevant Williams factors include: (1) the accustomed standard of living of the parties prior to the separation, (2) the income and expenses of each of the parties at the time of the trial, (3) the value of the estates, if any, of both spouses at the time of the hearing, and (4) “the length of [the] marriage and the contribution each party has made to the financial status of the family over the years.” Hunt v. Hunt, 112 N.C. App. 722, 726-27 , 436 S.E.2d 856, 859 (1993) (quoting Williams, 299 N.C. at 183-85 , 261 S.E.2d at 856-57 ).

21993–2019
Smith v. Arizona green
scotus · 2024
2 sentences

2025But Smith specifically did not address the second part of the Williams analysis, whether the test results were testimonial evidence, and Smith did not - 32 - overrule or disapprove of this portion in Williams.6 As noted by the United States Supreme Court in Smith, the Williams Court “failed to produce a majority opinion[,]” Smith, 602 U.S. at 788 , 219 L. Ed. 2d at 429, and its opinions “have sown confusion in courts across the country about the Confrontation Clause’s application to expert opinion testimony.” Id. at 789, 219 L. Ed. 2d at 430 (citation and quotation marks omitted).

2025But Smith specifically did not address the second part of the Williams analysis, whether the test results were testimonial evidence, and Smith did not - 32 - overrule or disapprove of this portion in Williams.6 As noted by the United States Supreme Court in Smith, the Williams Court “failed to produce a majority opinion[,]” Smith, 602 U.S. at 788 , 219 L. Ed. 2d at 429, and its opinions “have sown confusion in courts across the country about the Confrontation Clause’s application to expert opinion testimony.” Id. at 789, 219 L. Ed. 2d at 430 (citation and quotation marks omitted).

12025–2025
Evans v. Housing Auth. of City of Raleigh green
nc · 2004
2 sentences

2018Thus, even when the legislature "has not directly resolved whether a specific activity is governmental or proprietary in nature," Williams , 366 N.C. at 202 , 732 S.E.2d at 142 , a legislative provision addressing the activity may still be relevant-in conjunction with the other Williams factors-to a determination of whether an activity is governmental, particularly if the statutory language suggests "a significant 'statutory indication' that the [activity] is a governmental function," id. at 200 , 732 S.E.2d at 141 (quoting Evans , 359 N.C. at 55 , 602 S.E.2d at 672 ).

2018Thus, even when the legislature "has not directly resolved whether a specific activity is governmental or proprietary in nature," Williams , 366 N.C. at 202 , 732 S.E.2d at 142 , a legislative provision addressing the activity may still be relevant-in conjunction with the other Williams factors-to a determination of whether an activity is governmental, particularly if the statutory language suggests "a significant 'statutory indication' that the [activity] is a governmental function," id. at 200 , 732 S.E.2d at 141 (quoting Evans , 359 N.C. at 55 , 602 S.E.2d at 672 ).

12018–2018
Estate of Williams ex rel. Overton v. Pasquotank County Parks & Recreation Department green
nc · 2012
2 sentences

2018Thus, even when the legislature "has not directly resolved whether a specific activity is governmental or proprietary in nature," Williams , 366 N.C. at 202 , 732 S.E.2d at 142 , a legislative provision addressing the activity may still be relevant-in conjunction with the other Williams factors-to a determination of whether an activity is governmental, particularly if the statutory language suggests "a significant 'statutory indication' that the [activity] is a governmental function," id. at 200 , 732 S.E.2d at 141 (quoting Evans , 359 N.C. at 55 , 602 S.E.2d at 672 ).

2018Thus, even when the legislature "has not directly resolved whether a specific activity is governmental or proprietary in nature," Williams , 366 N.C. at 202 , 732 S.E.2d at 142 , a legislative provision addressing the activity may still be relevant-in conjunction with the other Williams factors-to a determination of whether an activity is governmental, particularly if the statutory language suggests "a significant 'statutory indication' that the [activity] is a governmental function," id. at 200 , 732 S.E.2d at 141 (quoting Evans , 359 N.C. at 55 , 602 S.E.2d at 672 ).

12018–2018
State Farm Mutual Automobile Insurance v. Fortin green
nc · 1999
2 sentences

2010Co. v. Fortin, 350 N.C. 264 , 513 S.E.2d 782 (1999) and Williams and determined that [t]he per se rule suggested by defendants, that the Williams analysis must apply whenever an insurer does not produce a valid selection/rejection form, cannot be reconciled with our Supreme Court’s holding in Fortin .

2010Co. v. Fortin, 350 N.C. 264 , 513 S.E.2d 782 (1999) and Williams and determined that [t]he per se rule suggested by defendants, that the Williams analysis must apply whenever an insurer does not produce a valid selection/rejection form, cannot be reconciled with our Supreme Court’s holding in Fortin .

12010–2010
Clark v. Clark green
nc · 1980
2 sentences

2008The record demonstrates that the trial court’s denial of Williams’ motion was not “manifestly unsupported by reason,” Clark, 301 N.C. at 129 , 271 S.E.2d at 63 , and accordingly, Williams’ assignment of error is overruled.

2008The record demonstrates that the trial court’s denial of Williams’ motion was not “manifestly unsupported by reason,” Clark, 301 N.C. at 129 , 271 S.E.2d at 63 , and accordingly, Williams’ assignment of error is overruled.

12008–2008
Williams v. Hillhaven Corp. green
ncctapp · 1988
2 sentences

1989Id. at 39, 370 S.E. 2d at 425 .

1989Id. at 39, 370 S.E.2d at 425 .

11989–1989
State v. Woodrup neutral
ncctapp · 1982
2 sentences

1983State v. Woodrup, 60 N.C.

1983State v. Woodrup, 60 N.C.

11983–1983

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 1A-1 (4) NC § N.C. Gen. Stat. § 50-20 (4)

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

FL 422 (1933–2026) CA 151 (1959–2026) GA 138 (1981–2026) TX 106 (1970–2026) IL 91 (1988–2026) CT 90 (2003–2025) OH 89 (1997–2026) PA 80 (1948–2026) MS 55 (1990–2025) WA 39 (1980–2026) AL 38 (1985–2025) IN 36 (1894–2023) VA 27 (1987–2026) MO 25 (1973–2025) LA 20 (1983–2025) TN 19 (1981–2026) WI 17 (1998–2025) KS 17 (1983–2024) AZ 17 (1985–2025) NE 16 (1983–2024) MD 15 (1975–2022) MN 15 (1967–2026) SC 14 (2004–2025) DC 14 (1977–2024) AR 14 (1974–2024) MT 13 (1973–2017) MI 13 (1966–2020) DE 12 (1970–2026) NC 12 (1983–2025) NY 11 (1974–2026) AK 10 (1983–2023) NJ 10 (1967–2022) NM 10 (1976–2024) CO 9 (1994–2026) ME 8 (2001–2024) UT 8 (1999–2019) MA 8 (1981–2026) NV 7 (1983–2021) OK 7 (1987–2018) ID 7 (1974–2018) ND 6 (1987–2025) WY 6 (1980–2026) IA 6 (1996–2026) WV 5 (1980–2017) NH 3 (1998–2011) HI 3 (2007–2020) SD 2 (2006–2008) KY 2 (2020–2023) VT 2 (1985–2019) OR 2 (2023–2024) VI 2 (2011–2016)

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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