intentional tort claim (North Carolina) · Go Syfert
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intentional tort claim in North Carolina

11 North Carolina opinions name it 2 courts 1990–2024 3 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
Hawkins v. Stategreen
ncctapp · 1995 · cited in 3 North Carolina opinions naming this issue, 2002–2024
2 sentences

2024In such cases, “[b]ecause malice encompasses intent, . . . if a party alleges an intentional tort claim, the doctrine of qualified immunity does not immunize public officials . . . from suit in their individual capacities.” Hawkins v. State, 117 N.C.

2024App. 615, 630 , 453 S.E.2d 233, 242 (applying the rule in a case where the plaintiff alleges, inter alia, intentional infliction of emotional distress), disc. rev. denied, 342 N.C. 188 , 463 S.E.2d 79 (1995); see also Wells, 152 N.C.

33
Beck v. City of Durhamgreen
ncctapp · 2002 · cited in 3 North Carolina opinions naming this issue, 2015–2021
2 sentences

2021Thus, only tortious “actions that are malicious, corrupt, or outside the scope of official duties will pierce the cloak of official immunity.” Id. (citation, internal quotation marks, brackets, and ellipsis omitted). “[I]f the plaintiff alleges an intentional tort claim, a determination of governmental immunity is unnecessary since, in such cases, neither a public official nor a public employee is immunized from suit in his individual capacity.” Beck v. City of Durham, 154 N.C.

2021JOHNSON 2021-NCCOA-489 Opinion of the Court tortious “actions that are malicious, corrupt, or outside the scope of official duties will pierce the cloak of official immunity.” Id. (citation, internal quotation marks, brackets, and ellipsis omitted). “[I]f the plaintiff alleges an intentional tort claim, a determination of governmental immunity is unnecessary since, in such cases, neither a public official nor a public employee is immunized from suit in his individual capacity.” Beck v. City of Durham, 154 N.C.

33
Wells v. North Carolina Department of Correctiongreen
ncctapp · 2002 · cited in 2 North Carolina opinions naming this issue, 2002–2024
2 sentences

2024App. 615, 630 , 453 S.E.2d 233, 242 (applying the rule in a case where the plaintiff alleges, inter alia, intentional infliction of emotional distress), disc. rev. denied, 342 N.C. 188 , 463 S.E.2d 79 (1995); see also Wells, 152 N.C.

2002However, “if the plaintiff alleges an intentional tort claim, a determination [of governmental immunity] is unnecessary since, in such cases, neither a public official nor a public employee is immunized from suit in his individual capacity.” Wells v. North Carolina Dept. of Correction, 152 N.C.

22
Harwood v. Johnsongreen
nc · 1990 · cited in 1 North Carolina opinions naming this issue, 2013–2013
2 sentences

2013See id.

2013See id.

11
Jensen v. Sport Bowl, Inc.green
sd · 1991 · cited in 1 North Carolina opinions naming this issue, 2002–2002
2 sentences

2002Under the intentional tort exception, workers may bring suit against their employers at common law only `when an ordinary, reasonable, prudent person would believe an injury was substantially certain to result from [the employer's] conduct.'" Jensen v. Sport Bowl, Inc., 469 N.W.2d 370, 371 (S.D. 1991) (citing VerBouwens v. Hamm Wood Products, 334 N.W.2d 874, 876 (S.D.1983) (emphasis in original)).

2002Under the intentional tort exception, workers may bring suit against their employers at common law only ‘when an ordinary, reasonable, prudent person would believe an injury was substantially certain to result from [the employer’s] conduct.’ ” Jensen v. Sport Bowl, Inc., 469 N.W.2d 370, 371 (S.D. 1991) (citing VerBouwens v. Hamm Wood Products, 334 N.W.2d 874, 876 (S.D. 1983) (emphasis in original)).

11
VerBouwens v. Hamm Wood Productsgreen
sd · 1983 · cited in 1 North Carolina opinions naming this issue, 2002–2002
2 sentences

2002Under the intentional tort exception, workers may bring suit against their employers at common law only `when an ordinary, reasonable, prudent person would believe an injury was substantially certain to result from [the employer's] conduct.'" Jensen v. Sport Bowl, Inc., 469 N.W.2d 370, 371 (S.D. 1991) (citing VerBouwens v. Hamm Wood Products, 334 N.W.2d 874, 876 (S.D.1983) (emphasis in original)).

2002Under the intentional tort exception, workers may bring suit against their employers at common law only ‘when an ordinary, reasonable, prudent person would believe an injury was substantially certain to result from [the employer’s] conduct.’ ” Jensen v. Sport Bowl, Inc., 469 N.W.2d 370, 371 (S.D. 1991) (citing VerBouwens v. Hamm Wood Products, 334 N.W.2d 874, 876 (S.D. 1983) (emphasis in original)).

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
Turner v. City of Greenville green
ncctapp · 2009
2 sentences

2021Thus, only tortious “actions that are malicious, corrupt, or outside the scope of official duties will pierce the cloak of official immunity.” Id. (citation, internal quotation marks, brackets, and ellipsis omitted). “[I]f the plaintiff alleges an intentional tort claim, a determination of governmental immunity is unnecessary since, in such cases, neither a public official nor a public employee is immunized from suit in his individual capacity.” Beck v. City of Durham, 154 N.C.

2021JOHNSON 2021-NCCOA-489 Opinion of the Court tortious “actions that are malicious, corrupt, or outside the scope of official duties will pierce the cloak of official immunity.” Id. (citation, internal quotation marks, brackets, and ellipsis omitted). “[I]f the plaintiff alleges an intentional tort claim, a determination of governmental immunity is unnecessary since, in such cases, neither a public official nor a public employee is immunized from suit in his individual capacity.” Beck v. City of Durham, 154 N.C.

22021–2021
Powell v. S & G PRESTRESS CO. neutral
· 1995
1 sentence

2024App. 615, 630 , 453 S.E.2d 233, 242 (applying the rule in a case where the plaintiff alleges, inter alia, intentional infliction of emotional distress), disc. rev. denied, 342 N.C. 188 , 463 S.E.2d 79 (1995); see also Wells, 152 N.C.

12024–2024
Hawkins v. State neutral
nc · 1995
1 sentence

2024App. 615, 630 , 453 S.E.2d 233, 242 (applying the rule in a case where the plaintiff alleges, inter alia, intentional infliction of emotional distress), disc. rev. denied, 342 N.C. 188 , 463 S.E.2d 79 (1995); see also Wells, 152 N.C.

12024–2024
Beauchamp v. Dow Chemical Co. green
mich · 1986
2 sentences

2002The legislature in Michigan has by statute rejected the "substantially certain" test announced in Beauchamp v. Dow Chemical Co., 427 Mich. 1 , 398 N.W.2d 882 (1986), and adopted a more rigorous "true intentional tort" standard as the proper test for determining the presence of an intentional tort to overcome the exclusivity of their workers' compensation provisions.

2002The legislature in Michigan has by statute rejected the "substantially certain" test announced in Beauchamp v. Dow Chemical Co., 427 Mich. 1 , 398 N.W.2d 882 (1986), and adopted a more rigorous "true intentional tort" standard as the proper test for determining the presence of an intentional tort to overcome the exclusivity of their workers' compensation provisions.

12002–2002
Dunleavy v. YATES CONST. CO., INC. green
ncctapp · 1992
1 sentence

1993Although plaintiff is correct in her argument that Woodson is to be applied retroactively if the facts are applicable, Dunleavy v. Yates Construction Company, Inc., 106 N.C.

11993–1993
Southern Railway Co. v. O'Boyle Tank Lines, Inc. green
ncctapp · 1984
1 sentence

1990App. 1 , 318 S.E.2d 872 (1984), and similar cases wherein it was held that an assignment of a personal injury claim or an intentional tort claim was ineffective under common law and was contrary to public policy.

11990–1990

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 1A-1 (5) NC § N.C. Gen. Stat. § 1-52 (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

OH 137 (1986–2025) TX 79 (1984–2025) MI 65 (1984–2026) FL 53 (1967–2024) LA 31 (1986–2026) CT 20 (1994–2026) PA 18 (1982–2023) CA 14 (1983–2021) MS 14 (1994–2026) NY 13 (1983–2024) NE 13 (1989–2024) NC 11 (1990–2024) TN 10 (1996–2020) SD 9 (1991–2022) IA 8 (2011–2025) IL 7 (1984–2022) MA 7 (1987–2025) MN 7 (1984–2019) NJ 7 (1988–2026) IN 7 (1992–2004) WA 6 (1998–2018) AZ 5 (1994–2024) OK 4 (2005–2023) AR 4 (1998–2025) DC 4 (1988–2007) CO 4 (1985–2003) AL 4 (2001–2026) GA 3 (1998–2008) HI 3 (2002–2014) MT 2 (1997–2017) DE 2 (2019–2023) NV 2 (2014–2014) UT 2 (2015–2024) KY 2 (2026–2026) VA 2 (1989–1990) OR 2 (1994–2016) ID 2 (1986–1997) ND 2 (1997–1997) RI 2 (1989–1997) MO 2 (1994–2009) NM 2 (2010–2017) VT 2 (2004–2018) WY 2 (2010–2022) WI 2 (1997–2024) KS 2 (2012–2022)

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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