standalone claim (North Carolina) · Go Syfert
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standalone claim in North Carolina

11 North Carolina opinions name it 1 courts 2018–2025 6 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 (7)

CaseFollowedCited
Weatherford v. Keenangreen
ncctapp · 1997 · cited in 6 North Carolina opinions naming this issue, 2018–2022
2 sentences

2021Ct. Oct. 9, 2018) (“[A] constructive trust is not a standalone claim for relief or cause of action.”) (citing Weatherford v. Keenan, 128 N.C.

2021Ct. Oct. 9, 2018) (“[A] constructive trust is not a standalone claim for relief or cause of action.” (citing Weatherford v. Keenan, 128 N.C.

66
Shope v. Boyergreen
nc · 1966 · cited in 2 North Carolina opinions naming this issue, 2019–2025
2 sentences

2025To the extent that Plaintiffs’ cause of action is instead an attempt to assert a claim for civil conspiracy, as their briefing suggests, that too is not a standalone claim and “does nothing more than associate the defendants together and perhaps liberalize the rules of evidence to the extent that under proper circumstances the acts and conduct of one might be admissible against all.” Shope v. Boyer, 268 N.C. 401, 405 (1966) (citation omitted); New Restoration & Recovery Servs., LLC v. Dragonfly Pond Works, LLC, 2023 NCBC LEXIS 80 , at *23 (N.C.

2019App. at 83, 661 S.E.2d at 922 (internal quotation marks omitted), and an “overt act” in furtherance of the conspiracy’s objective, Shope, 268 N.C. at 405 , 150 S.E.2d at 774 (quotation marks omitted), the dismissal of Plaintiffs’ tortious interference claim against Cone Health “does not bar [Cone Health] from liability for damages resulting from the [acts] of other conspirator[s]”—the Individual Defendants and the PLLC Defendants, Chisum v. MacDonald, 2018 NCBC LEXIS 34 , at *32 (N.C.

22
Collier v. Bryantgreen
ncctapp · 2011 · cited in 1 North Carolina opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., Collier v. Bryant, 216 N.C.

11
USA Trouser v. Williamsgreen
ncctapp · 2018 · cited in 1 North Carolina opinions naming this issue, 2022–2022
1 sentence

2022A claim for civil conspiracy is not a standalone claim and therefore “must be based on an adequately pled underlying claim.” USA Trouser, S.A. de C.V. v. Williams, 258 N.C.

11
Krawiec v. Manlygreen
nc · 2018 · cited in 1 North Carolina opinions naming this issue, 2022–2022
1 sentence

2022App. 192, 201 (2018); see Krawiec, 370 N.C. at 615 (dismissing civil conspiracy claim where the underlying claims were dismissed). 64.

11
Sellers v. Mortongreen
ncctapp · 2008 · cited in 1 North Carolina opinions naming this issue, 2019–2019
1 sentence

2019App. at 83, 661 S.E.2d at 922 (internal quotation marks omitted), and an “overt act” in furtherance of the conspiracy’s objective, Shope, 268 N.C. at 405 , 150 S.E.2d at 774 (quotation marks omitted), the dismissal of Plaintiffs’ tortious interference claim against Cone Health “does not bar [Cone Health] from liability for damages resulting from the [acts] of other conspirator[s]”—the Individual Defendants and the PLLC Defendants, Chisum v. MacDonald, 2018 NCBC LEXIS 34 , at *32 (N.C.

11
Carcano v. JBSS, LLCgreen
ncctapp · 2009 · cited in 1 North Carolina opinions naming this issue, 2019–2019
1 sentence

2019See Carcano v. JBSS, LLC, 200 N.C.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in North Carolina. Read the followed side critically anyway.

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 75-1.1 (6) NC § N.C. Gen. Stat. § 1A-1 (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

NC 11 (2018–2025) OR 9 (2020–2026) DE 8 (2022–2026) WI 7 (2021–2025) IL 4 (2022–2026) IA 3 (2022–2022) PA 3 (2009–2025) SC 2 (2016–2016) CA 2 (2026–2026) WA 2 (2024–2024) VA 2 (2021–2024) IN 2 (2016–2025) MI 2 (2023–2024) UT 2 (2024–2024) ID 2 (2021–2025) AZ 2 (2014–2022)

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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