protection rule (North Dakota) · Go Syfert
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protection rule in North Dakota

11 North Dakota opinions name it 1 courts 1897–2023 1 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 (5)

CaseFollowedCited
In Re Discipline of Schaefergreen
nev · 2001 · cited in 1 North Dakota opinions naming this issue, 2010–2010
2 sentences

2010See In re Schaefer, 117 Nev. 496 , 25 P.3d 191, 199 (2001) (“The lawyer still has an advantage over the average layperson, and the integrity of the relationship between the represented person and counsel is not entitled to less protection merely because the lawyer is appearing pro se.”); In re Segall, 117 Ill.2d 1 , 109 Ill.Dec. 149 , 509 N.E.2d 988, 990 (1987) (“A party, having employed counsel to act as an intermediary between himself and opposing counsel, does not lose the protection of the rule merely because opposing counsel is also a party to the litigation.”).

2010See In re Schaefer, 117 Nev. 496 , 25 P.3d 191, 199 (2001) (“The lawyer still has an advantage over the average layperson, and the integrity of the relationship between the represented person and counsel is not entitled to less protection merely because the lawyer is appearing pro se.”); In re Segall, 117 Ill.2d 1 , 109 Ill.Dec. 149 , 509 N.E.2d 988, 990 (1987) (“A party, having employed counsel to act as an intermediary between himself and opposing counsel, does not lose the protection of the rule merely because opposing counsel is also a party to the litigation.”).

11
In Re Segallgreen
ill · 1987 · cited in 1 North Dakota opinions naming this issue, 2010–2010
2 sentences

2010See In re Schaefer, 117 Nev. 496 , 25 P.3d 191, 199 (2001) (“The lawyer still has an advantage over the average layperson, and the integrity of the relationship between the represented person and counsel is not entitled to less protection merely because the lawyer is appearing pro se.”); In re Segall, 117 Ill.2d 1 , 109 Ill.Dec. 149 , 509 N.E.2d 988, 990 (1987) (“A party, having employed counsel to act as an intermediary between himself and opposing counsel, does not lose the protection of the rule merely because opposing counsel is also a party to the litigation.”).

2010See In re Schaefer, 117 Nev. 496 , 25 P.3d 191, 199 (2001) (“The lawyer still has an advantage over the average layperson, and the integrity of the relationship between the represented person and counsel is not entitled to less protection merely because the lawyer is appearing pro se.”); In re Segall, 117 Ill.2d 1 , 109 Ill.Dec. 149 , 509 N.E.2d 988, 990 (1987) (“A party, having employed counsel to act as an intermediary between himself and opposing counsel, does not lose the protection of the rule merely because opposing counsel is also a party to the litigation.”).

11
State v. Faschinggreen
nd · 1990 · cited in 1 North Dakota opinions naming this issue, 1991–1991
1 sentence

1991See State v. Fasching, 453 N.W.2d 761 (N.D.1990).

11
Schmerber v. Californiagreen
scotus · 1966 · cited in 1 North Dakota opinions naming this issue, 1980–1980
2 sentences

1980The distinction which has emerged, often expressed in different ways, is that the privilege is a bar against compelling ‘communications’ or ‘testimony,’ but that compulsion which makes a *245 suspect or accused the source of ‘real or physical evidence’ does not violate it.” Schmerber v. California, 384 U.S. 757, 763-764 , 86 S.Ct. 1826, 1831-1832 , 16 L.Ed.2d 908, 916 (1966).

1980The distinction which has emerged, often expressed in different ways, is that the privilege is a bar against compelling ‘communications’ or ‘testimony,’ but that compulsion which makes a *245 suspect or accused the source of ‘real or physical evidence’ does not violate it.” Schmerber v. California, 384 U.S. 757, 763-764 , 86 S.Ct. 1826, 1831-1832 , 16 L.Ed.2d 908, 916 (1966).

11
Counselman v. Hitchcockgreen
scotus · 1892 · cited in 1 North Dakota opinions naming this issue, 1976–1976
2 sentences

1976Such situations call to mind the principle that the protection of the privilege ‘is as broad as the mischief against which it seeks to guard.’ Counselman v. Hitchcock, 142 U.S. 547, 562 , 12 S.Ct. 195, 198 [ 35 L.Ed. 1110 ].

1976Such situations call to mind the principle that the protection of the privilege ‘is as broad as the mischief against which it seeks to guard.’ Counselman v. Hitchcock, 142 U.S. 547, 562 , 12 S.Ct. 195, 198 [ 35 L.Ed. 1110 ].

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 (10)

CaseCitedYears
Ordahl v. Lykken green
· 2022
2 sentences

2023Ordahl, LCC v. Lykken, 2022 ND 193, ¶ 6 , 981 N.W.2d 901 (citations and quotations omitted). [¶16] 4201 acknowledges the personal pledge signed by 4201 and the bank does not allow 4201 to recover fees but allows the bank to recover “all costs and expenses (including without limitation reasonable attorney fees and legal expenses) incurred by Lender in connection with the protection, defense or enforcement of this PLEDGE in any litigation or bankruptcy or insolvency proceeding.” The plain language of the contract clearly allows for reimbursement of fees related to the protection or defense of th

2023Ordahl, LCC v. Lykken, 2022 ND 193, ¶ 6 , 981 N.W.2d 901 (citations and quotations omitted). [¶16] 4201 acknowledges the personal pledge signed by 4201 and the bank does not allow 4201 to recover fees but allows the bank to recover “all costs and expenses (including without limitation reasonable attorney fees and legal expenses) incurred by Lender in connection with the protection, defense or enforcement of this PLEDGE in any litigation or bankruptcy or insolvency proceeding.” The plain language of the contract clearly allows for reimbursement of fees related to the protection or defense of th

12023–2023
Skadberg v. Skadberg green
nd · 2002
2 sentences

2010The [conduct for finding] disorderly conduct is defined differently from domestic violence.” This Court has said, “Like the domestic violence protection order statute, the disorderly conduct restraining order statute creates a special summary proceeding and directs a hearing upon order of the district court” and that “[b]oth statutes seek to quickly and effectively combat volatile situations before any tragic escalation.” Skadberg v. Skadberg, 2002 ND 97, ¶ 13 , 644 N.W.2d 873 .

2010The [conduct for finding] disorderly conduct is defined differently from domestic violence.” This Court has said, “Like the domestic violence protection order statute, the disorderly conduct restraining order statute creates a special summary proceeding and directs a hearing upon order of the district court” and that “[b]oth statutes seek to quickly and effectively combat volatile situations before any tragic escalation.” Skadberg v. Skadberg, 2002 ND 97, ¶ 13 , 644 N.W.2d 873 .

12010–2010
In Re Application for Disciplinary Action Against Hoffman green
nd · 2003
2 sentences

2010In addition, we have recognized Rule 4.2 “is to prevent lawyers from taking advantage of laypersons.” Disciplinary Bd. v. Hoffman, 2003 ND 161, ¶ 17 , 670 N.W.2d 500 . [¶ 10] Lucas relies on a Connecticut Supreme Court decision to argue Rule 4.2 does not apply when he is representing himself because he is not representing a client.

2010In addition, we have recognized Rule 4.2 “is to prevent lawyers from taking advantage of laypersons.” Disciplinary Bd. v. Hoffman, 2003 ND 161, ¶ 17 , 670 N.W.2d 500 . [¶ 10] Lucas relies on a Connecticut Supreme Court decision to argue Rule 4.2 does not apply when he is representing himself because he is not representing a client.

12010–2010
Chubb Integrated Systems Ltd. v. National Bank green
dcd · 1984
1 sentence

1990"Since Lois, the weight of authority is that waiver can occur through inadvertence. ( Chubb Integrated Systems v. National Bank of Wash. (D.D.C.1984) 103 F.R.D. 52, 67 .) The trend is to base the decision on all the circumstances. ( Hartford Fire Ins.

11990–1990
Gowin v. Hazen Memorial Hospital Ass'n green
nd · 1981
1 sentence

1988E.g., Gowin v. Hazen Memorial Hospital Ass’n, 311 N.W.2d 554 (N.D. 1981).

11988–1988
Boyd v. United States red
scotus · 1886
2 sentences

1976Boyd v. United States, 116 U.S. 616 , 6 S.Ct. 524 , 29 L.Ed. 746 .

1976Boyd v. United States, 116 U.S. 616 , 6 S.Ct. 524 , 29 L.Ed. 746 .

11976–1976
Wilson v. Yellow Cab Co. of Shreveport green
lactapp · 1953
1 sentence

1958Co., La.App., 64 So.2d 463 .

11958–1958
Wessel v. D. S. B. Johnston Land & Mortgage Co. neutral
nd · 1893
2 sentences

1901The rule, as stated and recognized by this court in Wessel v. Mortgage Co., 3 N. D. 160 , 54 N. W.

1901The rule, as stated and recognized by this court in Wessel v. Mortgage Co., 3 N. D. 160 , 54 N. W.

11901–1901
Speer v. Skinner neutral
ohioctapp · 1864
1 sentence

1897In Bruner v. Dyball, 42 Ill. 34 , the court said: “In the case of Speer v. Skinner, 35 Ill. 282 , it was held that a landlord who had distrained goods of his tenant for rent in arrear lost his lien on the goods when they were replevied by the tenant, and it is now urged that the principle announced in that case governs this.

11897–1897
Bruner v. Dyball neutral
ill · 1866
1 sentence

1897In Bruner v. Dyball, 42 Ill. 34 , the court said: “In the case of Speer v. Skinner, 35 Ill. 282 , it was held that a landlord who had distrained goods of his tenant for rent in arrear lost his lien on the goods when they were replevied by the tenant, and it is now urged that the principle announced in that case governs this.

11897–1897

Where else courts name it

CA 107 (1881–2026) NY 99 (1840–2026) PA 60 (1853–2026) IL 52 (1873–2024) TX 48 (1885–2025) AL 44 (1866–2018) NJ 40 (1830–2026) IN 37 (1872–2024) CT 34 (1920–2023) MD 32 (1878–2014) NC 29 (1891–2025) VA 28 (1919–2024) WA 27 (1912–2026) FL 26 (1917–2020) WI 26 (1888–2018) MO 25 (1889–2024) MA 21 (1869–2025) MN 21 (1925–2025) DC 20 (1972–2025) OH 19 (1907–2024) OR 18 (1875–2020) LA 17 (1940–2008) KS 16 (1913–2005) AZ 15 (1965–2017) KY 15 (1916–2021) MI 15 (1963–2022) DE 14 (1952–2022) NM 14 (1964–2023) SD 13 (1972–2015) GA 13 (1884–2019) CO 13 (1927–2025) AK 12 (1972–2025) OK 12 (1912–2016) IA 12 (1922–2022) NE 11 (1899–2016) SC 11 (1884–2025) ND 11 (1897–2023) WV 10 (1875–2019) MS 9 (1970–2017) AR 9 (1882–2012) ME 9 (1984–2017) TN 8 (1953–2024) WY 8 (1923–2021) ID 7 (1971–2020) RI 6 (1962–2007) VT 5 (1920–1996) NH 5 (1981–2021) HI 5 (1947–2008) NV 4 (1923–2020) UT 4 (1922–2020) MT 4 (1977–1999) PR 3 (1953–1969)

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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