harsh doctrine (North Carolina) · Go Syfert
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harsh doctrine in North Carolina

9 North Carolina opinions name it 2 courts 1911–2004 0 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 (2)

CaseFollowedCited
Medicare Rentals, Inc. v. Advanced Servicesgreen
ncctapp · 1995 · cited in 4 North Carolina opinions naming this issue, 2002–2004
2 sentences

2004The test for judicial estoppel in North Carolina is stated as "a harsh doctrine and requires at a minimum that the party against whom the doctrine is asserted [ (1) ] intentionally have [ (2) ] changed its position in order to gain an advantage." Medicare Rentals, Inc. v. Advanced Services, 119 N.C.App. 767, 771 , 460 S.E.2d 361, 364 , disc. review denied, 342 N.C. 415 , 467 S.E.2d 700 (1995) (emphasis added).

2004The test for judicial estoppel in North Carolina is stated as "a harsh doctrine and requires at a minimum that the party against whom the doctrine is asserted [ (1) ] intentionally have [ (2) ] changed its position in order to gain an advantage." Medicare Rentals, Inc. v. Advanced Services, 119 N.C.App. 767, 771 , 460 S.E.2d 361, 364 , disc. review denied, 342 N.C. 415 , 467 S.E.2d 700 (1995) (emphasis added).

14
Harry F. Chaveriat, Jr. v. Williams Pipe Line Companygreen
ca7 · 1993 · cited in 1 North Carolina opinions naming this issue, 1995–1995
1 sentence

1995Allen, 667 F.2d at 1167 ; see Chaveriat v. Williams Pipe Line Co., 11 F.3d 1420, 1428 (7th Cir. 1993) (“Judicial estoppel is strong medicine, and this has led courts and commentators to characterize the grounds for its invocation in terms redolent of intentional wrongdoing.”).

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
Rose v. Isenhour Brick & Tile Co. neutral
nc · 1995
2 sentences

2004The test for judicial estoppel in North Carolina is stated as "a harsh doctrine and requires at a minimum that the party against whom the doctrine is asserted [ (1) ] intentionally have [ (2) ] changed its position in order to gain an advantage." Medicare Rentals, Inc. v. Advanced Services, 119 N.C.App. 767, 771 , 460 S.E.2d 361, 364 , disc. review denied, 342 N.C. 415 , 467 S.E.2d 700 (1995) (emphasis added).

2004App. 767, 771 , 460 S.E.2d 361, 364 , disc. review denied, 342 N.C. 415 , 467 S.E.2d 700 (1995) (emphasis added).

22004–2004
Medicare Rentals, Inc. v. Advanced Services neutral
nc · 1995
2 sentences

2004The test for judicial estoppel in North Carolina is stated as "a harsh doctrine and requires at a minimum that the party against whom the doctrine is asserted [ (1) ] intentionally have [ (2) ] changed its position in order to gain an advantage." Medicare Rentals, Inc. v. Advanced Services, 119 N.C.App. 767, 771 , 460 S.E.2d 361, 364 , disc. review denied, 342 N.C. 415 , 467 S.E.2d 700 (1995) (emphasis added).

2004App. 767, 771 , 460 S.E.2d 361, 364 , disc. review denied, 342 N.C. 415 , 467 S.E.2d 700 (1995) (emphasis added).

22004–2004
Grady Allen v. Zurich Insurance Company green
ca4 · 1982
1 sentence

1995Allen, 667 F.2d at 1167 ; see Chaveriat v. Williams Pipe Line Co., 11 F.3d 1420, 1428 (7th Cir. 1993) (“Judicial estoppel is strong medicine, and this has led courts and commentators to characterize the grounds for its invocation in terms redolent of intentional wrongdoing.”).

11995–1995
Ray Ex Rel. Gudger v. Ray green
nc · 1941
2 sentences

1981Ray v. Ray, 219 N.C. 217 , 13 S.E. 2d 224 (1941).

1981Ray v. Ray, 219 N.C. 217 , 13 S.E. 2d 224 (1941).

11981–1981
Raftery v. Wm. C. Vick Construction Co. green
nc · 1976
2 sentences

1979Raftery v. Vick Construction Co., 291 N.C. 180 , 230 S.E. 2d 405 (1976).

1979Raftery v. Vick Construction Co., 291 N.C. 180 , 230 S.E. 2d 405 (1976).

11979–1979
Berwer v. Union Central Life Insurance neutral
nc · 1936
1 sentence

1937Co., supra. Nor is this a harsh rule.

11937–1937
Dunlop v. . James green
ny · 1903
1 sentence

1911Tbis doctrine is well settled in Dunlop v. James, 174 N. Y., 411 , as follows: “In modern times courts of law bave dealt witb subrogation as they would witb assignments, and, wben tbe right of action to which tbe plaintiff asks to be subrogated is a legal right of action, a court of law may treat a plaintiff who is entitled in equity to subrogation as an as-signee, and allow him to maintain an action of a legal nature upon tbe right to which he claims to be subrogated.” In Bledsoe v. Nixon, 68 N. C., 521 (cited in the opinion of the Court), Judge Rodman strongly intimates that the harsh rule b

11911–1911
Bledsoe v. . Nixon neutral
nc · 1873
1 sentence

1911Tbis doctrine is well settled in Dunlop v. James, 174 N. Y., 411 , as follows: “In modern times courts of law bave dealt witb subrogation as they would witb assignments, and, wben tbe right of action to which tbe plaintiff asks to be subrogated is a legal right of action, a court of law may treat a plaintiff who is entitled in equity to subrogation as an as-signee, and allow him to maintain an action of a legal nature upon tbe right to which he claims to be subrogated.” In Bledsoe v. Nixon, 68 N. C., 521 (cited in the opinion of the Court), Judge Rodman strongly intimates that the harsh rule b

11911–1911

Statutes the citing opinions construe

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

CA 59 (1891–2026) TX 58 (1889–2018) NY 34 (1876–2025) PA 24 (1827–2018) IL 24 (1899–2020) MO 23 (1885–2016) FL 17 (1920–2010) GA 17 (1950–2012) KS 16 (1906–2022) IA 15 (1889–2018) OR 13 (1920–2025) OK 13 (1914–2001) LA 13 (1926–1994) WA 13 (1901–2009) CT 13 (1914–2010) WV 12 (1882–2003) MA 11 (1888–2018) NJ 10 (1950–2004) OH 10 (1914–2013) MI 10 (1926–1994) ID 9 (1966–2011) NC 9 (1911–2004) IN 9 (1890–2023) HI 9 (1923–2003) CO 9 (1930–2017) AL 8 (1895–1996) KY 8 (1917–2005) WI 8 (1900–2019) MN 7 (1947–1986) AR 7 (1978–2018) AZ 6 (1913–1979) TN 6 (1966–2005) SD 6 (1914–1996) MD 6 (1948–2014) ND 6 (1913–1991) VA 5 (1918–1998) SC 5 (1927–2001) WY 5 (1895–1988) VT 4 (1868–2014) MT 4 (1896–1947) RI 3 (1978–1999) NE 3 (1998–2019) AK 3 (1991–2019) DE 3 (1915–2021) NM 3 (1943–1995) VI 2 (1982–2014) NH 2 (1976–2018) DC 2 (1978–1980)

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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