three-factor test (North Carolina) · Go Syfert
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three-factor test in North Carolina

9 North Carolina opinions name it 2 courts 2015–2025 5 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 (3)

CaseFollowedCited
Bailey v. Stategreen
nc · 1998 · cited in 4 North Carolina opinions naming this issue, 2015–2023
2 sentences

2023Our courts use a three-factor test to “determine whether a Contract Clause violation exists.” Id. (citing Bailey v. State, 348 N.C. 130, 141 , 500 S.E.2d 54, 60 (1998)).

2023Our courts use a three-factor test to “determine whether a Contract Clause violation exists.” Id. (citing Bailey v. State, 348 N.C. 130, 141 , 500 S.E.2d 54, 60 (1998)).

24
Little v. Omega Meats I, Inc.green
ncctapp · 2005 · cited in 2 North Carolina opinions naming this issue, 2022–2022
2 sentences

2022Little v. Omega Meats I, Inc., 171 N.C.

2022Little v. Omega Meats I, Inc., 171 N.C.

22
Solem v. Helmred
scotus · 1983 · cited in 1 North Carolina opinions naming this issue, 2018–2018
2 sentences

2018See Helm, 463 U.S. at 290 -92 , 103 S.Ct. 3001 , 77 L.Ed. 2d at 649-50 (applying a three-factor test to strike down a sentence as significantly disproportionate after considering (1) the gravity of the offense versus the harshness of the penalty, (2) the sentences imposed on other criminals in the same jurisdiction, and (3) the sentences imposed for the commission of the same crime in other jurisdictions).

2018See Helm, 463 U.S. at 290 -92 , 103 S.Ct. 3001 , 77 L.Ed. 2d at 649-50 (applying a three-factor test to strike down a sentence as significantly disproportionate after considering (1) the gravity of the offense versus the harshness of the penalty, (2) the sentences imposed on other criminals in the same jurisdiction, and (3) the sentences imposed for the commission of the same crime in other jurisdictions).

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 (2)

CaseCitedYears
State v. Lawrence green
nc · 2012
2 sentences

2025Second, the defendant must show that the error had a “probable impact” on the outcome, meaning that “absent the error, the jury probably would have returned a different verdict.” Finally, the defendant must show that the error is an “exceptional case” that warrants plain error review, typically by showing that the error seriously affects “the fairness, integrity or public reputation of judicial proceedings.” State v. Reber, 386 N.C. 153 , 158 (2024) (quoting Lawrence, 365 N.C. at 518–19).

2024When we issued our “doctrinal statement” on plain error in Lawrence, we incorporated these principles into a three-factor test: First, the defendant must show that a fundamental error occurred at trial. 365 N.C. at 518 .

22024–2025
United States Trust Co. of NY v. New Jersey green
scotus · 1977
2 sentences

2015The trial court based this conclusion on its application of the three-factor test articulated by the United States Supreme Court in U.S. Trust Co. v. New Jersey, 431 U.S. 1 , 97 S.Ct. 1505 , 52 L.Ed.2d 92 (1977) to determine whether a state law violates the Contract Clause.

2015The trial court based this conclusion on its application of the three-factor test articulated by the United States Supreme Court in U.S. Trust Co. v. New Jersey, 431 U.S. 1 , 97 S.Ct. 1505 , 52 L.Ed.2d 92 (1977) to determine whether a state law violates the Contract Clause.

22015–2023

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 115C-325 (4) NC § N.C. Gen. Stat. § 7A-30 (4) NC § N.C. Gen. Stat. § 115C-325.3 (3) NC § N.C. Gen. Stat. § 1A-1 (3)

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

TX 97 (1972–2026) AL 73 (1978–2024) PA 57 (1982–2024) ID 44 (1980–2024) MI 43 (1976–2025) CA 43 (1965–2025) CO 36 (1984–2026) NJ 32 (1990–2026) IL 29 (1988–2025) MN 28 (1981–2025) WA 26 (2001–2024) NV 22 (2006–2022) NM 21 (1987–2026) WI 20 (1995–2024) KS 20 (1983–2022) VI 16 (2014–2025) IN 16 (1984–2025) OH 15 (1999–2025) GA 15 (1996–2023) IA 14 (1984–2024) LA 14 (1994–2026) MS 14 (1994–2025) MO 14 (1985–2021) MD 12 (1988–2026) HI 12 (1978–2025) WV 12 (1988–2023) MT 11 (1998–2024) CT 11 (1985–2021) AZ 11 (1986–2022) NY 11 (1994–2026) NH 10 (1996–2023) DE 10 (2015–2025) OR 10 (1982–2025) NC 9 (2015–2025) AR 9 (2004–2024) UT 8 (2004–2022) MA 8 (2000–2025) TN 7 (1999–2024) FL 7 (2001–2026) VT 5 (2000–2025) ME 4 (1989–2020) VA 4 (2002–2025) SC 4 (2009–2023) NE 4 (1991–2016) WY 3 (1992–2026) KY 3 (2018–2024) SD 3 (1997–2024) DC 3 (1983–2021) ND 2 (2016–2022) OK 2 (1999–2010) AK 2 (1996–2025)

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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