continuous representation rule (North Dakota) · Go Syfert
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continuous representation rule in North Dakota

9 North Dakota opinions name it 1 courts 1985–2004 0 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 (7)

CaseFollowedCited
Wall v. Lewisgreen
nd · 1986 · cited in 4 North Dakota opinions naming this issue, 1989–2004
2 sentences

2004The continuous representation rule requires any subsequent representation to relate to the same transaction or subject matter as the allegedly negligent acts. *452 Wall, 393 N.W.2d at 762 ; Binstock, 374 N.W.2d at 85 .

2004Id. [¶ 14] In Wall, 393 N.W.2d at 763-64 , we considered an issue about the termination of representation in the context of the continuous representation rule.

14
Froysland v. Altenburggreen
nd · 1989 · cited in 2 North Dakota opinions naming this issue, 1990–1999
2 sentences

1999See Froysland , at 799 (we have only applied the continuous representation doctrine to legal malpractice cases). [¶22] Schanilec last visited Dr. Lambie at the Grand Forks Clinic on February 14, 1994.

1990We have recently discussed the continuing treatment or continuing care rule in its application to malpractice actions in Froysland v. Alten-burg, supra. In Froysland , we said: “There are two branches of the continuing care idea: one of continuous treatment for medical malpractice and another of continuous representation for legal malpractice.... [[Image here]] “Although the continuous representation rule originated as an adaptation of the continuous treatment rule, we have only applied the idea to legal malpractice so far.” Froysland, 439 N.W.2d at 799 .

12
Binstock v. Tschidergreen
nd · 1985 · cited in 1 North Dakota opinions naming this issue, 2004–2004
2 sentences

2004The continuous representation rule requires any subsequent representation to relate to the same transaction or subject matter as the allegedly negligent acts. *452 Wall, 393 N.W.2d at 762 ; Binstock, 374 N.W.2d at 85 .

2004Id. [¶ 14] In Wall, 393 N.W.2d at 763-64 , we considered an issue about the termination of representation in the context of the continuous representation rule.

11
Heller v. Production Credit Ass'n of Minotgreen
nd · 1990 · cited in 1 North Dakota opinions naming this issue, 1991–1991
2 sentences

1991E.g., Heller v. Production Credit Association of Minot, 462 N.W.2d 125, 127 (N.D.1990).

1991E.g., Heller v. Production Credit Association of Minot, 462 N.W.2d 125, 127 (N.D.1990).

11
Boorman v. Bleakleygreen
nyappdiv · 1982 · cited in 1 North Dakota opinions naming this issue, 1986–1986
2 sentences

1986See, e.g., Goodwin v. Schulte, 115 Mich.App. 402 , 320 N.W.2d 391, 395 (1982); Boorman v. Bleakley, Platt, Schmidt, Hart & Fritz, 88 A.D.2d 942 , 451 N.Y.S.2d 179, 180 (1982); Brown v. Johnstone, 5 Ohio App.3d 165 , 450 N.E.2d 693, 695-696 (1982).

1986See, e.g., Goodwin v. Schulte, 115 Mich.App. 402 , 320 N.W.2d 391, 395 (1982); Boorman v. Bleakley, Platt, Schmidt, Hart & Fritz, 88 A.D.2d 942 , 451 N.Y.S.2d 179, 180 (1982); Brown v. Johnstone, 5 Ohio App.3d 165 , 450 N.E.2d 693, 695-696 (1982).

11
Goodwin v. Schultegreen
michctapp · 1982 · cited in 1 North Dakota opinions naming this issue, 1986–1986
2 sentences

1986See, e.g., Goodwin v. Schulte, 115 Mich.App. 402 , 320 N.W.2d 391, 395 (1982); Boorman v. Bleakley, Platt, Schmidt, Hart & Fritz, 88 A.D.2d 942 , 451 N.Y.S.2d 179, 180 (1982); Brown v. Johnstone, 5 Ohio App.3d 165 , 450 N.E.2d 693, 695-696 (1982).

1986See, e.g., Goodwin v. Schulte, 115 Mich.App. 402 , 320 N.W.2d 391, 395 (1982); Boorman v. Bleakley, Platt, Schmidt, Hart & Fritz, 88 A.D.2d 942 , 451 N.Y.S.2d 179, 180 (1982); Brown v. Johnstone, 5 Ohio App.3d 165 , 450 N.E.2d 693, 695-696 (1982).

11
Brown v. Johnstonegreen
ohioctapp · 1982 · cited in 1 North Dakota opinions naming this issue, 1986–1986
2 sentences

1986See, e.g., Goodwin v. Schulte, 115 Mich.App. 402 , 320 N.W.2d 391, 395 (1982); Boorman v. Bleakley, Platt, Schmidt, Hart & Fritz, 88 A.D.2d 942 , 451 N.Y.S.2d 179, 180 (1982); Brown v. Johnstone, 5 Ohio App.3d 165 , 450 N.E.2d 693, 695-696 (1982).

1986See, e.g., Goodwin v. Schulte, 115 Mich.App. 402 , 320 N.W.2d 391, 395 (1982); Boorman v. Bleakley, Platt, Schmidt, Hart & Fritz, 88 A.D.2d 942 , 451 N.Y.S.2d 179, 180 (1982); Brown v. Johnstone, 5 Ohio App.3d 165 , 450 N.E.2d 693, 695-696 (1982).

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 (7)

CaseCitedYears
Iverson v. Lancaster green
nd · 1968
1 sentence

1989We discussed, but did not adopt or apply, the continuous treatment theory for the first time in Iverson v. Lancaster, 158 N.W.2d 507 (N.D.1968).

11989–1989
Three Affiliated Tribes of the Fort Berthold Reservation v. Wold Engineering, P.C. green
nd · 1985
1 sentence

1988Issues regarding jurisdiction were resolved in Three Affiliated Tribes, Etc. v. Wold Engineering, P.C., 321 N.W. 2d 510 (N.D.1982), vacated and rem'd 467 U.S. 138 , 104 S.Ct. 2267 , 81 L.Ed.2d 113 (1984), on remand 364 N.W.2d 98 (N.D.1985) rev'd by 476 U.S. 877 , 106 S.Ct. 2305 , 90 L.Ed.2d 881 (1986). [2] Because the judgment is sustainable on the issues of proximate cause and breach of duty, we do not consider the other issues challenging the alternative bases for the trial court's decision, i.e., whether the trial court was correct in determining that the action was barred by the two-year s

11988–1988
THREE AFFILIATED TRIBES, ETC. v. Wold Eng., PC green
nd · 1982
1 sentence

1988Issues regarding jurisdiction were resolved in Three Affiliated Tribes, Etc. v. Wold Engineering, P.C., 321 N.W. 2d 510 (N.D.1982), vacated and rem'd 467 U.S. 138 , 104 S.Ct. 2267 , 81 L.Ed.2d 113 (1984), on remand 364 N.W.2d 98 (N.D.1985) rev'd by 476 U.S. 877 , 106 S.Ct. 2305 , 90 L.Ed.2d 881 (1986). [2] Because the judgment is sustainable on the issues of proximate cause and breach of duty, we do not consider the other issues challenging the alternative bases for the trial court's decision, i.e., whether the trial court was correct in determining that the action was barred by the two-year s

11988–1988
Three Affiliated Tribes of the Fort Berthold Reservation v. Wold Engineering, P. C. green
scotus · 1984
2 sentences

1988Issues regarding jurisdiction were resolved in Three Affiliated Tribes, Etc. v. Wold Engineering, P.C., 321 N.W. 2d 510 (N.D.1982), vacated and rem'd 467 U.S. 138 , 104 S.Ct. 2267 , 81 L.Ed.2d 113 (1984), on remand 364 N.W.2d 98 (N.D.1985) rev'd by 476 U.S. 877 , 106 S.Ct. 2305 , 90 L.Ed.2d 881 (1986). [2] Because the judgment is sustainable on the issues of proximate cause and breach of duty, we do not consider the other issues challenging the alternative bases for the trial court's decision, i.e., whether the trial court was correct in determining that the action was barred by the two-year s

1988Issues regarding jurisdiction were resolved in Three Affiliated Tribes, Etc. v. Wold Engineering, P.C., 321 N.W. 2d 510 (N.D.1982), vacated and rem'd 467 U.S. 138 , 104 S.Ct. 2267 , 81 L.Ed.2d 113 (1984), on remand 364 N.W.2d 98 (N.D.1985) rev'd by 476 U.S. 877 , 106 S.Ct. 2305 , 90 L.Ed.2d 881 (1986). [2] Because the judgment is sustainable on the issues of proximate cause and breach of duty, we do not consider the other issues challenging the alternative bases for the trial court's decision, i.e., whether the trial court was correct in determining that the action was barred by the two-year s

11988–1988
Three Affiliated Tribes of the Fort Berthold Reservation v. Wold Engineering, P. C. green
scotus · 1986
2 sentences

1988Issues regarding jurisdiction were resolved in Three Affiliated Tribes, Etc. v. Wold Engineering, P.C., 321 N.W. 2d 510 (N.D.1982), vacated and rem'd 467 U.S. 138 , 104 S.Ct. 2267 , 81 L.Ed.2d 113 (1984), on remand 364 N.W.2d 98 (N.D.1985) rev'd by 476 U.S. 877 , 106 S.Ct. 2305 , 90 L.Ed.2d 881 (1986). [2] Because the judgment is sustainable on the issues of proximate cause and breach of duty, we do not consider the other issues challenging the alternative bases for the trial court's decision, i.e., whether the trial court was correct in determining that the action was barred by the two-year s

1988Issues regarding jurisdiction were resolved in Three Affiliated Tribes, Etc. v. Wold Engineering, P.C., 321 N.W. 2d 510 (N.D.1982), vacated and rem'd 467 U.S. 138 , 104 S.Ct. 2267 , 81 L.Ed.2d 113 (1984), on remand 364 N.W.2d 98 (N.D.1985) rev'd by 476 U.S. 877 , 106 S.Ct. 2305 , 90 L.Ed.2d 881 (1986). [2] Because the judgment is sustainable on the issues of proximate cause and breach of duty, we do not consider the other issues challenging the alternative bases for the trial court's decision, i.e., whether the trial court was correct in determining that the action was barred by the two-year s

11988–1988
Avram v. Haddad green
nyappdiv · 1982
2 sentences

1986See, e.g., Goodwin v. Schulte, 115 Mich.App. 402 , 320 N.W.2d 391, 395 (1982); Boorman v. Bleakley, Platt, Schmidt, Hart & Fritz, 88 A.D.2d 942 , 451 N.Y.S.2d 179, 180 (1982); Brown v. Johnstone, 5 Ohio App.3d 165 , 450 N.E.2d 693, 695-696 (1982).

1986See, e.g., Goodwin v. Schulte, 115 Mich.App. 402 , 320 N.W.2d 391, 395 (1982); Boorman v. Bleakley, Platt, Schmidt, Hart & Fritz, 88 A.D.2d 942 , 451 N.Y.S.2d 179, 180 (1982); Brown v. Johnstone, 5 Ohio App.3d 165 , 450 N.E.2d 693, 695-696 (1982).

11986–1986
Fetch v. Buehner green
nd · 1972
1 sentence

1985Relying on Fetch v. Buehner, 200 N.W.2d 258 (N.D.1972), and Krueger v. St.

11985–1985

Where else courts name it

NY 276 (1975–2026) LA 28 (1990–2019) CT 17 (1993–2019) KS 15 (1988–2022) WA 15 (2001–2024) WV 10 (1996–2025) CA 10 (1987–2023) ND 9 (1985–2004) IN 8 (2003–2018) SD 7 (1988–2020) KY 6 (1994–2024) MS 5 (1993–2011) IL 5 (1995–2025) NM 4 (1993–2024) NE 4 (2007–2020) WY 4 (1997–2013) VA 4 (2004–2025) SC 4 (2005–2016) DC 3 (1997–2022) NV 3 (2014–2016) TN 2 (2004–2017) NC 2 (2003–2011) AZ 2 (1983–2012) ME 2 (2010–2017) DE 2 (2019–2025) FL 2 (1992–2009) MT 2 (1989–2010) IA 2 (2018–2019)

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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