undue influence claim (North Dakota) · Go Syfert
← North Dakota issues

undue influence claim in North Dakota

8 North Dakota opinions name it 1 courts 1992–2023 2 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 (3)

CaseFollowedCited
Johnson v. Johnsongreen
nd · 1957 · cited in 2 North Dakota opinions naming this issue, 2014–2023
2 sentences

2023Thus, “this first element of undue influence resolves itself into a lessened capacity of the object to make a free contract.” Odorizzi, at 540; see also Johnson, 85 N.W.2d at 221 (“The essential elements of undue influence required to be shown to authorize the cancellation of the deed are that the victim is rendered incapable of acting on his own motives, which implies a weak mentality.”). 6 [¶19] Regarding the first element of an undue influence claim—that Hennessey is a person susceptible to undue influence—the district court held “Hennessey’s complaint fails to assert he is a person who can

2014In cases involving nontestamentary transactions, this Court has defined undue influence as “improper influence [] exercised over the grantor ... in such a way and to such an extent as to destroy his free agency or his voluntary action by substituting for his will the will of another.” Johnson v. Johnson, 85 N.W.2d 211, 221 (N.D.1957).

22
Erickson v. Olsengreen
nd · 2014 · cited in 1 North Dakota opinions naming this issue, 2023–2023
1 sentence

2023Thus, “this first element of undue influence resolves itself into a lessened capacity of the object to make a free contract.” Odorizzi, at 540; see also Johnson, 85 N.W.2d at 221 (“The essential elements of undue influence required to be shown to authorize the cancellation of the deed are that the victim is rendered incapable of acting on his own motives, which implies a weak mentality.”). 6 [¶19] Regarding the first element of an undue influence claim—that Hennessey is a person susceptible to undue influence—the district court held “Hennessey’s complaint fails to assert he is a person who can

11
Wilson v. Dallasgreen
sc · 2011 · cited in 1 North Dakota opinions naming this issue, 2017–2017
1 sentence

2017In Wilson, 743 S.E.2d at 759-60 (footnotes omitted), the South Carolina Supreme Court discussed the good faith requirement in the context of a settlement agreement in litigation raising an undue influence challenge to an estate plan consisting of a will and an irrevocable charitable trust: “The ‘good faith’ requirement has been variously interpreted, with jurisdictions applying definitions that can be categorized along a continuum from a subjective to an objective standard, and they have afforded the claims a level of scrutiny that is less than that given to ordinary contracts, up to what has

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 (5)

CaseCitedYears
In the Matter of Estate of Stave green
nd · 2007
2 sentences

2018For an undue influence claim ultimately to be "submitted to a jury, the evidence must be sufficient with regard to each essential element of the claim and the evidence must also create more than just a mere suspicion of undue activity." In re Estate of Stave , 2007 ND 53 , ¶ 13, 729 N.W.2d 706 (quoting In re Estate of Dion , 2001 ND 53 , ¶ 34, 623 N.W.2d 720 ) (emphasis added).

2018For an undue influence claim ultimately to be "submitted to a jury, the evidence must be sufficient with regard to each essential element of the claim and the evidence must also create more than just a mere suspicion of undue activity." In re Estate of Stave , 2007 ND 53 , ¶ 13, 729 N.W.2d 706 (quoting In re Estate of Dion , 2001 ND 53 , ¶ 34, 623 N.W.2d 720 ) (emphasis added).

32018–2021
In Re Estate of Dion green
nd · 2001
2 sentences

2018For an undue influence claim ultimately to be "submitted to a jury, the evidence must be sufficient with regard to each essential element of the claim and the evidence must also create more than just a mere suspicion of undue activity." In re Estate of Stave , 2007 ND 53 , ¶ 13, 729 N.W.2d 706 (quoting In re Estate of Dion , 2001 ND 53 , ¶ 34, 623 N.W.2d 720 ) (emphasis added).

2018For an undue influence claim ultimately to be "submitted to a jury, the evidence must be sufficient with regard to each essential element of the claim and the evidence must also create more than just a mere suspicion of undue activity." In re Estate of Stave , 2007 ND 53 , ¶ 13, 729 N.W.2d 706 (quoting In re Estate of Dion , 2001 ND 53 , ¶ 34, 623 N.W.2d 720 ) (emphasis added).

22018–2018
Riskey v. Riskey green
nd · 2018
1 sentence

2021Id. (citing In re Estate of Stave, 2007 ND 53, ¶ 9 , 729 N.W.2d 706 ).

12021–2021
Estate of Baur v. West green
nd · 1952
2 sentences

1992In In re Bauers Estate, 79 N.D. 113 , 54 N.W.2d 891 (N.D.1952), the daughter of a testator challenged a will on the grounds the will could not be admitted to probate because the testator had never published, and declared to the witnesses to the instrument, that it was his last will.

1992In In re Bauers Estate, 79 N.D. 113 , 54 N.W.2d 891 (N.D.1952), the daughter of a testator challenged a will on the grounds the will could not be admitted to probate because the testator had never published, and declared to the witnesses to the instrument, that it was his last will.

11992–1992
Estate of Hamm v. Jenkins green
wis · 1975
1 sentence

1992Hamm, supra, 67 Wis.2d p. 294, 227 N.W.2d 34 .

11992–1992

Statutes the citing opinions construe

ND § N.D. Cent. Code § 59-12-02 (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

CA 17 (1987–2025) PA 15 (2001–2025) TN 14 (1998–2017) WA 12 (1983–2023) TX 11 (1991–2024) AL 10 (1979–2018) IA 9 (2013–2025) WI 8 (1975–2023) NJ 8 (1999–2026) ND 8 (1992–2023) SD 7 (1982–2025) FL 7 (1962–2015) OR 6 (1994–2025) IL 6 (1993–2022) NY 6 (1979–2026) IN 6 (2011–2024) MO 5 (1993–2020) MS 5 (1987–2018) GA 5 (1961–2023) MI 5 (1999–2025) WY 5 (1991–2024) NM 4 (1966–2020) KS 4 (1982–2019) MA 4 (2008–2025) OH 4 (2016–2024) NC 3 (1990–2021) VA 3 (1988–2017) AZ 2 (2021–2023) CT 2 (2023–2023) ME 2 (1995–2005) WV 2 (1980–2014) MD 2 (2022–2022) AR 2 (2001–2008) CO 2 (2008–2017) NV 2 (2008–2008) NE 2 (2015–2017)

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.

← Caselaw search · G Cite Topics · Brief Check