four-corners rule (Oregon) · Go Syfert
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four-corners rule in Oregon

8 Oregon opinions name it 2 courts 2010–2023 2 in the last five years

The cases below were cited by Oregon 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
First State Bank at Gallup v. Clarkgreen
nm · 1977 · cited in 1 Oregon opinions naming this issue, 2019–2019
1 sentence

2019See, e.g., Holsonback v. First State Bank of Albertville, 394 So 2d 381, 383 (Ala Civ App 1980), cert den, 394 So 2d 384 (Ala Sup Ct 1981) (“Negotiability is determined from the face, the four-corners, of the instrument without reference to extrin- sic facts.”); First State Bank at Gallup v. Clark, 91 NM 117 , 119, 570 P2d 1144 (1977) (“[I]t is clear that in order to determine whether an instrument meets [the requirements of UCC § 3-104] only the instrument itself may be looked to, not other documents, even when other documents are referred to in the instru- ment.”); First Fed.

11
Nielsen v. St. Paul Companiesgreen
or · 1978 · cited in 1 Oregon opinions naming this issue, 2010–2010
1 sentence

2010See, e.g., Nielsen, 283 Or at 280 ; Oakridge Comm. Ambulance, 278 Or at 24 ; Ferguson, 254 Or at 507 ; Isenhart, 233 Or at 54 . 6 Gemini (and Shearer, by way of concession) would have us apply the same four-corners rule to both inquiries, looking exclusively to the facts of the underlying complaint to determine (1) whether Shearer was an “insured” within the meaning of the policy and (2) if so, whether the alleged conduct falls within the scope of the coverage.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Bresee Homes, Inc. v. Farmers Insurance Exchange green
or · 2012
2 sentences

2023Further, in Bresee Homes, 353 Or at 123 , the Supreme Court has explicitly rejected Arrowood’s contention, holding that an insured has “no bur- den to come forth with facts beyond those alleged” in the complaint.

2023Further, in Bresee Homes, 353 Or at 123 , the Supreme Court has explicitly rejected Arrowood’s contention, holding that an insured has “no bur- den to come forth with facts beyond those alleged” in the complaint.

22023–2023
Fred Shearer & Sons, Inc. v. Gemini Insurance green
orctapp · 2010
2 sentences

2020However, the four-corners analysis asks us to consider whether the pleaded “allegations reasonably can be interpreted as falling within the coverage.” Fred Shearer & Sons, Inc., 237 Or App at 478 .

2018Co. , 237 Or.App. 468 , 476, 240 P.3d 67 (2010), rev. den. , 349 Or. 602 , 249 P.3d 123 (2011) (emphasis in original).

22018–2020
West Hills Development Co. v. Chartis Claims, Inc. green
or · 2016
2 sentences

2018By limiting the analysis to the complaint and the insurance policy, the four-corners rule generally prevents consideration of extrinsic evidence." West Hills Development Co. v. Chartis Claims , 360 Or. 650 , 653, 385 P.3d 1053 (2016) ( West Hills ) (citations omitted).

2018By limiting the analysis to the complaint and the insurance policy, the four-corners rule generally prevents consideration of extrinsic evidence." West Hills Development Co. v. Chartis Claims , 360 Or. 650 , 653, 385 P.3d 1053 (2016) ( West Hills ) (citations omitted).

22016–2018
Lee v. ætna Casualty & Surety Co. green
nysd · 1949
2 sentences

2016Id.

2016Id.

22016–2016
Venaglia v. Kropinak green
nmctapp · 1998
1 sentence

2019The chief purpose of Article 3 of the UCC “is [to grease] the wheels of commerce by establishing clear, prac- tical rules governing negotiable instruments, so that sub- sequent parties (after the negotiation) know their rights.” Venaglia v. Kropinak, 125 NM 25 , 37, 956 P2d 824 (1998).

12019–2019
Lane v. NOOTH green
or · 2011
2 sentences

2018Co. , 237 Or.App. 468 , 476, 240 P.3d 67 (2010), rev. den. , 349 Or. 602 , 249 P.3d 123 (2011) (emphasis in original).

2018Co. , 237 Or.App. 468 , 476, 240 P.3d 67 (2010), rev. den. , 349 Or. 602 , 249 P.3d 123 (2011) (emphasis in original).

12018–2018
Ferguson v. Birmingham Fire Insurance Company green
or · 1969
1 sentence

2010See, e.g., Nielsen, 283 Or at 280 ; Oakridge Comm. Ambulance, 278 Or at 24 ; Ferguson, 254 Or at 507 ; Isenhart, 233 Or at 54 . 6 Gemini (and Shearer, by way of concession) would have us apply the same four-corners rule to both inquiries, looking exclusively to the facts of the underlying complaint to determine (1) whether Shearer was an “insured” within the meaning of the policy and (2) if so, whether the alleged conduct falls within the scope of the coverage.

12010–2010
Isenhart v. General Casualty Co. green
· 1962
1 sentence

2010See, e.g., Nielsen, 283 Or at 280 ; Oakridge Comm. Ambulance, 278 Or at 24 ; Ferguson, 254 Or at 507 ; Isenhart, 233 Or at 54 . 6 Gemini (and Shearer, by way of concession) would have us apply the same four-corners rule to both inquiries, looking exclusively to the facts of the underlying complaint to determine (1) whether Shearer was an “insured” within the meaning of the policy and (2) if so, whether the alleged conduct falls within the scope of the coverage.

12010–2010
OAKRIDGE COM. AMB. SERV. v. US Fid. & Guar. green
or · 1977
1 sentence

2010See, e.g., Nielsen, 283 Or at 280 ; Oakridge Comm. Ambulance, 278 Or at 24 ; Ferguson, 254 Or at 507 ; Isenhart, 233 Or at 54 . 6 Gemini (and Shearer, by way of concession) would have us apply the same four-corners rule to both inquiries, looking exclusively to the facts of the underlying complaint to determine (1) whether Shearer was an “insured” within the meaning of the policy and (2) if so, whether the alleged conduct falls within the scope of the coverage.

12010–2010

Where else courts name it

TX 46 (1956–2026) IL 35 (1992–2026) IN 24 (1984–2025) WI 23 (2007–2025) DE 13 (2014–2025) PA 11 (1975–2017) MS 10 (2001–2016) OR 8 (2010–2023) CO 6 (1981–2015) FL 5 (2008–2022) MD 4 (2005–2008) OH 3 (2018–2025) CT 2 (2014–2018) WA 2 (2003–2003) MI 2 (2005–2015) NM 2 (1991–2023) VA 2 (1996–2024) MO 2 (2014–2014) TN 2 (2011–2019) UT 2 (1993–2021)

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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