Watkins presumption (North Carolina) · Go Syfert
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Watkins presumption in North Carolina

7 North Carolina opinions name it 2 courts 1996–2023 3 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 (5)

CaseFollowedCited
Watkins v. Central Motor Lines, Inc.green
nc · 1971 · cited in 5 North Carolina opinions naming this issue, 1996–2023
2 sentences

2023This presumption, known as the Watkins presumption, states that the disability continues each week until “the employee returns to work at wages equal to those he was receiving at the time his injury occurred.” Watkins v. Central Motor Lines, 279 N.C. 132, 137 , 181 S.E.2d 588, 592 (1971).

2023This presumption, known as the Watkins presumption, states that the disability continues each week until “the employee returns to work at wages equal to those he was receiving at the time his injury occurred.” Watkins v. Central Motor Lines, 279 N.C. 132, 137 , 181 S.E.2d 588, 592 (1971).

35
In Re Stone v. G G Buildersgreen
nc · 1997 · cited in 2 North Carolina opinions naming this issue, 2023–2023
2 sentences

2023Stone v. G&G Builders , 346 N.C. 154, 157 , 484 S.E.2d 365, 367 (1997).

2023Stone v. G&G Builders , 346 N.C. 154, 157 , 484 S.E.2d 365, 367 (1997).

22
Nash v. Conrad Industries, Inc.green
ncctapp · 1983 · cited in 2 North Carolina opinions naming this issue, 1996–1997
2 sentences

1997See Nash v. Conrad Industries , 62 N.C.

1997See Nash v. Conrad Industries , 62 N.C.

22
Saunders v. Edenton Ob/Gyn Centergreen
nc · 2000 · cited in 1 North Carolina opinions naming this issue, 2023–2023
2 sentences

2023Three years after Saums, our Supreme Court in dicta quotes Saums and Kennedy, but suggests that the Watkins presumption also shifts the burden of proof to the employer: “Likewise, in order to rebut plaintiff’s claim of ongoing partial disability, in the event such issue arises, defendants have the burden of proving ‘not only suitable jobs are available, but also that the plaintiff is capable of getting one, taking into account both physical and vocational limitations.’ Saums [citation] (quoting Kennedy [citation].” Saunders v. Edenton Ob/Gyn Ctr., 352 N.C. 136, 141-42 , 530 S.E.2d 62, 66 (2000

2023Three years after Saums, our Supreme Court in dicta quotes Saums and Kennedy, but suggests that the Watkins presumption also shifts the burden of proof to the employer: “Likewise, in order to rebut plaintiff’s claim of ongoing partial disability, in the event such issue arises, defendants have the burden of proving ‘not only suitable jobs are available, but also that the plaintiff is capable of getting one, taking into account both physical and vocational limitations.’ Saums [citation] (quoting Kennedy [citation].” Saunders v. Edenton Ob/Gyn Ctr., 352 N.C. 136, 141-42 , 530 S.E.2d 62, 66 (2000

11
Cialino v. Wal-Mart Storesgreen
ncctapp · 2003 · cited in 1 North Carolina opinions naming this issue, 2005–2005
2 sentences

2005To avail herself of the Watkins presumption, a claimant must meet the initial burden of proving a disability in one of two ways: “(1) by a previous Industrial Commission award of continuing disability, or (2) by producing a Form 21 or Form 26 Settlement agreement approved by the Industrial Commission.” Cialino v. Wal-Mart Stores, 156 N.C.

2005To avail herself of the Watkins presumption, a claimant must meet the initial burden of proving a disability in one of two ways: “(1) by a previous Industrial Commission award of continuing disability, or (2) by producing a Form 21 or Form 26 Settlement agreement approved by the Industrial Commission.” Cialino v. Wal-Mart Stores, 156 N.C.

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 (1)

CaseCitedYears
Radica v. Carolina Mills green
ncctapp · 1994
2 sentences

2003See e.g., Watkins, 279 N.C. at 137 , 181 S.E.2d at 592 (“If an award is made by the Industrial Commission, payable during disability, there is a presumption that disability lasts until the employee returns to work and likewise a presumption that disability ends when the employee returns to work at wages equal to those he was receiving at the time his injury occurred.”); Radica v. Carolina Mills, 113 N.C.

2003See e.g., Watkins, 279 N.C. at 137 , 181 S.E.2d at 592 (“If an award is made by the Industrial Commission, payable during disability, there is a presumption that disability lasts until the employee returns to work and likewise a presumption that disability ends when the employee returns to work at wages equal to those he was receiving at the time his injury occurred.”); Radica v. Carolina Mills, 113 N.C.

12003–2003

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 97-2 (5) NC § N.C. Gen. Stat. § 97-88.1 (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

MI 24 (2016–2026) OH 8 (2008–2025) NC 7 (1996–2023) GA 7 (1999–2022) FL 6 (1992–2019) TX 5 (2005–2022) CA 5 (1995–2025) WA 5 (1984–2013) MS 4 (2011–2023) IN 4 (2007–2018) MO 4 (1963–2023) IL 4 (1972–2014) SC 4 (1988–2023) MN 4 (2013–2016) DC 3 (1999–2008) MD 3 (1962–2000) LA 2 (1984–1984) TN 2 (2014–2014) IA 2 (2015–2020) AR 2 (1953–2016) KS 2 (2003–2007)

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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