controversy requirement (North Carolina) · Go Syfert
← North Carolina issues

controversy requirement in North Carolina

6 North Carolina opinions name it 3 courts 1984–2013 0 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 (8)

CaseFollowedCited
Town of Tryon v. Duke Power Co.green
nc · 1942 · cited in 4 North Carolina opinions naming this issue, 1984–2012
2 sentences

2002In Town of Tryon v. Duke Power Co., 222 N.C. 200 , 22 S.E.2d 450 (1942) this Court acknowledged that, although the actual controversy rule may be difficult to apply in some cases and the definition of a “controversy” must depend on the facts of each case, “[a] mere difference of opinion between the parties” does not constitute a controversy within the meaning of the Declaratory Judgment Act.

2002In Town of Tryon v. Duke Power Co., 222 N.C. 200 , 22 S.E.2d 450 (1942) this Court acknowledged that, although the actual controversy rule may be difficult to apply in some cases and the definition of a “controversy” must depend on the facts of each case, “[a] mere difference of opinion between the parties” does not constitute a controversy within the meaning of the Declaratory Judgment Act.

24
Carolina Power & Light Co. v. Iseleygreen
nc · 1933 · cited in 1 North Carolina opinions naming this issue, 2013–2013
2 sentences

2013Thus, communications service providers satisfy the controversy requirement when they “allege in [their] complaint and show at the trial that a real controversy, arising out of [these statutory rights] .. . exists.” Carolina Power & Light Co., 203 N.C. at 820 , 167 S.E. at 61 ; Briscoe, 148 N.C. at 413 , 62 S.E. at 607 .

2013Thus, communications service providers satisfy the controversy requirement when they “allege in [their] complaint and show at the trial that a real controversy, arising out of [these statutory rights] .. . exists.” Carolina Power & Light Co., 203 N.C. at 820 , 167 S.E. at 61 ; Briscoe, 148 N.C. at 413 , 62 S.E. at 607 .

11
Creek Pointe Homeowner's Ass'n v. Happgreen
ncctapp · 2001 · cited in 1 North Carolina opinions naming this issue, 2013–2013
1 sentence

2013See Creek Pointe Homeowner’s Ass’n, 146 N.C.

11
Bullington v. . Angelgreen
nc · 1941 · cited in 1 North Carolina opinions naming this issue, 2012–2012
2 sentences

2012THE LEGISLATIVE ROLE IN DEFINING SUBJECT MATTER JURISDICTION OF NORTH CAROLINA COURTS UNDER THE DECLARATORY JUDGMENT ACT {55} The North Carolina Supreme Court’s treatment of the controversy requirement for adjudication under the Declaratory Judgment Act comports with the more general notion that the North Carolina General Assembly may, “‘within constitutional limitations, . . . fix and circumscribe the jurisdiction of the courts of this State,’” In re T.R.P., 360 N.C. at 590 , 636 S.E.2d at 790 (quoting Bullington v. Angel, 220 N.C. 18, 20 , 16 S.E.2d 411, 412 (1941)), such that “‘[w]here juri

2012THE LEGISLATIVE ROLE IN DEFINING SUBJECT MATTER JURISDICTION OF NORTH CAROLINA COURTS UNDER THE DECLARATORY JUDGMENT ACT {55} The North Carolina Supreme Court’s treatment of the controversy requirement for adjudication under the Declaratory Judgment Act comports with the more general notion that the North Carolina General Assembly may, “‘within constitutional limitations, . . . fix and circumscribe the jurisdiction of the courts of this State,’” In re T.R.P., 360 N.C. at 590 , 636 S.E.2d at 790 (quoting Bullington v. Angel, 220 N.C. 18, 20 , 16 S.E.2d 411, 412 (1941)), such that “‘[w]here juri

11
State Ex Rel. Utilities Commission v. Carolina Utility Customers Ass'n Inc.green
· 1998 · cited in 1 North Carolina opinions naming this issue, 2012–2012
2 sentences

2012Customers Assoc., Inc., 348 N.C. 452, 461 , 500 S.E.2d 693, 700 (1998) (“[T]he Commission is required to render its decisions upon questions of law and of fact in the same manner as a court of record.” (emphasis added)). {65} While this Court has identified no binding decision of a North Carolina court that either instructs or prompts the Court to apply the controversy standard developed under the Act to matters that are “in the nature of declaratory judgment actions,” i.e., “non-Declaratory Judgment Act” cases in which declaratory relief is otherwise sought, a plain reading of the Act implies

2012Customers Assoc., Inc., 348 N.C. 452, 461 , 500 S.E.2d 693, 700 (1998) (“[T]he Commission is required to render its decisions upon questions of law and of fact in the same manner as a court of record.” (emphasis added)). {65} While this Court has identified no binding decision of a North Carolina court that either instructs or prompts the Court to apply the controversy standard developed under the Act to matters that are “in the nature of declaratory judgment actions,” i.e., “non-Declaratory Judgment Act” cases in which declaratory relief is otherwise sought, a plain reading of the Act implies

11
Neuse River Foundation, Inc. v. Smithfield Foods, Inc.green
ncctapp · 2002 · cited in 1 North Carolina opinions naming this issue, 2012–2012
1 sentence

2012See, e.g., Neuse River Foundation, 155 N.C.

11
Eudy v. Eudygreen
nc · 1975 · cited in 1 North Carolina opinions naming this issue, 2012–2012
2 sentences

2012THE LEGISLATIVE ROLE IN DEFINING SUBJECT MATTER JURISDICTION OF NORTH CAROLINA COURTS UNDER THE DECLARATORY JUDGMENT ACT {55} The North Carolina Supreme Court’s treatment of the controversy requirement for adjudication under the Declaratory Judgment Act comports with the more general notion that the North Carolina General Assembly may, “‘within constitutional limitations, . . . fix and circumscribe the jurisdiction of the courts of this State,’” In re T.R.P., 360 N.C. at 590 , 636 S.E.2d at 790 (quoting Bullington v. Angel, 220 N.C. 18, 20 , 16 S.E.2d 411, 412 (1941)), such that “‘[w]here juri

2012THE LEGISLATIVE ROLE IN DEFINING SUBJECT MATTER JURISDICTION OF NORTH CAROLINA COURTS UNDER THE DECLARATORY JUDGMENT ACT {55} The North Carolina Supreme Court’s treatment of the controversy requirement for adjudication under the Declaratory Judgment Act comports with the more general notion that the North Carolina General Assembly may, “‘within constitutional limitations, . . . fix and circumscribe the jurisdiction of the courts of this State,’” In re T.R.P., 360 N.C. at 590 , 636 S.E.2d at 790 (quoting Bullington v. Angel, 220 N.C. 18, 20 , 16 S.E.2d 411, 412 (1941)), such that “‘[w]here juri

11
Bailey & Associates, Inc. v. Wilmington Board of Adjustmentgreen
ncctapp · 2010 · cited in 1 North Carolina opinions naming this issue, 2012–2012
1 sentence

2012See Bailey & Assocs., 202 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 (10)

CaseCitedYears
Briscoe v. Henderson Lighting & Power Co. green
nc · 1908
2 sentences

2013Thus, communications service providers satisfy the controversy requirement when they “allege in [their] complaint and show at the trial that a real controversy, arising out of [these statutory rights] .. . exists.” Carolina Power & Light Co., 203 N.C. at 820 , 167 S.E. at 61 ; Briscoe, 148 N.C. at 413 , 62 S.E. at 607 .

2013Thus, communications service providers satisfy the controversy requirement when they “allege in [their] complaint and show at the trial that a real controversy, arising out of [these statutory rights] .. . exists.” Carolina Power & Light Co., 203 N.C. at 820 , 167 S.E. at 61 ; Briscoe, 148 N.C. at 413 , 62 S.E. at 607 .

12013–2013
Gaston Board of Realtors, Inc. v. Harrison green
nc · 1984
2 sentences

2013North Carolina’s Declaratory Judgment Act expands the controversy requirement by establishing that trial courts not only have jurisdiction over alleged prior violations of rights, but also when litigation over a potential violation “appear[s] unavoidable.” Gaston Bd. of Realtors, 311 N.C. at 234 , 316 S.E.2d at 61 .

2013North Carolina’s Declaratory Judgment Act expands the controversy requirement by establishing that trial courts not only have jurisdiction over alleged prior violations of rights, but also when litigation over a potential violation “appear[s] unavoidable.” Gaston Bd. of Realtors, 311 N.C. at 234 , 316 S.E.2d at 61 .

12013–2013
Quick v. Quick green
· 1982
2 sentences

2012THE LEGISLATIVE ROLE IN DEFINING SUBJECT MATTER JURISDICTION OF NORTH CAROLINA COURTS UNDER THE DECLARATORY JUDGMENT ACT {55} The North Carolina Supreme Court’s treatment of the controversy requirement for adjudication under the Declaratory Judgment Act comports with the more general notion that the North Carolina General Assembly may, “‘within constitutional limitations, . . . fix and circumscribe the jurisdiction of the courts of this State,’” In re T.R.P., 360 N.C. at 590 , 636 S.E.2d at 790 (quoting Bullington v. Angel, 220 N.C. 18, 20 , 16 S.E.2d 411, 412 (1941)), such that “‘[w]here juri

2012THE LEGISLATIVE ROLE IN DEFINING SUBJECT MATTER JURISDICTION OF NORTH CAROLINA COURTS UNDER THE DECLARATORY JUDGMENT ACT {55} The North Carolina Supreme Court’s treatment of the controversy requirement for adjudication under the Declaratory Judgment Act comports with the more general notion that the North Carolina General Assembly may, “‘within constitutional limitations, . . . fix and circumscribe the jurisdiction of the courts of this State,’” In re T.R.P., 360 N.C. at 590 , 636 S.E.2d at 790 (quoting Bullington v. Angel, 220 N.C. 18, 20 , 16 S.E.2d 411, 412 (1941)), such that “‘[w]here juri

12012–2012
In Re TRP green
nc · 2006
1 sentence

2012THE LEGISLATIVE ROLE IN DEFINING SUBJECT MATTER JURISDICTION OF NORTH CAROLINA COURTS UNDER THE DECLARATORY JUDGMENT ACT {55} The North Carolina Supreme Court’s treatment of the controversy requirement for adjudication under the Declaratory Judgment Act comports with the more general notion that the North Carolina General Assembly may, “‘within constitutional limitations, . . . fix and circumscribe the jurisdiction of the courts of this State,’” In re T.R.P., 360 N.C. at 590 , 636 S.E.2d at 790 (quoting Bullington v. Angel, 220 N.C. 18, 20 , 16 S.E.2d 411, 412 (1941)), such that “‘[w]here juri

12012–2012
In re T.R.P. green
nc · 2006
1 sentence

2012THE LEGISLATIVE ROLE IN DEFINING SUBJECT MATTER JURISDICTION OF NORTH CAROLINA COURTS UNDER THE DECLARATORY JUDGMENT ACT {55} The North Carolina Supreme Court’s treatment of the controversy requirement for adjudication under the Declaratory Judgment Act comports with the more general notion that the North Carolina General Assembly may, “‘within constitutional limitations, . . . fix and circumscribe the jurisdiction of the courts of this State,’” In re T.R.P., 360 N.C. at 590 , 636 S.E.2d at 790 (quoting Bullington v. Angel, 220 N.C. 18, 20 , 16 S.E.2d 411, 412 (1941)), such that “‘[w]here juri

12012–2012
State Ex Rel. Utilities Commission v. Carolina Water Service, Inc. green
ncctapp · 2002
2 sentences

2012The text of the Act, nevertheless, sheds no meaningful light on the Carolina Water Service court’s use of the Act’s controversy standard to adjudicate a matter that came to the judiciary as an appeal of an administrative decision, under a statute granting specified powers of review. 149 N.C.

2012App. at 657–58, 562 S.E.2d at 62 ; N.C.

12012–2012
Adams v. North Carolina Department of Natural & Economic Resources green
nc · 1978
2 sentences

1997We have described an actual controversy as a "jurisdictional prerequisite" to a proceeding brought under the Declaratory Judgment Act, the purpose of which is to "`preserve inviolate the ancient and sound juridic concept that the inherent function of judicial tribunals is to adjudicate genuine controversies between antagonistic litigants with respect to their rights, status or other legal relations.'" Adams, 295 N.C. at 703 , 249 S.E.2d at 414 (quoting Lide, 231 N.C. at 118 , 56 S.E.2d at 409 .) In Town of Tryon v. Duke Power Co., 222 N.C. 200, 205 , 22 S.E.2d 450, 453 (1942), our Supreme Cour

1997We have described an actual controversy as a "jurisdictional prerequisite" to a proceeding brought under the Declaratory Judgment Act, the purpose of which is to "`preserve inviolate the ancient and sound juridic concept that the inherent function of judicial tribunals is to adjudicate genuine controversies between antagonistic litigants with respect to their rights, status or other legal relations.'" Adams, 295 N.C. at 703 , 249 S.E.2d at 414 (quoting Lide, 231 N.C. at 118 , 56 S.E.2d at 409 .) In Town of Tryon v. Duke Power Co., 222 N.C. 200, 205 , 22 S.E.2d 450, 453 (1942), our Supreme Cour

11997–1997
Lide v. Mears green
nc · 1949
2 sentences

1997We have described an actual controversy as a "jurisdictional prerequisite" to a proceeding brought under the Declaratory Judgment Act, the purpose of which is to "`preserve inviolate the ancient and sound juridic concept that the inherent function of judicial tribunals is to adjudicate genuine controversies between antagonistic litigants with respect to their rights, status or other legal relations.'" Adams, 295 N.C. at 703 , 249 S.E.2d at 414 (quoting Lide, 231 N.C. at 118 , 56 S.E.2d at 409 .) In Town of Tryon v. Duke Power Co., 222 N.C. 200, 205 , 22 S.E.2d 450, 453 (1942), our Supreme Cour

1997We have described an actual controversy as a "jurisdictional prerequisite" to a proceeding brought under the Declaratory Judgment Act, the purpose of which is to "`preserve inviolate the ancient and sound juridic concept that the inherent function of judicial tribunals is to adjudicate genuine controversies between antagonistic litigants with respect to their rights, status or other legal relations.'" Adams, 295 N.C. at 703 , 249 S.E.2d at 414 (quoting Lide, 231 N.C. at 118 , 56 S.E.2d at 409 .) In Town of Tryon v. Duke Power Co., 222 N.C. 200, 205 , 22 S.E.2d 450, 453 (1942), our Supreme Cour

11997–1997
Rental Towel & Uniform Service v. Bynum International, Inc. green
nc · 1981
2 sentences

1987While the judge must submit to the jury such issues raised by the pleadings and evidence as are necessary to fairly adjudicate the controversy at bar, Rental Towel and Uniform Service v. Bynum International, Inc., 304 N.C. 174 , 282 S.E. 2d 426 (1981), the form and number of the issues submitted is within the sound discretion of the trial judge.

1987While the judge must submit to the jury such issues raised by the pleadings and evidence as are necessary to fairly adjudicate the controversy at bar, Rental Towel and Uniform Service v. Bynum International, Inc., 304 N.C. 174 , 282 S.E. 2d 426 (1981), the form and number of the issues submitted is within the sound discretion of the trial judge.

11987–1987
Link v. Link green
· 1971
2 sentences

1987Link v. Link, 278 N.C. 181 , 179 S.E. 2d 697 (1971).

1987Link v. Link, 278 N.C. 181 , 179 S.E. 2d 697 (1971).

11987–1987

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 1-253 (4) 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

NJ 361 (1967–2026) DE 47 (1952–2026) WI 38 (1953–2026) TX 30 (1880–2022) IL 25 (1913–2025) CA 21 (1895–2025) OK 16 (1940–2024) MI 14 (1932–2018) NV 12 (1948–2022) AR 11 (1947–2016) NY 11 (1873–2025) FL 8 (1957–2024) ND 7 (1948–2017) VA 7 (2007–2024) IA 6 (1916–1978) NC 6 (1984–2013) WA 6 (1903–2018) MA 6 (1943–2014) NM 6 (1978–2022) LA 5 (1946–2019) MD 5 (2004–2025) OR 5 (1908–2000) AL 5 (1909–1997) SD 5 (1995–2025) WV 5 (1945–2014) IN 4 (2000–2008) OH 3 (1978–2004) PA 3 (1953–2018) UT 3 (1996–2020) GA 3 (1925–2019) RI 3 (1992–2007) WY 2 (2005–2019) NH 2 (1841–2019) MS 2 (2001–2003) ME 2 (2004–2017) TN 2 (1946–1968) CO 2 (1942–1960) KS 2 (1915–1991) AZ 2 (1988–1989)

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