faith and credit clause (North Carolina) · Go Syfert
← North Carolina issues

faith and credit clause in North Carolina

46 North Carolina opinions name it 2 courts 1909–2014 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 (17)

CaseFollowedCited
Fleming v. Fleminggreen
ncctapp · 1980 · cited in 8 North Carolina opinions naming this issue, 1987–2010
2 sentences

2010App. 345, 349-50 , 271 S.E.2d 584, 587 (1980) (concluding that “[a] decree for the future payment of... child support is, as to installments past due and unpaid, within the protection of the full faith and credit clause of the Constitution unless by the law of the state in which the decree was rendered” the amounts are not considered vested).

1999This Court held in Fleming v. Fleming, 49 N.C.App. 345, 349-50 , 271 S.E.2d 584, 587 (1980) that: The full faith and credit clause ... requires that the judgment of the court of one state must be given the same effect in a sister state that it has in the state where it was rendered.

48
May v. Andersongreen
scotus · 1953 · cited in 2 North Carolina opinions naming this issue, 1967–1991
2 sentences

1991In May v. Anderson, 345 U.S. 528, 533-34 , 97 L.Ed. 1221, 1226-27 (1953), the United States Supreme Court essentially held that the full faith and credit clause of the United States Constitution does not require a state court to honor the custody decree of a sister state rendered in an action where the non-resident defendant did not have “minimum contacts” with the sister state.

1991In May v. Anderson, 345 U.S. 528, 533-34 , 97 L.Ed. 1221, 1226-27 (1953), the United States Supreme Court essentially held that the full faith and credit clause of the United States Constitution does not require a state court to honor the custody decree of a sister state rendered in an action where the non-resident defendant did not have “minimum contacts” with the sister state.

12
Sistare v. Sistaregreen
· 1910 · cited in 2 North Carolina opinions naming this issue, 1978–1980
2 sentences

1978Id. § 99. “. . . mere modes of execution provided by the laws of a state in which a judgment is rendered are not, by operation of the full faith and credit clause, obligatory upon the courts of another state in which the judgment is sought to be enforced. . . .” Sistaire v. Sistaire, 218 U.S. 1, 26 , 54 L.Ed. 905, 914 , 30 S.Ct. 682, 690 (1910).

1978Id. § 99. “. . . mere modes of execution provided by the laws of a state in which a judgment is rendered are not, by operation of the full faith and credit clause, obligatory upon the courts of another state in which the judgment is sought to be enforced. . . .” Sistaire v. Sistaire, 218 U.S. 1, 26 , 54 L.Ed. 905, 914 , 30 S.Ct. 682, 690 (1910).

12
Howland v. Stitzergreen
nc · 1950 · cited in 2 North Carolina opinions naming this issue, 1951–1980
2 sentences

1980It is improper to permit an alteration or re-examination of the judgment, or of the grounds on which it is based * * * ” Sears v. Sears, 253 N.C. 415, 417 , 117 S.E. 2d 7, 9 (1960), quoting, Howland v. Stitzer, 231 N.C. 528, 531 , 58 S.E. 2d 104, 106 (1950).

1980It is improper to permit an alteration or re-examination of the judgment, or of the grounds on which it is based * * * ” Sears v. Sears, 253 N.C. 415, 417 , 117 S.E. 2d 7, 9 (1960), quoting, Howland v. Stitzer, 231 N.C. 528, 531 , 58 S.E. 2d 104, 106 (1950).

12
Carr v. Bettgreen
mont · 1998 · cited in 1 North Carolina opinions naming this issue, 2014–2014
2 sentences

2014Similarly, the Supreme Court of Nevada stated that “the defenses preserved by Nevada’s Uniform Enforcement of Foreign Judgments Act and available under NRCP 60(b) are limited to those defenses that a judgment debtor may constitutionally raise under the full faith and credit clause and which are directed to the validity of the foreign judgment.” Rosenstein v. Steele, 103 Nev. 571, 573 , 747 P.2d. 230, 232 (1987) (per curiam) (citations omitted); see also Marworth, Inc. v. *380 McGuire, 810 P.2d 653, 657 (Colo. 1991) (en banc) (stating that under the Colorado UEFJA “[o]ur courts may consider C.R

2014Similarly, the Supreme Court of Nevada stated that “the defenses preserved by Nevada’s Uniform Enforcement of Foreign Judgments Act and available under NRCP 60(b) are limited to those defenses that a judgment debtor may constitutionally raise under the full faith and credit clause and which are directed to the validity of the foreign judgment.” Rosenstein v. Steele, 103 Nev. 571, 573 , 747 P.2d. 230, 232 (1987) (per curiam) (citations omitted); see also Marworth, Inc. v. *380 McGuire, 810 P.2d 653, 657 (Colo. 1991) (en banc) (stating that under the Colorado UEFJA “[o]ur courts may consider C.R

11
Marworth, Inc. v. McGuiregreen
colo · 1991 · cited in 1 North Carolina opinions naming this issue, 2014–2014
1 sentence

2014Similarly, the Supreme Court of Nevada stated that “the defenses preserved by Nevada’s Uniform Enforcement of Foreign Judgments Act and available under NRCP 60(b) are limited to those defenses that a judgment debtor may constitutionally raise under the full faith and credit clause and which are directed to the validity of the foreign judgment.” Rosenstein v. Steele, 103 Nev. 571, 573 , 747 P.2d. 230, 232 (1987) (per curiam) (citations omitted); see also Marworth, Inc. v. *380 McGuire, 810 P.2d 653, 657 (Colo. 1991) (en banc) (stating that under the Colorado UEFJA “[o]ur courts may consider C.R

11
Wooster v. Woostergreen
sd · 1987 · cited in 1 North Carolina opinions naming this issue, 2014–2014
1 sentence

2014Similarly, the Supreme Court of Nevada stated that “the defenses preserved by Nevada’s Uniform Enforcement of Foreign Judgments Act and available under NRCP 60(b) are limited to those defenses that a judgment debtor may constitutionally raise under the full faith and credit clause and which are directed to the validity of the foreign judgment.” Rosenstein v. Steele, 103 Nev. 571, 573 , 747 P.2d. 230, 232 (1987) (per curiam) (citations omitted); see also Marworth, Inc. v. *380 McGuire, 810 P.2d 653, 657 (Colo. 1991) (en banc) (stating that under the Colorado UEFJA “[o]ur courts may consider C.R

11
Rosenstein v. Steelegreen
nev · 1987 · cited in 1 North Carolina opinions naming this issue, 2014–2014
2 sentences

2014Similarly, the Supreme Court of Nevada stated that “the defenses preserved by Nevada’s Uniform Enforcement of Foreign Judgments Act and available under NRCP 60(b) are limited to those defenses that a judgment debtor may constitutionally raise under the full faith and credit clause and which are directed to the validity of the foreign judgment.” Rosenstein v. Steele, 103 Nev. 571, 573 , 747 P.2d. 230, 232 (1987) (per curiam) (citations omitted); see also Marworth, Inc. v. *380 McGuire, 810 P.2d 653, 657 (Colo. 1991) (en banc) (stating that under the Colorado UEFJA “[o]ur courts may consider C.R

2014Similarly, the Supreme Court of Nevada stated that “the defenses preserved by Nevada’s Uniform Enforcement of Foreign Judgments Act and available under NRCP 60(b) are limited to those defenses that a judgment debtor may constitutionally raise under the full faith and credit clause and which are directed to the validity of the foreign judgment.” Rosenstein v. Steele, 103 Nev. 571, 573 , 747 P.2d. 230, 232 (1987) (per curiam) (citations omitted); see also Marworth, Inc. v. *380 McGuire, 810 P.2d 653, 657 (Colo. 1991) (en banc) (stating that under the Colorado UEFJA “[o]ur courts may consider C.R

11
Salmeri v. Salmerigreen
wyo · 1976 · cited in 1 North Carolina opinions naming this issue, 2014–2014
1 sentence

2014Similarly, the Supreme Court of Nevada stated that “the defenses preserved by Nevada’s Uniform Enforcement of Foreign Judgments Act and available under NRCP 60(b) are limited to those defenses that a judgment debtor may constitutionally raise under the full faith and credit clause and which are directed to the validity of the foreign judgment.” Rosenstein v. Steele, 103 Nev. 571, 573 , 747 P.2d. 230, 232 (1987) (per curiam) (citations omitted); see also Marworth, Inc. v. *380 McGuire, 810 P.2d 653, 657 (Colo. 1991) (en banc) (stating that under the Colorado UEFJA “[o]ur courts may consider C.R

11
Wener v. Perrone & Cramer Realty, Inc.green
ncctapp · 2000 · cited in 1 North Carolina opinions naming this issue, 2004–2004
1 sentence

2004App. 362, 364, 528 S.E.2d 65, 67 (2000) (quotation marks and citation omitted) (applying North Carolina statute of limitations to a Florida judgment).

11
Twaddell v. Andersongreen
ncctapp · 1999 · cited in 1 North Carolina opinions naming this issue, 2003–2003
1 sentence

2003App. at 66-67 , 523 S.E.2d at 718 (the full faith and credit clause of U.S. Const, art.

11
Matanuska Valley Lines, Inc., a Corporation of the Territory of Alaska v. Frank H. Molitorgreen
ca9 · 1966 · cited in 1 North Carolina opinions naming this issue, 2000–2000
1 sentence

2000Application of the forum’s statute of limitations entails no violation of the full faith and credit clause of the Constitution since such statutes are deemed to affect procedure only and not the substance of the action. *365 Matanuska Valley Lines, Inc. v. Molitor, 365 F.2d 358, 359-60 (9th Cir. 1966), cert. denied, 386 U.S. 914 , 17 L.

11
Ellison v. Hunsingergreen
nc · 1953 · cited in 1 North Carolina opinions naming this issue, 1988–1988
11
Thomas Ex Rel. Thomas v. Thomasgreen
nc · 1958 · cited in 1 North Carolina opinions naming this issue, 1988–1988
11
Sears v. Searsgreen
nc · 1960 · cited in 1 North Carolina opinions naming this issue, 1980–1980
11
Spence v. Durhamgreen
nc · 1973 · cited in 1 North Carolina opinions naming this issue, 1980–1980
11
Lefferts v. Leffertsgreen
ny · 1933 · cited in 1 North Carolina opinions naming this issue, 1944–1944
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 (56)

CaseCitedYears
Allman v. Register green
nc · 1951
2 sentences

1960This decision does not conflict with our decisions in Allman v. Register, 233 N.C. 531 , 64 S.E. 2d 861 or Richter v. Harmon, 243 N.C. 373 , 90 S.E. 2d 744 , except in the latter case it is stated: “If the petitioner were still a citizen and resident of the State of Florida, the decree in that State awarding the custody of the minor child * * * to her * * would be binding on our courts under the full faith and credit clause of the Constitution of the United* States.” The foregoing statement seems to be in conflict with the decision of the Supreme Court of the United States in May v. Anderson,

1960This decision does not conflict with our decisions in Allman v. Register, 233 N.C. 531 , 64 S.E. 2d 861 or Richter v. Harmon, 243 N.C. 373 , 90 S.E. 2d 744 , except in the latter case it is stated: “If the petitioner were still a citizen and resident of the State of Florida, the decree in that State awarding the custody of the minor child * * * to her * * would be binding on our courts under the full faith and credit clause of the Constitution of the United* States.” The foregoing statement seems to be in conflict with the decision of the Supreme Court of the United States in May v. Anderson,

31951–1960
Boyles v. Boyles green
ncctapp · 1982
2 sentences

2000Boyles v. Boyles, 59 N.C.

1985Boyles v. Boyles, 59 N.C.

21985–2000
Lockman v. . Lockman green
nc · 1941
2 sentences

1991Ed. 227 (citations omitted). *722 In the case under review defendant argues that the statutory denial of jurisdiction to North Carolina courts to hear suits on judgments based on gaming debts or futures contracts has been upheld as an exception to the application of the full faith and credit clause described by the Court in Milwaukee County as “a cause of action for which the state of the forum has not provided a court.” See Lockman v. Lockman, 220 N.C. 95 , 16 S.E.2d 670 (1941); Cody v. Hovey, 219 N.C. 369 , 14 S.E.2d 30 (1941).

1991Ed. 227 (citations omitted). *722 In the case under review defendant argues that the statutory denial of jurisdiction to North Carolina courts to hear suits on judgments based on gaming debts or futures contracts has been upheld as an exception to the application of the full faith and credit clause described by the Court in Milwaukee County as “a cause of action for which the state of the forum has not provided a court.” See Lockman v. Lockman, 220 N.C. 95 , 16 S.E.2d 670 (1941); Cody v. Hovey, 219 N.C. 369 , 14 S.E.2d 30 (1941).

21951–1991
Dansby v. North Carolina Mutual Life Insurance neutral
nc · 1936
2 sentences

1988The only question presented is whether the judgment sued on is valid under the law of Virginia; Dansby v. North Carolina Mutual Life Insurance Co., 209 N.C. 127 , 183 S.E. 521 (1936); if it is the full faith and credit clause of the United States Constitution art.

1988The only question presented is whether the judgment sued on is valid under the law of Virginia; Dansby v. North Carolina Mutual Life Insurance Co., 209 N.C. 127 , 183 S.E. 521 (1936); if it is the full faith and credit clause of the United States Constitution art.

21938–1988
Williams v. North Carolina green
scotus · 1945
2 sentences

1962This clause is now construed to mean that a foreign decree of divorce rendered in a state in which neither of the parties had a bona fide domicile is not required to be recognized in another state under the full faith and credit clause of the Federal Constitution, and that the court of another state is free to go behind the findings of the foreign divorce court as to the jurisdictional fact of domicile in the divorce forum, and find for itself, contrary to the finding of the foreign divorce court, that no domicile in fact existed in the foreign state to entitle the foreign decree to extraterri

1962This clause is now construed to mean that a foreign decree of divorce rendered in a state in which neither of the parties had a bona fide domicile is not required to be recognized in another state under the full faith and credit clause of the Federal Constitution, and that the court of another state is free to go behind the findings of the foreign divorce court as to the jurisdictional fact of domicile in the divorce forum, and find for itself, contrary to the finding of the foreign divorce court, that no domicile in fact existed in the foreign state to entitle the foreign decree to extraterri

21962–1984
State v. . Williams green
nc · 1944
2 sentences

1982Marketing Systems v. Realty Co., 277 N.C. 230 , 176 S.E.2d 775 (1970); State v. Williams, 224 N.C. 183 , 29 S.E.2d 744 (1944); Prather, Thomas, Campbell, Pridgeon, Inc. v. Properties, Inc., 29 N.C.App. 316 , 224 S.E.2d 289 (1976).

1982Marketing Systems v. Realty Co., 277 N.C. 230 , 176 S.E.2d 775 (1970); State v. Williams, 224 N.C. 183 , 29 S.E.2d 744 (1944); Prather, Thomas, Campbell, Pridgeon, Inc. v. Properties, Inc., 29 N.C.App. 316 , 224 S.E.2d 289 (1976).

21976–1982
American Institute of Marketing Systems, Inc. v. Willard Realty Co. green
nc · 1970
2 sentences

1982Marketing Systems v. Realty Co., 277 N.C. 230 , 176 S.E.2d 775 (1970); State v. Williams, 224 N.C. 183 , 29 S.E.2d 744 (1944); Prather, Thomas, Campbell, Pridgeon, Inc. v. Properties, Inc., 29 N.C.App. 316 , 224 S.E.2d 289 (1976).

1982Marketing Systems v. Realty Co., 277 N.C. 230 , 176 S.E.2d 775 (1970); State v. Williams, 224 N.C. 183 , 29 S.E.2d 744 (1944); Prather, Thomas, Campbell, Pridgeon, Inc. v. Properties, Inc., 29 N.C.App. 316 , 224 S.E.2d 289 (1976).

21976–1982
McMillin v. McMillin green
colo · 1945
2 sentences

1956In re Biggers, 228 N.C. 743 , 47 S.E. 2d 32 ; McMillin v. McMillin, 114 Col. 247 , 158 P. 2d 444 , 160 A.L.R. 396 ; Cole v. Cole, 194 Miss. 292 , 12 So. 2d 425 ; Parsley v. Parsley, 189 La. 584 , 180 So. 417 ; Fraley v. Martin (Tex. Civ.

1956In re Biggers, 228 N.C. 743 , 47 S.E. 2d 32 ; McMillin v. McMillin, 114 Col. 247 , 158 P. 2d 444 , 160 A.L.R. 396 ; Cole v. Cole, 194 Miss. 292 , 12 So. 2d 425 ; Parsley v. Parsley, 189 La. 584 , 180 So. 417 ; Fraley v. Martin (Tex. Civ.

21951–1956
Parsley v. Parsley neutral
la · 1938
2 sentences

1956In re Biggers, 228 N.C. 743 , 47 S.E. 2d 32 ; McMillin v. McMillin, 114 Col. 247 , 158 P. 2d 444 , 160 A.L.R. 396 ; Cole v. Cole, 194 Miss. 292 , 12 So. 2d 425 ; Parsley v. Parsley, 189 La. 584 , 180 So. 417 ; Fraley v. Martin (Tex. Civ.

1956In re Biggers, 228 N.C. 743 , 47 S.E. 2d 32 ; McMillin v. McMillin, 114 Col. 247 , 158 P. 2d 444 , 160 A.L.R. 396 ; Cole v. Cole, 194 Miss. 292 , 12 So. 2d 425 ; Parsley v. Parsley, 189 La. 584 , 180 So. 417 ; Fraley v. Martin (Tex. Civ.

21951–1956
Cole v. Cole green
· 1943
2 sentences

1956In re Biggers, 228 N.C. 743 , 47 S.E. 2d 32 ; McMillin v. McMillin, 114 Col. 247 , 158 P. 2d 444 , 160 A.L.R. 396 ; Cole v. Cole, 194 Miss. 292 , 12 So. 2d 425 ; Parsley v. Parsley, 189 La. 584 , 180 So. 417 ; Fraley v. Martin (Tex. Civ.

1956In re Biggers, 228 N.C. 743 , 47 S.E. 2d 32 ; McMillin v. McMillin, 114 Col. 247 , 158 P. 2d 444 , 160 A.L.R. 396 ; Cole v. Cole, 194 Miss. 292 , 12 So. 2d 425 ; Parsley v. Parsley, 189 La. 584 , 180 So. 417 ; Fraley v. Martin (Tex. Civ.

21951–1956
In Re Biggers green
nc · 1948
2 sentences

1956In re Biggers, 228 N.C. 743 , 47 S.E. 2d 32 ; McMillin v. McMillin, 114 Col. 247 , 158 P. 2d 444 , 160 A.L.R. 396 ; Cole v. Cole, 194 Miss. 292 , 12 So. 2d 425 ; Parsley v. Parsley, 189 La. 584 , 180 So. 417 ; Fraley v. Martin (Tex. Civ.

1956In re Biggers, 228 N.C. 743 , 47 S.E. 2d 32 ; McMillin v. McMillin, 114 Col. 247 , 158 P. 2d 444 , 160 A.L.R. 396 ; Cole v. Cole, 194 Miss. 292 , 12 So. 2d 425 ; Parsley v. Parsley, 189 La. 584 , 180 So. 417 ; Fraley v. Martin (Tex. Civ.

21951–1956
Taylor v. Taylor green
cal · 1923
2 sentences

1948Sharp v. Sharp, supra; Taylor v. Taylor , 218 P. 756 , 51 A.L.R., 1074 ; Perkins v. Mining Co., supra .

1948Sharp v. Sharp,, supra; Taylor v. Taylor, 218 P., 756 , 51 A. L.

21948–1948
Fitzsimmons v. Oklahoma City green
okla · 1942
2 sentences

1948Jurisdiction is a prerequisite of a valid judgment, 31 A. J., 70; Fitzsimmons v. City of Oklahoma City , 135 P.2d 340 , and if jurisdiction does not exist, enforcement thereof in another state is not compelled by the full faith and credit clause of the Constitution.

1948Jurisdiction is a prerequisite of a valid judgment, 31 A. J., 70; Fitzsimmons v. City of Oklahoma City, 135 P. (2d), 340 , and if jurisdiction’ does not exist, enforcement thereof in another state is not compelled by the full faith and credit clause of the Constitution.

21948–1948
Haddock v. Haddock red
· 1906
2 sentences

1941This question is answered in the negative by the celebrated case of Haddock v. Haddock , 201 U.S. 562 , 26 Sup. Ct., 525 , 50 L.Ed., 867 , justly recognized as a landmark in the law of foreign divorces.

1941This question is answered in the negative by the celebrated case of Haddock v. Haddock , 201 U.S. 562 , 26 Sup. Ct., 525 , 50 L.Ed., 867 , justly recognized as a landmark in the law of foreign divorces.

21932–1941
Matanuska Valley Lines, Inc. v. Molitor green
scotus · 1967
1 sentence

2000Application of the forum’s statute of limitations entails no violation of the full faith and credit clause of the Constitution since such statutes are deemed to affect procedure only and not the substance of the action. *365 Matanuska Valley Lines, Inc. v. Molitor, 365 F.2d 358, 359-60 (9th Cir. 1966), cert. denied, 386 U.S. 914 , 17 L.

12000–2000
Jefferson Construction Co. of Florida v. United States green
scotus · 1967
1 sentence

2000Application of the forum’s statute of limitations entails no violation of the full faith and credit clause of the Constitution since such statutes are deemed to affect procedure only and not the substance of the action. *365 Matanuska Valley Lines, Inc. v. Molitor, 365 F.2d 358, 359-60 (9th Cir. 1966), cert. denied, 386 U.S. 914 , 17 L.

12000–2000
Mayer v. Mayer green
ncctapp · 1984
1 sentence

1995In Mayer v. Mayer, 66 N.C.

11995–1995
Cody v. . Hovey green
nc · 1941
2 sentences

1991Ed. 227 (citations omitted). *722 In the case under review defendant argues that the statutory denial of jurisdiction to North Carolina courts to hear suits on judgments based on gaming debts or futures contracts has been upheld as an exception to the application of the full faith and credit clause described by the Court in Milwaukee County as “a cause of action for which the state of the forum has not provided a court.” See Lockman v. Lockman, 220 N.C. 95 , 16 S.E.2d 670 (1941); Cody v. Hovey, 219 N.C. 369 , 14 S.E.2d 30 (1941).

1991Ed. 227 (citations omitted). *722 In the case under review defendant argues that the statutory denial of jurisdiction to North Carolina courts to hear suits on judgments based on gaming debts or futures contracts has been upheld as an exception to the application of the full faith and credit clause described by the Court in Milwaukee County as “a cause of action for which the state of the forum has not provided a court.” See Lockman v. Lockman, 220 N.C. 95 , 16 S.E.2d 670 (1941); Cody v. Hovey, 219 N.C. 369 , 14 S.E.2d 30 (1941).

11991–1991
Vanderbilt v. Vanderbilt green
scotus · 1957
11985–1985
Huntington v. Attrill green
scotus · 1892
11983–1983
Prather, Thomas, Campbell, Pridgeon, Inc. v. Florilina Properties, Inc. neutral
ncctapp · 1976
11982–1982
Searl v. Searl green
ncctapp · 1977
11980–1980
Ross v. California green
scotus · 1974
11980–1980
In Re Custody of Craigo green
nc · 1965
11969–1969
Cleeland v. Cleeland green
nc · 1958
11969–1969
Lennon v. Lennon green
nc · 1960
11967–1967
Surratt v. Surratt green
nc · 1965
11967–1967
Staedler v. Staedler green
nj · 1951
11962–1962
Robinson v. United States green
scotus · 1945
11962–1962
Metrik v. Fort Tryon Gardens, Inc. green
scotus · 1945
11962–1962
Ballard v. Logan green
wva · 1911
11962–1962
Childress v. Johnson Motor Lines, Inc. green
nc · 1952
11962–1962
Richter v. Harmon green
nc · 1956
11960–1960
Goodman v. Goodman green
njch · 1937
11958–1958
Lopez v. Avery green
fla · 1953
11958–1958
Sadler v. Sadler neutral
nc · 1951
11956–1956
Elliott v. Elliott green
ga · 1935
11952–1952
State Ex Rel. Rasco v. Rasco neutral
fla · 1939
11952–1952
Callahan v. Callahan green
kyctapphigh · 1944
11952–1952
Wilson v. Wilson neutral
· 1923
11952–1952

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 1A-1 (7) NC § N.C. Gen. Stat. § 1-47 (4) NC § N.C. Gen. Stat. § 1C-1701 (3) NC § N.C. Gen. Stat. § 50-13.10 (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

NY 196 (1905–2025) CA 143 (1917–2025) TX 95 (1913–2026) IL 90 (1907–2026) NJ 82 (1906–2022) PA 78 (1926–2026) FL 77 (1922–2017) GA 75 (1907–2025) CT 74 (1930–2024) LA 49 (1923–2014) WA 47 (1908–2026) NC 46 (1909–2014) OH 45 (1919–2024) MD 37 (1915–2021) MO 35 (1909–2011) TN 34 (1917–2024) MA 32 (1914–2024) AL 30 (1922–2015) WV 27 (1914–2025) MI 26 (1918–2026) AR 24 (1926–2014) KS 24 (1907–2010) IN 24 (1922–2018) VA 23 (1924–2006) CO 22 (1912–2024) AZ 22 (1940–2023) SC 21 (1923–2018) OK 21 (1919–1994) IA 21 (1919–2025) OR 21 (1910–1983) MN 20 (1918–2001) NM 19 (1931–2018) NE 18 (1902–2023) MS 17 (1928–2024) DE 16 (1936–2022) RI 15 (1914–2010) ID 15 (1919–2012) NV 14 (1948–2015) MT 12 (1924–2008) KY 12 (1924–2021) UT 11 (1907–2011) DC 11 (1946–2025) ND 10 (1922–1984) AK 10 (1970–2022) SD 8 (1937–2024) VT 8 (1919–1976) WY 7 (1976–1998) HI 7 (1953–2010) ME 7 (1941–2014) NH 7 (1950–2014) WI 6 (1916–2002)

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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