NC General Statutes
N.C. Gen. Stat. § 1D-50 (2026)
Judicial review of award
✓ current as of July 2026
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When reviewing the evidence regarding a finding by the trier of fact concerning liability for punitive damages in accordance with G.S. 1D-15(a), or regarding the amount of punitive damages awarded, the trial court shall state in a written opinion its reasons for upholding or disturbing the finding or award. In doing so, the court shall address with specificity the evidence, or lack thereof, as it bears on the liability for or the amount of punitive damages, in light of the requirements of this Chapter. (1995, c. 514, s. 1.)
Notes of Decisions
Cited in 10
cases (1 in the last 5 years), 2003–2021 · leading case: Hayes v. Waltz, 784 S.E.2d 607 (N.C. Ct. App. 2016).
Hayes v. Waltz, 784 S.E.2d 607 (N.C. Ct. App. 2016). “Among the statutes contained in Chapter 1D is N.C. Gen. Stat. § 1D-50, which provides for judicial review of a punitive damages award and states as follows: *453 When reviewing the evidence regarding a finding by the trier of fact concerning liability for punitive damages in…”
Scarborough v. Dillard's, Inc., 693 S.E.2d 640 (N.C. 2009). “On 24 February 2005, the trial court granted Dillard's motion for JNOV as to punitive damages and entered an order setting aside that award.”
Scarborough v. Dillard's Inc., 655 S.E.2d 875 (N.C. Ct. App. 2008). “On 24 February 2005, the trial court granted Dillard's motion for judgment notwithstanding the verdict and entered an order setting aside the punitive damages award.”
Oddo v. Presser, 581 S.E.2d 123 (N.C. Ct. App. 2003). “Plaintiff also points to the trial court's judicial review of the punitive damages award pursuant to N.C.G.S. § 1D-50 (2001): (a) That the defendant knew the sexual affair between himself and Debbie Oddo Presser was wrong, and pursued said affair, and the sexual conduct…”
Desmond v. The News & Observer Publ'g Co., 823 S.E.2d 412 (N.C. Ct. App. 2018). “3 Pursuant to North Carolina General Statute § 1D-50, the trial court reduced the punitive damages award against defendant N & O to approximately $4.”
Jones v. Harrelson & Smith Contractors, LLC, 670 S.E.2d 242 (N.C. Ct. App. 2008). “General Statute § 1D-50, for such findings? 4. Did the Trial Court err by refusing to find the conversion of plaintiff's house by the defendant, in commerce, to be an unfair and deceptive trade practice, as a matter of law, and refusing to award treble damages and consider…”
Jones v. Harrelson & Smith Contractors, LLC, 638 S.E.2d 222 (N.C. Ct. App. 2006). “General Statute § 1D-50, for such findings? 4. Did the Trial Court err by refusing to find the conversion of plaintiff's house by the defendant, in commerce, to be an unfair and deceptive trade practice, as a matter of law, and refusing to award treble damages and consider…”
Simmons, Jr. v. Wiles (Bankr. E.D.N.C. 2021). “at 2, citing N.C.G.S. § 1D-50. The standard of review applied by that court is essential to this court’s disposition of the matter at hand, and is discussed infra, but it suffices to say for background purposes that the court upheld the jury’s verdict and it remains undisturbed…”
Springs v. City of Charlotte, 701 S.E.2d 700 (N.C. Ct. App. 2010). “We uphold the trial court's denial of the motion for a directed verdict and judgment notwithstanding the verdict ("JNOV") on the issue of permanent injuries, but we agree with defendants that the trial court erred in not providing a written opinion setting out its reasons for…”
In re: J.M. (N.C. Ct. App. 2020). “In Springs, the original trial court failed to enter a written opinion stating “its reasons for upholding or disturbing the finding or award” of punitive damages as required by N.C. Gen. Stat. § 1D-50, and thus this Court remanded the case to the trial court with instructions to…”
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