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NC General Statutes

N.C. Gen. Stat. § 20-71.1 (2026)

Registration evidence of ownership; ownership evidence of defendant's responsibility for conduct of operation

✓ current as of July 2026
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(a) In all actions to recover damages for injury to the person or to property or for the death of a person, arising out of an accident or collision involving a motor vehicle, proof of ownership of such motor vehicle at the time of such accident or collision shall be prima facie evidence that said motor vehicle was being operated and used with the authority, consent, and knowledge of the owner in the very transaction out of which said injury or cause of action arose.

(b) Proof of the registration of a motor vehicle in the name of any person, firm, or corporation, shall for the purpose of any such action, be prima facie evidence of ownership and that such motor vehicle was then being operated by and under the control of a person for whose conduct the owner was legally responsible, for the owner's benefit, and within the course and scope of his employment. (1951, c. 494; 1961, c. 975.)

 

Part 3A. Salvage Titles.
Notes of Decisions
Cited in 93 cases (4 in the last 5 years), 1952–2024 · leading case: DeArmon v. B. Mears Corp., 325 S.E.2d 223 (N.C. 1985).
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DeArmon v. B. Mears Corp., 325 S.E.2d 223 (N.C. 1985). · cites it 15× “The Court of Appeals reasoned that despite Mears’ evidence, which if believed would establish that the driver Canady was not its agent at the time of the accident, the prima facie case for agency created by N.C.G.S. § 20-71.1 upon a showing of registered ownership in Mears was…”
Branch v. Dempsey, 145 S.E.2d 395 (N.C. 1965). · cites it 30× “G.S. § 20-71.1 provides that in an action to recover damages for injury to property or for injury to or the death of a person, arising out of an accident or collision involving a motor vehicle, "Proof of the registration of a motor vehicle in the name of any person, firm, or…”
Jyachosky v. Wensil, 81 S.E.2d 644 (N.C. 1954). · cites it 25× “Thurston Motor Lines, supra, all arising prior to G.S. § 20-71.1. Thereafter, the General Assembly enacted Ch.”
Winston v. Brodie, 517 S.E.2d 203 (N.C. Ct. App. 1999). · cites it 19× “Winston in his pleadings as well as argument at trial thus relied entirely upon the principles enunciated in N.C.G.S. § 20-71.1 (1993), which provides: (a) In all actions to recover damages for injury to the person or to property .”
Parker v. Wilson, 100 S.E.2d 258 (N.C. 1957). · cites it 6× “Then the annotation sets forth cases which hold that one who was shown to be driving an automobile shortly prior to an accident is presumed to have continued as driver, a principle that needs no consideration in the instant case, because there is no evidence that Donald Wilson…”
Roberts v. Hill, 82 S.E.2d 373 (N.C. 1954). · cites it 6× “Even so, the answer thereto puts at rest the question of the applicability of G.S. 20-71.1. Plaintiff’s cause of action, as set forth in his complaint, is not bottomed on the master-servant relationship as between Foster and the Hills.”
Thompson v. Three Guys Furniture Co., 469 S.E.2d 583 (N.C. Ct. App. 1996). · cites it 5× “Plaintiff relies on G.S. § 20-71.1, which provides: (a) In all actions to recover damages for injury to the person or to property or for the death of a person, arising out of an accident or collision involving a motor vehicle, proof of ownership of such motor vehicle at the time…”
Howard v. Sasso, 116 S.E.2d 341 (N.C. 1960). · cites it 8× “Since plaintiff relies solely on the (admitted) fact that defendant was the registered owner of the 1957 Ford, decision turns upon the answer to this question: Is G.S. 20-71.1 applicable in the determination by the court of the crucial question of fact, namely, whether the 1957…”
Hartley v. Smith, 79 S.E.2d 767 (N.C. 1954). · cites it 4× “Smith’s family, and, on this aspect of the ease, he relies solely on the rule of evidence created by G.S. 20-71.1 which makes proof of ownership prima facie proof of agency.”
Atkinson v. Lesmeister, 651 S.E.2d 294 (N.C. Ct. App. 2007). · cites it 10× “Lastly, plaintiff argues he has established a prima facie case of agency pursuant to N.C. Gen.Stat. § 20-71.1 (2006) and is therefore entitled to judgment in his favor.”
Taylor v. Parks, 118 S.E.2d 779 (N.C. 1961). · cites it 8× “, Evidence, § 301), and by virtue of the provisions of G.S. 20-71.1 (a) constitutes prima facie evidence that the 1946 Plymouth automobile was being operated and used by Arnold Charlie Pope at the time of the collision here with the authority, consent, and knowledge of the…”
Smith v. Simpson, 133 S.E.2d 474 (N.C. 1963). · cites it 3× “order to qualify as a provider under the family purpose doctrine one must be a principal mover, one who intends to provide for another or others the particular thing, the automobile, and takes steps on his own responsibility to see to the consummation of the transaction, and…”
Show all 93 citing cases →
— N.C. Gen. Stat. § 20-71.1(a) — 2 cases
Taylor v. Parks, 118 S.E.2d 779 (N.C. 1961). “, Evidence, § 301), and by virtue of the provisions of G.S. 20-71.1 (a) constitutes prima facie evidence that the 1946 Plymouth automobile was being operated and used by Arnold Charlie Pope at the time of the collision here with the authority, consent, and knowledge of the…”
Blue v. Hill (E.D.N.C. 2020).
— N.C. Gen. Stat. § 20-71.1(b) — 4 cases
DeArmon v. B. Mears Corp., 325 S.E.2d 223 (N.C. 1985). “The Court of Appeals reasoned that despite Mears’ evidence, which if believed would establish that the driver Canady was not its agent at the time of the accident, the prima facie case for agency created by N.C.G.S. § 20-71.1 upon a showing of registered ownership in Mears was…”
Winston v. Brodie, 517 S.E.2d 203 (N.C. Ct. App. 1999). “Winston in his pleadings as well as argument at trial thus relied entirely upon the principles enunciated in N.C.G.S. § 20-71.1 (1993), which provides: (a) In all actions to recover damages for injury to the person or to property .”
DeArmon v. B. Mears Corp., 314 S.E.2d 124 (N.C. Ct. App. 1984).
Shinn v. Greeness, 218 F.R.D. 478 (M.D.N.C. 2003).
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