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· 10/26/2023

Severance v. Howe

Citations

  • 2023 ND 197

Syllabus

The tort of battery exists at common law. A person is civilly liable for offensive-contact battery if he or she (1) acts intending to cause a harmful or offensive contact with the person of the other or a third person, or an imminent apprehension of such a contact, and (2) an offensive contact with the person of the other directly or indirectly results. North Dakota is a notice pleading state. North Dakota's rules do not require plaintiffs to allege every element of their claim. The formal character of a complaint does not strictly determine the cause of action. Whether to abrogate a common law claim is a policy matter for the Legislature to decide. Section 28-01-46, N.D.C.C, which requires plaintiffs to submit an affidavit containing an expert opinion to support a prima facie case of professional medical negligence, does not apply to a claim for the intentional tort of battery.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

  • holding that a surreply should be permitted where a new argument is advanced in a reply brief
  • holding that a plaintiff can present evidence that her evaluation was deliberately falsified or manipulated to adversely alter her employment status
  • concluding that plaintiffs had satisfied their prima facie burden by demonstrating that they were terminated while “at least one younger and/or nonminority employee was retained”
  • holding that a district court “does not abuse its discretion by precluding a surreply” when deciding a motion “without relying on the new materials and arguments in the movant’s reply”
  • concluding that when a district court is confronted with new arguments for dismissal in a reply brief it may permit nonmovant to file a surreply or refrain from relying on the material
  • explaining that selective use of RIF criteria in identifying employees to be laid off is evidence of pretext

Source: CourtListener parenthetical corpus (CC0).

Judges: Crothers, Daniel John

Read full opinion on CourtListener

Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.