Legal Articles

Avoidances: Affirmative Defense to an Affirmative Defense

In civil litigation, defendants often plead affirmative defenses. An affirmative defenses is an additional fact which, if true, defeats a plaintiff’s claim. For example, the statute of limitations is an affirmative defense. A plaintiff may allege, then, that because plaintiff’s claim is untimely the lawsuit fails. The most meritorious claim in the world will be…

Ultimate Facts, Material Facts, Evidentiary Facts

Depending on the context — eg, pleadings, summary judgment, motions to dismiss, jury instructions — cases use the phrases “ultimate fact,” “material fact,” and “evidentiary fact.” The distinctions are subtle but legally important. A “material fact” and an “ultimate fact” generally mean the same thing. “Ultimate facts are those the jury must find to return…

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