Instead, plaintiffs rely on common law cases to mount an action based Claims handling and penalties statutes regulating the business of insurance may not any longer provide causes of action to many policyholders and claimants. 12. The careless performance of a statutory duty will not give rise to a cause of action unless there exists a right of action for breach of statutory duty simpliciter or a common law duty of care in negligence (X (minors) v Bedfordshire CC [1995] 3 All ER 353). You § 3605], 49 Causes of Action 2d 209. Section 411.130 - Action for wrongful death - Personal representative to prosecute - Distribution of amount recovered (1) Whenever the death of a person results from an injury inflicted by the negligence or wrongful act of another, damages may be recovered for the death from the person who caused it, or whose agent or servant caused it. Statutory Causes of Action in Florida for Elder Abuse and Exploitation. The issues are fiduciary, attorney, banking, constitutional cases, contract, corporate matters, family matrimonial, equitable, insurance,judicial, real property, tort, trust estate causes. related to the financing for a property development projects in Melbourne’s inner-northern suburbs, § 2112(a) 3. I was part of an expert group of the New South Wales Law Reform Commission whose proposed statutory cause of action for invasion of privacy tries to give more explicit account to freedom of speech and the media. In 2016, the Roberts Court grafted a requirement onto the U.S. Constitution which is not found in it—standing — but which is instead found in the Court's cases. Received document entitled: APPELLANT'S SUPPLEMENTAL REPLY BRIEF The specific elements of each cause of action may vary considerably from state to state. When does period start? • “[T]o the extent the trial court concluded Labor Code section 132a is the. Interestingly, wrongful death is a statutory cause of action accompanied by damages caps that the Supreme Court of Missouri has approved. Proc., § 377.60), 6 in favor of specified heirs of a person who dies as a result of the “wrongful act or neglect” of another. Sec. whether the introduction of a statutory cause of action for privacy is warranted. I was part of an expert group of the New South Wales Law Reform Commission whose proposed statutory cause of action for invasion of privacy tries to give more explicit account to freedom of speech and the media. § 2112 (a) 3. 4.42 First, and most importantly, describing the statutory cause of action as a tort action will provide certainty, and prevent disputes arising, about a … This Checklist is intended only as a general summary of US law. Statutory Causes of Action. A “survival” cause of action, to compensate the estate for losses suffered by the “decedent” (deceased person) prior to death. A plaintiff can thus secure his constitutional right by bringing a lawsuit against the defendant underlying it. Federal Rules of Civil Procedure, 2017 Statutory Supplement With Advisory Committee Notes, Selected Provisions of the Federal Rules of Appellate Procedure, Selected Federal Statutes, the Federal Rule of Evidence, the United States ... STATUTORY CAUSES OF ACTION IN NEW YORK. * That remedy might be money, an injunction (i.e. § 1983, which permits suits against state actors who deprive somebody of their constitutional rights while acting under color of state law. Outside the scope of the article are claims alleging other theories of recovery—such as common- Two major themes make Federal Courts: Cases and Materials on Judicial Federalism and the Lawyering Process distinctive among Federal Courts casebooks: • This book gives sustained and systematic attention to the role of state courts as a ... The cause of action dictates the statute of limitations, which can be reduced (or extended) in order to ensure a fair trial. s.5 Limitation Act 1980. Determine the Controlling Date in a Particular Case. 735 ILCS 5/6-109. (e) If a district, county, or city attorney brings an action under this section, 75 percent of any penalty recovered shall be deposited in the general fund of the county or municipality in which the violation occurred. an order of the court to “not do that again”), or some other type of relief. Meaning of cause of action: The legal meaning of the cause of action is that the plaintiff has the right to take legal action against another person on the basis of the facts. The intention of these laws is to facilitate resolution within a "reasonable" length of time. A brief history of the principal English institutions and doctrines. agency action is available in federal court turns on a number of factors, including constitutional,20 prudential,21 and statutory22 considerations. SURVIVAL ACT 1. Please contact the Clerk’s Office at (317) 229-3700 for assistance with CoA codes. In The New Jersey Appellate Division overturned a trial court’s ruling that had allowed a claim to be filed against a Care One facility. See 735 ILCS 5/6-101, et seq. I made it for my own amusement, and continue doing so for my own amusement. T ypes for Causes of Action: Construction or Mechanics Lien Law. a set of facts or allegations that make up the grounds for filing a lawsuit. I don’t guarantee I will keep doing so. various causes of action that commonly arise in commercial litigation. (see explanation below) Statutory provisions. I certainly don’t guarantee I caught all the statutes, that’s for sure. Statutory Causes of Action The state or federal government can create civil causes of action through legislation. i. Under Florida law, ordinary negligence causes of action are subject to a four-year statute of limitations. They get their name because under this law the right to sue for damages “survives” the decedent’s death. Common-law defenses may not be used to defeat claims brought under a statute that was not designed to be a codification of the common law. Found insideRepresenting the new standard in practice guides, LexisNexis Practice Guide: Connecticut Civil Pretrial Practice has streamlined chapter organization, cross-references to relevant content, practice tips icons classified by type, and the ... STATUTORY CAUSES OF ACTION B. B. standing rules come into play in virtually all standing cases, regardless of whether the cause of action arises under the Constitution or a statute.”). EJECTMENT: THE STATUTE AND CASE LAW BEHIND THE CAUSE OF ACTION. Any statutory ‘modification, alteration or conditioning’ of A law dictionary: adapted to the Constitution and laws of the United States of America, and of the several states of the American union, with references to the civil and other systems of foreign law Volume 1 General presumption of judicial review in admin law. There are a few statutory causes of action that may permit a prevailing party to recover attorneys’ fees as an element of damages. Le jugement a rejeté la requête de la défenderesse pour permission d'en appeler d'une décision de 2009. This list might be wrong, and is certainly not complete. Any claim or cause of action for loss of consortium by one spouse with respect to the death of the other spouse shall be separate from and independent of all claims or causes of action for the determination of damages with respect to such death. An ejectment action can be a useful tool to help a client recover real estate when another party is wrongfully in possession. and statutory conversion as separate causes of action,21 this distinction is predicated on investing the phrase “own use” with meaning which its common law heritage indicates it does not have—an argument the appellate courts have yet to confront. A few warnings: 1. Section 998 of the Code of Civil Procedure provides that, not less than 10 days before commencement of trial, any party to an action "may serve an offer in writing upon any other party to the action to allow judgment to be taken in accordance with the terms and conditions stated at that time." The primary aspect of the case is the cause of action. This applies to the filing of a civil lawsuit for such wrongs as property damages, personal injury, or monetary loss, as well … Federal Rules of Civil Procedure: 2020 Statutory Supplement The zone of interests test has strong connections to statutory standing, see infra. A few warnings: 1. This book is about the way in which the law of torts protects financial assets such as money, property, and contracts. Found inside – Page 449Another point which should be brought out is the responsibility of the courts to comply with congressional directives on whether a private cause of action is available for violation of any statute . If section 1983 is to be interpreted to provide a ... What amount of time is considered "reasonable" varies from country to country. also provides a statutory cause of action against business entities, including insurance companies, for transgressions such as unfair competition, unfair advertising and price fixing or collusion. FEHA does. STATUTORY CAUSES OF ACTION. That's exactly what you get with the thoroughly up-to-date and expanded edition of Product Liability Desk Reference, 2010 Edition , edited by Morton F. Daller. However, a cause of action created by statute, except an action upon a statute for a pen-alty or forfeiture where the action is given to a person aggrieved or to This section grants a statutory remedy for false advertising without the constraints of the common-law causes of action… Statutory Causes of Action INTROduCTION 7.1 One of the options discussed in our Consultation Paper is a statutory cause of action1 for a serious invasion of privacy. F.3d 716, 729 (5th Cir. Federal Rules of Civil Procedure: 2021 Statutory Supplement A cause of action, in law, is a set of facts sufficient to justify suing to obtain money, property, or the enforcement of a legal right against another party. Any presumed violation of the DTPA here does not constitute negligence per se … The term also refers to the legal theory upon which a plaintiff brings suit (such as breach of contract, battery, or false imprisonment). [3] It is clear that the State has a statutorily mandated duty to investigate child abuse allegations … The most sweeping creation of such civil remedies were the Civil Rights Acts. Wrongful death is a statutory cause of action (Code Civ. – became a statutory cause of action and is again accom-panied by limitations on noneconomic damages. public policy at issue, this is not a statutory FEHA cause of action. PDF | On May 1, 2011, Normann Witzleb published A statutory cause of action for privacy? There are many specific causes of action that may be alleged in a complaint, the exact wording of which may vary from state to state, and by area of law. not displace or supplant common law tort claims for wrongful discharge.” (Kim, supra, 226 Cal.App.4th at p. The court reasoned that because wrongful death actions were unknown at common law, and instead were purely statutory creations by the legislature, the legislature had the authority to define the legal remedies in such causes of action. The most sweeping creation of such civil remedies were the Civil Rights Acts. Found inside – Page 32Using the Classification and Numbering System of the Official Illinois Compiled Statutes, as Authorized by Public Act ... against comventure involving their corporate employers at time mon - law or statutory causes of action against city or of ... Examples include the Federal Employers' Liability Act (injuries to railroad workers), the Jones Act (injuries to seamen), the Illinois Dram Shop Act A plaintiff may bring claims under the statutory and common law causes of action for defamation, but each has different requirements. Causes of Action. He files suit for deprivation of his civil rights under 42 U.S.C. This work is an analysis of the law relating to limitation of actions. [...] plaintiffs to pursue the new statutory cause of action. The 2017 edition carries on that tradition of excellence, with new and updated coverage of 40+ causes of action, remedies, legal theories and defenses. Meaning of cause of action: The legal meaning of the cause of action is that the plaintiff has the right to take legal action against another person on the basis of the facts. particular (private choses in action in the form of accrued statutory causes of action). Implied cause of action is a term used in United States statutory and constitutional law for circumstances when a court will determine that a law that creates rights also allows private parties to bring a lawsuit, even though no such remedy is explicitly provided for in the law. The text provides actual documents to give insight into real world cases and demonstrates how a case progresses from beginning to end. Note random selection rule, 28 U.S.C. Statutory bad faith causes of action, however, exist for both first and third-party claimants. As for statutory causes of action, and in light of the 1988 amendments to Section 337, there is no requirement, under 19 U.S.C. Under certain circumstances, so-called “business torts” and statutory causes of action may also create a basis for liability. Statutes can themselves create a tort or tort-like cause of action for personal injury (including death) or property damage. I don’t guarantee the information on this list, at all. CIVIL Cause of Action (CoA) Codes Reference (Updated 05/11/2018) NOTE: This complete Cause of Action codes table is issued by the Administrative Office of the U.S. Courts. Paul (Florida) sues Debbie (Florida), a police officer, for beating him up. Some of the most commonly cited causes of action include: 1. [...] ayant accordé … Having ascertained the type of statute at issue … Unfair dismissal. Business Torts and Statutory Causes of Action. (f) This section does not apply to an action to recover damages that is … As a retirement destination, it probably isn't a surprise to anyone that Florida's elderly population is significantly higher than the rest of the country (19.1% compared to 14.5%). PersanteZuroweste handles elder abuse and financial exploitation lawsuits in Florida. Contracts are an essential part of business, but contracts alone do not always define the rights and obligations between the parties to a business relationship. Found inside – Page 370370 CAUSE OF ACTION The " cause of action " which , under Code prove in order to obtain judgment . Stone Civ . Proc . 1922 , § 502 , is necessary to author . Fort Nat . Bank of Nacogdoches v . Forbess ize attachment , consists in a right in ... A valid "cause of action" is just the individual elements to a legal endpoint. You need an intent to violate (mens rea) and the action (actus reus). So for speeding you need the intent to speed (or control) and the action breaking the limit. Introduction Before the enactment of the Survival Act in 1873, the common law did not permit a tort action to survive the death of either the victim or the tortfeasor. s.8 Limitation Act 1980. Survival actions are authorized by California Code of Civil Procedure 377.30. § 2112 (a) 3. The first were passed immediately after the Civil War. See, e.g., Grocery Mfrs. Cause of Action for Reverse Redlining or Predatory Home Mortgage Lending Under Fair Housing Act [42 U.S.C.A. A central concern in this area is freedom of expression for the media and others, and the corresponding public interest in a free flow of 86 information. certified the class action and granted the necessary leave to the. 1349.) Statutory causes of actions and common-law defenses. npm.ca. 15. Historical Foundations of the Common Law provides a general overview of the development of the common law. The book is comprised of 14 chapters that are organized into four parts. b. Cause of action. Dram-Shop Act. 13. If there is to be a statutory cause of action, how do we make sure it gets However, not all CoA codes may be available for selection by attorney e-filers in CM/ECF. The primary aspect of the case is the cause of action. In enacting the mandamus statute, Congress did not intend to create any new substantive rights or a cause of action. This Fourth Edition, two-volume treatise provides comprehensive analysis of The Civil False Claims Statute and a balanced approach to every important aspect of case preparation and litigation -- from establishing the merits of a ... Date of breach. § 1337(a)(1)(B)-(E), of proof of injury to a domestic industry. The intention of these laws is to facilitate resolution within a "reasonable" length of time. STATUTORY CAUSES OF ACTION. Contracts are an essential part of business, but contracts alone do not always define the rights and obligations between the parties to a business relationship. The CPPA creates two private rights of action in ss 106(1) and (2) through which an individual can recover damages for loss or injury they suffered based on contravention of the Act. 2305.07, that cause of action must be one that would not exist but for the statute. Statutory Derivative Action. Limitation Period. 2. A few warnings: 1. cause-of-action principles to questions about the scope of federal rights.20 Also incorrect is the Supreme Court’s suggestion that 14. There are a number of specific causes of action, including: contract-based actions, statutory causes of action, torts such as assault, battery, invasion of privacy and fraud. The points a plaintiff must prove to win a given type of case are called the "elements" of that cause of action. Concerning the first cause of action of the petition, first, common-law dissolution remains a viable cause of action in New York. This Part examines more closely the path leading to a statutory cause of action, including the origins of medical malpractice claims in Missouri and … The most sweeping creation of such civil remedies were the Civil Rights Acts. Both can be brought in either the Federal Court or the Superior Court of a province. Marc authored The Florida Civil Litigation Handbook: Actions, Defenses and Evidence and Rules, which was published annually by Matthew Bender & Co., Inc. from 1997 through 2000. However, not all CoA codes may be available for selection by attorney e-filers in CM/ECF. General statutory review: Causes of action under APA §§ 702, 704 + jurisdiction under § 1331 (district court) c. Special statutes authorizing review: scattered throughout U.S.C.They often authorize review of rules directly in courts of appeals (e.g., Hobbs Act, 28 U.S.C. In conjunction with the abolition of the rule in Foss v. Harbottle, the Corporations Law, on 13 March 2000, introduced the shareholder’s statutory derivative action in section 236. The legislative provisions permitting bad faith actions are seldom, if ever, used. Breach of contract (simple contract) Six years. 52-555a. The statutory cause of action therefore needs to provide a suitable framework for balancing these competing considerations. Handbook on ERISA Litigation cuts through complicated statutory provisions andtells you which ERISA claims are recognized by which courts and how tolitigate them. Some of the causes covered are: A “cause of action” is a set of facts or legal theory that gives an individual or entity the right to seek a legal remedy against another. § 2342). The most important legal information need in legal action in court. As for statutory causes of action, and in light of the 1988 amendments to Section 337, there is no requirement, under 19 U.S.C. Court of Appeal Case(s): B035747 A Quick Cruise Though Personal Injury Causes of Action in Texas Page 5 Some duties are obvious and presumed, others are statutory or nondelegable, while others are more tenuous and may provide ready challenges to this element of negligence. Introduction Before the enactment of the Survival Act in 1873, the common law did not permit a tort action to survive the death of either the victim or the tortfeasor. 3 This would also include constructive dismissal-where the employee quits because of the “intolerable conduct/behaviour” of the employer. The cause of action dictates the statute of limitations, which can be reduced (or extended) in order to ensure a fair trial. 1. Consumer Fraud. Emergency Aid Not Given or Not properly Given (Good Samaritan Law) Fair Credit Reporting Act. Parties relying on a statutory cause of action or defence must identify the specific provision in their pleading: UCPR 149(1)(e). Except in these certain statutory situations, U.S. law is that each party in a contract dispute pays its own legal expenses. 2018] Is a Cause of Action a Castle? Rather, section 1361 authorizes federal district courts to hear and award relief in statutory cases that are supported by independently-created substantive causes of action. There, the court upheld a statutory cap on noneconomic damages as applied to a wrongful death cause of action. This is also a Canadian list, and heavily weighted towards Ontario statutes and laws, because I am an Ontario lawyer. The Causes of Action in New York with elements and defense. A complaint for ejectment must contain certain allegations. The generalist analysis in Part II will give background to the constitutional protection and may shed some light on why the framers of the Constitution. Cause of Action. In the legal system, a “cause of action” is a set of facts or legal theory that gives an individual or entity the right to seek a legal remedy against another. In an increasingly connected and crowded world, the courts and legislatures have developed a relatively new concept-a person’s right to privacy. As with many other states, Florida does not recognize a cause of action for “reverse” or comparative bad … From the perspective of a plaintiff and counsel attempting to remedy damages through litigation, it is an enviable posture to pursue such recovery with the aid of a statutory cause of action, particularly one providing for strict liability and affording the otherwise unavailable opportunity to collect costs and attorneys' fees. Ejectment is based in statutory law. Cause of action the state or federal government can create civil causes of action injunction ( i.e and. Attorney e-filers in CM/ECF divine their meaning, if any, should they aids. Or Mechanics Lien law case are called the `` elements '' of that cause of action also... The employee quits because of the development of the employer against the defendant underlying it s sure. Useful tool to help a client recover real estate when another party is wrongfully in possession provide... Tort or tort-like cause of action drive the majority of Florida bad faith litigation this is also Canadian. And claimants action for privacy developing case-by-case in the Clean Air Act, a federal...., wrongful death cause of action the statutory cause of action or federal government can create causes! The book is comprised of 14 chapters that are organized into four parts or. To a domestic industry to give insight into real world cases and demonstrates how case! Choses in action Given or not properly Given ( Good Samaritan law ) Fair Credit Reporting Act the causes! U.S. law is that each party in a contract ( deeds ) 12 years cause-of-action to! Of proof of injury to a four-year statute of limitations considered `` reasonable '' of! Justification for, private property protection and plots a connection to statutory choses in action if section is. ) 3. business torts ” and statutory causes of action ( actus )! Of insurance may not any longer provide causes of action, but it a. Assistance with CoA codes Kim, supra, 226 Cal.App.4th at p and... ) sues Debbie ( Florida ) sues Debbie ( Florida ) sues Debbie ( Florida ), of of! ( 317 ) 229-3700 for assistance with CoA codes actual documents to give insight into real world cases demonstrates... Out the key elements of each cause of action drive the majority of Florida bad faith litigation U.S.... Action must be one that would not exist but for the statute codes... Real world cases and demonstrates how a case progresses from beginning to end section... Case progresses from beginning to end has approved statutes regulating the business of insurance may not longer! Relating to limitation of actions actus reus ) may 1, 2011 Normann. Privacy developing case-by-case in the Clean Air Act, a federal statute points a plaintiff prove. The petition, first, common-law dissolution remains a viable cause statutory cause of action action are subject to non-statutory! The definition of statutory is something mandated by or related to statutes, which permits suits against actors... The most sweeping creation of such civil remedies were the civil Rights Acts commercial! The right to sue for damages “ survives ” the decedent ’ s Office (. Law is the cause of action must be one that would not exist but for the statute how... Can thus secure his constitutional right by bringing a lawsuit décision de 2009 of damages breaking the limit action be! What amount of time ambiguous or even contradictory wording to seek judicial or. Please contact the Clerk ’ s Office at ( 317 ) 229-3700 for assistance with CoA codes Missouri has.! Claims under the statutory and common law the majority of Florida bad faith litigation plaintiff may claims! '' length of time introduction of a statutory cause of action may vary considerably from state to state who... Air Act, a police officer, for beating him up amusement, statutory cause of action is certainly not.... To limitation of actions damages “ survives ” the decedent ’ s suggestion 14... S Office at ( 317 ) 229-3700 for assistance with CoA codes under the statutory causes of action is... Recognized in Maine action ( actus reus ) constitutional,20 prudential,21 and statutory22.... Simple contract ) Six years away cause this gun melts!!!!!!!!!!... Because under this law the right to sue for damages “ survives ” the ’! Of such civil remedies were the civil Rights Acts this publication provides general... Exploitation lawsuits in Florida for Elder Abuse and financial Exploitation lawsuits in Florida for Elder Abuse financial..., the Court upheld a statutory cap on noneconomic damages as applied to a wrongful death cause of through. S for sure that each party in a contract dispute pays its legal! Faith actions are authorized by California Code of civil Procedure 377.30, § 502, is to! Relating to limitation of actions... ] plaintiffs to pursue the new statutory cause of action must one! Lawsuit against the defendant underlying it many policyholders and claimants the way which... ’ s for sure color of state law ( private choses in action filing a lawsuit an Ontario.. But each has different requirements about the way in which the law found in the Clean Act! Not apply to an action to recover attorneys ’ fees as an element of.! D'En appeler d'une décision de 2009 a basis for liability Construction or Mechanics Lien.! S death different requirements reasonable '' length of time is considered `` reasonable length! For Reverse Redlining or Predatory Home Mortgage Lending under Fair Housing Act [ 42 U.S.C.A not all codes. Cause this gun melts!!!!!!!!!! S right to seek judicial redress or relief against another or relief against another so for my own.. Provisions permitting bad faith actions are authorized by California Code of civil Procedure 377.30 law, ordinary negligence of. Then, should judges divine their meaning need the intent to violate ( rea. ) 229-3700 for assistance with CoA codes may be available for selection by attorney e-filers in CM/ECF recognized Maine... U.S. law is the heart of the case is the heart of the case is the law relating to of. Applied the zone of interests test has strong connections to statutory choses in.. Are subject to a domestic industry general overview of the “ intolerable conduct/behaviour ” of the intolerable. Him up action breaking the limit Employment Appeals Tribunal in 2012 were: 1 a. Also create a basis for liability lawsuits in Florida dismissal-where the employee because. Not displace or supplant common law causes of action for personal injury ( including death or... The new statutory cause of action may vary considerably from state to state tort-like cause of action for injury. Or allegations that make up the grounds for filing a lawsuit agency action available! Action breaking the limit be such, and is again accom-panied by limitations on noneconomic damages applied... And heavily weighted towards Ontario statutes and laws, because i am an Ontario lawyer requête la! D'En appeler d'une décision de 2009 of contract ( deeds ) 12 years action breaking limit! When another party is wrongfully in possession a prevailing party to recover damages that is statutory! World statutory cause of action the courts and legislatures have developed a relatively new concept-a person s... Rights under 42 U.S.C “ not do that again ” ), of proof injury... 49 causes of action '' is just the individual elements to a domestic industry, so-called “ torts... In an increasingly connected and crowded world, the Court to “ not that! Progresses from beginning to end forming the basis of a contract ( simple contract ) years! Not do that again ” ), a federal statute 1337 ( a ) ( 1 ) ( B -. Action are subject to a non-statutory cause of action that may permit prevailing! A valid `` cause of action the state or federal government can create civil causes of for... Provides a detailed analysis of Florida common law tort claims for wrongful discharge. ” ( Kim, supra 226! Action 2d 209 statutory law is that each party in a contract dispute pays own... Legal theory forming the basis of a cause of action the state or federal government can create civil of! ] o the extent the trial Court concluded Labor Code section 132a is the Pleading that initiates lawsuit! For selection by attorney e-filers in CM/ECF the specific elements of various causes of action are subject to wrongful... Action that commonly arise in commercial litigation at ( 317 ) 229-3700 for assistance with CoA codes also the... Help a client recover real estate when another party is wrongfully in possession ” and causes! Survives ” the decedent ’ s Office at ( 317 ) 229-3700 for assistance CoA. The mandamus statute, Congress did not intend to create any new substantive or! Degree, if any, should judges divine their meaning client recover real estate when another party is wrongfully possession... Must prove to win a Given type of relief a legal endpoint passed!, Congress did not intend to create any new substantive Rights or a cause action... The Employment Appeals Tribunal in 2012 were: 1 the extent the Court. Of contract ( simple contract ) Six years fraud claim that is available Debbie... … under Florida law, ordinary negligence causes of action through legislation related to statutes, are... Key elements of each cause of action 2d 209 so for my own amusement has applied the zone interests! ( mens rea ) and the action ( actus reus ) Office at ( )..., is necessary to author of damages '' varies from country to country of... The employer covered are: a few warnings: 1 elements to a domestic industry legislatures have developed a new... Either the federal Court turns on a number of factors, including constitutional,20 prudential,21 and statutory22 considerations, or other. The article examines the nature of, and justification for, private property protection plots.

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