Justia North Dakota Supreme Court Opinion Summaries

Oak Reile, a delivery driver for Core Mark International, Inc., suffered a cervical spine fracture after falling off a loading ramp at work. He underwent surgery and rehabilitation, resulting in quadriplegia and other severe conditions. Reile later sought workers' compensation benefits for a psychological condition, specifically adjustment disorder with depressed mood, which he claimed was caused by his physical injury. Workforce Safety and Insurance (WSI) denied his claim, leading Reile to request reconsideration and an independent medical review.The Administrative Law Judge (ALJ) affirmed WSI's denial, concluding that while Reile's psychological condition resulted from his work injury, it did not meet the requirements of the North Dakota Administrative Code § 92-01-02-02.5. This regulation required the psychological condition to be the "physiological product" of the physical injury. The ALJ found that Reile's condition was compensable under the statute but not under the administrative rule. The district court upheld the ALJ's decision, leading to Reile's appeal.The North Dakota Supreme Court reviewed the case and determined that WSI exceeded its statutory authority in promulgating N.D. Admin. Code § 92-01-02-02.5. The court held that the regulation was invalid because it imposed additional burdens not present in the statute, such as requiring proof of a physiological nexus and excluding certain aspects of physical injuries from consideration. The court found that the ALJ's decision to deny benefits based on the invalid regulation was not in accordance with the law. Consequently, the Supreme Court reversed the district court's judgment, holding that Reile was entitled to benefits under the applicable statute. View "Reile v. WSI" on Justia Law

Nicholas Caspers pled guilty to murder in November 2010 and was sentenced to fifteen years’ incarceration with seven years suspended and five years of probation. He was released on probation in August 2017. The State filed four petitions to revoke his probation. The first petition was denied in February 2020, with the court amending his probation to include mandatory participation in a sobriety program. The second petition was denied in September 2020, but the court amended the judgment to include sixty days of incarceration. The third petition was granted in November 2022, revoking his probation and resentencing him to thirty months of probation. The fourth petition was granted in October 2023, revoking his probation and sentencing him to serve the seven suspended years of incarceration.Caspers moved for correction of his sentence in February 2024, arguing that the September 2020 and November 2022 judgments were illegal, and that the October 2023 judgment should be vacated. The district court granted his motion in part, awarding him credit for thirty days, but denied the remaining requests for relief.On appeal, Caspers argued that the October 2023 judgment was illegal because it followed an impermissible third revocation of his probation. The North Dakota Supreme Court reviewed the case and determined that the September 2020 proceedings did not result in a revocation of probation but rather an intermediate sanction. The court concluded that Caspers was not subject to an impermissible third revocation of probation in October 2023 and affirmed the district court's order. View "State v. Caspers" on Justia Law

Jason Thompson was charged with two counts of terrorizing, one count of criminal trespass, and one count of disorderly conduct due to his actions at two bars in Mandan. During the trial, the State presented video evidence from an officer’s body camera to demonstrate Thompson’s intent. Thompson objected to the video evidence, arguing it was irrelevant, prejudicial, and violated rules against character evidence and hearsay. The district court overruled his objections and admitted the video evidence. The jury found Thompson guilty on all counts, and he appealed.The District Court of Morton County, South Central Judicial District, presided over by Judge Bonnie L. Storbakken, conducted the trial. Thompson’s objections to the video evidence were overruled, and the jury convicted him on all charges. Thompson appealed the decision, arguing that the district court erred in admitting the video evidence, limiting his cross-examination of the victims, and that the evidence was insufficient to support the convictions.The Supreme Court of North Dakota reviewed the case. The court held that the district court did not abuse its discretion in admitting the video evidence, as it was relevant and not unfairly prejudicial. The court also found that the district court did not err in limiting Thompson’s cross-examination of the victims, as the questions were either irrelevant or had been sufficiently answered. Finally, the court concluded that substantial evidence supported the jury’s verdicts. The Supreme Court of North Dakota affirmed the criminal judgment. View "State v. Thompson" on Justia Law

Kyle Woodman was charged with three counts of gross sexual imposition in Stark County, North Dakota, in April 2022. A jury trial was held in September 2023, and Woodman was found guilty on all counts. In January 2024, the district court sentenced him to twenty years in prison for count one (with all but five years suspended for ten years), and seven and a half years each for counts two and three, with all sentences running consecutively.Woodman appealed, arguing that the district court committed obvious error by not including the essential element that the crimes occurred in North Dakota in the jury instructions, that the prosecutor committed obvious error during closing arguments by creating evidence, incorporating personal beliefs, and vouching for witnesses, and that the district court relied on an impermissible factor (a pending charge) in determining the severity of his sentence.The North Dakota Supreme Court reviewed the case. It concluded that Woodman failed to establish obvious error regarding the jury instructions, as the instructions, when read together, adequately informed the jury that the offenses had to occur in Stark County, North Dakota. The court also found that Woodman did not demonstrate that the prosecutor's comments during closing arguments constituted obvious error affecting his substantial rights, as the jury was instructed to rely on their own recollection of the evidence and disregard any unsupported statements by the attorneys. Lastly, the court determined that Woodman did not show that the district court substantially relied on the pending charge in determining the severity of his sentence.The North Dakota Supreme Court affirmed the amended criminal judgment. View "State v. Woodman" on Justia Law

Randall Moe executed a Last Will and Testament in 1989, shortly after ending a relationship with Cynthia Almer. The will included provisions to bequeath all his property to Almer, with a contingent bequest to his daughter, Amanda Miller, if Almer predeceased him. Moe also designated Almer as the guardian for Miller and the personal representative of his estate. Moe passed away in July 2022, and Miller was appointed as the personal representative of his estate. Almer later filed a petition for formal probate and to set aside Miller’s appointment, while Miller sought to reform the will to reflect Moe’s intent to pass his estate to her.The District Court of Williams County held a bench trial and found the will valid and enforceable but concluded it was affected by a mistake of law or fact. The court reformed the will to state that Almer would hold Moe’s property in trust for Miller if she was a minor at the time of his death, otherwise, the property would go to Miller outright. The court also appointed Miller as the personal representative of the estate.The Supreme Court of North Dakota reviewed the case and found that the district court erred in its findings. The Supreme Court concluded that the will was not inconsistent and that the extrinsic evidence considered by the district court did not relate to Moe’s intent at the time he executed the will. The Supreme Court held that the district court misapplied the law by considering post-execution evidence unrelated to Moe’s intent when he executed the will. Consequently, the Supreme Court reversed the district court’s judgment reforming Moe’s will. View "Estate of Moe" on Justia Law

In December 2021, Jordan Juneau was charged in Wells County with attempted murder, armed robbery, and burglary. Later that month, he was charged in Stutsman County with unauthorized use of personal identifying information. In July 2022, he faced additional charges in Stutsman County for theft of property and criminal mischief. On May 10, 2023, Juneau entered Alford pleas in the Stutsman County cases based on a binding plea agreement, which stipulated he would not receive a sentence exceeding four years. The district court accepted his pleas but deferred sentencing to a different judge, who could accept or reject the plea agreement.At the August 24, 2023 hearing, the sentencing judge treated Juneau’s plea as an open plea and sentenced him to five years, exceeding the agreed-upon four-year limit. Juneau applied for postconviction relief in September 2023, arguing his sentence was illegal as it did not adhere to the plea agreement. The State did not oppose a remand for further dispositional hearings. However, the district court denied Juneau’s application, finding the nature of the plea agreement unclear and concluding he failed to establish his sentence was illegal.The Supreme Court of North Dakota reviewed the case and found the district court’s determination that Juneau’s plea agreement was unclear to be clearly erroneous. The Supreme Court held that Juneau’s sentence was illegal because it did not comply with the binding plea agreement. The court reversed the district court’s order and remanded the case, instructing the lower court to determine the terms of the plea agreement and either accept or reject it in compliance with Rule 11(c). If the terms cannot be determined, Juneau must be allowed to withdraw his pleas in the relevant case. View "Juneau v. State" on Justia Law

Ryan Eldon Greene was charged with eleven sexual offenses involving his 15-year-old daughter, who was visiting him in North Dakota during the summer of 2023. The charges included luring minors by computers, incest, corruption of a minor, sexual assault, and solicitation of a minor. Greene pled guilty to all charges on an open plea basis, and the district court sentenced him to a total of 50 years' imprisonment, with some sentences suspended subject to probation.The District Court of Grand Forks County accepted Greene's guilty plea, finding a sufficient factual basis for all charges. Greene was sentenced to five years for each of the ten class C felonies, to run consecutively, and 227 days for the class A misdemeanor, with credit for time served. The sentences for five of the felonies were suspended, contingent on Greene completing ten years of supervised probation.The Supreme Court of North Dakota reviewed Greene's appeal, in which he argued that his convictions and sentences were multiplicitous and violated the Fifth Amendment, and that his sentence constituted cruel and unusual punishment under the Eighth Amendment. The court held that by pleading guilty, Greene waived his right to appeal on the grounds of multiplicity. Additionally, the court found that Greene's sentence was within statutory limits and not grossly disproportionate to the offenses committed. The court concluded that Greene's sentence did not violate the Eighth Amendment or the North Dakota Constitution.The Supreme Court of North Dakota affirmed the criminal judgment, upholding Greene's convictions and sentences. View "State v. Greene" on Justia Law

Mark Nelson, operating North Country Weatherization Technologies, provided ice removal services to Pine View First Addition Association, a Minnesota non-profit homeowners' association, in spring 2023. Pine View's property manager, a North Dakota LLC, contacted Nelson for urgent ice removal due to water damage. Nelson completed the work and invoiced Pine View, but payment was delayed, allegedly due to Pine View's attempt to have insurance cover the costs. Nelson filed a lawsuit in North Dakota for breach of contract and unjust enrichment, seeking $79,695 plus interest and attorney’s fees.The District Court of Cass County, East Central Judicial District, granted Pine View's motion to dismiss for lack of personal jurisdiction, concluding that North Dakota did not have jurisdiction over Pine View, as it is a Minnesota entity and the services were performed in Minnesota. The court also denied Pine View's motion for Rule 11 sanctions against Nelson and his attorney, as well as Nelson's request for prevailing party attorney’s fees.The Supreme Court of North Dakota reviewed the case and reversed the district court's decision. The Supreme Court held that North Dakota has specific personal jurisdiction over Pine View because Pine View, through its North Dakota-based property manager, initiated contact with Nelson for the ice removal services. The court found that Pine View's contacts with North Dakota were sufficient to satisfy the state's long-arm provision and due process requirements. The Supreme Court also determined that the district court abused its discretion in denying Nelson's request for prevailing party attorney’s fees under Rule 11(c)(2), as Pine View's motion for sanctions against Nelson violated Rule 11(c)(5)(A). The case was remanded for further proceedings and to determine the amount of attorney’s fees Nelson is owed. View "Nelson v. Pine View First Addition Association" on Justia Law

Jacob Hollingsworth filed for divorce from Katie Hollingsworth after nearly five years of marriage. They had one child and stipulated to a parenting plan, leaving the division of marital property, spousal support, and attorney’s fees as the issues for trial. Katie entered the marriage with significant debt and a house, while Jacob had a house, personal assets, and business interests. They kept separate finances except for a joint account for shared expenses. Jacob paid off much of Katie’s debt during the marriage.The District Court of Morton County, South Central Judicial District, heard testimony from both parties, two valuation experts, and Jacob’s father. The court awarded Jacob 92% and Katie 8% of the marital assets, denied Katie’s requests for spousal support and attorney’s fees, and allowed Jacob’s valuation expert to testify despite a late report disclosure. Katie appealed the decisions.The North Dakota Supreme Court reviewed the case. It upheld the district court’s decision to allow the expert testimony, noting that the court offered a continuance, which Katie declined. The court found no abuse of discretion in the district court’s handling of the late disclosure.The Supreme Court also affirmed the district court’s valuation and division of the marital estate, finding the valuations were within the range of evidence presented and the unequal distribution was justified by the parties’ financial contributions and spending habits. The court upheld the use of the agreed valuation date for assets and found no error in including interim order funds in the marital estate.The court found no clear error in denying spousal support, as both parties were capable of self-support. It also upheld the denial of attorney’s fees, noting Katie’s sufficient income and excessive spending habits. The district court’s judgment was affirmed in all respects. View "Hollingsworth v. Hollingsworth" on Justia Law

KNB Properties LLC and Delta Dawn, LLP, appealed a judgment and an order denying their motion to alter or amend the judgment. They argued that the district court erred in granting summary judgment in favor of Cass County. The case revolves around whether KNB needed the County’s approval under its subdivision ordinance for its development of an unplatted parcel of land in Stanley Township, which KNB bought in October 2017. KNB constructed a commercial building on the parcel and later subdivided it into two parcels, conveying one to Delta Dawn by warranty deed in 2021.The District Court of Cass County initially denied the parties’ cross-motions for summary judgment, finding disputed issues of material fact. Later, it granted the County’s motion for summary judgment, concluding that KNB’s creation of two auditor’s lots and the conveyance of one lot to Delta Dawn in 2021 triggered the subdivision ordinance. The court issued a permanent injunction requiring compliance with the subdivision ordinance before any further development, sale, or transfer of the parcel. KNB and Delta Dawn’s counterclaim was dismissed with prejudice.The Supreme Court of North Dakota reviewed the case and concluded that the subdivision ordinance was not violated until the act of subdivision in 2021. The court held that the County’s authority was not implicated until KNB platted the parcel into two parcels and conveyed one to Delta Dawn. The court found that the district court erred in granting a permanent injunction and that the proper remedy was to void the conveyance of the 12.451-acre parcel to Delta Dawn, thus restoring the KNB parcel to its original size. The Supreme Court reversed the judgment and the order denying the motion to alter or amend the judgment and remanded with instructions to enter an amended judgment vacating the auditor’s lots and restoring the parties to their original positions. View "Cass Co. v. KNB Properties" on Justia Law