Justia North Dakota Supreme Court Opinion Summaries

In 2003, Terry Ramsey was found guilty of one count of gross sexual imposition for sexually abusing his half-sister's daughter, "Jane." Ramsey appealed the judgment of conviction, and the Supreme Court affirmed. In 2011, Ramsey applied for post-conviction relief alleging he was entitled to vacation of his criminal judgment based on newly discovered evidence and ineffective assistance of counsel. Ramsey alleged a letter he received from Jane recanting her trial testimony was newly discovered evidence entitling him to vacation. The trial court found Terry Ramsey failed to show newly discovered evidence existed and denied his claim for post-conviction relief. Upon review, the Supreme Court concluded the trial court did not abuse its discretion in rejecting Ramsey's post-conviction relief application based on newly discovered evidence. View "Ramsey v. North Dakota" on Justia Law

In 2011, Defendant Angela Dieterle was arrested for simple assault. The State alleged she willfully caused bodily injury to another person by biting and striking her husband. She argued on appeal the district court abused its discretion by admitting evidence of prior bad acts. Finding no error, the Supreme Court affirmed. View "North Dakota v. Dieterle" on Justia Law

John Holly appealed his conviction on drug charges related to the possession of marijuana and other controlled substances. He argued that the search of his vehicle was not supported by probable cause, and therefore the evidence used to convict him should have been suppressed. Upon review of the trial court record, the Supreme Court concluded that the search of Holly's vehicle was lawful; sufficient evidence existed on the record to sustain a conviction of guilt; and that the trial court did not err in finding, sua sponte, Holly guilty of a lesser-included offense. Therefore, the Court affirmed the criminal judgments which were based on the evidence found in Holly's vehicle. With regard to his residence however, the Court concluded the nighttime search warrant was not supported by separate probable cause, and the evidence found there should have been suppressed. The Court reversed those criminal judgments based on the evidence found in his residence. The case was remanded for the trial court to amend its order denying Holly's motion to suppress and the criminal judgments consistent with the Court's findings. View "North Dakota v. Holly" on Justia Law

The State appealed a district court order that dismissed felony theft of property charges against Steven Goldmann for lack of probable cause. After review of the trial court record, the Supreme Court concluded the State produced evidence to establish probable cause for a class B felony theft and the district court erred in its theft valuation. Accordingly, the Court reversed and remanded the case. View "North Dakota v. Goldmann" on Justia Law

Matthew Eagleman appealed an order that granted the State's motion to correct an illegal sentence and which resentenced him to imprisonment. Because the district court acted within the statutorily prescribed sentencing limits and did not rely on an impermissible factor in resentencing Eagleman, the Supreme Court affirmed. View "North Dakota v. Eagleman" on Justia Law

The North Dakota Department of Transportation appealed the reversal of its hearing officer's decision to suspend Debbie Ann Painte's driving privileges for 180 days. Upon review of the matter, the Supreme Court concluded the district court erred in deciding the hearing officer made insufficient findings of fact and conclusions of law to establish the police officer had reasonable grounds to believe Painte was in actual physical control of a vehicle. Furthermore, the Court concluded the Department laid a proper foundation for the admission of Painte's chemical test for intoxication. The district court's judgment was reversed and the hearing officer's decision suspending Painte's driving privileges was reinstated. View "Painte v. N.D. Dep't of Transportation" on Justia Law

The North Dakota Department of Transportation appealed a district court judgment that reversed its administrative hearing officer's decision to suspend Jay Olson's driving privileges for 180 days for driving under the influence of alcohol. Upon review of the matter, the Supreme Court concluded reasonable minds could have concluded the hearing officer's finding that Olson did not have anything to eat, drink, or smoke during the twenty minutes before the Intoxilyzer test was supported by the weight of the evidence in the record. The Court therefore reversed the district court's judgment which found differently, and reinstated the administrative suspension of Olson's driving privileges. View "Olson v. N.D. Dep't of Transportation" on Justia Law

In early 2013, S.R.B.'s father filed a petition for his involuntary commitment. The petition alleged S.R.B. was mentally ill and there was a reasonable expectation of a serious risk of harm if left untreated. The petition alleged that S.R.B. called a nearby school looking for his daughter, wife, and lover, of which he had none. The petition also alleged S.R.B.'s neighbor saw S.R.B. "walking around his house this morning with nothing on but his underwear shorts." The father requested emergency treatment, noting S.R.B. was not taking his medication. S.R.B. appealed the trial court's order for hospitalization and treatment at the North Dakota State Hospital for ninety days. The Supreme Court held the trial court's findings were insufficient to support the trial court's order, and remanded for expedited findings. On remand, the trial court entered additional findings and issued an amended order. The Supreme Court concluded the trial court did not err in finding clear and convincing evidence that supported the order for hospitalization and treatment. View "Interest of S.R.B." on Justia Law

Carol Johnson appealed the denial of her motions for summary judgment, to amend her complaint, and the grant of the defendants' summary judgment motions for various claims related to her involuntary hospitalization. Johnson also appealed an order denying her motion for reconsideration and an order denying her objections to the district court's award of costs and disbursements to the defendants. In 2009, Johnson, a formerly licensed attorney in California appearing pro se, sued Dr. Natalya Bronson, Registered Nurse B.R. Clark, Prairie St. John's Hospital, John Does 1-100, Jane Does 1-100 (collectively "Medical Defendants"), and Attorney Steven Mottinger after being involuntarily hospitalized. Her claims against the Medical Defendants essentially asserted that because "[a]t all material times, [she] was without mental defect or disease of any kind whatsoever," the Medical Defendants had no authority to involuntarily commit her. Johnson's claims against Mottinger asserted that he committed legal malpractice in his representation of Johnson and was also liable for false imprisonment and negligent and intentional infliction of emotional distress. Johnson alleged that, as a result of Mottinger and the Medical Defendants' conduct, she was subjected to numerous electronic hazards and suffered "severe and serious injuries and monetary damages." Johnson sought compensatory damages for costs related to medical care and treatment, pain and suffering, and the "loss of the enjoyment of life." Johnson sought damages in excess of $10,000,000 for lost wages and reduced earning capacity, asserting her ability to reenter the legal profession had been destroyed due to the stigma of being civilly committed. Finding no reason to overturn the trial court's decisions to deny Johnson's motions, the Supreme Court affirmed the trial court. View "Johnson v. Bronson" on Justia Law

Edward Waslaski, Jr. appealed a district court order denying his motion for reconsideration of his post-conviction relief application. Upon review of the matter, the Supreme Court concluded the district court did not abuse its discretion in denying Waslaski's motion. View "Waslaski v. North Dakota" on Justia Law