Justia North Dakota Supreme Court Opinion Summaries

Antonio Eugenio Medina entered a guilty plea following the denial of his motion to suppress evidence in a criminal case. Medina, his attorney, the prosecutor, and the district court discussed and appeared to agree that his plea was conditional, allowing him to reserve the right to appeal the suppression ruling. However, the written judgment did not specify that the plea was conditional as required by the applicable procedural rule.The District Court of Grand Forks County, Northeast Central Judicial District, presided over Medina’s plea hearing and subsequent proceedings. Despite indications in the transcript that all parties consented to a conditional plea, the court did not issue a written order or judgment expressly stating that the plea was conditional, nor did the record contain written consents as required by N.D.R.Crim.P. 11(a)(2). Medina appealed, arguing that his plea should be recognized as conditional so that he could pursue an appeal of the suppression decision.The Supreme Court of North Dakota reviewed the record and found that while the transcript reflected substantial compliance with the requirements for a conditional plea, the absence of a written order and a judgment specifying that the plea was conditional did not satisfy the explicit requirements of N.D.R.Crim.P. 11(a)(2), as amended in 2017. The Supreme Court remanded the case to the district court with instructions to clarify whether it accepted a conditional plea and, if so, to enter an order and correct the judgment to properly reflect the conditional nature of the plea. The Supreme Court retained jurisdiction pending the district court’s clarification. The holding requires district courts to strictly comply with the procedural requirements for conditional pleas under Rule 11(a)(2), including written consents, a court order, and a judgment specifying the plea is conditional. View "State v. Medina" on Justia Law

Niko Solis was charged with indecent exposure, a class A misdemeanor, after engaging in conduct outside a courthouse near a school. He entered a guilty plea to the charge. The State requested that Solis be required to register as a sex offender, while Solis argued that the court should exercise its discretion to deviate from the registration requirement, citing statutory criteria that permit deviation under certain circumstances.The District Court of Ward County, North Central Judicial District, presided by Judge Stacy J. Louser, sentenced Solis to 360 days’ imprisonment with all but one day suspended, imposed two years of supervised probation, and required Solis to register as a sex offender under N.D.C.C. § 12.1-32-15(2)(b). The court acknowledged its discretion to deviate from registration but ultimately declined to do so, citing concerns about the nature of Solis’s conduct and his explanation for it. Solis appealed, arguing that the court abused its discretion and failed to make specific findings required for deviation.The Supreme Court of North Dakota reviewed the appeal under an abuse of discretion standard. It held that the statute’s language allows the court discretion to deviate from the registration requirement if certain criteria are met, but does not mandate deviation even if those criteria are satisfied. The Supreme Court determined that the district court’s decision was not arbitrary, capricious, or unreasonable, and that it was the result of a rational process. The Supreme Court affirmed the criminal judgment and the requirement that Solis register as a sex offender. View "State v. Solis" on Justia Law

In March 2024, Christopher Bauer was charged with disorderly conduct following an incident in Williston, North Dakota. He retained legal counsel and the case proceeded to a jury trial, at the conclusion of which Bauer was acquitted. After his acquittal, Bauer submitted a motion seeking reimbursement for attorney’s fees and costs incurred during the defense of his criminal prosecution.The District Court of Williams County, Northwest Judicial District, presided over by Judge Kirsten M. Sjue, reviewed Bauer’s post-judgment motion. The court denied his request for attorney’s fees and costs, determining that Bauer had not established a legal basis for recovering such expenses in the context of the criminal proceeding. Bauer also argued that the district court judge committed misconduct warranting discipline, but the court’s order did not address this allegation, and there was no indication that the issue had been properly raised or preserved during district court proceedings.On appeal, the Supreme Court of North Dakota considered whether the district court’s post-judgment order was appealable and addressed the merits of Bauer’s requests. The Supreme Court held that Bauer’s motion for recovery of attorney’s fees, which sought reimbursement of property allegedly expended in connection with the criminal action, constituted a substantial right under N.D.C.C. § 29-28-06(5), making the order appealable. However, the Court affirmed the district court’s denial of Bauer’s motion, finding he had not shown entitlement to attorney’s fees and costs in the criminal case. The Supreme Court also declined to consider Bauer’s judicial misconduct claim on appeal, as it had not been preserved in the trial court. The district court’s order was affirmed. View "City of Williston v. Bauer" on Justia Law

After pleading guilty to felony child neglect, the defendant was sentenced to five years’ imprisonment with three years suspended, credit for 375 days already served, supervised probation, and restitution. Following his release, the State alleged that the defendant violated multiple conditions of his probation. At a probation revocation hearing, the defendant waived his right to counsel and admitted the violations, leading the district court to revoke his probation. The court orally stated the defendant would receive credit for two years plus the time he spent in custody after being arrested on the probation violation warrant, which amounted to twenty-four days.The written order issued after the revocation hearing, however, erroneously recorded the credit for time served as “3 years and 34 days” instead of the correct “2 years and 24 days.” The State moved to correct this mistake under North Dakota Rule of Criminal Procedure 36, arguing it was a clerical error that conflicted with the court’s oral pronouncement. The District Court of McHenry County granted the State’s motion, found the original written order contained a clerical error, and issued an amended order reflecting the proper credit. The defendant appealed, arguing that the correction improperly reduced his credit for time served and conflicted with the court’s oral pronouncement. He also asserted his constitutional right to counsel was violated when the court did not appoint an attorney to represent him in the Rule 36 proceedings.The Supreme Court of North Dakota affirmed the district court’s orders. It held that the correction was a permissible exercise of the court’s discretion under Rule 36 to remedy a clerical error in the judgment so that it accurately reflected the oral pronouncement at the revocation hearing. The court also concluded that the defendant’s constitutional right to counsel was not violated because the correction of a clerical error under Rule 36 is not a critical stage of the prosecution. View "State v. Jaeger" on Justia Law

The defendant was charged with simple assault following an incident in April 2022. Throughout the proceedings, he was represented by a series of court-appointed attorneys. The first attorney was replaced due to a change in employment. The next two attorneys withdrew, one citing a breakdown in the attorney-client relationship and the other a conflict of interest. Each time, a new attorney was appointed. Upon the withdrawal of the fourth appointed attorney, due to a deteriorated attorney-client relationship and the defendant’s insistence on pursuing an unethical defense, the defendant was informed by court order that no further counsel would be provided at public expense. He was served with the withdrawal orders but was not present at every hearing. At a pretrial hearing the day before trial, the defendant again requested appointed counsel, but the court required him to proceed pro se if he had not retained a lawyer by the next day. The defendant represented himself at trial and was convicted.The District Court of Burleigh County, South Central Judicial District, presided over the pretrial proceedings, withdrawals, and trial. The court concluded that, given the repeated breakdowns with counsel and explicit orders, the defendant’s conduct constituted the functional equivalent of a voluntary waiver of his right to counsel, and therefore required him to proceed without appointed counsel.Upon review, the Supreme Court of North Dakota found that, although the defendant’s actions amounted to a functional waiver of his right to counsel, the record did not establish that such waiver was made knowingly and intelligently. Specifically, the court noted the absence of a warning or explanation to the defendant regarding the dangers and disadvantages of self-representation prior to his final attorney’s withdrawal. The Supreme Court of North Dakota reversed the conviction and remanded the case for further proceedings, holding that the defendant’s waiver of counsel was not knowing and intelligent as required by law. View "State v. Hoff" on Justia Law

A driver was involved in a traffic collision in Grand Forks County, North Dakota, which resulted in injuries to two people in another vehicle, including a minor who later died. Law enforcement, led by the North Dakota Highway Patrol, responded to the scene and investigated the driver for driving under the influence. During the investigation, a chemical breath test was administered to the driver to determine his blood alcohol content. The State later charged the driver with criminal vehicular injury and criminal vehicular homicide, both alleging he was driving under the influence.The District Court of Grand Forks County, Northeast Central Judicial District, held an evidentiary hearing on the driver's motion to suppress the results of the chemical breath test. The driver argued that his consent to the test was not voluntary and that the evidence was obtained in violation of statute and his due process rights. The court granted the motion, suppressing the breath test evidence, finding that the State failed to show that the driver voluntarily consented to the chemical test after being read the implied consent advisory.The North Dakota Supreme Court reviewed the District Court’s decision and applied a de novo standard to questions of law, while deferring to the lower court’s factual findings unless they were contrary to the manifest weight of the evidence. The Supreme Court held that the District Court misapplied the law by treating the relevant statutes—N.D.C.C. §§ 39-20-01 and 39-20-01.1—as separate and distinct rather than as statutes that operate in conjunction. The Supreme Court clarified that both statutes may apply simultaneously and that providing an accurate implied consent advisory does not constitute per se coercion. The Court reversed the suppression order and remanded the case for further findings on whether the driver’s consent was voluntary, using the correct legal standards. View "State v. Bell" on Justia Law

Lawrence Harris sought postconviction relief following his criminal conviction, arguing that his trial counsel was ineffective and that the State violated its obligations under Brady v. Maryland by failing to disclose favorable evidence—specifically, the probation conditions of a witness. Harris claimed that these alleged deficiencies undermined the fairness of his trial and warranted relief from his conviction.The District Court of Burleigh County, South Central Judicial District, reviewed Harris’s claims. Applying the standard from Strickland v. Washington, the district court found that Harris failed to demonstrate that any alleged errors by his trial counsel prejudiced the outcome of his case; in other words, he did not show a reasonable probability of a different result but for counsel’s unprofessional errors. Regarding the Brady claim, the court determined that Harris did not provide evidence that the State suppressed the witness’s probation conditions, and thus denied relief on that basis as well.On appeal, the Supreme Court of North Dakota considered Harris’s arguments. The Court affirmed the district court’s denial of postconviction relief. It held that the lower court’s findings regarding ineffective assistance of counsel were not clearly erroneous and were supported by evidence. Regarding the Brady claim, the Supreme Court concluded that Harris waived the issue by failing to meet the minimum briefing requirements under the North Dakota Rules of Appellate Procedure, as his appellate brief did not adequately articulate or support the claim. As a result, the Supreme Court declined to address the Brady claim on its merits and affirmed the district court’s order denying Harris’s application for postconviction relief. View "Harris v. State" on Justia Law

Joshua Martinez was charged in two separate cases with serious offenses, including attempted murder, reckless endangerment, terrorizing, fleeing from law enforcement, violation of a domestic violence protection order, unlawful firearm possession, and other related crimes. The cases were consolidated and proceeded to a seven-day jury trial, where twelve jurors and two alternates were sworn in. After the first day of trial, Juror 9 was observed interacting with Jacob Martinez, a relative of the defendant. Upon questioning, Juror 9 disclosed he only learned of the familial relationship after speaking with Jacob Martinez. Despite Juror 9’s assurance of impartiality, the district court dismissed him, citing concerns about the interaction, and replaced him with an alternate juror.The District Court of Williams County, Northwest Judicial District, presided over the consolidated trial. Following the jury’s verdict, Martinez was convicted on all counts except one of reckless endangerment. Martinez objected to the removal of Juror 9, arguing that the substitution violated his constitutional rights and exceeded the court’s authority under North Dakota Rule of Criminal Procedure 24(c)(1).On appeal, the Supreme Court of North Dakota reviewed whether the district court’s decision to replace Juror 9 constituted an abuse of discretion or violated the Double Jeopardy Clause. The Supreme Court held that substituting a properly qualified alternate juror did not implicate double jeopardy, as it did not terminate the original jeopardy. The court further held that the district court’s expressed concerns regarding Juror 9’s impartiality constituted a sufficient basis for dismissal, and that the court did not abuse its discretion in replacing Juror 9 with an alternate. Accordingly, the Supreme Court of North Dakota affirmed the criminal judgments against Martinez. View "State v. Martinez" on Justia Law

The defendant was charged with preventing arrest and domestic violence following an incident at his mother’s residence in Minot, North Dakota. The alleged facts included a confrontation between the defendant and his sister, during which she claimed the defendant pushed her, causing her to fall and sustain injuries. Police responded to the scene, and when attempting to arrest the defendant, he physically resisted, repeatedly stating he was “not going to jail.” Officers used force to restrain and handcuff him, and body camera footage was entered into evidence.The case was heard in the District Court of Ward County, North Central Judicial District. At trial, testimony was provided by the victim, two police officers, and the defendant. The court also reviewed photographic and video evidence. The defendant made motions for acquittal at the close of the State’s case and at the end of all evidence, both of which were denied. The District Court found the defendant guilty of both charges, sentencing him to 360 days’ imprisonment with most suspended for supervised probation on the preventing arrest conviction, and a concurrent 30-day sentence on the domestic violence conviction.On appeal to the Supreme Court of North Dakota, the defendant argued that the evidence was insufficient to support his convictions, claiming he was not informed of his arrest before being restrained and that he acted in self-defense with no intent to cause injury. The Supreme Court held that sufficient evidence supported both convictions. The Court found that the officers were justified in not informing the defendant of his arrest prior to his resistance, and that the defendant’s actions toward his sister constituted willful, or at least reckless, conduct resulting in bodily injury. The criminal judgment was affirmed. View "State v. Gores" on Justia Law

On November 4, 2024, an individual went to his stepchild’s elementary school to speak with the principal about the child’s recent suspension from bus privileges. During and after this meeting, his behavior—raising his voice, pushing a garbage can into a door, forcefully exiting the building, yelling obscenities, and making obscene gestures in the presence of children—alarmed the principal, a school counselor, and a paraprofessional. Each testified that his actions caused them alarm. He was later charged with disorderly conduct under North Dakota law.The case proceeded to a bench trial in the District Court of Richland County, Southeast Judicial District. The defendant waived his right to a jury trial. The district court found, based on testimony and the totality of the conduct, that the defendant’s actions—including using obscene language, physical agitation, and reckless driving in the school parking lot—constituted tumultuous behavior that reasonably alarmed those present. The court found the statutory elements of disorderly conduct were proven beyond a reasonable doubt and entered a criminal judgment of conviction. The defendant appealed.The Supreme Court of North Dakota reviewed the conviction. The defendant argued that his conduct was constitutionally protected as an exercise of parental rights and that the evidence was insufficient. The Supreme Court held that because the defendant did not raise constitutional claims at trial or argue obvious error on appeal, those arguments would not be addressed. Applying the standard of viewing evidence in the light most favorable to the verdict, the court found that there was sufficient evidence that the defendant acted with at least reckless disregard as to whether his behavior would alarm others and that his conduct was tumultuous. The Supreme Court of North Dakota affirmed the conviction for disorderly conduct. View "State v. Vetter" on Justia Law