Justia North Dakota Supreme Court Opinion Summaries

In May 2020, Daniel Samaniego was charged with gross sexual imposition, a class AA felony. During his trial in May 2021, a detective testified about attempting to interview Samaniego, leading to an objection from Samaniego’s counsel, which was sustained. The jury found Samaniego guilty. Post-trial, a juror indicated that the jury discussed Samaniego’s decision not to testify. Samaniego’s counsel did not move for a new trial based on this potential jury misconduct.Samaniego appealed the criminal judgment in September 2021, arguing insufficient evidence and prosecutorial misconduct. The North Dakota Supreme Court affirmed the conviction, noting the prosecutorial misconduct claim was not preserved for appeal. In May 2023, Samaniego filed for postconviction relief, claiming ineffective assistance of counsel for not preserving the prosecutorial misconduct issue and not moving for a new trial based on jury misconduct. The district court held an evidentiary hearing and denied the application in February 2024.The North Dakota Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that Samaniego did not demonstrate a reasonable probability that the trial outcome would have been different but for his counsel’s alleged errors. The court found no prosecutorial misconduct in the detective’s testimony and noted that the jury’s discussion about Samaniego not testifying did not constitute juror misconduct under the law. The court concluded that Samaniego’s trial counsel’s actions did not fall below an objective standard of reasonableness and that Samaniego was not prejudiced by these actions. View "Samaniego v. State" on Justia Law

Thomas Roller was charged with multiple offenses, including terrorizing an adult victim, reckless endangerment, criminal mischief, unauthorized use of a vehicle, and domestic violence. The unauthorized use of a vehicle charge was dismissed before trial. The jury found Roller guilty of the remaining charges. Roller contested the jury instruction on criminal mischief, arguing it allowed for a non-cognizable offense, and also challenged his sentence as a habitual offender, claiming the court improperly considered his prior convictions.The District Court of Burleigh County, South Central Judicial District, presided over the trial. The jury instructions defined criminal mischief as willfully damaging property and intentionally causing pecuniary loss over $100. Roller did not object to these instructions during the trial. The jury convicted Roller on all counts. At the presentencing hearing, the court took judicial notice of Roller’s prior convictions, despite his initial objection, which he later withdrew. The court found Roller met the criteria for habitual offender status and sentenced him accordingly.The North Dakota Supreme Court reviewed the case. The court held that the jury instructions did not constitute obvious error, as the terms "willfully" and "intentionally" were not legally incongruent. The court also found that the district court did not err in taking judicial notice of Roller’s prior convictions for sentencing purposes, as the rules of evidence do not apply to sentencing procedures. The court concluded that the district court acted within its discretion and did not impose an illegal sentence. The North Dakota Supreme Court affirmed the judgment. View "State v. Roller" on Justia Law

Trent Rolland was involved in a traffic accident with a minor, who later alleged that Rolland had been communicating with her via SnapChat, sending explicit messages and photographs, and had sexual contact with her. Rolland was charged with luring a minor and other related offenses. During his arrest, his smartphone was seized, and he was taken to the Richland County jail, where he was read his Miranda rights and subsequently made several incriminating admissions during an interview. Law enforcement obtained a warrant to search his phone, leading to additional charges.The District Court of Sargent County, Southeast Judicial District, presided over by Judge Nicholas D. Thornton, denied Rolland's motions to suppress evidence and his motion to dismiss based on his competency to stand trial. Rolland had undergone multiple psychological evaluations, with conflicting opinions on his competency. The court overruled Rolland's objection to the timeliness of one of the competency reports and found him competent to stand trial. Rolland entered a conditional guilty plea and appealed the judgment, arguing errors in the competency determination and the denial of his motions to suppress evidence.The North Dakota Supreme Court reviewed the case and found that the district court did not provide adequate findings to support its decision on Rolland's competency. The Supreme Court noted that the district court's statements were merely a recitation of the legal standard without explaining the basis for its decision. The Supreme Court retained jurisdiction and remanded the case for 60 days for the district court to determine whether Rolland was fit to proceed before entering his conditional guilty plea, based on the record at the time of his motion to dismiss. The district court must conduct an additional competency hearing to assess the evaluators' testimony and credibility. View "State v. Rolland" on Justia Law

David Gaddie was charged with four counts of gross sexual imposition for allegedly sexually abusing a child. In a separate case, he was charged with three counts of gross sexual imposition for allegedly abusing the child's mother, but those charges were dismissed. The case involving the child proceeded to trial, and Gaddie was found guilty on all counts. On direct appeal, one conviction was reversed due to an issue with jury instructions.Gaddie then filed an application for postconviction relief, claiming ineffective assistance of counsel and prosecutorial misconduct. The State moved for partial summary dismissal, arguing that Gaddie should have raised the prosecutorial misconduct claim on direct appeal. The district court reserved ruling on this motion and held a hearing. During the hearing, it was revealed that the State had introduced a video containing statements about Gaddie abusing the child's mother, which Gaddie’s attorney had objected to during the trial. The district court denied the State's motion for partial summary dismissal but ultimately denied Gaddie’s application for postconviction relief, reasoning that the situation was a misunderstanding rather than intentional misconduct.The North Dakota Supreme Court reviewed the case and found that prosecutorial misconduct had occurred because the State introduced inadmissible prior bad act evidence without providing the required notice under N.D.R.Ev. 404(b). The Court held that this misconduct prejudiced Gaddie’s right to a fair trial. Consequently, the Supreme Court reversed the district court's judgment denying postconviction relief and remanded the case with instructions to vacate the criminal judgment and enter any supplementary orders required by law. View "Gaddie v. State" on Justia Law

Ladarius Miller was charged with theft of property and deceptive writings for using falsified paystubs to purchase a vehicle from an automotive dealership in Grand Forks, North Dakota. After a warrant was issued for his arrest, Miller was apprehended in Oregon and extradited to Grand Forks. He pleaded guilty to theft of property and agreed to a plea deal that included imprisonment, various fees, and $800 in restitution, with the possibility of additional restitution to be determined within sixty days. The district court sentenced him according to the plea agreement. Subsequently, the State sought additional restitution for the costs associated with Miller's extradition, totaling $2,435.91. The district court granted this request, and Miller appealed.The District Court of Grand Forks County initially allowed Miller to contest the restitution despite the State's claim that he failed to request a hearing within the required thirty days. The court found that the State did not provide proper notice of the deadline and that a hearing had already been set, making it reasonable for Miller to assume the matter would be addressed then. The district court ultimately ordered Miller to pay the additional restitution for extradition costs.The North Dakota Supreme Court reviewed the case and reversed the district court's decision. The Supreme Court held that the extradition costs were not directly related to Miller's criminal conduct of theft of property. The court emphasized that restitution must be limited to damages directly related to the offense, which was not the case here. Additionally, the court found that imposing extradition costs as prosecution costs was not permissible because it would violate the terms of Miller's binding plea agreement. Therefore, the restitution order for the extradition expenses was reversed. View "State v. Miller" on Justia Law

Christapher Enriquez pled guilty to possession of a controlled substance with intent to deliver or manufacture, a class B felony, and was sentenced to probation. A condition of his probation was that he not possess a firearm or dangerous weapon. Federal officers from the DEA executed a search warrant on Enriquez’s home and allegedly found a handgun, fentanyl pills, and methamphetamine. The State filed a petition to revoke his probation based on these findings. At the revocation hearing, the State presented testimony from Enriquez’s probation officer, who had received a picture of the handgun and narcotics from a DEA agent. The probation officer did not know where in the house the handgun was found or if it was functional.The District Court of Ward County found that the State did not prove Enriquez possessed fentanyl or methamphetamine but did prove by a preponderance of the evidence that he possessed a handgun. The court revoked Enriquez’s probation and resentenced him, relying on the principle that a single violation is sufficient to sustain revocation.The Supreme Court of North Dakota reviewed the case and applied a two-step analysis: first, reviewing the district court’s factual findings under the clearly erroneous standard, and second, reviewing the decision to revoke probation under the abuse-of-discretion standard. The Supreme Court found that the district court’s reliance on the case State v. Clinkscales was misplaced and that the State did not provide sufficient evidence to prove the handgun was functional or readily capable of expelling a projectile, as required by the statutory definitions of “dangerous weapon” and “firearm.”The Supreme Court of North Dakota held that the district court’s finding that Enriquez possessed a dangerous weapon was clearly erroneous and that the court abused its discretion in revoking his probation. The decision to revoke Enriquez’s probation was reversed. View "State v. Enriquez" on Justia Law

In 2023, Victoria Reiswig was charged with corruption of a minor, a class C felony, under North Dakota law. Reiswig filed a motion to dismiss, arguing that the State failed to corroborate her confession and did not provide sufficient evidence that a sexual act occurred between her and the minor. The evidence presented included testimony from various witnesses and a video interview in which Reiswig admitted to having sex with the minor.The District Court of Burleigh County, South Central Judicial District, denied Reiswig’s motion to dismiss. The court found that the confession was voluntary and that the totality of the evidence, including witness testimonies and the video interview, supported the truth of Reiswig’s confession. The court noted that while individual pieces of evidence might not independently prove a sexual act occurred, together they corroborated the confession. Reiswig then entered a conditional guilty plea, reserving her right to appeal the denial of her motion to dismiss.The North Dakota Supreme Court reviewed the case, applying the same standard of review as for a motion to suppress. The court emphasized the importance of corroborating evidence to support the trustworthiness of a confession. The court found that the district court’s findings were supported by sufficient evidence, including the video interview and witness testimonies that corroborated details of the confession. The Supreme Court concluded that the district court correctly applied the law and that its findings were not clearly erroneous. Therefore, the North Dakota Supreme Court affirmed the denial of Reiswig’s motion to dismiss and upheld the criminal judgment. View "State v. Reiswig" on Justia Law

Dayne Watts was involved in an altercation with his girlfriend, Leah Redeagle, in their shared home, which also housed Redeagle’s infant child. Watts was charged with multiple offenses, including domestic violence, terrorizing, felonious restraint, child neglect, simple assault on emergency personnel, contact by bodily fluids, preventing arrest, and criminal mischief. During the trial, both Redeagle and Watts testified, along with law enforcement and medical personnel. The jury acquitted Watts of domestic violence but found him guilty of the remaining charges.The District Court of Grand Forks County, Northeast Central Judicial District, presided over by Judge John A. Thelen, held a jury trial in October 2023. Following the trial, Watts was convicted on several charges, and a criminal judgment was entered. Watts appealed, arguing errors in jury instructions, insufficient evidence for the child neglect conviction, and prosecutorial misconduct.The North Dakota Supreme Court reviewed the case. The court found that Watts failed to establish that the jury instructions on the definition of “family or household member” constituted obvious error affecting his substantial rights. The court also determined that there was sufficient evidence to support the child neglect conviction, as testimony indicated Watts was a household member and partially responsible for the child’s care. Additionally, the court concluded that Watts did not meet his burden to show that the prosecutor’s comments constituted prosecutorial misconduct.The North Dakota Supreme Court affirmed the criminal judgment but remanded the case to the district court to correct a clerical error in the judgment, ensuring it accurately reflected that Watts was found guilty after a jury trial, not based on guilty pleas. View "State v. Watts" on Justia Law

Brandon Schweitzer was charged with one count of reckless endangerment, four counts of fleeing a police officer, and one count of driving under suspension after a series of police pursuits on August 15-16, 2022. Schweitzer pleaded guilty to the charges during a change of plea hearing where the court confirmed he understood the charges and the potential penalties. Schweitzer later filed a petition for postconviction relief, claiming ineffective assistance of counsel for not advising him of a potential double jeopardy defense and failing to file a motion to dismiss some of the charges.The District Court of Burleigh County denied Schweitzer's petition and amended petition for postconviction relief. The court found that Schweitzer and his attorney had discussed the case, and the attorney had advised him appropriately. The court also found that Schweitzer's claims lacked credible evidence and legal support. The court concluded that Schweitzer's attorney's performance did not fall below an objective standard of reasonableness and that Schweitzer failed to show his attorney was ineffective for not raising a double jeopardy defense.The North Dakota Supreme Court reviewed the case and affirmed the district court's decision. The Supreme Court held that Schweitzer did not meet the first prong of the Strickland test, which requires showing that counsel's performance fell below an objective standard of reasonableness. The court found that Schweitzer failed to provide substantive law supporting his claim that the four counts of fleeing police violated the double jeopardy clause. The court concluded that the district court's findings were not clearly erroneous and that Schweitzer did not prove ineffective assistance of counsel. View "Schweitzer v. State" on Justia Law

Cody Wayne Ritter was convicted of sexual assault after his fifteen-year-old stepdaughter alleged inappropriate contact. The minor underwent a forensic interview at the Children’s Advocacy Center, which was recorded and marked as evidence. During the trial, the defense and prosecution discussed the contents of the video, which included allegations of misconduct in Texas. The district court admitted the video into evidence over the defense's objections, which argued that its prejudicial impact outweighed its probative value.The District Court of Ransom County admitted the video, reasoning that the defense had opened the door to its contents by eliciting testimony about the Texas incident. The court allowed the video to be shown to the jury during deliberations, despite the defense's objections under N.D.R.Ev. 403. The jury subsequently convicted Ritter of sexual assault.The North Dakota Supreme Court reviewed the case and found that the district court abused its discretion by admitting the video without properly weighing its prejudicial impact against its probative value. The Supreme Court noted that the district court had not viewed the video in its entirety and failed to assess the specific instances of alleged misconduct. The court emphasized that the doctrine of "opening the door" requires a careful, topic-by-topic assessment and that the district court did not adequately consider the potential for undue prejudice and confusion. Consequently, the North Dakota Supreme Court reversed the criminal judgment against Ritter. View "State v. Ritter" on Justia Law