Justia North Dakota Supreme Court Opinion Summaries

The case revolves around a dispute over oil and gas interests between Spottie, Inc., a Nevada corporation, and several other Nevada corporations and a limited liability company. Spottie alleged that the defendants had wrongfully claimed title to these interests, which were once owned by Edward Davis, who had formed Spottie as a holding company. The defendants countered that they had entered into an agreement with Davis to acquire these interests, and that Davis and Spottie had transferred the disputed interests to one of the defendants via an assignment in 2016.The district court dismissed several of Spottie's claims, leaving only a quiet title claim and a claim for unjust enrichment. After a three-day bench trial, the court ruled in favor of the defendants, finding that the assignment from Davis and Spottie to one of the defendants was valid. The court also found that Spottie had erroneously received revenue from the disputed interests and awarded damages to the defendants.Spottie appealed the decision, arguing that the district court had erred in its ownership determination, its rejection of Spottie's laches defense, its binding of a non-party to the judgment, and its award of attorney fees and costs. The Supreme Court of North Dakota affirmed in part, concluding that the district court did not err in its ownership determination and its award of attorney fees. However, it reversed in part, finding that the court had erred in awarding costs for non-legal expenses. The case was remanded for the court to recalculate its cost award and to consider the defendants' request for additional attorney fees and legal costs. View "SPOTTIE v. BAIUL-FARINA" on Justia Law

The case involves Timothy Morales, who was injured when he was hit by a vehicle driven by Ruby Junewal within the Weatherford Distribution Facility in Williston. Morales filed a lawsuit alleging negligence against Weatherford U.S., L.P., Junewal, and Junewal's employer, Wilhoit Properties, Inc. He also claimed that Weatherford was negligent for failing to install proper lighting, road signs, or sidewalks near the road.The District Court of Williams County dismissed Morales's claims against Wilhoit with prejudice after the parties did not oppose Wilhoit’s motion for summary judgment. Later, Weatherford moved for summary judgment, arguing that it owed no duty to Morales because he was aware of the obvious danger posed by vehicles on the roadway. The district court granted Weatherford’s motion, and Morales appealed.Meanwhile, Junewal notified the court that she and Morales had reached a settlement. However, no concluding documents were filed. The district court then entered an order for judgment under its order granting Weatherford summary judgment. Morales appealed again, but the Supreme Court of North Dakota dismissed his appeal because claims against Junewal remained pending in the district court.In the Supreme Court of North Dakota, the court concluded that the district court misapplied the law when it treated Morales’s request as a Rule 60(b) motion and held it “no longer has jurisdiction.” The Supreme Court reversed the district court's order denying Morales's request and remanded the case with instructions for the district court to enter a single final judgment adjudicating all the claims and all the parties’ rights and liabilities within twenty days from the filing of the Supreme Court's opinion. View "Morales v. Weatherford U.S., L.P." on Justia Law

The defendant, Jason Pederson, was found guilty of one count of terrorizing following a jury trial. The charge was based on two emails Pederson sent to her former employer, threatening to retrieve damages through the taking of physical assets and warning employees to stay out of the way to avoid unnecessary deaths. These emails were sent after Pederson had filed an employment discrimination lawsuit against her former employer. After receiving the emails, the employer contacted law enforcement, leading to Pederson's arrest.The case was first heard in the District Court of Cass County, East Central Judicial District. During the trial, Pederson, who represented herself, argued that the State had violated her rights under Brady v. Maryland by failing to provide her with a recording of a conversation she had with Officer Tanner Anderson, who had informed her that she was trespassed from her former employer's property. The State argued that the recording was not relevant to the terrorizing charge and had been filed under a civil trespass file, not the criminal case. The court ruled that the State's failure to disclose the recording was not intentional and that the State must provide it before Officer Anderson was called as a witness.The case was then appealed to the Supreme Court of North Dakota. The Supreme Court affirmed the lower court's decision, concluding that Pederson did not establish a Brady violation. The court found that although the State had possessed the recording and did not disclose it to Pederson, Pederson had not demonstrated that the recording was favorable to her or plainly exculpatory. The court also concluded that Pederson did not preserve the issue of insufficient evidence because she failed to move for acquittal under N.D.R.Crim.P. 29 and did not argue obvious error. View "State v. Pederson" on Justia Law

In June 2015, Jordan Morsette was driving on the wrong side of the road when his vehicle collided head-on with another vehicle driven by Shayna Monson. Monson suffered serious bodily injuries, while two passengers in her vehicle, Taylor Goven and Abby Renschler, died at the scene. Morsette admitted liability for the collision, and a jury trial was held to determine the amount of compensatory damages. The jury awarded the plaintiffs a total of $242 million in noneconomic compensatory damages and $895 million in punitive damages.Morsette appealed the verdict, and the Supreme Court of North Dakota reversed and remanded the case, holding that the lower court erred in admitting evidence of Morsette’s intoxication when liability was admitted, and in allowing a claim for punitive damages. On remand, the district court held another jury trial, which resulted in a verdict awarding a total of $175 million in noneconomic damages. Morsette again appealed, arguing that the plaintiffs improperly referred to alcohol at the trial on remand, that the damages award was excessive, and that the jury improperly speculated as to the damages.The Supreme Court of North Dakota found that the district court did not abuse its discretion in denying Morsette a new trial based on the limited references to alcohol during the trial on remand. However, the court concluded that the district court did abuse its discretion by not providing an explanation of the evidence supporting the jury’s award of noneconomic damages, and by concluding the damages award was not excessive. Therefore, the court reversed the judgment and the order denying Morsette’s motion for new trial, and remanded the case to the district court for further proceedings. View "Zander v. Morsette" on Justia Law

Joseph and Brenda Field, who were divorced in California, have a minor child. The California court granted joint legal and physical custody of the child to both parents, with Brenda Field having primary physical custody. The court also allowed Brenda and the child to move to North Dakota and established a parenting schedule. The court did not modify the child support order, which required Joseph Field to pay $500 per month in child support and share other specified expenses of the child. The court also transferred venue for all future custody matters to North Dakota.After Brenda and the child moved to North Dakota, the Burleigh County district court registered the California court’s divorce judgment and orders. Later, the Burleigh County district court assumed jurisdiction over the child custody and parenting determinations. Joseph Field filed a motion to modify his parenting time, which Brenda Field opposed. After a hearing, the Burleigh County district court issued an amended judgment modifying parenting time, decision-making, and certain expenses to be paid by the parties.Joseph Field appealed, arguing that the Burleigh County district court lacked jurisdiction to modify the child support order because a California court retained jurisdiction under the Uniform Interstate Family Support Act. He also argued that the modified parenting plan was not in the child’s best interests.The Supreme Court of North Dakota affirmed the decision of the Burleigh County district court. The court found that Joseph Field had not provided sufficient evidence to support his argument that the Burleigh County district court lacked jurisdiction over child support. The court also found that the district court’s decision to modify the parties’ parenting time was not clearly erroneous and was in the best interests of the child. View "Field v. Field" on Justia Law

Michael Fuglesten was charged with driving under the influence of intoxicating liquor after a police officer entered his garage without a warrant. The officer had responded to a 911 call about a truck repeatedly driving by a house with loud music. The officer identified the truck as Fuglesten's, knew his license was suspended, and followed him to his home. The officer did not attempt a traffic stop or initiate his overhead lights. Upon reaching Fuglesten's home, the officer approached the garage on foot and interacted with Fuglesten, who was inside the garage. Fuglesten was subsequently arrested and charged.Fuglesten filed a motion to suppress the evidence, arguing that the officer's entry into his garage was unlawful. The district court denied the motion, and Fuglesten conditionally pled guilty to the charge, reserving the right to appeal the denial of his motion to suppress. The district court found that the officer had probable cause to believe Fuglesten had committed the offense of driving under suspension, but did not find evidence of exigent circumstances relating to dissipation or destruction of evidence.On appeal, the Supreme Court of North Dakota reversed the district court's decision. The court held that, under the U.S. Supreme Court's decision in Lange v. California, exigent circumstances were required for law enforcement to enter Fuglesten's garage without a warrant. The court found that the facts presented to the district court did not establish exigent circumstances. The court concluded that the officer's entry into Fuglesten's garage, without exigent circumstances, constituted an illegal entry. The court reversed the criminal judgment and remanded the case to allow Fuglesten to withdraw his guilty plea. View "State v. Fuglesten" on Justia Law

The case revolves around a fatal collision that occurred in May 2016 when Lyle Lima, who was legally blind, drove his truck into a horse-drawn hay trailer on a highway, resulting in the death of one passenger and injuries to others. In April 2015, a doctor at Dakota Eye Institute had declared Lima legally blind and instructed him not to drive. In April 2016, another doctor from the same institute, Dr. Briana Bohn, examined Lima and advised him not to drive at night and only minimally during the day, specifically avoiding highways. The plaintiffs, injured parties and their representatives, claimed that Dr. Bohn was liable for medical malpractice as Lima's eyesight was still below the minimum vision standards required to operate a vehicle in North Dakota.The plaintiffs initially filed a suit against the defendants, which was dismissed by the district court. However, the Supreme Court of North Dakota reversed and remanded the decision. On remand, the defendants moved for summary judgment, arguing that the plaintiffs failed to establish a prima facie case showing a breach of duty and that Dr. Bohn did not proximately cause Lima’s economic injuries. The district court granted summary judgment in favor of the defendants, concluding that no reasonable jury could find Dr. Bohn proximately caused Lyle Lima’s injury.The Supreme Court of North Dakota affirmed the district court's decision. The court found that Dr. Bohn had clearly instructed Lima not to drive on highways, and the accident had occurred on a highway. The court concluded that the plaintiffs had failed to present competent admissible evidence to raise an issue of fact, and thus, the district court had correctly granted summary judgment in favor of the defendants. View "Cichos v. Dakota Eye Institute, P.C." on Justia Law

The case involves William Schmidt, an employee of Tesoro Logistics, who was injured while working at a site owned and operated by Hess Corporation. Schmidt claimed that Hess required him to use breathing air equipment, installed by Basin Safety Consulting Corporation, which caused him to trip and fall, injuring his arm and shoulder. He filed negligence and premises liability claims against both Hess and Basin Safety.The District Court of McKenzie County dismissed Schmidt’s claims on summary judgment, ruling that neither Hess nor Basin Safety owed him a duty of care. The court determined that while Hess required Schmidt to wear an air hose, it did not specify the method of using it, thus Hess did not retain control over Schmidt. The court also ruled that Basin Safety did not owe a duty of care to Schmidt as it did not provide training regarding the air hose or have any control over the worksite.Upon appeal, the Supreme Court of North Dakota affirmed the judgment in favor of Basin Safety but reversed the judgment in favor of Hess. The court found that there were genuine issues of material fact regarding whether Hess owed Schmidt a duty of care. The court concluded that evidence indicating Hess required the use of the air hose and prohibited its use in a manner preferred by the workers could be seen as Hess retaining control over the work. The case was remanded for further proceedings. View "Schmidt v. Hess Corp." on Justia Law

Tevin Dewayne Freeman was charged with the murder of Erica L. Herrera, a class AA felony, in October 2020. The case was brought to trial in November 2022. The prosecution's witnesses included the 911 dispatcher who received Freeman's emergency call, law enforcement officers who responded to the scene and investigated Herrera's death, the medical examiner who conducted Herrera's autopsy, and a mutual friend of Freeman and Herrera. The medical examiner testified that Herrera's injuries were inconsistent with self-inflicted or accident-related injuries and that she died from blunt force trauma. Freeman claimed that Herrera's injuries were from a fall. After the prosecution rested its case, Freeman moved for a judgment of acquittal, which the district court denied. The defense did not call any witnesses.During the defense's closing argument, the prosecution objected to the defense counsel's use of "I believe" statements. This led to a sidebar conference, after which the court was informed that a juror needed a break. The court allowed a ten-minute recess. After the recess, Freeman moved for a mistrial, arguing that the break and the prosecution's objection during closing argument prejudiced him. The court denied Freeman's motion for a mistrial. The jury found Freeman guilty of murder, and judgment was entered in June 2023.On appeal to the Supreme Court of North Dakota, Freeman argued that the district court abused its discretion in denying his motion for a mistrial. He claimed that the break during the defense's closing argument showed indifference to the defense's case and that no curative jury instruction could remedy the situation. The Supreme Court of North Dakota affirmed the district court's decision, stating that Freeman had not shown that allowing a short break in the defense's closing argument at the request of a juror to use the restroom was a manifest injustice or that the district court abused its discretion. Freeman also argued that the convictions were not supported by sufficient evidence regarding the culpability element of intentionally or knowingly. The Supreme Court of North Dakota found that sufficient evidence existed for a jury to draw a reasonable inference that Freeman intentionally or knowingly committed the charged offense. View "State v. Freeman" on Justia Law

In April 2021, Jaime Urrabazo was found guilty of delivering a controlled substance by a jury. While his appeal was pending, Urrabazo filed his first application for postconviction relief, which was dismissed after he failed to attend the hearing. In April 2023, Urrabazo filed a second application for postconviction relief, arguing that the jury in his trial was not unanimous because one juror's response during the polling of the jury was inaudible on the recording.The District Court of Cass County denied Urrabazo's second application for postconviction relief. The court found that Urrabazo had misused the process by failing to raise his claim about the lack of jury unanimity in his first postconviction proceeding. The court also found that Urrabazo's trial counsel was objectively reasonable for not moving for a mistrial after the jury polling, and that Urrabazo's appellate counsel was objectively reasonable in not raising the issue of jury unanimity on appeal.Urrabazo appealed to the Supreme Court of North Dakota, arguing that the district court erred in finding his application for postconviction relief was a misuse of process and that his counsel was not ineffective. The Supreme Court affirmed the district court's decision. The court found that Urrabazo's second petition for postconviction relief was not a misuse of process and that his counsels' representation was objectively reasonable. The court concluded that Urrabazo had not shown that the jury was not unanimous and that his counsels' representation did not fall below an objective standard of reasonableness. View "Urrabazo v. State" on Justia Law