Justia North Dakota Supreme Court Opinion Summaries

Phillip Armstrong appealed a judgment adjudicating ownership of interests in an oil and gas lease and the parties’ claims to revenue proceeds from production on those interests. Continental Resources operated wells located on lands covered by the lease. When Continental learned of competing claims to the leasehold interests in question, it began holding production royalties in suspense and recouping amounts it had paid on the wells. Continental sued Armstrong alleging it had overpaid him. Continental later amended its complaint to add the other defendants and request interpleader relief. Continental requested the district court determine ownership of the interests and the amount of revenue proceeds to which each defendant was entitled on production from wells the parties referred to as the Hartman Wells. The defendants filed various crossclaims and counterclaims. The North Dakota Supreme Court affirmed the judgment to the extent it determined ownership of the disputed interests and dismissed Armstrong’s claims against Continental Resources. The Court reversed and vacated the judgment to the extent it ordered Armstrong to pay Citation 2002 Investment Limited Partnership restitution for unjust enrichment. View "Continental Resources v. Armstrong, et al." on Justia Law

Workforce Safety and Insurance (WSI) appealed a district court order and judgment affirming an administrative law judge’s (ALJ) order reversing a WSI order. The reversed WSI order had determined Badger Roustabouts was an employer of individuals providing roustabout services. In addition to affirming the ALJ’s order, the court awarded attorney’s fees to Badger under N.D.C.C. 28-32-50. The North Dakota Supreme Court affirmed the judgment affirming the ALJ’s order, but reversed the court’s award of attorney’s fees. View "WSI v. Badger Roustabouts" on Justia Law

Cruz Muscha appealed a district court order denying his petition for discharge from civil commitment as a sexually dangerous individual. On appeal, Muscha argued the district court’s factual basis was insufficient to legally conclude he met the substantive due process requirement of serious difficulty controlling his behavior. Finding no reversible error, the North Dakota Supreme Court affirmed. View "Matter of Muscha" on Justia Law

J.B. appealed a juvenile court order terminating her parental rights to her two children. She argued there was not evidence beyond a reasonable doubt to support the court’s determination under the Indian Child Welfare Act (ICWA) that continued custody by J.B. was likely to result in serious emotional or physical damage to the children. Retaining jurisdiction under N.D.R.App.P. 35(a)(3), the North Dakota Supreme Court remanded to the juvenile court for detailed findings under ICWA, allowing for additional testimony from the qualified expert witness if necessary to make the required findings. After receiving additional testimony, the district court made additional findings, denied the petition to terminate J.B.’s parental rights, and ordered the children be removed from J.B.’s custody for nine months. No party requested additional briefing or argument following the order on remand. Finding no reversible error, the Supreme Court affirmed the juvenile court order. View "Interest of K.B." on Justia Law

Continental Resources, Inc. (“Continental”) appeals from a district court amended order denying its motion to intervene in this proceeding. P&P Industries, LLC I (“P&P”), a foreign limited liability company, initially obtained a certificate of authority to transact business in North Dakota as a foreign limited liability company in December 2012. Richard Manning was the managing member of the LLC. In 2015, the North Dakota Secretary of State revoked the certificate of authority of P&P as a result of P&P’s failure to file its annual report. In 2020, Manning (represented by counsel) petitioned for reinstatement. The Secretary of State admitted service of the petition, waived the right to any further notice, and consented to the immediate reinstatement of P&P. After reviewing the petition and exhibits, the court entered an order for reinstatement. In May 2020, Continental moved the district court to intervene in this matter and to vacate the reinstatement order. Continental sought to intervene as a matter of right and asserted the district court’s reinstatement order was void. Continental asserted Manning filed the petition to defeat its motion to dismiss P&P’s counterclaims in a pending matter on remand in Williams County district court. After an October 2020 hearing, the district court entered an order denying Continental’s amended motion to intervene and refusing to consider its request to vacate the order for reinstatement. In its order denying intervention, the court held Continental’s claimed interest in this proceeding derived from the motion to dismiss it filed in the separate pending lawsuit. The court rejected Continental’s argument that it had a right to intervene in this proceeding merely because the court’s prior reinstatement order affected an argument Continental was asserting in the separate action. The court concluded this was not a legally protectable interest in the appeal for reinstatement. The North Dakota Supreme Court concluded We conclude the district court did not err in denying Continental’s amended motion to intervene. Furthermore, the Court declined Continental’s request for it to exercise its supervisory authority to direct the district court to vacate its prior order for reinstatement. View "Manning v. Jaeger, et al." on Justia Law

Darin Johnson appealed after a jury found him guilty of terrorizing under N.D.C.C. 12.1-17-04. The North Dakota Supreme Court rejected Johnson’s invitation to create an exception to N.D.C.C. 12.1-17-04 when the unlawful conduct is directed toward a law enforcement officer, and concluded that sufficient evidence supported Johnson’s conviction. View "North Dakota v. Johnson" on Justia Law

Steve and Russell Hartman, as personal representatives of the estate of Ray Hartman (the “Estate”), appealed an amended judgment entered after a bench trial. The Estate argued Ray lacked the capacity to contract, no valid contract for the sale of his farmstead and farmland existed, Trent Grager owed rent for the 2017 farming season, and Ray did not gift a tractor to Grager. Grager cross-appealed, arguing he was entitled to compensation for the Estate’s wrongful occupation of the farm. The North Dakota Supreme Court affirmed in part, concluding the district court did not err in finding Ray was capable of contracting, the 2016 agreement was a valid contract for the sale of the farmstead and farmland, Grager had no obligation to pay rent in 2017, and the tractor was gifted. The Supreme Court reversed in part, concluding the 2017 document did not supplement or alter the terms of the 2016 agreement, and Grager was entitled to compensation for the Estate’s wrongful occupation of the farm. The case was remanded for the court to determine Grager’s damages for the Estate’s wrongful occupation. View "Hartman, et al. v. Grager" on Justia Law

Mathew Finch appealed a district court order related to the administration of the Estate of Janel Finch (“Estate”). Finch argued the court erred in granting Christine Binstock’s petition to remove Finch as a co-personal representative from the estate, erred in denying his counter-petition to remove Binstock as co-personal representative, and erred in denying his attorney’s fees request. (Finch and Binstock were siblings). Finding no abuse of discretion, the North Dakota Supreme Court affirmed the district court. View "Estate of Finch" on Justia Law

James Dubois, Jr. appealed an order denying his application for post-conviction relief, arguing he received ineffective assistance of counsel, his plea was not knowing, voluntary and intelligent, and his sentence was illegal. In August 2017, Dubois pleaded guilty to two counts of criminal trespass and one count of refusal to halt. Dubois was sentenced to 18 months with the Department of Corrections and Rehabilitation, first to serve 90 days with the balance suspended for 18 months of supervised probation. Probation was ultimately revoked and he was resentenced to five years in prison. Dubois filed a direct appeal where he argued the district court abused its discretion in revoking his probation, and that the court’s new sentence was illegal because it exceeded his original sentence. The North Dakota Supreme Court affirmed, finding the district court did not abuse its discretion in revoking probation and resentencing. Dubois then filed for post-conviction relief at issue here, arguing he received ineffective assistance of counsel. Dubois claimed his counsel failed to object to the illegal sentence and did not explain to Dubois that probation revocation could result in him being resentenced to five years. A majority of the North Dakota Supreme Court reversed, thereby overruling North Dakota v. Gefroh, 458 N.W.2d 479 (N.D. 1990), which allowed district courts to resentence defendants on probation revocation to any sentence initially available, and did not limit the new sentence to no more than that which was suspended. View "Dubois v. North Dakota" on Justia Law

Edwin Schulz appealed a judgment following a bench trial on the damages to his barn, pole barn and shed. Schulz sued Adam Helmers for negligence and breach of contract following a fire that destroyed the barn, pole barn and shed. At the time of the fire, Schulz was leasing the farmstead to Helmers, including the three buildings. He argued the district court applied the wrong measure of damages in his breach of contract claim against Helmers. The district court concluded N.D.C.C. 32-03-09.1 applied to the breach of contract claim, which provided the measure of damages for an injury to property not arising from contract was the diminution of value. The North Dakota Supreme Court concurred with the district court's finding and affirmed the judgment. View "Schulz v. Helmers" on Justia Law