Search Tips

Opinions

On this page, you can search and view the Supreme Court’s opinions. If you wish to review the docket or documents filed in a matter, please go to the Court’s public portal search page.

1 - 100 of 12137 results

State v. Krall 2026 ND 7
Docket No.: 20240233
Filing Date: 1/15/2026
Case Type: Appeal - Criminal - Homicide
Author: McEvers, Lisa K. Fair

Highlight: In an appeal challenging the sufficiency of the evidence, we look only to the evidence and reasonable inferences most favorable to the verdict to ascertain if there is substantial evidence to warrant the conviction.

A conviction rests upon insufficient evidence only when, after reviewing the evidence in the light most favorable to the prosecution and giving the prosecution the benefit of all inferences reasonably to be drawn in its favor, no rational fact finder could find the defendant guilty beyond a reasonable doubt.

A conviction may be justified on circumstantial evidence alone if the circumstantial evidence has such probative force as to enable the trier of fact to find the defendant guilty beyond a reasonable doubt. A verdict based on circumstantial evidence carries the same presumption of correctness as other verdicts.

Jury instructions are reviewed as a whole to determine if they correctly and adequately inform the jury. Selecting and considering only a part of the instructions is not proper.

An error in a jury instruction provides grounds for reversal only when the instructions as a whole are erroneous, relate to a central subject in the case, and affect the defendant's substantial right.

Ziemann v. Grosz 2026 ND 6
Docket No.: 20250164
Filing Date: 1/15/2026
Case Type: Appeal - Civil - Other
Author: McEvers, Lisa K. Fair

Highlight: The mandate rule, a more specific application of law of the case, requires the district court to follow pronouncements of an appellate court on legal issues in subsequent proceedings of the case and to carry the appellate court's mandate into effect according to its terms.

An appellate court retains authority to decide whether the district court on remand fully carried out terms of its mandate.

Gum v. Muddy Boyz Drywall 2026 ND 5
Docket No.: 20250324
Filing Date: 1/15/2026
Case Type: Appeal - Civil - Contracts
Author: Bahr, Douglas Alan

Highlight: A party does not have a right to appeal if there is no final judgment or proper N.D.R.Civ.P. 54(b) certification.

Weigel, et al. v. Albertson 2026 ND 4
Docket No.: 20250342
Filing Date: 1/15/2026
Case Type: Appeal - Civil - Other
Author: Tufte, Jerod E.

Highlight: An order from a district court granting a motion to disqualify an attorney is not appealable under N.D.C.C. § 28-27-02(3) or the collateral order doctrine.

Supervisory jurisdiction may be exercised to review an order granting a motion to disqualify an attorney because a civil litigant has a protected interest in counsel of the litigant's choice, and an appeal from a final judgment is not an adequate remedy for erroneous disqualification.

When a district court finds a lawyer-client relationship between an attorney and a company based on objective manifestations, including providing legal advice to the company's officers and employees, the district court does not abuse its discretion in disqualifying the attorney under N.D.R. Prof. Conduct 1.7(a)(1) if the attorney represents clients on both sides of the litigation.

A district court commits legal error by concluding an attorney has a lawyer-client relationship with a company solely because the attorney signed and prosecuted derivative claims brought by a shareholder on behalf of the company.

An error is harmless if it does not affect the outcome of the case or a party's substantial rights.

Rangel v. State 2026 ND 3
Docket No.: 20250281
Filing Date: 1/15/2026
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: An order granting a motion for summary disposition of postconviction relief applications is summarily affirmed under N.D.R.App.P. 35.1(a)(6).

State v. Mogren 2026 ND 2
Docket No.: 20250266
Filing Date: 1/15/2026
Case Type: Appeal - Criminal - Other
Author: Tufte, Jerod E.

Highlight: When a container has been previously opened by a government agent under lawful authority, and there is no substantial likelihood its contents have changed, a warrantless search of that container by law enforcement does not violate the
Fourth Amendment of the United States Constitution or Article I, Section 8 of the North Dakota Constitution.

Law enforcement officers are legally present in a home when the occupant consents to their entry

Pederson v. State 2026 ND 1
Docket No.: 20250208
Filing Date: 1/15/2026
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Crothers, Daniel John

Highlight: Ineffective assistance of counsel claims ordinarily are unsuited for summary disposition and denial without an evidentiary hearing.

Summary disposition of an applicant's ineffective assistance of counsel claims is error when the State does not move for summary disposition and instead requests a hearing on the claims.

A court's subject matter jurisdiction can be challenged at any stage of the proceedings, including during postconviction relief.

A judge presented with a motion for disqualification must determine whether a reasonable person could, on the basis of all the facts, reasonably question the judge's impartiality.

State v. Lawrence 2025 ND 237
Docket No.: 20250299
Filing Date: 12/31/2025
Case Type: Appeal - Criminal - Drugs/Contraband
Author: Tufte, Jerod E.

Highlight: A district court order denying a petition to return forfeited bail is affirmed.

White Bird v. State 2025 ND 236
Docket No.: 20250217
Filing Date: 12/31/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: A judgment denying an application for postconviction relief is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

Tischmak v. Theurer, et al. 2025 ND 235
Docket No.: 20250059
Filing Date: 12/31/2025
Case Type: Appeal - Civil - Real Property
Author: Tufte, Jerod E.

Highlight: District courts have wide judicial discretion in partition actions to do equity and to make a fair and just division of the property or proceeds between the parties, and great flexibility in fashioning appropriate relief for the parties.

The court may correct a clerical mistake or a mistake arising from oversight or omission whenever one is found in a judgment, order, or other part of the record. The task of weighing the evidence and judging the credibility of witnesses
belongs to the trier of fact, and this Court does not reweigh credibility or resolve conflicts in the evidence.

State v. Medina 2025 ND 234
Docket No.: 20250178
Filing Date: 12/31/2025
Case Type: Appeal - Criminal - Drugs/Contraband
Author: Crothers, Daniel John

Highlight: Rule 11(a)(2), N.D.R.Crim.P., addresses conditional guilty pleas and requires: (1) the defendant, any defendant's attorney and the prosecuting attorney consent in writing to the conditional plea; (2) the court accept the conditional plea and enter an order; and (3) the judgment specify the plea is conditional.

Temporary remand is warranted for the district court's determination whether the plea was conditional and, if so, entry of an order and judgment consistent with the requirements of N.D.R.Crim.P. 11(a)(2).

State v. Solis 2025 ND 233
Docket No.: 20250247
Filing Date: 12/31/2025
Case Type: Appeal - Criminal - Sexual Offense
Author: Crothers, Daniel John

Highlight: A district court did not abuse its discretion by requiring registration as a sex offender.

Under N.D.C.C. § 12.1-32-15(2)(b), a court may deviate from the registration requirement if the court makes findings on the specified criteria. The court is not required to make the findings unless it first exercises its discretion to deviate
from the registration requirement.

Bohe v. State 2025 ND 232
Docket No.: 20250285
Filing Date: 12/31/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: A district court order denying an application for postconviction relief is summarily affirmed under N.D.R.App.P. 35.1(a)(2) & (4).

City of Williston v. Bauer 2025 ND 231
Docket No.: 20250216
Filing Date: 12/31/2025
Case Type: Appeal - Criminal - Disorderly Conduct
Author: Crothers, Daniel John

Highlight: The order denying the defendant's motion for recovery of attorney's fees and costs, brought in a criminal case after acquittal, is affirmed.

Markestad v. Markestad, et al. 2025 ND 230
Docket No.: 20250220
Filing Date: 12/31/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: McEvers, Lisa K. Fair

Highlight: The district court must state its findings of fact with sufficient specificity to enable a reviewing court to understand the factual basis for its decisions.

Under the clearly erroneous standard of review, we do not reweigh the evidence or reassess the credibility of witnesses, and we will not retry a custody case or substitute our judgment for the district court's decision merely because we might have reached a different result. A fit non-custodial parent is routinely awarded some form of extended summer visitation unless the court has reason to deny it.

Appellate courts review the record and findings as a whole and if the controlling findings are supported by the evidence, they will be upheld on appeal notwithstanding immaterial misstatements in the lower court's decision.

A party is not entitled to attorney's fees on appeal if the issue is inadequately briefed or the appeal is not frivolous

State v. Jenkins 2025 ND 229
Docket No.: 20250308
Filing Date: 12/31/2025
Case Type: Appeal - Criminal - DUI/DUS/APC
Author: McEvers, Lisa K. Fair

Highlight: This Court lacks jurisdiction to review untimely appeals.

Inadequately briefed issues are waived.

Wardner v. Porath, et al. 2025 ND 228
Docket No.: 20250256
Filing Date: 12/31/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: Bahr, Douglas Alan

Highlight: A district court has jurisdiction to modify a foreign custody determination, including visitation orders, when the child's home state is North Dakota and the child and parents no longer reside in the issuing jurisdiction.

Appellate courts have the authority and duty to determine the applicability of relevant statutes to legal controversies, even when the parties do not identify those statutes or argue for their application.

When a parent seeks to modify an existing nonparent visitation order, the court must apply the modification standards under the Uniform Nonparent Custody and Visitation Act.

When modifying an order granting nonparent visitation, the court must determine whether the nonparent rebutted in the initial proceeding the presumption that the parent's decision regarding visitation is in the child's best interest. If the nonparent rebutted the presumption in the initial proceeding, the presumption remains rebutted.

Geiger v. State 2025 ND 227
Docket No.: 20250236
Filing Date: 12/31/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: An order denying relief in a postconviction proceeding is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Duffi v. State 2025 ND 226
Docket No.: 20250230
Filing Date: 12/31/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: An order denying postconviction relief is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Myrick, et al. v. Holmes 2025 ND 225
Docket No.: 20250199
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Protection/Restraining Order
Author: Per Curiam

Highlight: An appeal from a disorderly conduct restraining order is summarily affirmed under N.D.R.App.P. 35.1(a)(8).

State v. Hamilton 2025 ND 224
Docket No.: 20250307
Filing Date: 12/18/2025
Case Type: Appeal - Criminal - Sexual Offense
Author: Per Curiam

Highlight: The district court's order removing a condition from the defendant's criminal judgment that required money from his prison account to be applied to his child support obligations is summarily affirmed under N.D.R.App.P. 35.1(a)(4).

State v. Gaede 2025 ND 223
Docket No.: 20250313
Filing Date: 12/18/2025
Case Type: Appeal - Criminal - Homicide
Author: Per Curiam

Highlight: An order denying a North Dakota Rule of Criminal Procedure 35(a) motion to correct an illegal sentence is summarily affirmed under North Dakota Rule of Appellate Procedure 35.1(a)(7).

State v. Jaeger 2025 ND 222
Docket No.: 20250195
Filing Date: 12/18/2025
Case Type: Appeal - Criminal - Child Abuse/Child Neglect
Author: Jensen, Jon J.

Highlight: Pursuant to N.D.R.Crim.P. 36, a district court has authority to correct a clerical error in a written order that inaccurately states the court's oral pronouncement of sentence when the correction does not make the sentence more onerous than
the original sentence, but merely corrects the written order's failure to record accurately an earlier unambiguous oral pronouncement.

The failure to appoint a criminal defendant counsel to respond to a Rule 36 motion to correct a clerical error in a probation revocation proceeding does not violate the defendant's constitutional right to counsel because the process of
probation revocation is not a critical stage of a criminal prosecution.

Thornberg v. Thornberg, et al. 2025 ND 221
Docket No.: 20250203
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Contempt of Court
Author: Jensen, Jon J.

Highlight: The district court's order holding the appellant in contempt of court for interfering with the appellee's parenting time is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

The district court's orders awarding compensatory parenting time and attorney's fees to the appellee are affirmed.

The appellee's motion for attorney's fees on appeal is denied.

Matter of William C. Hansen and Verna Hansen Trust 2025 ND 220
Docket No.: 20250206
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Probate, Wills, Trusts
Author: Jensen, Jon J.

Highlight: North Dakota Century Code § 59-14-02(5) governs whether an agent acting under a power of attorney has authority to amend a trust. It permits amendments "only to the extent expressly authorized by the terms of the trust or the power, exercised in writing and delivered to the trustee." Under N.D.C.C. § 59-19-02(1)(b), the express authorization requirement applies "to all judicial proceedings concerning trusts which are commenced after July 31, 2007." The word "express" means clearly and unmistakably communicated; stated with directness and clarity. Express authority cannot be implied from general provisions.

Dukart, et al. v. Holmes 2025 ND 219
Docket No.: 20250151
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Protection/Restraining Order
Author: Per Curiam

Highlight: A disorderly conduct restraining order is summarily affirmed under N.D.R.App.P. 35.1(a)(8).

Mollner v. State 2025 ND 218
Docket No.: 20250229
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: An order denying relief in a postconviction proceeding is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Interest of J.C. 2025 ND 217
Docket No.: 20250378
Filing Date: 12/18/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Crothers, Daniel J.

Highlight: A juvenile court order terminating parental rights is remanded for specified findings of active efforts under N.D.C.C. § 27-19.7-01(2). The Supreme Court retains jurisdiction.

Interest of S.C.Y. 2025 ND 217
Docket No.: 20250379
Filing Date: 12/18/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Crothers, Daniel J.

Highlight: A juvenile court order terminating parental rights is remanded for specified findings of active efforts under N.D.C.C. § 27-19.7-01(2). The Supreme Court retains jurisdiction.

Estate of Lepp 2025 ND 216
Docket No.: 20240310
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Probate, Wills, Trusts
Author: Crothers, Daniel John

Highlight: Probate law distinguishes between informal and formal proceedings and between unsupervised and supervised administration.

An appeal of multiple orders in an unsupervised probate is dismissed without N.D.R.Civ.P. 54(b) certification or resolution of all claims by and against a party.

This Court generally will not consider an appeal in a multi-claim or multi-party action that disposes of fewer than all claims against all of the parties unless the district court has first independently assessed the case and determined a certification under N.D.R.Civ.P. 54(b) is appropriate.

Even in an unsupervised probate, the existence of unresolved claims by or against a party prevents immediate appellate review without N.D.R.Civ.P. 54(b) certification.

State v. Hoff 2025 ND 215
Docket No.: 20240354
Filing Date: 12/18/2025
Case Type: Appeal - Criminal - Assault
Author: Crothers, Daniel John

Highlight: A defendant can waive his right to counsel either expressly, or through his conduct.

A waiver of the right to counsel must be knowingly and intelligently made. This requires the defendant be advised of the dangers and difficulties of self-representation.

Interest of G.S. 2025 ND 214
Docket No.: 20250394
Filing Date: 12/18/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Highlight: An order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

Interest of A.S. 2025 ND 214
Docket No.: 20250395
Filing Date: 12/18/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Highlight: An order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

Kolstad v. Claussen 2025 ND 213
Docket No.: 20250192
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: Tufte, Jerod E.

Highlight: The district court must state its findings of fact with sufficient specificity to enable a reviewing court to understand the factual basis for its decisions. A court's findings of fact are sufficient if they afford a clear understanding of the court's decision and assist the appellate court in conducting its review.

Under the clearly erroneous standard, the Court does not reweigh evidence or reassess witness credibility. The district court did not clearly err in finding a parent did not change employment to reduce his child support obligation, but rather to parent his children.

Wright, et al. v. Holmes 2025 ND 212
Docket No.: 20250179
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Protection/Restraining Order
Author: Per Curiam

Highlight: A disorderly conduct restraining order is summarily affirmed under N.D.R.App.P. 35.1(a)(8).

State v. Ahmed 2025 ND 211
Docket No.: 20250188
Filing Date: 12/18/2025
Case Type: Appeal - Criminal - Drugs/Contraband
Author: Bahr, Douglas Alan

Highlight: Under N.D.C.C. § 62.1-01-01(3), a firearm means any weapon that will expel, or is readily capable of expelling, a projectile by the action of an explosive.

The State can rely on the surrounding facts and circumstances, including testimony from lay witnesses, to prove a weapon is a "dangerous weapon" or "firearm" as defined in N.D.C.C. § 62.1-01-01(3).

State v. Running Bear 2025 ND 210
Docket No.: 20250138
Filing Date: 12/18/2025
Case Type: Appeal - Criminal - Child Abuse/Child Neglect
Author: Per Curiam

Highlight: A jury verdict's criminal conviction for child abuse of a victim under six years of age is summarily affirmed under N.D.R.App.P. 35.1(a)(3).

Fairville Township v. Wells Cty. Water Resource District 2025 ND 209
Docket No.: 20250255
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Administrative Proceeding
Author: Bahr, Douglas Alan

Highlight: Section 61-16.1-51, N.D.C.C., does not authorize water resource boards to assess their costs against governing bodies not acting as a landowner.

Adoption of G.M.H. 2025 ND 208
Docket No.: 20250376
Filing Date: 12/18/2025
Case Type: Appeal - Civil - Adoption
Author: Bahr, Douglas Alan

Highlight: District courts have discretion to terminate parental rights based on abandonment by evaluating whether a noncustodial parent failed to communicate with or support their child without justifiable cause. Courts must assess the specific facts of each case to determine if the parent's lack of contact and care was justified by the circumstances or represented an unjustified failure to maintain the parent-child relationship.

An as-applied constitutional challenge that merely disagrees with how the court weighed the evidence does not demonstrate the statute was applied unconstitutionally.

Interest of B.L.H. 2025 ND 207
Docket No.: 20250397
Filing Date: 12/4/2025
Case Type: Appeal - Civil - Mental Health
Author: Per Curiam

Highlight: An order granting involuntary treatment with prescribed medication is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

MidFirst Bank v. Young, et al. 2025 ND 206
Docket No.: 20240266
Filing Date: 12/4/2025
Case Type: Appeal - Civil - Foreclosure
Author: Tufte, Jerod E.

Highlight: A mortgagor lacks standing to challenge a mortgage assignment between the assignor and assignee as a non-party to that transaction.

A district court abuses its discretion by denying a request for an audio recording without explanation.

Court transcripts carry a rebuttable presumption of accuracy.

A judge advising self-represented litigants to seek counsel does not establish judicial bias.

Harris v. State 2025 ND 205
Docket No.: 20250250
Filing Date: 12/4/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Crothers, Daniel John

Highlight: A plaintiff seeking postconviction relief is required to show but for counsel's errors, there is a reasonable probability the result at trial would have been different.

Inadequate briefing or support of an issue on appeal will prevent review.

State v. Martinez 2025 ND 204
Docket No.: 20250190
Filing Date: 12/4/2025
Case Type: Appeal - Criminal - Terrorizing
Author: Bahr, Douglas Alan

Highlight: Under N.D.R.Crim.P. 24, a jury is not empaneled until all jurors, including any alternates, have been qualified, accepted, and sworn.

In a jury trial, jeopardy attaches when the jury is empaneled and sworn.

A court's replacement of a juror with an alternate juror does not generally implicate the Double Jeopardy Clause.

The district court does not abuse its discretion by replacing an empaneled juror with an alternate juror due to an association between a juror and a relative of the defendant.

State v. Martinez 2025 ND 204
Docket No.: 20250191
Filing Date: 12/4/2025
Case Type: Appeal - Criminal - Attempted Murder
Author: Bahr, Douglas Alan

Highlight: Under N.D.R.Crim.P. 24, a jury is not empaneled until all jurors, including any alternates, have been qualified, accepted, and sworn.

In a jury trial, jeopardy attaches when the jury is empaneled and sworn.

A court's replacement of a juror with an alternate juror does not generally implicate the Double Jeopardy Clause.

The district court does not abuse its discretion by replacing an empaneled juror with an alternate juror due to an association between a juror and a relative of the defendant.

Interest of A.D.-B. 2025 ND 203
Docket No.: 20250371
Filing Date: 12/4/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Highlight: The juvenile court's order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Interest of M.D.-B. 2025 ND 203
Docket No.: 20250372
Filing Date: 12/4/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Highlight: The juvenile court's order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Interest of C.B. 2025 ND 203
Docket No.: 20250373
Filing Date: 12/4/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Highlight: The juvenile court's order terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Kalmio v. State 2025 ND 202
Docket No.: 20250259
Filing Date: 12/4/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: An order denying relief in a postconviction proceeding is summarily affirmed under N.D.R.App.P. 35.1(a)(6).

State v. Bell 2025 ND 201
Docket No.: 20250092
Filing Date: 12/4/2025
Case Type: Appeal - Criminal - DUI/DUS/APC
Author: McEvers, Lisa K. Fair

Highlight: When interpreting a statute, the primary goal is to determine the legislature's intent by looking to the statute's plain language and attempting to give each word, phrase, and sentence its ordinary meaning.

Statutes are construed as a whole and harmonized to give meaning to related provisions. The statutes' context and the purposes for which they are enacted are considered, in addition to the actual language, its connection with other clauses, and the words or expressions which obviously are by design omitted.

Chapter 39-20, N.D.C.C., addresses chemical tests for intoxication and implied consent for individuals who operate motor vehicles. Section 39-20-01, providing for implied consent for chemical tests, must be read in conjunction with section 39-20-01.1, addressing chemical tests of drivers in serious bodily injury or fatal crashes.

Warrantless searches are unreasonable unless they fall within a recognized exception to the warrant requirement. Consent is one exception to the warrant requirement, provided the consent is voluntary. A district court must determine whether the consent was voluntary under the totality of the circumstances.

State v. Lizotte 2025 ND 200
Docket No.: 20250226
Filing Date: 12/4/2025
Case Type: Appeal - Criminal - DUI/DUS/APC
Author: Per Curiam

Highlight: A district court order revoking probation and resentencing the defendant is summarily affirmed under N.D.R.App.P. 35.1(a)(2), (4), and (7).

Access Independent Health Services, Inc., d/b/a Red River Women's Clinic. et al. v. Wrigley, et al. 2025 ND 199
Docket No.: 20240291
Filing Date: 11/21/2025
Case Type: Appeal - Civil - Constitutional Law
Author: Per Curiam

Highlight: A sufficient majority was not reached to declare unconstitutional N.D.C.C. ch. 12.1-19.1, which criminalizes abortion with exceptions. The effect of the separate opinions is that a district court judgment declaring N.D.C.C. ch. 12.1-19.1 unconstitutional and void is reversed.

Johnson v. Staiger 2025 ND 198
Docket No.: 20250048
Filing Date: 11/20/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: Bahr, Douglas Alan

Highlight: District courts may properly consider a parent's alcohol abuse and act of driving under the influence when determining whether a material change of circumstances exists. However, our cases do not show an isolated incident of a parent driving under the influence automatically mandates a finding of a material change of circumstances.

A party may not challenge prior unappealed parenting time requirements in an appeal of a subsequent order modifying parenting time.

Under N.D.R.Ct. 3.2(a)(2), a district court errs in not allowing a party the opportunity to file a reply brief; however, a court may remedy the premature issuance of an order by subsequently reviewing a timely submitted reply brief to determine whether it impacts the court's decision.

A district court does not abuse its discretion by denying a motion under N.D.R.Civ.P. 60(b) when the movant does not identify or argue a specific ground for relief under N.D.R.Civ.P. 60(b).

State v. Vetter 2025 ND 197
Docket No.: 20250149
Filing Date: 11/20/2025
Case Type: Appeal - Criminal - Disorderly Conduct
Author: McEvers, Lisa K. Fair

Highlight: Issues not raised or considered in the district court, including claims of constitutionally protected activity, cannot be raised for the first time on appeal, unless the issue rises to the level of obvious error. It is the defendant's burden to show an obvious error that affects a substantial right, and the discretion to notice obvious error need not be exercised when obvious error is not raised on appeal.

Tumultuous behavior may include conduct that is loud, noisy, or creates a disorderly commotion.

Diop v. Altepeter, et al. 2025 ND 196
Docket No.: 20250209
Filing Date: 11/20/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: Per Curiam

Highlight: An order denying Altepeter's motion to amend parenting time provisions in a divorce judgment is summarily affirmed under N.D.R.App.P. 35.1(a)(7) and (8).

Clemenson v. Clemenson, et al. 2025 ND 195
Docket No.: 20250097
Filing Date: 11/20/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: Crothers, Daniel John

Highlight: The domestic violence factor in N.D.C.C. § 14-09-06.2(1)(j) requires the district court find credible evidence that domestic violence occurred. The court next must find an instance of (1) serious bodily injury, or (2) use of a dangerous weapon, or (3) a pattern of domestic violence within a reasonable time proximate to the proceeding.

We do not reweigh the findings of a district court under the clearly erroneous standard.

State v. Gores 2025 ND 194
Docket No.: 20250055
Filing Date: 11/20/2025
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Crothers, Daniel John

Highlight: A criminal judgment entered after a bench trial is affirmed because sufficient evidence supports the convictions.

Unlike in a jury trial, a defendant does not need to move for judgment of acquittal under N.D.R.Crim.P. 29 at a bench trial to preserve the issue of sufficiency-of-the-evidence for appeal.

The process of "making an arrest" or "effecting an arrest" contains many steps, which, if uninterrupted, result in an arrest. "Preventing arrest" is the charged crime for preventing an officer from "effecting an arrest" at any point during the arrest process.

During the process of "making an arrest" law enforcement is required to inform the individual of the cause of arrest unless the officer does not have an opportunity to do so. See N.D.C.C. § 29-06-17.

Boyda v. Boyda, et al. 2025 ND 193
Docket No.: 20250054
Filing Date: 11/20/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: Crothers, Daniel John

Highlight: An existing parenting plan that creates conflict between a parent and the children can be a material change of circumstances for modification of the plan.

A district court has broad discretion in determining which party bears the costs for an examination under N.D.R.Civ.P. 35 and for therapy.

A parenting plan that gives a third party the power to unilaterally determine progress and set requirements without criteria from the district court is an improper delegation of the court's authority.

The decision whether to hold a person in contempt is addressed to a district court's discretion, and will be reversed only upon a showing of an abuse of discretion.

Vacancy in Judgeship No. 6, ECJD 2025 ND 192
Docket No.: 20250363
Filing Date: 11/5/2025
Case Type: Judicial Administration - Vacancy - Vacancy
Author: Per Curiam

Highlight: Judgeship retained at Fargo

State v. Cotton 2025 ND 191
Docket No.: 20250152
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Jensen, Jon J.

Highlight: District courts have discretion to issue consecutive terms of imprisonment for felonies, but N.D.C.C. § 12.1-32-11 limits the court's authority for misdemeanors. When sentenced only for misdemeanors, a defendant may not be consecutively sentenced to more than one year, unless the defendant is being sentenced for two or more class A misdemeanors and each was committed as part of a different course of conduct or each involved a substantially different criminal objective. Crimes are not necessarily part of the same course of conduct simply because they were committed close in time or by similar means.

State v. Cotton 2025 ND 191
Docket No.: 20250153
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Jensen, Jon J.

Highlight: District courts have discretion to issue consecutive terms of imprisonment for felonies, but N.D.C.C. § 12.1-32-11 limits the court's authority for misdemeanors. When sentenced only for misdemeanors, a defendant may not be consecutively sentenced to more than one year, unless the defendant is being sentenced for two or more class A misdemeanors and each was committed as part of a different course of conduct or each involved a substantially different criminal objective. Crimes are not necessarily part of the same course of conduct simply because they were committed close in time or by similar means.

State v. Cotton 2025 ND 191
Docket No.: 20250154
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Jensen, Jon J.

Highlight: District courts have discretion to issue consecutive terms of imprisonment for felonies, but N.D.C.C. § 12.1-32-11 limits the court's authority for misdemeanors. When sentenced only for misdemeanors, a defendant may not be consecutively sentenced to more than one year, unless the defendant is being sentenced for two or more class A misdemeanors and each was committed as part of a different course of conduct or each involved a substantially different criminal objective. Crimes are not necessarily part of the same course of conduct simply because they were committed close in time or by similar means.

State v. Cotton 2025 ND 191
Docket No.: 20250155
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Jensen, Jon J.

Highlight: District courts have discretion to issue consecutive terms of imprisonment for felonies, but N.D.C.C. § 12.1-32-11 limits the court's authority for misdemeanors. When sentenced only for misdemeanors, a defendant may not be consecutively sentenced to more than one year, unless the defendant is being sentenced for two or more class A misdemeanors and each was committed as part of a different course of conduct or each involved a substantially different criminal objective. Crimes are not necessarily part of the same course of conduct simply because they were committed close in time or by similar means.

State v. Wallette 2025 ND 190
Docket No.: 20250073
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Misc. Felony
Author: Jensen, Jon J.

Highlight: The Eighth Amendment to the United States Constitution and Article I, § 11 of the North Dakota Constitution respectively prohibit infliction of "cruel and unusual punishments" and "cruel or unusual punishments." A punishment in a non-capital case that is grossly disproportionate to the offense is cruel and unusual. The disproportionality principle is narrow. It forbids only extreme sentences.

Generally, unless there is a statute to the contrary, it is within the trial court's sound discretion whether a sentence should run concurrently with or consecutively to another sentence.

The Court will review a claim that a sentence is illegal even when it was not raised below, but a significant distinction exists between claims of error regarding a sentence imposed in a procedurally or factually flawed manner, which can be waived, from an unauthorized sentence that could not lawfully be imposed under any circumstances in the particular case.

Smith v. State 2025 ND 189
Docket No.: 20250127
Filing Date: 11/5/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Jensen, Jon J.

Highlight: An attorney's representation of a criminal defendant fell below an objective
standard of reasonableness when the attorney failed to exclude certain evidence
under N.D.R.Ev. 404(b) prior to trial, failed to object to the evidence at trial, failed
to request a limiting or curative instruction after the evidence was introduced,
and failed to develop an obvious error argument regarding the evidence on
direct appeal.

The district court erred in concluding a criminal defendant was prejudiced by
counsel's representation without first assessing counsel's errors within the
context of the remaining evidence properly presented and the overall conduct of
the trial to determine whether there was a reasonable probability that the
outcome of the proceeding would have been different.

The case is remanded to supplement the record with additional evidence from
the original record, if possible, and to permit the district court to address all of
the grounds for relief raised by the applicant in his postconviction proceeding.

State v. Miller 2025 ND 188
Docket No.: 20250174
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Assault
Author: McEvers, Lisa K. Fair

Highlight: Orders revoking probation and resentencing defendant for aggravated assault and violations of a domestic violence protection order are affirmed in part, reversed in part, and remanded.

In probation revocation proceedings, a district court need not make factual findings explaining its decision to revoke probation and sentence incarceration instead of alternative sanctions. On appeal, a party may not challenge an order or judgment not designated in the notice of appeal. A party may not collaterally attack a final decision, that was not appealed, in subsequent proceedings.

State v. Miller 2025 ND 188
Docket No.: 20250175
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Assault
Author: McEvers, Lisa K. Fair

Highlight: Orders revoking probation and resentencing defendant for aggravated assault and violations of a domestic violence protection order are affirmed in part, reversed in part, and remanded.

In probation revocation proceedings, a district court need not make factual findings explaining its decision to revoke probation and sentence incarceration instead of alternative sanctions. On appeal, a party may not challenge an order or judgment not designated in the notice of appeal. A party may not collaterally attack a final decision, that was not appealed, in subsequent proceedings.

Overton v. Overton 2025 ND 187
Docket No.: 20250189
Filing Date: 11/5/2025
Case Type: Appeal - Civil - Protection/Restraining Order
Author: Crothers, Daniel John

Highlight: Procedural due process does not require the district court to ensure incarcerated parties to civil litigation are present at hearings.

A hearing for a domestic violence protection order does not implicate confrontation clause rights protected by the Sixth Amendment.

State v. Barrett 2025 ND 186
Docket No.: 20250114
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Sexual Offense
Author: Crothers, Daniel John

Highlight: A jury's question or request to view evidence during deliberations shall take place in open court, unless the defendant agrees otherwise.

For a closure of the courtroom to comply with the constitution, the district court must make correct and adequate findings on the closure.

A violation of the constitutional right to a public trial can seriously affect the fairness, integrity, or public reputation of judicial proceedings, warranting reversal.

State v. Watterud 2025 ND 185
Docket No.: 20250082
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Sexual Offense
Author: Crothers, Daniel John

Highlight: A victim's testimony about misconduct occurring over several years can be sufficient to support a conviction.

An improper communication to a jury in deliberations must actually prejudice the defendant to warrant a reversal of a conviction.

McMahon v. Sanford, et al. 2025 ND 184
Docket No.: 20250100
Filing Date: 11/5/2025
Case Type: Appeal - Civil - Other
Author: Tufte, Jerod E.

Highlight: A professional negligence action against a physician, nurse, or hospital generally requires an expert affidavit. Generally, decisions to provide medication, refuse to provide medication, or discharge a patient are medical decisions requiring the expertise of medical professionals.

In an "obvious occurrence" case, expert testimony is unnecessary if a layperson can find negligence without the benefit of an expert opinion. Determining whether to discharge a patient or provide pain medication requires medical expertise beyond the common understanding of a layperson.

The tort of intentional infliction of emotional distress requires (1) extreme and outrageous conduct that is (2) intentional or reckless and that causes (3) severe emotional distress. The district court must first determine if, as a matter of law, the defendant's conduct is sufficiently extreme and outrageous to permit recovery. This standard is strenuously high and requires conduct beyond all possible bounds of decency. The liability clearly does not extend to mere insults, indignities, threats, annoyances, petty oppressions, or other trivialities.

State v. Weber 2025 ND 183
Docket No.: 20250098
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Sexual Offense
Author: Bahr, Douglas Alan

Highlight: A party bears the burden to correctly label its motion as to inform the court of the relief sought. The district court did not err when it treated appellant's motion as a request for relief under N.D.R.Crim.P. 35(a) based on its label.

An as-applied challenge to probation conditions is not ripe for review when the individual subject to the probation conditions is still incarcerated.

This Court declines to address a facial challenge to the constitutionality of a statute without the benefit of adversarial briefing.

State v. Wilson 2025 ND 182
Docket No.: 20250169
Filing Date: 11/5/2025
Case Type: Appeal - Criminal - Assault
Author: Bahr, Douglas Alan

Highlight: A probationer's right to counsel does not arise from the Sixth Amendment but rather from North Dakota Rule of Criminal Procedure 32(f)(3)(A)(iii). Because of the statutory origin of a probationer's right to counsel at a revocation hearing, the full panoply of rights due a defendant in a criminal proceeding does not apply.

On review of a district court's finding that a probationer voluntarily, knowingly, and intelligently waived the right to counsel, we apply a clearly erroneous standard.

Interest of M.P. 2025 ND 181
Docket No.: 20250320
Filing Date: 11/5/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Highlight: The juvenile court's orders terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Interest of A.P. 2025 ND 181
Docket No.: 20250321
Filing Date: 11/5/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Highlight: The juvenile court's orders terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Interest of C.P. 2025 ND 181
Docket No.: 20250322
Filing Date: 11/5/2025
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Highlight: The juvenile court's orders terminating parental rights is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Heisler v. Reiger, et al. 2025 ND 180
Docket No.: 20250133
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: Jensen, Jon J.

Highlight: A post-trial motion invoking both N.D.R.Civ.P. 59 and N.D.R.Civ.P. 60(b) extends the time to file an appeal until notice of entry of the order disposing of the motion when the motion is brought within the time limits set forth in N.D.R.Civ.P. 59(c)(2) and N.D.R.App.P. 4(a)(3).

The 60-day period for filing an appeal under N.D.R.App.P. 4(a)(1) starts to run in the absence of a notice of entry of the judgment or order only when the record clearly shows the appealing party had actual knowledge of the judgment or order, as evidenced by some affirmative action taken by the appealing party that shows actual knowledge.

The email notice the clerk of district court provides the parties pursuant to N.D.R.Ct. 3.5(e)(5) does not equate to actual notice that will start the 60-day period for filing an appeal in the absence of a notice of entry of the judgment or order.

The judgment of the district court in favor of the appellee is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

Eggl v. State 2025 ND 179
Docket No.: 20250183
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: Trial counsel did not render ineffective assistance of counsel when his client chose to enter an open plea rather than accept the State's plea offer where counsel provided his client the options on how to proceed, explained the strengths and weaknesses of the case, and left the final decision on how to proceed to his client.

State v. Chambers 2025 ND 178
Docket No.: 20250108
Filing Date: 10/22/2025
Case Type: Appeal - Criminal - Attempted Murder
Author: Jensen, Jon J.

Highlight: A criminal defendant failed to show his substantial rights were prejudiced by the potential ambiguity of pleading guilty to both a cognizable offense and a non-cognizable offense where there was a sufficient factual basis to support the guilty plea to the cognizable offense. The requirements of N.D.R.Crim.P. 11(c)(3)(B) did not apply where the criminal defendant entered an open plea rather than pleading guilty under a plea agreement in which the parties presented a joint recommendation on a proposed sentence.

Schultz v. Schultz 2025 ND 177
Docket No.: 20250156
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Divorce
Author: Per Curiam

Highlight: A district court divorce judgment awarding equal residential responsibility and distributing the marital estate is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

Hernandez v. State 2025 ND 176
Docket No.: 20250116
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: A district court order dismissing an application for postconviction relief is summarily affirmed under N.D.R.App.P. 35.1(a)(6).

Corey v. Kenneh 2025 ND 175
Docket No.: 20250239
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Protection/Restraining Order
Author: McEvers, Lisa K. Fair

Highlight: A disorderly conduct restraining order is affirmed.

An appeal is not moot if a district court order has collateral consequences for the appealing party.

Citations to non-existent case law may preclude review of issues on appeal.

It is the appellant's responsibility to obtain a transcript and they must bear any consequences for failing to provide a transcript on appeal.

State v. King 2025 ND 174
Docket No.: 20250101
Filing Date: 10/22/2025
Case Type: Appeal - Criminal - Terrorizing
Author: Crothers, Daniel John

Highlight: Obvious error analysis requires consideration whether the district court clearly deviated from applicable current law.

An alleged error that is not plain will not be analyzed further in accordance with judicial restraint and constitutional avoidance.

Olson v. Olson, et al. 2025 ND 173
Docket No.: 20250120
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Certified Question of Law
Author: Crothers, Daniel John

Highlight: Certified questions from our state district courts have a more stringent standard than foreign courts, requiring the question to be determinative, because the parties have a right to appeal.

The district court's certified question of law is not answered because the question is not dispositive of the issues before that court and our response would be purely advisory

State v. Santiago Agosto 2025 ND 172
Docket No.: 20250135
Filing Date: 10/22/2025
Case Type: Appeal - Criminal - Assault
Author: Per Curiam

Highlight: A district court criminal judgment is summarily affirmed under N.D.R.App.P. 35.1(a)(3).

Interest of Skorick 2025 ND 171
Docket No.: 20250071
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Civil Commitment of Sexually Dangerous Individual
Author: Bahr, Douglas Alan

Highlight: A district court must have sufficient factual findings to show a sexually dangerous individual continues to have an inability to control his behavior. Past conduct is relevant and may be considered with present conduct to determine if an individual continues to have an inability to control his behavior. Failure to attend treatment might demonstrate inability to control behavior just as violation of other institutional rules.

Williamson v. Williamson 2025 ND 170
Docket No.: 20250007
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Divorce - Property
Author: Per Curiam

Highlight: A district court's judgment of divorce, order denying reconsideration, and order awarding attorney's fees is summarily affirmed under N.D.R.App.P. 35.1(a)(1), (4), and (6).

Thompson v. City of Adams, et al. 2025 ND 169
Docket No.: 20250185
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Other
Author: Per Curiam

Highlight: A district court judgment granting summary judgment is summarily affirmed under N.D.R.App.P. 35.1(a)(8).

Cache Private Capital Diversified Fund v. Braddock, et al. 2025 ND 168
Docket No.: 20250176
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Eviction
Author: Bahr, Douglas Alan

Highlight: Valid service of process is necessary to assert personal jurisdiction over a defendant. Once a prima facie showing of valid service has been presented, the burden shifts to the defendant to present facts and documentation to establish service of process was insufficient.

Eviction actions are not joinable with other actions, and counterclaims and defenses may not be interposed except as a setoff to a demand made for damages, rents, or profits.

A contract for deed may be canceled by statutory cancellation. By following the statutes' strict guidelines, a vendor cancels the contract for deed by operation of law. Upon cancellation, the vendee's interest in the property terminates, and the vendee is required to return possession of the property to the vendor. If the vendee fails to return possession of the property, the vendee is in wrongful possession of the property, and an eviction is proper.

Cache Private Capital Diversified Fund v. Braddock, et al. 2025 ND 168
Docket No.: 20250177
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Eviction
Author: Bahr, Douglas Alan

Highlight: Valid service of process is necessary to assert personal jurisdiction over a defendant. Once a prima facie showing of valid service has been presented, the burden shifts to the defendant to present facts and documentation to establish service of process was insufficient.

Eviction actions are not joinable with other actions, and counterclaims and defenses may not be interposed except as a setoff to a demand made for damages, rents, or profits.

A contract for deed may be canceled by statutory cancellation. By following the statutes' strict guidelines, a vendor cancels the contract for deed by operation of law. Upon cancellation, the vendee's interest in the property terminates, and the vendee is required to return possession of the property to the vendor. If the vendee fails to return possession of the property, the vendee is in wrongful possession of the property, and an eviction is proper.

State v. Jemal 2025 ND 167
Docket No.: 20250222
Filing Date: 10/22/2025
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Tufte, Jerod E.

Highlight: In probation revocation proceedings, a district court need not make factual findings to support its decision to revoke probation instead of choosing alternative sanctions.

Appellate review of sentencing decisions is limited to determining whether the sentence is within the statutory range and whether the court considered impermissible factors.

A party may not challenge an order or judgment on appeal without designating it in a notice of appeal.

Sutherby v. Astanina, et al. 2025 ND 166
Docket No.: 20250132
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: Tufte, Jerod E.

Highlight: A district court must credit a noncustodial parent for voluntary child support payments made during the pendency of an action when calculating past-due support obligations. When a court orders child support with a retroactive effective date, it must offset any past-due support owed by payments the noncustodial parent made to the custodial parent for the children's benefit during the relevant period.

Rugland v. State 2025 ND 165
Docket No.: 20250117
Filing Date: 10/22/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: An order denying a postconviction relief application is summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (4).

Interest of Hoff 2025 ND 164
Docket No.: 20250016
Filing Date: 10/9/2025
Case Type: Appeal - Civil - Civil Commitment of Sexually Dangerous Individual
Author: McEvers, Lisa K. Fair

Highlight: An order denying discharge from civil commitment as a sexually dangerous individual is reversed and remanded for further findings. A district court's order finding an individual remains a sexually dangerous individual must contain sufficient and specific factual findings to show the individual has serious difficulty controlling his behavior.

State v. Moen 2025 ND 163
Docket No.: 20250018
Filing Date: 10/9/2025
Case Type: Appeal - Criminal - Homicide
Author: Jensen, Jon J.

Highlight: The Confrontation Clause provides two protections to criminal defendants: the right to physically face someone who testifies against them, and the right to cross-examine. Although the right to confront witnesses is of a constitutional magnitude, it is not absolute and, in appropriate cases, may bow to accommodate other legitimate interests in the criminal trial process.

North Dakota Century Code § 31-04-04.2 permits remote electronic testimony by children if testifying in front of a criminal defendant would traumatize a child in a manner impacting the child's ability to communicate.

A district court's findings of fact in preliminary proceedings of a criminal case will not be reversed if, after the conflicts in the testimony are resolved in favor of affirmance, there is sufficient competent evidence fairly capable of supporting the court's findings, and the decision is not contrary to the manifest weight of the evidence.

State v. Guthmiller 2025 ND 162
Docket No.: 20250085
Filing Date: 10/9/2025
Case Type: Appeal - Criminal - Sexual Offense
Author: Bahr, Douglas Alan

Highlight: In criminal cases, errors not raised in the district court may be either forfeited errors or waived errors. Forfeiture is the failure to timely assert a right, while waiver is the intentional relinquishment of a right.

Although this Court may review forfeited errors for obvious error, the obvious error analysis under N.D.R.Crim.P. 52(b) does not apply to waived errors.

Unchallenged jury instructions become the law of the case for purposes of assessing a claim about the sufficiency of the evidence.

Anderson v. Krueger 2025 ND 161
Docket No.: 20250078
Filing Date: 10/9/2025
Case Type: Appeal - Civil - Protection/Restraining Order
Author: Bahr, Douglas Alan

Highlight: A district court may enter a protection order when there has been a showing of actual or imminent domestic violence. A district court's finding of domestic violence is a finding of fact that will not be overturned unless it is clearly erroneous.

Domestic violence protection orders are civil in nature and governed by N.D.C.C. ch. 14-07.1. Criminal justification defenses under N.D.C.C. § 12.1-05-06 do not apply to civil domestic violence protection order proceedings.

Diop v. Altepeter, et al. 2025 ND 160
Docket No.: 20240285
Filing Date: 9/25/2025
Case Type: Appeal - Civil - Parenting Responsibility
Author: Per Curiam

Highlight: An appeal from an order finding the appellant in contempt of court in a divorce and parental responsibility action is dismissed as untimely.

Another contempt finding and the first amended judgment appealed in the same matter are summarily affirmed under N.D.R.App.P. 35.1(a)(2) and (7).

Duchaine v. State 2025 ND 159
Docket No.: 20250118
Filing Date: 9/25/2025
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Highlight: An order denying an application for postconviction relief is summarily affirmed under N.D.R.App.P. 35.1(a)(7).

State v. Pittsley 2025 ND 158
Docket No.: 20250009
Filing Date: 9/25/2025
Case Type: Appeal - Criminal - Child Abuse/Child Neglect
Author: Per Curiam

Highlight: A criminal judgment entered after a jury found the defendant guilty of child neglect is summarily affirmed under N.D.R.App.P. 35.1(a)(3).

Interest of K.I.B. 2025 ND 157
Docket No.: 20250060
Filing Date: 9/25/2025
Case Type: Appeal - Juvenile - Delinquency
Author: Bahr, Douglas Alan

Highlight: The State is an aggrieved party under N.D.C.C. § 27-20.2-26 and may appeal a juvenile court's ruling exempting a juvenile adjudicated delinquent as a sexual offender from registration as a sexual offender.

This Court reviews a juvenile court's interpretation of a statute de novo. When interpreting a statute, the primary goal is to determine the intent of the statute by looking to the statute's language as a whole and giving meaning and effect to every word, phrase, and sentence.

Section 12.1-32-15(2), N.D.C.C., does not allow the court to deviate from the sexual offender registration requirement for juveniles adjudicated delinquent under N.D.C.C. ch. 12.1-27.2.

Section 29-28-35, N.D.C.C., does not apply to appeals of juvenile cases because the Juvenile Court Act controls procedure in juvenile cases.

Page 1 of 122