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1001 - 1100 of 12137 results

Simmons v. Cudd Pressure Control, et al. 2022 ND 20
Docket No.: 20210166
Filing Date: 1/21/2022
Case Type: Appeal - Civil - Personal Injury
Author: McEvers, Lisa K. Fair

Anderson v. Pedie, et al. 2022 ND 19
Docket No.: 20210147
Filing Date: 1/21/2022
Case Type: Appeal - Civil - Child Support
Author: Tufte, Jerod E.

State v. Bolinske, Sr. 2022 ND 18
Docket No.: 20210128
Filing Date: 1/21/2022
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Crothers, Daniel John

Fischer v. Hoyt 2022 ND 17
Docket No.: 20210164
Filing Date: 1/21/2022
Case Type: Appeal - Civil - Contracts
Author: Crothers, Daniel John

Pomarleau v. Pomarleau, et al. 2022 ND 16
Docket No.: 20210083
Filing Date: 1/21/2022
Case Type: Appeal - Civil - Child Support
Author: Jensen, Jon J.

Highlight: A district court may consider whether an obligor made a voluntary change in employment, and if they find the obligor did, the district court has the discretion to base the obligor’s child support income based on the previous, higher income.

A district court’s allocation of child tax credits is subject to the clearly erroneous standard of review.

A district court’s distribution of marital property is subject to the clearly erroneous standard of review. This Court reviews the findings as a whole, and they will be upheld on appeal despite relatively insignificant errors in the calculations.

Wald v. Hovey, et al. 2022 ND 15
Docket No.: 20210280
Filing Date: 1/6/2022
Case Type: Original Proceeding - Civil - Writ of Supervision
Author: VandeWalle, Gerald

Plaisimond v. State 2022 ND 14
Docket No.: 20210215
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Estate of Beach 2022 ND 13
Docket No.: 20210077
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Probate, Wills, Trusts
Author: VandeWalle, Gerald

Highlight: A holographic will is valid if the signature and material portions of the document are in the testator’s handwriting.

Material portions of a holographic will express donative and testamentary intent.

A district court’s finding that the material portions of a holographic will were not in the testator’s handwriting is supported by the record and affirmed.

Armstrong v. Helms 2022 ND 12
Docket No.: 20210227
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Oil, Gas and Minerals
Author: Jensen, Jon J.

Matter of Shane Lance Yates 2022 ND 11
Docket No.: 20210193
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Other
Author: Tufte, Jerod E.

Matter of Amy Jo Yates 2022 ND 11
Docket No.: 20210194
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Other
Author: Tufte, Jerod E.

Brendel Construction v. WSI 2022 ND 10
Docket No.: 20210229
Filing Date: 1/6/2022
Case Type: Appeal - Administrative - Workers Compensation
Author: McEvers, Lisa K. Fair

State v. Mayland 2022 ND 9
Docket No.: 20210213
Filing Date: 1/6/2022
Case Type: Appeal - Criminal - DUI/DUS/APC
Author: Jensen, Jon J.

Vic Christensen Mineral Trust v. Enerplus Resources Corp., et al. 2022 ND 8
Docket No.: 20210050
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Oil, Gas and Minerals
Author: Tufte, Jerod E.

Highlight: An oil and gas operator may suspend royalty payments to the mineral owner in the event of a dispute of title existing that would affect distribution of royalty payments. The operator shall make royalty payments to those mineral owners whose title and ownership interest is not in dispute.

State v. Castleman 2022 ND 7
Docket No.: 20210011
Filing Date: 1/6/2022
Case Type: Appeal - Criminal - Misc. Felony
Author: Tufte, Jerod E.

Highlight: The ordinary meaning of “mental injury” as used in N.D.C.C. § 14-09-22(1) requires mental suffering and trauma that has some lasting, non-transitory effect.

Livingston v. WSI, et al. 2022 ND 6
Docket No.: 20210232
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Administrative Proceeding
Author: Per Curiam

Lebeau v. State 2022 ND 5
Docket No.: 20210221
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

Muscha v. Krolik, et al. 2022 ND 4
Docket No.: 20210179
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Child Support
Author: Tufte, Jerod E.

State v. Dargbeh 2022 ND 3
Docket No.: 20210175
Filing Date: 1/6/2022
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Tufte, Jerod E.

Gerving v. Gerving, et al. 2022 ND 2
Docket No.: 20210074
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Child Support
Author: VandeWalle, Gerald

Highlight: The district court must comply with the child support guidelines in calculating a parent’s child support obligation.

The district court must properly calculate a child support obligor’s net income to determine the correct amount of support.

The district court has discretion to grant a parent’s request for a deviation in the amount of the child support obligation for expenses related to the child’s private school tuition.

Tergesen, et al. v. Nelson Homes 2022 ND 1
Docket No.: 20210113
Filing Date: 1/6/2022
Case Type: Appeal - Civil - Contracts
Author: VandeWalle, Gerald

Matter of Knoke 2021 ND 240
Docket No.: 20210081
Filing Date: 12/23/2021
Case Type: Appeal - Civil - Civil Commitment of Sexually Dangerous Individual
Author: VandeWalle, Gerald

Highlight: The district court’s probable cause determination in a civil commitment case becomes moot once the commitment hearing is held.

In proceedings for the civil commitment of a sexually dangerous individual, the district court errs when it fails to make a finding on whether the respondent has serious difficulty controlling his behavior.

State v. Carrillo 2021 ND 239
Docket No.: 20210223
Filing Date: 12/23/2021
Case Type: Appeal - Criminal - Drugs/Contraband
Author: McEvers, Lisa K. Fair

Estate of Smith 2021 ND 238
Docket No.: 20210114
Filing Date: 12/23/2021
Case Type: Appeal - Civil - Probate, Wills, Trusts
Author: Jensen, Jon J.

Taszarek, et al. v. Lakeview Excavating, et al. 2021 ND 237
Docket No.: 20210046
Filing Date: 12/23/2021
Case Type: Appeal - Civil - Other
Author: Tufte, Jerod E.

Highlight: When the Court remands for redetermination of an issue without specifying the procedure to be followed, the district court may decide the issue based on the evidence already before it or may take additional evidence.

Under the “alter ego” approach to piercing the corporate veil, there must be such a unity of interest and ownership between the corporation and its equitable owner that the separate personalities of the corporation and the shareholder do not in reality exist, and there must be an inequitable result if the acts in question are treated as those of the corporation alone. This approach analyzes whether a corporation is merely an instrumentality or alter ego of its owner, and requires examination of the Hilzendager-Jablonsky factors, including the “injustice, inequity or fundamental unfairness” element.

Cavare v. Kjelgren 2021 ND 236
Docket No.: 20200128
Filing Date: 12/23/2021
Case Type: Appeal - Civil - Other
Author: Jensen, Jon J.

Highlight: In an appeal from a bench trial, the district court’s findings of fact are reviewed under the clearly erroneous standard and its conclusions of law are fully reviewable.

A district court’s choice between two permissible views of the weight of the evidence is not clearly erroneous.

A district court’s decision to deny a motion for relief from a judgment will not be reversed on appeal unless the court abused its discretion in ruling there were not sufficient grounds for relief from the judgment.

Relief from a judgment on grounds of fraud, misrepresentation, or other misconduct is extraordinary relief that should only be granted in exceptional circumstances.

State v. Roberts 2021 ND 235
Docket No.: 20210161
Filing Date: 12/23/2021
Case Type: Appeal - Criminal - Drugs/Contraband
Author: Jensen, Jon J.

Heggem v. Heggem 2021 ND 234
Docket No.: 20210212
Filing Date: 12/23/2021
Case Type: Appeal - Civil - Child Support
Author: Per Curiam

Hehr v. Hehr 2021 ND 233
Docket No.: 20210176
Filing Date: 12/23/2021
Case Type: Appeal - Civil - Divorce - Property
Author: Per Curiam

Bridges v. State (consolidated w/20210119) 2021 ND 232
Docket No.: 20210118
Filing Date: 12/23/2021
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Crothers, Daniel John

Visser v. Visser, et al. 2021 ND 231
Docket No.: 20210151
Filing Date: 12/23/2021
Case Type: Appeal - Civil - Child Support
Author: Per Curiam

State v. Olsen 2021 ND 230
Docket No.: 20210127
Filing Date: 12/23/2021
Case Type: Appeal - Criminal - Sexual Offense
Author: Per Curiam

Motisi v. Hebron Public School District 2021 ND 229
Docket No.: 20210248
Filing Date: 12/23/2021
Case Type: Original Proceeding - Civil - Writ of Mandamus
Author: McEvers, Lisa K. Fair

American Federal Bank v. Grommesh, et al. 2021 ND 228
Docket No.: 20210080
Filing Date: 12/23/2021
Case Type: Appeal - Civil - Contracts
Author: Crothers, Daniel John

Highlight: When summary judgments are reviewed, the evidence is viewed in the light most favorable to the opposing party, giving that party the benefit of all favorable inference which can reasonably be drawn from the record.

The language of a contract governs its interpretation if the language is unambiguous.

Summary judgment is proper against a party who fails to make a showing sufficient to establish the existence of an element essential to the party’s case and on which the party will bear the burden of proof at trial.

The party asserting an avoidance or affirmative defense has the responsibility to set forth specific facts showing there is a genuine issue for trial on that defense to preclude summary judgment.

Vacancy in Judgeship No. 4, ECJD 2021 ND 227
Docket No.: 20210311
Filing Date: 12/22/2021
Case Type: Judicial Administration - Rule - Rule
Author: Per Curiam

State v. Brown 2021 ND 226
Docket No.: 20210191
Filing Date: 12/9/2021
Case Type: Appeal - Criminal - Misc. Felony
Author: McEvers, Lisa K. Fair

State v. Vannett 2021 ND 225
Docket No.: 20210158
Filing Date: 12/9/2021
Case Type: Appeal - Criminal - DUI/DUS/APC
Author: Crothers, Daniel John

State v. Hatcher 2021 ND 224
Docket No.: 20210137
Filing Date: 12/9/2021
Case Type: Appeal - Criminal - Misc. Felony
Author: Per Curiam

State v. Houkom 2021 ND 223
Docket No.: 20210058
Filing Date: 12/9/2021
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Tufte, Jerod E.

Highlight: The official proceeding or matter in which a false statement was made directly controls whether the falsification can be said to be material under N.D.C.C. § 12.1-11-03(1).

Hunter v. WSI 2021 ND 222
Docket No.: 20210185
Filing Date: 12/9/2021
Case Type: Appeal - Administrative - Workers Compensation
Author: Per Curiam

Narloch v. Narloch, et al. 2021 ND 221
Docket No.: 20210153
Filing Date: 12/9/2021
Case Type: Appeal - Civil - Child Support
Author: Per Curiam

State v. Lindeman 2021 ND 220
Docket No.: 20210159
Filing Date: 12/9/2021
Case Type: Appeal - Criminal - Sexual Offense
Author: Per Curiam

State v. Rieger 2021 ND 219
Docket No.: 20210092
Filing Date: 12/9/2021
Case Type: Appeal - Criminal - Misc. Felony
Author: Per Curiam

Highlight: A judgment finding the defendant guilty of corruption of a minor, victim over fifteen and adult over twenty-two, a class C felony, is summarily affirmed under N.D.R.App.P. 35.1(a)(3).

State v. S.J.H., et al. (Confidential) 2021 ND 218
Docket No.: 20210165
Filing Date: 12/9/2021
Case Type: Appeal - Civil - Paternity
Author: Tufte, Jerod E.

State v. Neilan 2021 ND 217
Docket No.: 20210065
Filing Date: 12/9/2021
Case Type: Appeal - Criminal - Drugs/Contraband
Author: Jensen, Jon J.

Highlight: The State may appeal from a district court order granting a defendant a reduction in sentence as the reduction affects a substantial right of the State.

The district court’s acceptance of a plea agreement does not preclude it from later exercising discretion in reducing the defendant’s sentence. Such a reduction is subject to the abuse of discretion standard of review on appeal.

This Court’s power on appeal is limited by N.D.C.C. § 29-28-35. When the State appeals, this Court cannot reverse an order of the district court if doing so would increase the defendant’s sentence.

DCI Credit Services v. Plemper 2021 ND 215
Docket No.: 20210183
Filing Date: 11/26/2021
Case Type: Appeal - Civil - Debtor/Creditor
Author: VandeWalle, Gerald

Wades Welding v. Tioga Properties 2021 ND 214
Docket No.: 20210107
Filing Date: 11/26/2021
Case Type: Appeal - Civil - Contracts
Author: Crothers, Daniel John

Boldt v. Boldt 2021 ND 213
Docket No.: 20210101
Filing Date: 11/26/2021
Case Type: Appeal - Civil - Child Support
Author: McEvers, Lisa K. Fair

Highlight: When determining primary residential responsibility of a minor child, the district court must consider the best interest factors and make findings with sufficient specificity to show the factual basis for its decision.

Deferential review of a district court’s primary residential responsibility determination is especially applicable in cases involving two fit parents.

Under N.D. Admin. Code § 75-02-04.1-01(6)(d), an individual obligated to provide child support may deduct a portion of payments made to afford health insurance coverage for the child.

State v. McCreary 2021 ND 212
Docket No.: 20210064
Filing Date: 12/1/2021
Case Type: Appeal - Criminal - Assault
Author: McEvers, Lisa K. Fair

Highlight: A flashlight may be found to be a dangerous weapon under N.D.C.C. 12.1-01-04(6).

Dangerous weapon statute is not exhaustive, and whether an object is a dangerous weapon under the circumstances is a determination for the fact finder.

Interest of C.E. (CONFIDENTIAL) 2021 ND 211
Docket No.: 20210264
Filing Date: 11/26/2021
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Iakel-Garcia v. Anderson 2021 ND 210
Docket No.: 20210021
Filing Date: 11/26/2021
Case Type: Appeal - Civil - Child Support
Author: VandeWalle, Gerald

Highlight: A district court’s award of primary residential responsibility is a finding of fact, which will not be reversed on appeal unless it is clearly erroneous.

The district court must award primary residential responsibility to the parent who will promote the child’s best interests and welfare.

The district court must determine the total value of the marital estate in order to make an equitable division of property.

Muchow v. Kohler, et al. 2021 ND 209
Docket No.: 20210103
Filing Date: 11/26/2021
Case Type: Appeal - Civil - Child Support
Author: Crothers, Daniel John

Highlight: North Dakota’s Uniform Nonparent Custody and Visitation Act governs nonparent visitation rights.

The district court may order visitation if petitioners prove: (1) a substantial relationship with the child and (2) the denial of visitation would result in harm to the child.

Petitioners have the burden of proving the requirements by clear and convincing evidence.

“Harm to child” means a “significant adverse effect on a child’s physical, emotional, or psychological well-being.”

Quamme v. Quamme 2021 ND 208
Docket No.: 20210093
Filing Date: 12/1/2021
Case Type: Appeal - Civil - Divorce - Property
Author: McEvers, Lisa K. Fair

Highlight: For purposes of determining child support, commissions do not necessarily constitute self-employment income under N.D. Admin. Code § 75-02-04.1-01(10).

Debt regularly forgiven by an employer from a loan based on an obligor’s employment constitutes gross income under N.D. Admin. Code § 75-02-04.1-01(4)(b) and (5).

For purposes of awarding spousal support, the district court does not need to provide a complete calculation of each parties’ assets, debts, and expenses, but a clear description of the parties’ financial situation is helpful in understanding the court’s rationale. When a court’s rationale is unclear, reversal and remand is appropriate.

Guardianship and Conservatorship of T.G.P.C. 2021 ND 207
Docket No.: 20210121
Filing Date: 11/26/2021
Case Type: Appeal - Civil - Guardian/Conservator
Author: Per Curiam

Chase v. State 2021 ND 206
Docket No.: 20200315
Filing Date: 11/17/2021
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Tufte, Jerod E.

Highlight: A motion for summary disposition of an application for postconviction relief under N.D.C.C. § 29-32.1-09(3) must be made consistent with our rules for motion practice. A district court may not order summary disposition in response to a request in a pleading, including the State’s answer to an application for postconviction relief.

Interest of A.D. (CONFIDENTIAL) 2021 ND 205
Docket No.: 20200299
Filing Date: 11/17/2021
Case Type: Appeal - Civil - Juvenile Law
Author: Tufte, Jerod E.

Highlight: Under N.D. Sup. Ct. Admin. R. 13, § 10(a), the findings and order of the judicial referee have the effect of the findings and order of the district court until superseded by a written order of a district court judge.

Juvenile court’s finding that father abandoned child is not clearly erroneous when the father has not provided care for or had any contact with the child since 2007 or 2008, and has not made any significant attempts to locate the child or have the child placed in his care.

Juvenile court is not required to specifically identify and discuss each best interest factor if the Court is able to discern how the juvenile court’s findings apply to the best interest factors.

When a child is deprived by the parents, no finding of exceptional circumstances is required to be made by the juvenile court to grant a guardianship. The finding of deprivation eliminates the need for a finding of exceptional circumstances.

Craig v. State 2021 ND 204
Docket No.: 20210108
Filing Date: 11/17/2021
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Jensen, Jon J.

Highlight: In a postconviction relief proceeding, claims that were raised or could have been raised in an earlier postconviction relief proceeding are barred by the doctrine of res judicata.

Matter of Michael J. Tharaldson Trust 2021 ND 203
Docket No.: 20210139
Filing Date: 11/17/2021
Case Type: Appeal - Civil - Probate, Wills, Trusts
Author: Crothers, Daniel John

Interest of J.M. (CONFIDENTIAL) (consolidated w/20210269-20210272) 2021 ND 202
Docket No.: 20210268
Filing Date: 11/17/2021
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Interest of L.L.D.R. (CONFIDENTIAL) 2021 ND 201
Docket No.: 20210130
Filing Date: 11/17/2021
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

State v. Nupdal 2021 ND 200
Docket No.: 20210015
Filing Date: 11/17/2021
Case Type: Appeal - Criminal - DUI/DUS/APC
Author: Tufte, Jerod E.

Highlight: A scale only alleged to have been used to weigh and package methamphetamine into smaller quantities did not satisfy the statutory element requiring use or intent to use the scale to produce or prepare methamphetamine.

Estate of Behle 2021 ND 199
Docket No.: 20210059
Filing Date: 11/17/2021
Case Type: Appeal - Civil - Probate, Wills, Trusts
Author: Crothers, Daniel John

Highlight: A defect in the application for probate of a will does not render the probate void.

Summary judgment is appropriate in an undue influence claim if the non-moving party’s opposition is not supported with admissible evidence showing a genuine issue for trial.

The plain language of N.D.C.C. § 28-26-01(2) requires courts in civil actions to award costs and fees upon a finding a claim for relief was frivolous, providing the prevailing party pled the alleged frivolousness of the claim.

Section 28-26-31, N.D.C.C., authorizes attorney’s fees if allegations and denials in any pleading are not made without good faith and reasonable cause.

State v. Brewer 2021 ND 198
Docket No.: 20210105
Filing Date: 11/17/2021
Case Type: Appeal - Criminal - Misc. Felony
Author: McEvers, Lisa K. Fair

Highlight: The defendant has the burden to show he is entitled to additional credit for time served in custody.

When time spent in custody is credited toward an unrelated charge, the defendant is not entitled to have that time spent in custody applied to another sentence.

An appellee who has not cross-appealed may not seek a more favorable result on appeal than received in the trial court.

Interest of S.A. (CONFIDENTIAL) (consolidated w/20210062) 2021 ND 197
Docket No.: 20210061
Filing Date: 10/28/2021
Case Type: Appeal - Civil - Juvenile Law
Author: Per Curiam

Highlight: A juvenile court order finding two children to be deprived is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

Guardianship of M.H. 2021 ND 196
Docket No.: 20210069
Filing Date: 10/28/2021
Case Type: Appeal - Civil - Guardian/Conservator
Author: Jensen, Jon J.

Highlight: This Court reviews the district court’s decision to uphold contact restrictions placed by a ward’s guardian under the clearly erroneous standard of review.

A district court’s order of guardianship and findings of fact related to contract restrictions placed by the guardian are affirmed.

Kremer v. State 2021 ND 195
Docket No.: 20210154
Filing Date: 10/28/2021
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Tufte, Jerod E.

State v. Suelzle 2021 ND 194
Docket No.: 20210028
Filing Date: 10/28/2021
Case Type: Appeal - Criminal - DUI/DUS/APC
Author: Jensen, Jon J.

Highlight: A driver weaving within their lane in traffic can rise to reasonable and articulable suspicion to justify a traffic stop.

A federal officer has jurisdiction to detain a non-Indian on an Indian reservation for a reasonable amount of time while waiting for a state law enforcement officer to arrive.

State v. Jensen 2021 ND 193
Docket No.: 20210098
Filing Date: 10/28/2021
Case Type: Appeal - Criminal - Drugs/Contraband
Author: Per Curiam

Highlight: A criminal judgment entered following denial of a motion to suppress evidence is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

State v. Kukert 2021 ND 192
Docket No.: 20210079
Filing Date: 10/28/2021
Case Type: Appeal - Criminal - Sexual Offense
Author: Crothers, Daniel John

Highlight: Whether a defendant voluntarily, knowingly, and intelligently waived his or her Miranda rights depends on the totality of the circumstances.

Statements to law enforcement may be involuntary even if law enforcement has complied with the Miranda requirements.

When a defendant makes an extrajudicial statement, there must be sufficient independent evidence establishing the trustworthiness of the statement.

Dunford v. Tryhus, et al. 2021 ND 191
Docket No.: 20210146
Filing Date: 10/28/2021
Case Type: Appeal - Civil - Personal Injury
Author: Per Curiam

Behle v. Harr 2021 ND 190
Docket No.: 20210051
Filing Date: 10/28/2021
Case Type: Appeal - Civil - Other
Author: McEvers, Lisa K. Fair

Highlight: Litigants may not contradict themselves to manufacture factual disputes for purposes of avoiding summary judgment.

Absent repudiation of a contract and the accompanying anticipatory breach, a breach of contract occurs when there is nonperformance of a contractual duty when it is due.

The term “claim” is defined by N.D.C.C. § 30.1-01-06(7) to exclude disputes regarding title of a decedent to assets alleged to be included in the decedent’s estate. The time limits set out by N.D.C.C. § 30.1-19-03(2) for demands against a decedent’s estate only apply to “claims.” For a demand to be excluded from the time limits because it is a dispute regarding title and not a “claim,” the claimant must make at least a “colorable showing” of title. Casting a claim in terms of title is insufficient to avoid the time limits if the gist of the claim sounds in contract or tort.

An argument is without merit if a party does not provide supportive reasoning or authority.

Interest of A.S.F. (CONFIDENTIAL) 2021 ND 189
Docket No.: 20210222
Filing Date: 10/28/2021
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Tufte, Jerod E.

Matter of Reciprocal Discipline of Ruffenach 2021 ND 188
Docket No.: 20210240
Filing Date: 10/21/2021
Case Type: Discipline - Attorney - Original Proceeding
Author: Per Curiam

State v. Woodruff 2021 ND 187
Docket No.: 20210026
Filing Date: 10/14/2021
Case Type: Appeal - Criminal - Misc. Misdemeanor
Author: Per Curiam

Highlight: Criminal judgment entered after a jury found the defendant guilty of preventing arrest is summarily affirmed under N.D.R.App.P. 35.1(a)(3).

Slappy v. Slappy, et al. 2021 ND 186
Docket No.: 20200352
Filing Date: 10/14/2021
Case Type: Appeal - Civil - Child Support
Author: Jensen, Jon J.

Highlight: To modify primary residential responsibility after two years, the moving party must meet the requirements of the statutory framework, including that there has been a material change in circumstances of the child or the parties, and that modification is necessary for the best interests of the child.

“Necessary” for the best interests of the child means there must be a showing that the changed circumstances had an adverse effect on the child or there had been a general decline in the child’s condition.

Because continuity and stability in a child’s life is favored, an improvement to the moving party’s life, without evidence of an adverse effect or general decline in the child, is insufficient to modify primary residential responsibility.

State v. Deleon 2021 ND 185
Docket No.: 20210018
Filing Date: 10/14/2021
Case Type: Appeal - Criminal - Sexual Offense
Author: VandeWalle, Gerald

Highlight: The evidence was sufficient to support the defendant’s conviction of possession of certain materials prohibited.

Interest of K.H. (CONFIDENTIAL) (consolidated w/20210246 & 20210247) 2021 ND 184
Docket No.: 20210245
Filing Date: 10/14/2021
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Kerzmann v. Kerzmann 2021 ND 183
Docket No.: 20210086
Filing Date: 10/14/2021
Case Type: Appeal - Civil - Child Support
Author: Jensen, Jon J.

Highlight: To establish a prima facie case to warrant an evidentiary hearing on a motion for a change in primary residential responsibility, the moving party must present facts showing there has been both a material change in circumstances and the change is necessary for the best interests of the child under N.D.C.C. § 14-09-06.6(6).

When a party has submitted an affidavit alleging first-hand knowledge of events that constitute a material change in circumstances and implicate the best interest factors, an evidentiary hearing on the motion must be held.

This Court exercises discretion in determining whether to administer sanctions on appeal.

Wheeler v. State (consolidated with 20210168 & 20210169) 2021 ND 182
Docket No.: 20210167
Filing Date: 10/14/2021
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Crothers, Daniel John

Estate of Nelson 2021 ND 181
Docket No.: 20210084
Filing Date: 10/14/2021
Case Type: Appeal - Civil - Probate, Wills, Trusts
Author: VandeWalle, Gerald

Highlight: District court orders denying motions for relief under N.D.R.Civ.P. 60(b)(6) are summarily affirmed under N.D.R.App.P. 35.1(a)(1) and (4), and double costs and attorney fees are awarded under N.D.R.App.P. 38.

State v. Reddog 2021 ND 180
Docket No.: 20210055
Filing Date: 10/14/2021
Case Type: Appeal - Criminal - Theft
Author: Per Curiam

Highlight: Criminal conviction for robbery with a firearm, destructive device, or other dangerous weapon and conspiracy to commit felonious restraint is summarily affirmed under N.D.R.App.P. 35.1(a)(3).

State v. Urrabazo 2021 ND 179
Docket No.: 20210142
Filing Date: 10/14/2021
Case Type: Appeal - Criminal - Drugs/Contraband
Author: Per Curiam

Interest of D.H.H. (CONFIDENTIAL) 2021 ND 178
Docket No.: 20210238
Filing Date: 10/14/2021
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Per Curiam

Brickle-Hicks v. State 2021 ND 177
Docket No.: 20210073
Filing Date: 10/14/2021
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

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

State v. Clemens 2021 ND 176
Docket No.: 20210136
Filing Date: 10/14/2021
Case Type: Appeal - Criminal - Theft
Author: Per Curiam

State v. Marsolek 2021 ND 175
Docket No.: 20210041
Filing Date: 9/30/2021
Case Type: Appeal - Criminal - Drugs/Contraband
Author: Tufte, Jerod E.

Highlight: A traffic stop has not been unlawfully prolonged if the officer has reasonable suspicion to believe further criminal activity is afoot.

State v. Demerais 2021 ND 174
Docket No.: 20210012
Filing Date: 9/30/2021
Case Type: Appeal - Criminal - Assault
Author: VandeWalle, Gerald

Highlight: Criminal conviction for aggravated assault summarily affirmed under N.D.R.App.P. 35.1(a)(3).

Ineffective assistance of counsel claims generally should not be brought on direct appeal, because post-conviction relief proceedings provide a more appropriate forum to develop the evidentiary record necessary for such claims.

Thomas v. State 2021 ND 173
Docket No.: 20210056
Filing Date: 9/30/2021
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Crothers, Daniel John

Highlight: Expert testimony is admissible whenever specialized knowledge will assist the trier of fact.

Expert testimony is admissible to address questions of fact, not law.

City of Jamestown v. Nygaard 2021 ND 172
Docket No.: 20210049
Filing Date: 9/30/2021
Case Type: Appeal - Criminal - DUI/DUS/APC
Author: Crothers, Daniel John

Highlight: “When the wording of a statute is clear and free of all ambiguity, the letter of it is not to be disregarded under the pretext of pursuing its spirit.” N.D.C.C. § 1-02-05.

The plain language of N.D.C.C. § 39-08-01(1)(f) does not require advice of criminal penalties to drivers before they can be charged with refusing a chemical breath test.

Continental Resources v. Armstrong, et al. 2021 ND 171
Docket No.: 20210060
Filing Date: 9/30/2021
Case Type: Appeal - Civil - Oil, Gas and Minerals
Author: McEvers, Lisa K. Fair

Highlight: An argument is without merit if the party does not provide supportive reasoning or citations to relevant authorities.

When ambiguity exists in an instrument conveying oil and gas interests, the parties’ intent is a question of fact requiring factual findings based on extrinsic evidence.

When the operator of an oil and gas well has relied to its detriment a division order signed by an underpaid royalty owner, the underpaid owner is estopped from recovering from the operator. The estoppel rule does not apply when the underpayments are not made according to a signed division order.

RTS Shearing v. BNI Coal 2021 ND 170
Docket No.: 20200340
Filing Date: 9/30/2021
Case Type: Appeal - Civil - Contracts
Author: Tufte, Jerod E.

Highlight: Parties to a contract may incorporate contractual terms by reference to a separate, noncontemporaneous document, including a separate agreement to which they are not parties, and including a separate document which is unsigned.

Although whether one agreement has incorporated another has factual components, whether material has been incorporated presents a question of law.

Galvanizers, et al. v. Kautzman, et al. 2021 ND 169
Docket No.: 20210042
Filing Date: 9/30/2021
Case Type: Appeal - Civil - Real Property
Author: VandeWalle, Gerald

Highlight: The district court must make sufficient findings of fact and conclusions of law after a bench trial to allow review of its decision on appeal.

Whether property held in the name of an individual belongs to the partnership is a question of fact.

Carpenter v. State 2021 ND 168
Docket No.: 20210104
Filing Date: 9/30/2021
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

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

Sims v. Sims 2021 ND 167
Docket No.: 20210039
Filing Date: 9/16/2021
Case Type: Appeal - Civil - Other
Author: Per Curiam

Highlight: A district court order entering a domestic violence protection order is summarily affirmed under N.D.R.App.P. 35.1(a)(2).

WSI v. Badger Roustabouts 2021 ND 166
Docket No.: 20210022
Filing Date: 9/16/2021
Case Type: Appeal - Administrative - Workers Compensation
Author: Jensen, Jon J.

Highlight: An individual who performs services for another for remuneration is presumed to be an employee of the person for which the services are performed, unless it is proven that the individual is an independent contractor under the common-law test.

Whether a worker is an independent contractor or an employee is a mixed question of fact and law.

To be entitled to an award attorney’s fees under N.D.C.C. § 28-32-50, a non-agency party must meet a two-part test: 1) the non-administrative agency party must prevail, and 2) the agency must have acted without substantial justification.

Fleck v. State 2021 ND 165
Docket No.: 20210089
Filing Date: 9/16/2021
Case Type: Appeal - Civil - Post-Conviction Relief
Author: Per Curiam

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

Matter of Muscha 2021 ND 164
Docket No.: 20210071
Filing Date: 9/16/2021
Case Type: Appeal - Civil - Civil Commitment of Sexually Dangerous Individual
Author: McEvers, Lisa K. Fair

Highlight: A district court must specify facts on which its conclusions are based that a sexually dangerous individual continues to have serious difficulty controlling his behavior. Both past conduct and present conduct are relevant to determine whether an individual continues to have serious difficulty controlling his behavior. The conduct need not be sexual in nature.

Evidence of negative and inappropriate behaviors, including incidents demonstrating more than mere horseplay, may be sufficient to demonstrate serious difficulty controlling behavior.

Interest of K.B. (CONFIDENTIAL) (CONSOLIDATED W/20210110) 2021 ND 163
Docket No.: 20210109
Filing Date: 9/9/2021
Case Type: Appeal - Juvenile - Termination of Parental Rights
Author: Tufte, Jerod E.

Manning v. Jaeger, et al. 2021 ND 162
Docket No.: 20200332
Filing Date: 9/2/2021
Case Type: Appeal - Civil - Other
Author: McEvers, Lisa K. Fair

Highlight: To intervene as a matter of right, a person must establish on timely motion that 1) the person has a cognizable interest in the subject matter of the litigation, 2) the interest may be impaired as a result of the litigation, and 3) the interest is not adequately represented by an existing party to the litigation.

Exercise of supervisory jurisdiction is purely discretionary and decided on a case-by-case basis, considering the unique circumstances of each case.

State v. Johnson 2021 ND 161
Docket No.: 20200252
Filing Date: 9/2/2021
Case Type: Appeal - Criminal - Misc. Felony
Author: Jensen, Jon J.

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

To convict for terrorizing, the State must prove that the defendant intended to cause another person to fear for his or another person’s safety or acted with reckless disregard of the risk of causing such fear and that the defendant made a threat to commit a crime of violence or act dangerous to human life.

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