North Dakota v. Ngale

Kenneth Ndumbe Ngale appealed after he conditionally pled guilty to actual physical control of a motor vehicle. He argued the district court erred in denying his motion to suppress because he was seized and arrested by a person who was not a licensed law enforcement officer and did not have authority to investigate and arrest. In rejecting Ngale's argument, the North Dakota Supreme Court found a reserve deputy, who provides services on a non-salaried basis and has full arrest authority, and is not required to be licensed to perform peace officer law enforcement duties. View "North Dakota v. Ngale" on Justia Law