Justia Criminal Law Opinion Summaries

The State appealed a district court order that dismissed felony theft of property charges against Steven Goldmann for lack of probable cause. After review of the trial court record, the Supreme Court concluded the State produced evidence to establish probable cause for a class B felony theft and the district court erred in its theft valuation. Accordingly, the Court reversed and remanded the case. View "North Dakota v. Goldmann" on Justia Law

Matthew Eagleman appealed an order that granted the State's motion to correct an illegal sentence and which resentenced him to imprisonment. Because the district court acted within the statutorily prescribed sentencing limits and did not rely on an impermissible factor in resentencing Eagleman, the Supreme Court affirmed. View "North Dakota v. Eagleman" on Justia Law

Edward Waslaski, Jr. appealed a district court order denying his motion for reconsideration of his post-conviction relief application. Upon review of the matter, the Supreme Court concluded the district court did not abuse its discretion in denying Waslaski's motion. View "Waslaski v. North Dakota" on Justia Law

Miguel Humberto Medina Romero was convicted by jury of murder, unlawful possession/manufacture of a controlled substance (marijuana), and unlawful possession of a controlled substance (cocaine) with intent to deliver. Upon review of Romero’s arguments on appeal, the Supreme Court concluded that the district court did not err in denying Romero's motion to allow the jury to view the crime scene, in instructing the jury on self-defense, and in denying Romero's motion under N.D.R.Crim.P. 29 for a judgment of acquittal on the charge of unlawful possession of cocaine with intent to deliver. Furthermore, the Court held that Romero failed to establish reversible error regarding inaudible words in the transcript of the jury selection. View "North Dakota v. Romero" on Justia Law

After a shooting incident in a Fargo movie theater parking lot, the State charged Felipe Estrada with attempted murder for shooting Juan Garza in an attempt to cause his death. Estrada was also charged with aggravated assault for striking Charles Roskom on the head with a handgun and fracturing his skull and with two counts of reckless endangerment for shooting in the direction of DeShawn Stodola as she ran away and for shooting toward members of the public inside the movie theater. Estrada appealed his convictions on two counts of aggravated assault and two counts of reckless endangerment. Viewed in the light most favorable to the verdict, the Supreme Court concluded the evidence was sufficient to support the guilty verdicts, and affirmed them. View "North Dakota v. Estrada" on Justia Law

William Florian Wosick appealed a criminal judgment entered after a jury found him guilty of driving under the influence of alcohol. Wosick argued the district court abused its discretion by admitting a blood analysis report and obvious error occurred because of lack of notice of the charge against him and the improper admission of testimony. Finding that Wosick did not demonstrate that admission of the blood test report constituted a clear deviation from an applicable legal rule under current law, the Supreme Court affirmed the criminal judgment against him. View "City of Grafton v. Wosick" on Justia Law

Tyler Dawson appealed a district court judgment affirming a North Dakota Department of Transportation hearing officer's decision to suspend his driving privileges for two years for driving under the influence of alcohol. Upon review of the matter, the Supreme Court concluded a reasoning mind could not reasonably conclude the finding that Dawson drove or was in physical control of a motor vehicle within two hours of the performance of a chemical test was supported by a preponderance of the evidence on the entire record. Therefore, the Court reversed the district court's judgment and the Department hearing officer's decision and remanded to the Department for reinstatement of Dawson's driving privileges. View "Dawson v. N.D. Dep't of Transportation" on Justia Law

The State appealed a juvenile court order adopting a judicial referee's findings of fact and order dismissing the State's petition alleging M.H.P. was a delinquent child. The State filed a petition alleging M.H.P. was a delinquent child who committed gross sexual imposition. The judicial referee found M.H.P. was not in need of treatment or rehabilitation as a delinquent child. The judicial referee explained he previously found beyond a reasonable doubt that M.H.P. committed the delinquent act of gross sexual imposition and stated, "Although this fact alone would be sufficient to sustain a finding of a need for treatment and rehabilitation, there was a substantial amount of evidence to the contrary." Based on these findings, the judicial referee dismissed the petition. The juvenile court adopted the judicial referee's findings and order, dismissed the proceeding and concluded the issue of M.H.P. registering as a sexual offender did not need to be addressed. Upon review, the Supreme Court concluded that the Double Jeopardy Clause of the Fifth Amendment of the United States Constitution barred the State from appealing the juvenile court's order. The Supreme Court therefore affirmed the dismissal of the juvenile court's findings. View "Interest of M.H.P." on Justia Law

Pro se Defendant-Appellant Michael Farrell appealed a district court civil judgment of $400 in unpaid fines and fees. In 1993, Farrell pled guilty to criminal trespass and criminal mischief and was ordered to pay fines, restitution, and fees. In 1994, the district court issued a bench warrant for failure to pay $1,351.88 in fines and costs. In 2012, Farrell requested from the district court under the Interstate Agreement on Detainers Act a final disposition on any and all charges. In response to Farrell's letter, the State moved to dismiss a separate pending simple assault charge because Farrell was incarcerated in Utah and the case was too old to warrant prosecution. The district court granted the State's motion to dismiss the simple assault charge. On the same day, the district court ordered a civil judgment totaling $400 be docketed against Farrell for unpaid fines and costs. The civil judgment was mailed, and Farrell appealed to the Supreme Court. Subsequently, the State moved to "satisfy the judgment," acknowledging that under N.D.C.C. 29-26-22.1, a criminal judgment that imposes fines and fees may be docketed as a civil judgment only within 10 years of the criminal judgment. The district court granted the State's motion and ordered the civil judgment satisfied on January 3, 2013. Generally, a satisfaction on the record extinguishes a claim, and the controversy is deemed ended, leaving an appellate court with nothing to review. Although the State's motion to the district court was labeled as a "motion to satisfy judgment" and the court ordered the "judgment be satisfied," there was not a satisfaction of judgment under North Dakota law. "The intent may have been to vacate the judgment, but because of the appeal, the district court lacked jurisdiction to enter the January 3, 2013, order." Accordingly the Supreme Court reversed the district court's civil judgment for costs and fees. View "North Dakota v. Farrell" on Justia Law

Defendant-Appellant Thomas Doppler appealed a district court judgment of conviction for possession of methamphetamine and possession of drug paraphernalia following a jury trial. Doppler argued on appeal that the district court abused its discretion by admitting evidence of Doppler's prior felony convictions. Upon review, the Supreme Court reversed and remanded for a new trial, concluding Doppler's substantial rights were affected by the improper admission of Doppler's prior convictions. View "North Dakota v. Doppler" on Justia Law