The North Dakota Supreme Court issued several opinions on December 19, 2024, addressing a range of legal issues from municipal authority to criminal procedure.
In "City of Fargo v. State," the court highlighted the limitations of a home rule city's power to enact ordinances that supersede state law, emphasizing that such powers must be based on statutory provisions. Justice Douglas Alan Bahr authored this opinion.
"Hoff v. State" dealt with post-conviction relief applications barred by a two-year limitation under N.D.C.C. § 29-32.1-01(2). The court clarified that exceptions are not applicable if the applicant's physical or mental conditions do not prevent timely filing for relief.
In juvenile matters, "Adoption of H.W.L." resulted in the affirmation of a district court order terminating parental rights and granting adoption under specific procedural rules.
A constitutional law appeal was addressed in "Overbo v. Overbo," where Justice Daniel John Crothers emphasized that courts should refrain from deciding constitutional questions not presented by litigants.
In "Sanderson v. Agotness," judicial immunity was affirmed for judges acting within their capacity, and attorney's fees were awarded to prevailing parties in frivolous actions.
Criminal appeals included "State v. Eagleman," where the court underscored the exclusive nature of the Uniform Postconviction Procedure Act for challenging convictions or sentences and clarified improper use of motions to correct illegal sentences as collateral attacks on convictions.
"Interest of A.E.E." involved guardian modification proceedings under N.D.C.C. § 27-20.1-16(2), stating petitions must demonstrate changes serve the child's best interest.
"State v. Werner" examined investigative stops, affirming they require reasonable suspicion or probable cause based on objective standards rather than subjective beliefs, alongside clarifying Miranda warnings during custodial interrogations.
"Lindeman v. State" focused on ineffective assistance claims requiring proof of both defective counsel performance and resulting prejudice to succeed.
In civil proceedings, "McKenzie Electric Coop., Inc. v. El-Dweek" denied a petition for supervisory writ regarding judicial recusal orders.
Lastly, "Cass Co. v. KNB Properties" dealt with zoning and subdivision ordinances' regulatory purposes, highlighting distinctions between county subdivision authority and township zoning authority under North Dakota statutes.