SBAND Seminar Materials DUI Case Law Update Materials | Page 13
and notice for refusal and released Morrow. The trooper listed N/A in the box for
probable cause to arrest.
Procedure: ND DOT suspended Morrow and the district court affirmed. Morrow
appealed arguing NDCC § 39-20-04 required the officer to include his observations that
Morrow’s body contained alcohol on the report and notice. ND Supreme Court
REVERSED.
Holding:
The Department's authority to suspend a person's license is given by
statute and is dependent upon the terms of the statute. The Department must meet the
basic and mandatory provisions of the statute to have authority to suspend a person's
driving privileges. The requirement that an officer include his or her observation that a
driver's body contained alcohol on the report and notice is basic and mandatory for the
Department of Transportation to have authority to suspend the driver's license for refusal
to submit to an onsite screening test.
Allowing the Department to infer elements that are basic and mandatory without any
factual basis on the report to support the inference slants the law too much toward the
Department's convenience.
VI.
Legislative Changes
Disclaimer: This handout is designed to be a quick reference guide to the criminal law
changes that occurred during the 2013 North Dakota legislative session. The notes
following the bill numbers below are not designed to fully explain every change found in
the legislation. Please review the latest text versions of the bills to see all possible
affected changes. Full bill version can be found at:
http://www.legis.nd.gov/assembly/63-2013/regular
If you believe a bill is missing from this list or you have any other comments or questions
you can contact Aaron Birst, NDACo legal counsel: [email protected]
HB 1027
Impacts: 39-06-17, 39-06-42 & 39-06.1-11
Court may dismiss DUS charge upon motion by the defendant if the defendant's
operator's license is reinstated within sixty days of the date of the offense.
HB 1070
Impacts: 19-03.1-05, 19-03.1-09, 19-03.1-11 & 19-03.1-13
Changes to the controlled substance schedule.
HB 1077
Impacts: 5-01
Creation of new winery regulation.
HB 1101
Impacts: 50-31 & 50-31-01
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