CHS Inc. v. Riemers, 910 N.W.2d 189

CHS obtained a money judgment against Riemers (originally $38,889; later amended to include prejudgment interest). CHS garnished funds from accounts held by Riemers.
Riemers deposited $41,100 into an Alerus Bank account and later moved to reopen the case alleging the Amended Judgment had been fully satisfied.
CHS opposed the Motion to Reopen and requested attorney’s fees, alleging the motion was frivolous.
The district court denied Riemers’ Motion to Reopen and awarded CHS $1,628.55 in fees and costs as sanctions under N.D.C.C. § 28-26-01(2) (Sanction Order).
After Riemers filed an appeal, the district court entered and adopted a proposed Corrected Amended Judgment stating $549.08 remained due; the Supreme Court held the district court lacked jurisdiction to enter that judgment after the appeal and vacated it.
The Supreme Court affirmed the sanction award but modified the Sanction Order to reflect the correct outstanding principal balance of $549.08 and vacated the post‑appeal Corrected Amended Judgment.

Issue	Plaintiff's Argument (CHS)	Defendant's Argument (Riemers)	Held
Whether court properly awarded attorney’s fees and costs as sanctions for a frivolous motion	CHS: Motion to Reopen was frivolous; statute (§ 28‑26‑01(2)) requires fees if prevailing party pled frivolousness	Riemers: Motion was not a "claim for relief" subject to § 28‑26‑01(2); if Rule 11 applied, he lacked its procedural protections	Court affirmed sanctions under § 28‑26‑01(2); motion was frivolous because it lacked factual/legal support and CHS pled frivolousness
Whether district court erred in calculating outstanding judgment balance and in entering a corrected judgment after appeal	CHS: Correct outstanding principal was $549.08 (conceded at argument)	Riemers: He had tendered payment and judgment was satisfied; district court compounded interest and miscalculated amounts	Court found district court erred by including $130 not Riemers’ debt (modified Sanction Order to $549.08). But because the district court entered the Corrected Amended Judgment after appeal, that judgment was vacated for lack of jurisdiction

Estate of Pedro v. O'Connor, 856 N.W.2d 775 (N.D. 2014) (standard for frivolous claim under § 28‑26‑01(2))
Tillich v. Bruce, 889 N.W.2d 899 (N.D. 2017) (district court discretion in assessing frivolousness and fee amount)
CHS Inc. v. Riemers, 888 N.W.2d 205 (N.D. 2016) (prior appeal addressing Amended Judgment adjustments)
Federal Land Bank v. Ziebarth, 520 N.W.2d 51 (N.D. 1994) (inherent power to control docket and sanction abuses)
First Nat’l Bank of Belfield v. Burich, 367 N.W.2d 148 (N.D. 1985) (correct result will not be set aside for incorrect rationale)
Deacon’s Dev., LLP v. Lamb, 719 N.W.2d 379 (N.D. 2006) (scope of what constitutes a claim subject to § 28‑26‑01(2))
Roise v. Kurtz, 587 N.W.2d 573 (N.D. 1998) (prejudgment interest as part of judgment and interest computation principles)
Matter of S.E., 820 N.W.2d 389 (N.D. 2012) (trial court loses jurisdiction upon filing of notice of appeal)
Rath v. Rath, 892 N.W.2d 205 (N.D. 2017) (mandate required to restore jurisdiction to trial court)