Background - James Glass and Sandra Glass Lenertz divorced in 1996; the decree required Glass to pay spousal support. - Lenertz remarried in 2002; in 2015 Glass moved to terminate spousal support. - The district court granted termination effective at Lenertz’s remarriage and entered an Amended Judgment awarding Lenertz $26,903.37 as a money judgment. - Glass tendered $26,903.37 conditioned on Lenertz signing a satisfaction; she refused, asserting the amount omitted post-judgment interest and that signing would affect appeal rights. - Glass moved to deposit the funds with the clerk; the district court ruled the $26,903.37 was interest (not principal), post-judgment interest did not accrue, permitted deposit, and ordered full satisfaction. - Lenertz appealed the deposit order; the Supreme Court affirmed under the law-of-the-case doctrine because she could have raised the classification-of-the-judgment issue on her prior appeal of the Amended Judgment. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---|---|---| | Whether the $26,903.37 money judgment is principal (subject to post-judgment interest) or interest (no post-judgment interest) | Lenertz: The Termination Order’s table shows unpaid principal and unpaid interest; the award should be treated as principal and accrue post-judgment interest | Glass: Lenertz failed to raise this issue on her prior appeal; law of the case bars relitigation and the Amended Judgment characterizes the award as interest | Court: Law of the case bars Lenertz from raising the classification now; Amended Judgment controls over any conflicting order, so deposit and satisfaction were proper | ### Key Cases Cited Jundt v. Jurassic Res. Dev., N. Am., L.L.C., 677 N.W.2d 209 (N.D. 2004) (res judicata and law-of-the-case principles explained) Frisk v. Frisk, 719 N.W.2d 332 (N.D. 2006) (describing typical application of law-of-the-case after an appellate decision) Tom Beuchler Constr., Inc. v. City of Williston, 413 N.W.2d 336 (N.D. 1987) (law of the case includes issues decided by trial court but not raised on first appeal) Serr v. Serr, 746 N.W.2d 416 (N.D. 2008) (where a judgment conflicts with an order for judgment, the judgment controls) * Glass v. Glass, 889 N.W.2d 885 (N.D. 2017) (prior appeal affirming the Amended Judgment terminating spousal support)