State v. Blunt
2011 ND 127
| N.D. | 2011Background
- Blunt served as Executive Director of Workforce Safety and Insurance from 2004 to 2007, and was charged with two counts of misapplication of entrusted property after a 2006 performance review raised concerns about WSI funds.
- Count I alleged misapplication exceeding $10,000, including gift certificates, meals, gifts, and unrecouped relocation expenses for Spencer, plus related items; Count II alleged misapplication between $500 and $10,000 for illegal bonuses.
- A jury found Blunt guilty on Count I and not guilty on Count II; imposition of sentence was deferred.
- After appeal, the State sought a ruling on alleged discovery violations under Rule 16 and Brady-based due process, and Blunt moved for a new trial or Count I dismissal.
- District court found possible Rule 16/Brady violations but held Blunt was not prejudiced; Blunt challenged the district court’s decision on appeal.
- Disclosures at issue included a Wahl memorandum, Quinn investigation report, and a C99 document with handwritten notes; Blunt also relied on an open-file policy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the State violate Rule 16 by withholding documents? | Blunt | Blunt | Yes, likely violated Rule 16 |
| Was Blunt prejudiced by any discovery violations? | Blunt | Blunt | No substantial prejudice established |
| Should the court have granted a new trial based on discovery violations? | Blunt | Blunt | District court did not abuse discretion; no new trial required |
Key Cases Cited
- State v. Ramstad, 658 N.W.2d 731 (N.D. 2003) (open-file policy does not dilute Rule 16 obligations)
- State v. Sauer, 795 N.W.2d 331 (N.D. 2011) (disclosure duties extend to material from other agencies)
- State v. Addai, 778 N.W.2d 555 (N.D. 2010) (rule 16 remedies discretionary; prejudice standard governs reversal)
- City of Fargo v. Levine, 747 N.W.2d 130 (N.D. 2008) (discretionary sanction decisions must be reasonable and rational)
- State v. Ensminger, 542 N.W.2d 722 (N.D. 1996) (Rule 16 disclosure duties and trial fair process considerations)
- State v. Roerick, 557 N.W.2d 55 (N.D. 1996) (admissibility and procedural safeguards in discovery)