State v. Davis
2016 ND 145
| N.D. | 2016Background
- In 2011 Davis was charged with murder and vehicle theft; he pleaded not guilty by reason of lack of criminal responsibility and was committed to the North Dakota State Hospital after being diagnosed with paranoid schizophrenia.
- The district court (2012) found Davis mentally ill and a substantial risk to commit violent acts but allowed conditional release later when supervision and treatment were deemed sufficient (2013 order providing conditional release with medication monitoring and DHS supervision).
- Annual treatment reports (2013–2015) and an independent evaluation reported Davis was stable, medication-compliant, employed, and in remission; both expert witnesses at the 2015 hearing testified there was not a present substantial risk Davis would commit a crime if discharged.
- Davis moved for discharge under N.D.C.C. § 12.1-04.1-25(5)(a) in 2015; the district court found Davis remains mentally ill and needs medication monitoring and psychotherapy, found no present substantial risk of violent crime but continued the conditional release to ensure medication compliance.
- Davis appealed, arguing the statute required discharge under subdivision (a) because the preponderance of evidence showed no substantial risk of any criminal act from his mental illness; the State defended the court’s authority to continue conditional release under subdivision (b).
- The Supreme Court affirmed: it held the statute is unambiguous, the district court’s factual findings (that Davis remains mentally ill, needs monitoring, and that risk increases if medications stop) were not clearly erroneous, and continuation under § 12.1-04.1-25(5)(b) was permissible.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court was required to discharge Davis under N.D.C.C. § 12.1-04.1-25(5)(a) | State: district court properly applied statute and could continue conditional release under (b) to protect society | Davis: evidence by preponderance shows no substantial risk of any criminal act; statute mandates discharge under (a) | Court: affirmed district court — findings support application of (b), not mandatory discharge under (a) |
| Standard of review for district court factual findings under §12.1-04.1-25(5) | State: factual findings reviewed for clear error | Davis: same but argues court misapplied statutory test and weighed past risks over present evidence | Court: applied clearly erroneous standard and concluded facts were supported; district court did not clearly err |
Key Cases Cited
- State v. Nording, 485 N.W.2d 781 (N.D. 1992) (articulating purposes of the Criminal Responsibility and Post-Trial Responsibility Act)
- Rasnic v. ConocoPhillips Co., 854 N.W.2d 659 (N.D. 2014) (statutory interpretation principles; give words plain meaning and harmonize related provisions)
- State v. Holbach, 842 N.W.2d 328 (N.D. 2014) (applying clearly erroneous standard to review factual findings in mental-competency context)
- Brandt v. Brandt, 523 N.W.2d 264 (N.D. 1994) (trial court may assign weight to expert testimony and need not accept it as conclusive)
- Stillwell v. Cincinnati Inc., 336 N.W.2d 618 (N.D. 1983) (trier of fact need not accept undisputed expert opinion; weight and credibility are factual questions)