State v. G.C.H., 934 N.W.2d 857

Defendant G.C.H. was charged in district court with five crimes allegedly committed when he was 16–17 years old.
G.C.H. was married at the time of the alleged offenses and remains married; he moved to dismiss for lack of subject‑matter jurisdiction, arguing juvenile court has exclusive jurisdiction.
The district court denied dismissal on the ground marriage made him an adult, then certified the legal question whether a married person under 18 is a “child” under N.D.C.C. § 27‑20‑02(4)(b).
The Supreme Court declined to answer the certified question because the answer would not wholly or principally dispose of the case, but it exercised supervisory jurisdiction due to time sensitivity (juvenile jurisdiction ends at age 20).
The Court interpreted § 27‑20‑02(4)(b) as an independent, three‑prong test (under 20 at filing; alleged delinquent act; act committed while under 18) and concluded G.C.H. met all prongs.
Holding: district court lacked subject‑matter jurisdiction; the Supreme Court reversed, directed vacatur of the judgment, and ordered dismissal so the State may pursue juvenile proceedings.

Issue	Plaintiff's Argument (State)	Defendant's Argument (G.C.H.)	Held
Whether the certified question should be answered by the Supreme Court	Did not oppose certification	Certification appropriate and dispositive (jurisdiction only)	Court declined to answer — question not wholly dispositive of proceedings
Whether a married minor is a “child” under N.D.C.C. § 27‑20‑02(4)(b) so juvenile court has exclusive jurisdiction	Marriage renders minor an adult under § 27‑20‑02(4)(a); (b) does not apply to married persons	Subsection (b) is independent; marriage is not an exclusion and a person under 20 who committed delinquent acts under 18 is a “child”	Court held (b) is independent and applies; G.C.H. met its three prongs; district court lacked jurisdiction; judgment vacated and case dismissed

Gelinske v. Farmers Grain & Trading Co., 446 N.W.2d 261 (N.D. 1989) (certified questions must wholly or principally dispose of the case to be answered)
State v. Brown, 771 N.W.2d 267 (N.D. 2009) (statutory‑interpretation principles and looking to plain language first)
Industrial Contractors, Inc. v. Workforce Safety & Ins., 772 N.W.2d 582 (N.D. 2009) ("or" is disjunctive; indicates alternatives)
State v. Haskell, 621 N.W.2d 358 (N.D. 2001) (scope of Supreme Court supervisory writs)
Braaten v. Deere & Co., 547 N.W.2d 751 (N.D. 1996) (certified‑question doctrine and limits on advisory opinions)