State v. Horn, 2014 ND 230

Horn was charged with three counts of burglary at three Burleigh County bars.
Evidence linked Horn to the burglaries via size 13 Nike shoe prints and pry marks; burglary tools were found in his vehicle.
A records custodian from Prairie Knights Casino testified to foundation for casino records.
Horn moved to dismiss for Rule 16 discovery violation; district court denied.
Horn challenged Brady disclosure and later argued the evidence was insufficient; jury found him guilty on all counts; the district court judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
preservation and obvious error under Rule 16	Horn contends Rule 16 violated by not giving the actual name.	Horn argues an obvious error occurred affecting substantial rights.	No preserved error; but no obvious error.
Brady violation	State failed to disclose a favorable witness name, violating Brady.	Disclosing job title suffices; no Brady violation.	No Brady violation.
Sufficiency of the evidence	Evidence was insufficient to prove Horn’s involvement beyond a reasonable doubt.	Circumstantial evidence and motive supported guilt.	Sufficient evidence supports verdict.

State v. Roerick, 557 N.W.2d 55 (N.D. 1996) (Rule 16 discovery standards—prompt disclosure expected)
State v. Thorson, 2003 ND 76 (N.D. 2003) (obvious error standard for undisposed rights despite Rules)
State v. Doppler, 2013 ND 54 (N.D. 2013) (obvious error review when not preserved)
State v. Lince, 490 N.W.2d 476 (N.D. 1992) (pretrial disclosure affecting cross-examination rights)
State v. Muhle, 2007 ND 132 (N.D. 2007) (Brady framework and materiality standard)
State v. Goulet, 1999 ND 80 (N.D. 1999) (Brady materials must be plainly exculpatory)
State v. Steffes, 500 N.W.2d 608 (N.D. 1993) (Rule 16 material may be alleged as exculpatory)
State v. Miller, 2001 ND 132 (N.D. 2001) (obvious error standard and substantial rights)
State v. Sabo, 2007 ND 193 (N.D. 2007) (circumstantial evidence sufficiency standard)