State v. Lafromboise, 959 N.W.2d 596

Travis Lafromboise was charged in Dec 2019 with burglary and criminal mischief while he was incarcerated on another matter; he filed a Detainers Act request for final disposition on April 13, 2020 (triggering a 90‑day period ending July 12, 2020).
The district court issued a writ to bring him to Cass County on June 15, 2020 and scheduled an arraignment for June 16; Lafromboise was not transported and his counsel (with his assent) requested a continuance because he refused remote participation.
Lafromboise was paroled July 16 and arraigned electronically July 17; he posted bond and was released.
On July 21 the State moved to schedule trial or obtain a good‑cause extension; Lafromboise moved to dismiss with prejudice arguing the 90‑day Detainers Act period had run and the court lost jurisdiction.
On August 17 the district court denied dismissal and granted a 30‑day continuance, finding good cause based on the COVID‑19 pandemic; Lafromboise conditionally pled guilty and reserved the right to appeal the dismissal ruling.
The Supreme Court reviewed whether the Detainers Act 90‑day deadline had been tolled by N.D. Sup. Ct. Admin. Order 25 (which directed that the period March 16–July 1, 2020 be deducted for cases where a continuance was granted during the pandemic).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in denying Lafromboise’s motion to dismiss under N.D.C.C. § 29‑33‑03 after the 90‑day period expired	State: court may grant a continuance for good cause (COVID‑19) and denial of dismissal was proper	Lafromboise: no continuance or good‑cause finding occurred within 90 days (by July 12), so court lost jurisdiction and dismissal with prejudice was required	Affirmed: denial upheld, but not on district court’s § 29‑33‑03 good‑cause reasoning (court’s rationale was legally incorrect)
Whether N.D. Sup. Ct. Admin. Order 25 tolled the Detainers Act 90‑day period (March 16–July 1, 2020 deduction) so that the June 16 continuance satisfied the tolling requirement	State: Admin. Order 25 automatically deducts March 16–July 1 when a continuance is granted, so the 90‑day clock was tolled and prosecution remained viable	Lafromboise: Detainers Act is distinct from speedy‑trial rules and Admin. Order 25 cannot be applied to detainers to avoid dismissal	Held: Admin. Order 25 tolled the period as a matter of law; after the June 16 continuance the 90‑day period was tolled and dismissal was not required

State v. Hinojosa, 798 N.W.2d 634 (N.D. 2011) (interpreting Detainers Act’s 90‑day rule and continuance for good cause)
State v. Moe, 581 N.W.2d 468 (N.D. 1998) (background on detainer proceedings applicability)
State v. Olsen, 540 N.W.2d 149 (N.D. 1995) (recognizing court discretion to grant continuances under the Detainers Act)
State v. Fulks, 566 N.W.2d 418 (N.D. 1997) (defendant‑caused delay can preclude relief under the Detainers Act)
State v. Mondragon, 937 N.W.2d 531 (N.D. 2020) (referring to the 90‑day statutory right under N.D.C.C. § 29‑33‑03)
Investors Title Ins. Co. v. Herzig, 788 N.W.2d 312 (N.D. 2010) (appellate principle: correct result affirmed even if district court’s reasoning was wrong)
Stanley v. Superior Court of Contra Costa County, 263 Cal. Rptr. 3d 735 (Cal. Ct. App. 2020) (COVID‑19 supported finding of good cause to continue trial past speedy‑trial limits)