State v. Nelson, 997 N.W.2d 849

Carolyn Nelson was president of the Oberon School Board; the board contracted with Laura Schnieber-Bruns / Victim Survivor the Voice, LLC for investigative/management services.
The written agreement listed large set‑up and ongoing management fees and an hourly rate; Schnieber‑Bruns was later charged with and pled guilty (Alford plea) to class A felony theft for taking over $150,000 under that agreement.
The State charged Nelson as an accomplice to theft, presenting evidence that Nelson frequently requested large, poorly‑described payments to Schnieber‑Bruns before board approval and instructed payments be made directly to Schnieber‑Bruns’ account.
The school business manager testified Nelson dismissed concerns about unauthorized payments and was ‘‘pretty much in charge,’’ and many invoices lacked detail for the large sums billed.
Nelson admitted receiving money from Schnieber‑Bruns (including at a casino) and that Schnieber‑Bruns loaned her daughter money; Nelson claimed payments were ultimately approved and funds she received were for school purchases.
After a bench trial the district court denied Nelson’s motion for acquittal, found her guilty of accomplice to theft, and sentenced her to ten years with most suspended; Nelson appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to convict Nelson as an accomplice to theft	Evidence showed Nelson knowingly aided the theft: instructed early payments, controlled vendor relationship, accepted money, and approved vague invoices	No evidence Nelson knew invoices were fraudulent or intentionally caused the theft; acquittal justified	Conviction affirmed; viewing evidence in the light most favorable to the verdict, competent evidence supported guilt
Whether unpreserved claims (incognizable offense, civil‑dispute doctrine, school board member as victim) warrant review under obvious‑error	State argues issues were not preserved below and Nelson failed to show obvious error	Nelson argues these issues undermine the conviction and should be considered despite not being raised below	Court declined to consider them—Nelson failed to raise these in district court, did not brief obvious‑error standard, and gave no meaningful analysis at argument
Denial of motion for acquittal at close of State’s case	State contends evidence presented sufficed to deny acquittal and go to verdict	Nelson argued no evidence of knowledge or intent to aid theft, meriting acquittal	Denial affirmed; the record permitted reasonable inferences of Nelson’s culpability

City of Napoleon v. Kuhn, 860 N.W.2d 460 (2015) (bench and jury sufficiency review standard is the same)
State v. Romero, 830 N.W.2d 586 (2013) (describes the standard for reviewing sufficiency of the evidence)
State v. Landrus, 974 N.W.2d 676 (2022) (requirements for invoking obvious‑error review)