Watford City Lodging LLC v. Miskin, 927 N.W.2d 860

WCL filed an eviction complaint against Miskin alleging nonpayment under an early-occupancy/purchase arrangement; a hearing was noticed for December 11, 2017.
Miskin did not appear at the December 11 hearing; on December 14 the court entered a default eviction judgment restoring possession to WCL.
Miskin moved to vacate the default eviction, arguing the hearing occurred 19 days after summons (outside the 3–15 day statutory window) and summary eviction jurisdiction was lacking.
The district court granted the motion to vacate, concluded the parties had a purchase agreement (not a lease), found WCL breached the purchase agreement, and awarded Miskin potential treble damages for wrongful eviction, restoring him to possession.
WCL moved to amend the vacatur judgment to strike extraneous findings; the district court denied the motion. WCL appealed the denial of its motion to amend.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court exceeded scope of summary eviction by adjudicating contract and damages claims	WCL: Court erred by deciding matters beyond possession; those claims are extraneous and must be litigated separately	Miskin: Court properly considered those matters in ruling on the motion to vacate	Court: District court erred — extraneous contract and wrongful-eviction findings were improper in a summary eviction once eviction was vacated
Whether findings about breach and treble damages were necessary to vacatur	WCL: Findings were unnecessary to possession determination and exceeded statutory limits	Miskin: Findings supported vacatur and relief	Court: Such findings were unnecessary and barred in summary eviction proceedings
Whether counterclaims/damage claims can be resolved in eviction proceeding	WCL: Damages and breach claims must be in separate action; eviction limited to possession/setoff	Miskin: Damages arose from possession dispute and could be addressed	Court: Eviction statute limits issues to possession and limited rent/damage setoffs; separate actions required for other claims
Whether denial of motion to amend judgment was an abuse of discretion	WCL: Denial allowed improper, extraneous findings to stand and the court misapplied the law	Miskin: District court acted within discretion	Court: Denial was an abuse of discretion; appellate court reversed and remanded to vacate specific paragraphs

Werven v. Werven, 877 N.W.2d 9 (N.D. 2016) (standard for reviewing denial of Rule 59/60 motions)
Flaten v. Couture, 912 N.W.2d 330 (N.D. 2018) (use of Rule 59(j) and Rule 60(b) relief described)
Spirit Prop. Mgmt. v. Vondell, 897 N.W.2d 334 (N.D. 2017) (summary eviction is limited to possession issues)
Cheetah Prop. 1, LLC v. Panther Pressure Testers, Inc., 879 N.W.2d 423 (N.D. 2016) (eviction statute strictly limits combining eviction with other claims)
Basin Elec. Power Coop. v. N.D. Workers Comp. Bureau, 541 N.W.2d 685 (N.D. 1996) (statutory time limits may be jurisdictional)