N.D. Cent. Code § 30.1-21-06 (2025)
Unless previously adjudicated in a formal testacy proceeding or in a proceeding settling the accounts of a personal representative or unless otherwise barred, the claim of any claimant to recover from a distributee who is liable to pay the claim, and the right of any heir or devisee, or of a successor personal representative acting in their behalf, to recover property improperly distributed or the value thereof from any distributee is forever barred at the later of:
2. One year after the time of distribution thereof.
This section does not bar an action to recover property or value received as the result of fraud.