State of North Dakota v. Madison Dearinger

Summary

The North Dakota Supreme Court reversed the dismissal of a felony hindering-law-enforcement charge against Madison Dearinger. The court held that the evidence presented at the preliminary hearing established probable cause to believe Dearinger knew of conduct by another that could constitute class B felony burglary, supporting the felony enhancement under N.D.C.C. § 12.1-08-03. The court emphasized that probable cause at a preliminary hearing is a minimal standard and that factual inferences must favor the prosecution.

Holdings

1. The State established probable cause to believe that Madison Dearinger knew of conduct by Adam Dearinger that could constitute class B felony burglary, satisfying the felony-enhancement requirement of N.D.C.C. § 12.1-08-03(2)(a).
2. The district court erred in dismissing the felony hindering-law-enforcement charge because the evidence was sufficient to establish probable cause.

Questions Presented

1. Whether the evidence at the preliminary hearing established probable cause to believe Madison Dearinger committed hindering law enforcement under N.D.C.C. § 12.1-08-03.
2. Whether the evidence established probable cause to believe that Dearinger knew of conduct by another constituting a class AA, class A, or class B felony, thereby supporting the felony enhancement for hindering law enforcement.

Disposition

reversed