State v. Lais

Summary

The North Dakota Supreme Court summarily affirmed Shantel Rose Lais’s criminal judgment after she conditionally pleaded guilty to child neglect and unlawful possession of drug paraphernalia. Relying on its decision in State v. Golberg, the court held that the prior ruling was dispositive of Lais’s Fourth Amendment challenge to the denial of her motion to suppress evidence.

Holdings

1. The district court did not err in refusing to suppress the evidence because, under the controlling reasoning of State v. Golberg, Lais had no reasonable expectation of privacy in the area entered by law enforcement.

Questions Presented

1. Whether the district court erred by denying Lais's motion to suppress evidence on the ground that law enforcement illegally entered an area in which she had a reasonable expectation of privacy under the Fourth Amendment.

Disposition

affirmed