North Dakota Supreme Court

Gaddie v. State

August 28, 20242024 ND 170

Summary

The court held that the State committed prosecutorial misconduct by knowingly offering evidence that Gaddie had sexually abused the child’s mother without providing the notice and explanation required for prior-act evidence. The misconduct prejudiced Gaddie because the evidence was detailed, highly prejudicial in a sex-related prosecution, and admitted without the required balancing analysis, thereby violating his due process right to a fair trial. The court reversed the denial of postconviction relief and remanded with instructions to vacate the criminal judgment.