North Dakota Supreme Court

Schweitzer v. State

July 18, 20242024 ND 151

Summary

The North Dakota Supreme Court affirmed the district court’s denial of Schweitzer’s post‑conviction petition, holding that he failed to satisfy the Strickland test for ineffective assistance of counsel and that his double‑jeopardy claim was waived by his unconditional guilty plea. The Court emphasized that ineffective‑assistance claims require concrete legal, rule, or evidentiary support, not merely conclusory allegations.