North Dakota Supreme Court

State v. Watts

August 1, 20242024 ND 158

Summary

The Court affirmed Watts's convictions, concluding he failed to establish obvious error in the jury's definition of "family or household member," the evidence was sufficient to support the child-neglect conviction, and the prosecutor's questions about his statements did not constitute obvious error. The Court declined to resolve whether the statements were made before or after arrest or Miranda warnings because Watts neither sought suppression nor developed the factual and legal record below or on appeal. The judgment was remanded only to correct a clerical error stating the convictions were based on guilty pleas rather than a jury verdict.