North Dakota Supreme Court
State v. Bell
December 4, 20252025 ND 201
Summary
The court held that the statutory provisions governing implied-consent testing and testing after crashes involving serious injury or death must be read together, rather than treating the crash-testing provision as exclusive. It further held that an accurate implied-consent advisory is not per se coercive and that Bell's consent must be evaluated under the totality of the circumstances. The suppression order was reversed and the case remanded for additional findings under the correct legal framework.