North Dakota Supreme Court

State v. Burton

April 24, 20252025 ND 83

Summary

The court affirmed Burton’s domestic-violence conviction, holding that admission of the 911 recording did not violate the Confrontation Clause because the call was directed at addressing an ongoing emergency. The court also held that circumstantial evidence sufficiently authenticated the recording and that Burton failed to show obvious error from its admission under the present-sense-impression hearsay exception.