State v. Jaeger

Summary

The North Dakota Supreme Court affirmed the district court’s correction of a clerical error in Jaeger’s probation revocation order and held that the failure to appoint counsel for the Rule 36 motion did not violate Jaeger’s constitutional right to counsel because probation revocation is not a critical stage of prosecution. The Court reasoned that Rule 36 permits correction of non‑onerous clerical errors and that the district court acted within its discretion.