Meiers v. NDDOT

2025 ND 21
CourtNorth Dakota Supreme Court
DecidedJanuary 23, 2025
DocketNo. 20240215
StatusPublished
Cited by5 cases

This text of 2025 ND 21 (Meiers v. NDDOT) is published on Counsel Stack Legal Research, covering North Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Meiers v. NDDOT, 2025 ND 21 (N.D. 2025).

Opinion

IN THE SUPREME COURT STATE OF NORTH DAKOTA

2025 ND 21

Lee Richard Meiers, Appellee v. North Dakota Department of Transportation, Appellant

No. 20240215

Appeal from the District Court of Mountrail County, North Central Judicial District, the Honorable Stacy J. Louser, Judge.

REVERSED.

Opinion of the Court by Bahr, Justice.

Chad R. McCabe, Bismarck, ND, for appellee.

Michael T. Pitcher, Assistant Attorney General, Bismarck, ND, for appellant. Meiers v. NDDOT No. 20240215

Bahr, Justice.

[¶1] The North Dakota Department of Transportation appeals from a district court judgment reversing the hearing officer’s decision suspending Lee Meiers’s driving privileges. On appeal, the Department argues it had authority to suspend Meiers’s driving privileges. We reverse the district court’s judgment and reinstate the Department’s decision suspending Meiers’s driving privileges.

I

[¶2] On December 19, 2023, a law enforcement officer arrested Meiers for driving under the influence. Following the arrest, the officer read Meiers the implied consent advisory and requested Meiers take a chemical breath test. Meiers consented to take the breath test, which the officer conducted. The breath test showed Meiers had an alcohol concentration above the legal limit for driving.

[¶3] The officer completed and certified a report and notice form. The report and notice form is a one-page document completed by an officer. The report and notice form documents information about the arrest, including whether a specimen for a chemical test was obtained, when it was obtained, and the test result. Above the space for the officer’s signature, the report and notice form reads, “I personally certify as a law enforcement officer that this written report is true and correct to the best of my knowledge at the time of completing this report.”

[¶4] The officer printed the test record and checklist. The test record and checklist is a one-page document the Intoxilyzer machine prints at the end of a chemical breath test. The following language precedes the operator’s signature line on the test record and checklist: “I followed the Approved Method and the instructions displayed by the Intoxilyzer in conducting this test.” The officer signed the test record and checklist. The officer gave to Meiers the driver’s copy of the report and notice form and a copy of the signed test record and checklist. The officer then forwarded to the Department a copy of the certified report and

1 notice form and a copy of the signed test record and checklist. The officer did not certify the test record and checklist before forwarding it to the Department. The certification language absent from the test record and checklist certifies the undersigned has custody of the original public record, that the document is a true and correct copy of the original document, and that it is maintained as part of the office’s activities.

[¶5] Meiers requested an administrative hearing. At the hearing, after the officer testified to the test record and checklist’s authenticity, the Department offered the uncertified test record and checklist into evidence. Meiers objected, arguing the test record and checklist was not certified under N.D.C.C. § 39-20- 03.1 and thus the Department lacked authority to suspend his driving privileges. The hearing officer overruled the objection and admitted the test record and checklist into evidence. At the end of the hearing, Meiers renewed his objection to the admission of the test record and checklist due to it not being certified. The hearing officer concluded the test result and checklist was admissible and the Department had authority to suspend Meiers’s driving privileges. The hearing officer suspended Meiers’s driving privileges for 180 days.

[¶6] Meiers appealed to the district court. The court reversed the hearing officer’s decision. The court concluded a certified copy of the test record and checklist was required to invoke the Department’s authority and, because the test record and checklist was not certified, the Department did not have authority to suspend Meiers’s driving privileges.

II

[¶7] “The Administrative Agencies Practice Act, N.D.C.C. ch. 28-32, governs our review of an administrative decision to suspend or revoke a driver’s license.” Schock v. N.D. Dep’t of Transp., 2012 ND 77, ¶ 11, 815 N.W.2d 255. In reviewing an administrative decision, “[w]e review the Department’s original decision, giving deference to its findings of fact and reviewing its legal conclusions de novo.” Goff v. Panos, 2022 ND 186, ¶ 6, 981 N.W.2d 909. This Court must affirm the Department’s decision unless it determines a statutory ground for reversal is present. N.D.C.C. § 28-32-46; N.D.C.C. § 28-32-49 (“The judgment of the district

2 court in an appeal from an order . . . of an administrative agency or the commission may be reviewed in the supreme court on appeal in the same manner as provided in section 28-32-46[.]”). One ground for reversal is if the Department’s order “is not in accordance with the law.” N.D.C.C. § 28-32-46(1). The issue here is whether the hearing officer’s decision the Department had authority to suspend Meiers’s driving privileges is in accordance with the law. Kirkpatrick v. N.D. Dep’t of Transp., 2023 ND 190, ¶ 8, 996 N.W.2d 640. That is a question of law we review de novo. Koenig v. N.D. Dep’t of Transp., 2005 ND 95, ¶ 9, 696 N.W.2d 534.

III

[¶8] The Department argues it had authority under N.D.C.C. § 39-20-04.1 to suspend Meiers’s driving privileges because the officer’s certification of the test record and checklist is not a basic and mandatory provision of the law that must be met for the Department to have authority to suspend a person’s driving privileges.

A

[¶9] In Kirkpatrick, 2023 ND 190, ¶¶ 10-12, this Court explained the difference between “jurisdiction” and “authority.” We explained the Department has jurisdiction to suspend a person’s driving privileges under N.D.C.C. ch. 39-20. Id. ¶¶ 12-13. However, it only has authority to suspend a person’s driving privileges when its jurisdiction is invoked by basic and mandatory statutory requirements being met. Id.

[¶10] Over the years, this Court has repeatedly used the phrase “basic and mandatory provisions” or “basic and mandatory statutory requirements” when determining whether the Department has authority to suspend driving privileges. See, e.g., Christiansen v. Panos, 2022 ND 27, ¶ 7, 969 N.W.2d 709 (“This Court has addressed questions related to the Department’s authority to suspend driving privileges by analyzing whether the statutory provisions at issue were ‘basic and mandatory.’”); Haynes v. Dir., Dep’t of Transp., 2014 ND 161, ¶ 8, 851 N.W.2d 172 (“The Department’s authority to revoke or suspend a person’s driving privileges is given by statute, and the Department must meet the basic

3 and mandatory provisions of the statute to have authority to revoke or suspend a person’s driving privileges.”); Schock, 2012 ND 77, ¶ 33 (“[W]e have held the Department’s failure to strictly comply with other statutory provisions did not deprive the Department of authority to suspend driving privileges when the statutory provision was not a basic and mandatory provision requiring compliance.”); Aamodt v. N.D. Dep’t of Transp., 2004 ND 134, ¶ 15, 682 N.W.2d 308 (“The Department’s authority to suspend a person’s license is given by statute and is dependent upon the terms of the statute. The Department must meet the basic and mandatory provisions of the statute to have authority to suspend a person’s driving privileges.”). Today we clarify what we mean by “basic and mandatory provisions.” In doing so, we do not decide whether past cases meet the standard articulated today.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 ND 21, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meiers-v-nddot-nd-2025.