Sanderson v. Cole

2026 ND 16
CourtNorth Dakota Supreme Court
DecidedJanuary 29, 2026
DocketNo. 20250288
StatusPublished
AuthorCrothers, Daniel John

This text of 2026 ND 16 (Sanderson v. Cole) 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
Sanderson v. Cole, 2026 ND 16 (N.D. 2026).

Opinion

IN THE SUPREME COURT STATE OF NORTH DAKOTA

2026 ND 16

Mitchell S. Sanderson, Plaintiff and Appellant v. Kelley Cole, Defendant and Appellee

No. 20250288

Appeal from the District Court of Walsh County, Northeast Judicial District, the Honorable Donovan J. Foughty, Judge.

AFFIRMED.

Opinion of the Court by Crothers, Justice.

Mitchell S. Sanderson, Park River, ND, plaintiff and appellant; on brief.

Daniel L. Gaustad, Joseph E. Quinn, Jaxen Bratcher, Grand Forks, ND, for defendant and appellee; on brief. Sanderson v. Cole No. 20250288

Crothers, Justice.

[¶1] Mitchell S. Sanderson appeals from a district court judgment dismissing his complaint against Walsh County State’s Attorney, Kelley Cole, and awarding Cole attorney’s fees. Sanderson argues the district court lacked subject matter jurisdiction because he did not file the complaint, and lacked personal jurisdiction because Cole failed to comply with N.D.R.Civ.P. 5(d)(2)(A)(ii) by filing the complaint without serving notice on Sanderson. He argues the court erred by dismissing his case as frivolous under N.D.R.Civ.P. 12(b)(6), and misapplying prosecutorial immunity to an investigative or administrative act. He further argues the court abused its discretion by dismissing the complaint without a hearing on the motion to dismiss. Sanderson also argues the court erred by awarding attorney’s fees under N.D.C.C. § 28-26-01(2). Sanderson also asserts several due process violations, arguing the court did not follow procedural rules. Sanderson seeks reassignment on remand under N.D. Code Jud. Conduct 2.11, and argues Cole violated the rules of professional conduct. We affirm the judgment.

I

[¶2] On February 24, 2025, Sanderson commenced this action by serving Cole with a copy of the summons and complaint. On March 17, 2025, Cole filed the summons and complaint with the district court. On the same day, Cole filed a motion to dismiss under N.D.R.Civ.P. 12(b)(6) and requested attorney’s fees due to the alleged frivolous nature of the complaint. Cole filed a declaration of service of the notice and motion to dismiss. Cole filed and served an answer to Sanderson’s complaint on March 21, 2025.

[¶3] On March 28, 2025, Sanderson filed a response to the motion to dismiss titled “Stipulation to Dismiss,” stating, “Sanderson agrees to dismiss[.]” The “stipulation” did not contain Cole’s signature. Cole and the district court treated Sanderson’s “stipulation” as a response brief to the motion to dismiss. Sanderson’s filing explained:

1 Sanderson inadvertently served this complaint on the Defendant. Sanderson obviously printed off a complaint by mistake in haste and mistakenly filed the wrong papers on the Defendant. It was in the Draft stage and never intended to be mailed to the Defendant. It is a correctible mistake and Sanderson apologizes to the Court and Defendant. . . . . If Sanderson had completed the Draft Sanderson would have evidence to the fact that laws were not enforced in Walsh and violations of law by government officials did exist and Defendant was made aware of them and she ignored State law by not investigating them and by doing so no charges were filed on the Government actors for violations of said laws. Sanderson did not file the case with the Court—the Defendant did! Sanderson cannot be liable for the actions of the Defendant when they have no idea if Sanderson ever intended to actually file this case with the Court or see if the Defendant would collaborate to settle out of Court. That is what the 21-day rule allows for. The Defendant has filed for a dismissal so Sanderson agrees to dismiss due to a correctable error.

(Emphasis in original.)

[¶4] On April 2, 2025, Cole filed a reply in support of the motion to dismiss, arguing Sanderson intended to serve the summons and complaint because he signed the summons and complaint and then delivered the signed documents to a third party for service on Cole. On April 16, 2025, Sanderson filed a reply brief titled “Reply/Response/Opposition to State[’]s Motion to Dismiss” with supporting exhibits, and requested a hearing.

[¶5] On April 17, 2025, the district court granted the motion to dismiss and awarded attorney’s fees and costs. Cole filed and served a declaration of attorney’s fees and costs on April 18, 2025. Sanderson did not object or respond to the declaration of fees and costs. The court awarded $3,927 in costs and fees.

[¶6] Before judgment was entered, Sanderson filed a “Motion for Void Judgment” and “Motion for Discovery” and requested a hearing on both motions. Cole responded to both motions and requested attorney’s fees and costs incurred to respond to both motions. The district court held a hearing on the motions on June 9, 2025. Sanderson filed a post-hearing brief. The court denied

2 the motion for void judgment and motion for discovery, and awarded Cole attorney’s fees and costs. Cole filed a declaration and account of attorney’s fees. Sanderson did not object or respond to the amount Cole requested. The court awarded Cole $3,779 in additional attorney’s fees and costs. Judgment was entered dismissing Sanderson’s complaint against Cole, and awarding Cole $7,706 in attorney’s fees and costs. Sanderson appeals.

II

[¶7] Sanderson claims the district court lacked jurisdiction to dismiss the complaint. He argues under federal law only the plaintiff can file the complaint, and Sanderson did not file the complaint. He also argues the court lacked jurisdiction because Cole filed the complaint without serving notice of filing as required by N.D.R.Civ.P. 5(d)(2)(A)(ii). We disagree.

[¶8] Sanderson’s reliance on the federal rules of civil procedure is misplaced. Sanderson commenced this action in state court, not federal court. North Dakota’s rule differs from the federal rule that requires filing of a complaint to commence an action. Fed.R.Civ.P. 3 (“A civil action is commenced by filing a complaint with the court.”); Hughes v. Olheiser Masonry, Inc., 2019 ND 273, ¶ 6, 935 N.W.2d 530 (same). Under the North Dakota Rules of Civil Procedure, “[a] civil action is commenced by the service of a summons.” N.D.R.Civ.P. 3. North Dakota rules allow the defendant to file the complaint in district court. N.D.R.Civ.P. 5(d)(2)(A)(iv) (“The defendant may file the summons and complaint[.]”). Cole filed the summons and complaint as permitted by Rule 5. The district court had subject matter jurisdiction.

[¶9] Sanderson argues the district court lacked personal jurisdiction. “Valid service of process is necessary to assert personal jurisdiction over a defendant.” Cache Priv. Cap. Diversified Fund LLC v. Braddock, 2025 ND 168, ¶ 10, 26 N.W.3d 688 (citation omitted). A district court “may acquire personal jurisdiction over any person through service of process as provided in this rule or by statute, or by voluntary general appearance in an action by any person either personally or through an attorney or any other authorized person.” N.D.R.Civ.P. 4(b)(4). “A party must strictly comply with the specific requirements for service of process.”

3 Baker v. Erickson, 2022 ND 137, ¶ 11, 977 N.W.2d 316 (quoting Sanderson v. Walsh Cnty., 2006 ND 83, ¶ 13, 712 N.W.2d 842). “Absent valid service of process, even actual knowledge of the existence of a lawsuit is insufficient to effectuate personal jurisdiction over a defendant.” Id. (quoting Sanderson v. Walsh Cnty., ¶ 13).

[¶10] Sanderson admits he served the summons and complaint on Cole on February 24, 2025, thereby commencing this action.

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Cite This Page — Counsel Stack

Bluebook (online)
2026 ND 16, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanderson-v-cole-nd-2026.