State v. Gores

2025 ND 194
CourtNorth Dakota Supreme Court
DecidedNovember 20, 2025
DocketNo. 20250055
StatusPublished

This text of 2025 ND 194 (State v. Gores) 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
State v. Gores, 2025 ND 194 (N.D. 2025).

Opinion

IN THE SUPREME COURT STATE OF NORTH DAKOTA

2025 ND 194

State of North Dakota, Plaintiff and Appellee v. Patrick Brian Gores, Defendant and Appellant

No. 20250055

Appeal from the District Court of Ward County, North Central Judicial District, the Honorable Douglas L. Mattson, Judge.

AFFIRMED.

Opinion of the Court by Crothers, Justice, in which Chief Justice Jensen and Justices McEvers and Tufte joined. Justice Bahr filed a dissenting opinion.

Tiffany M. Sorgen, Assistant State’s Attorney, Minot, ND, for plaintiff and appellee; on brief.

Kiara C. Kraus-Parr, Grand Forks, ND, for defendant and appellant; on brief. State v. Gores No. 20250055

Crothers, Justice.

[¶1] Patrick Brian Gores appeals from a criminal judgment entered after a bench trial, arguing insufficient evidence supports his convictions. Gores claims insufficient evidence supports his conviction of preventing arrest because he was not informed he was under arrest before officers began to restrain him. He also argues insufficient evidence supports his conviction of domestic violence because he did not willfully cause injury and he was acting in self-defense. We affirm the criminal judgment.

I

[¶2] Gores was charged with preventing arrest, a class A misdemeanor, and domestic violence, a class B misdemeanor. A one-day bench trial was held, and the district court heard testimony from the victim, two officers, and Gores. The court received seven exhibits, namely photographs of the victim and two body camera videos.

[¶3] At the end of the State’s case, Gores moved for acquittal. The district court denied the motion. Gores renewed his motion at the close of the defense’s case. The court took the matter under advisement and later denied the motion by order. The district court found Gores guilty of preventing arrest and domestic violence. Gores was sentenced to 360 days’ imprisonment with all but 125 days suspended for 18 months of supervised probation for preventing arrest and a concurrent 30 days’ imprisonment for domestic violence. Gores appeals.

II

[¶4] Gores argues insufficient evidence supports his convictions because “he did not willfully cause his si[s]ter injury, he was acting in self-defense, and he was never informed he was under arrest when officers began to physically restrain him.”

1 [¶5] “Our standard for reviewing the sufficiency of evidence is the same for both a bench trial and a jury trial.” State v. Nelson, 2023 ND 217, ¶ 5, 997 N.W.2d 849. This Court’s standard for reviewing a sufficiency-of-the-evidence challenge is well established:

When the sufficiency of evidence to support a criminal conviction is challenged, this Court merely reviews the record to determine if there is competent evidence allowing the jury to draw an inference reasonably tending to prove guilt and fairly warranting a conviction. The defendant bears the burden of showing the evidence reveals no reasonable inference of guilt when viewed in the light most favorable to the verdict. When considering insufficiency of the evidence, we will not reweigh conflicting evidence or judge the credibility of witnesses. A jury may find a defendant guilty even though evidence exists which, if believed, could lead to a verdict of not guilty.

State v. Grensteiner, 2024 ND 218, ¶ 9, 14 N.W.3d 587 (cleaned up).

[¶6] Unlike in a jury trial, “[a] defendant does not need to move for judgment of acquittal under N.D.R.Crim.P. 29 at a bench trial to preserve the issue of sufficiency-of-the-evidence for appeal.” State v. Smith, 2024 ND 127, ¶ 4, 9 N.W.3d 683. Here, like in Smith, we refrain from deciding whether a Rule 29 motion made during a bench trial narrows the issues reviewable on appeal because the result would be the same. Id. ¶ 5 (“We do not decide here whether Smith’s Rule 29 motion limits our review of grounds not specified to obvious error because the result here is the same when reviewed for obvious error or sufficiency-of-the-evidence.”).

III

[¶7] Gores argues insufficient evidence supports his conviction of preventing arrest because he was not told he was under arrest before officers began restraining him. Gores argues the officers acted unlawfully because they failed to inform him of his arrest as required by N.D.C.C. § 29-06-17. The State relies on an exception in N.D.C.C. § 29-06-17, arguing officers did not have time to inform him of his arrest before he resisted.

2 [¶8] Gores was convicted of preventing an officer “from effecting an arrest,” a class A misdemeanor under N.D.C.C. § 12.1-08-02(1). Section 12.1-08-02, N.D.C.C., provides:

1. A person is guilty of a class A misdemeanor if, with intent to prevent a public servant from effecting an arrest of himself or another for a misdemeanor or infraction, or from discharging any other official duty, he creates a substantial risk of bodily injury to the public servant or to anyone except himself, or employs means justifying or requiring substantial force to overcome resistance to effecting the arrest or the discharge of the duty. A person is guilty of a class C felony if, with intent to prevent a public servant from effecting an arrest of himself or another for a class A, B, or C felony, he creates a substantial risk of bodily injury to the public servant or to anyone except himself, or employs means justifying or requiring substantial force to overcome resistance to effecting such an arrest. 2. It is a defense to a prosecution under this section that the public servant was not acting lawfully, but it is no defense that the defendant mistakenly believed that the public servant was not acting lawfully. A public servant executing a warrant or other process in good faith and under color of law shall be deemed to be acting lawfully.

[¶9] Section 29-06-17, N.D.C.C., states:

When making an arrest without a warrant, the officer shall inform the person to be arrested of the officer’s authority and the cause of the arrest, unless: 1. The person to be arrested then is engaged in the commission of an offense; 2. Such person is pursued immediately after the commission of an offense or after an escape; 3. Such person flees or forcibly resists before the officer has opportunity so to inform the person; or 4. The giving of such information will imperil the arrest.

[¶10] Officer Sullivan testified regarding the arrest:

Mr. Gores, when we told him to stand up, he stated he was not going to jail and forcefully, like, sat down in the chair. I grabbed Mr. Gores’ left arm. Ofc. Shaide grabbed his right arm and pulled him out of

3 the chair. He was still resisting, he wouldn’t put his hands behind his back. He was still trying to pull away from us. Ofc. Shaide took him to the ground. He then trapped his arms underneath his chest and he wouldn’t pull them out. I pulled his right arm out moving his wrist outwards. And put a handcuff on it and put it behind his back and Ofc. Shaide was able to handcuff the other arm . . . with a different set of handcuffs.

[¶11] Officer Sullivan’s body camera video was entered into evidence. The video shows Officer Shaide walk towards Gores and speak to him. Gores was sitting in a chair near the corner of the room. Gores initially stood up, but immediately placed his hands in his pockets. Gores began digging around in his pockets. Shaide asked him to step closer to him, but Gores said, “nope.” Gores then stated multiple times, “not going to jail” and sat down in his chair. Shaide said, “don’t put your hands in your pockets,” and quickly grabbed Gores’s arms to restrain him.

[¶12] On cross-examination, Sullivan testified they had consent to enter the home. He also testified the force used to arrest Gores was reasonable.

[¶13] Shaide testified he advised Gores of the fact he was going to be placed under arrest.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 ND 194, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-gores-nd-2025.