State v. Kennedy

2025 ND 130
CourtNorth Dakota Supreme Court
DecidedJuly 17, 2025
DocketNo. 20240346
StatusPublished
Cited by2 cases

This text of 2025 ND 130 (State v. Kennedy) 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. Kennedy, 2025 ND 130 (N.D. 2025).

Opinion

IN THE SUPREME COURT STATE OF NORTH DAKOTA

2025 ND 130

State of North Dakota, Plaintiff and Appellee v. Kamauri Siede Kennedy, Defendant and Appellant

No. 20240346

Appeal from the District Court of Ward County, North Central Judicial District, the Honorable Gary H. Lee, Judge.

AFFIRMED.

Opinion of the Court by Bahr, Justice.

John M. Gonzalez (argued), Special Assistant State’s Attorney, Jamestown, ND, and Tiffany M. Sorgen (on brief), Assistant State’s Attorney, Minot, ND, for plaintiff and appellee.

Kiara C. Kraus-Parr, Grand Forks, ND, for defendant and appellant. State v. Kennedy No. 20240346

Bahr, Justice.

[¶1] Kamauri Kennedy appeals a criminal judgment entered following a jury verdict finding him guilty of murder. On appeal, Kennedy argues the district court erred by failing to exclude prior bad acts evidence, the State committed prosecutorial misconduct in its closing argument, and the court abused its discretion in denying Kennedy’s request for alternate counsel. We affirm.

I

[¶2] In July 2021, the State charged Kennedy with murder and conspiracy to commit murder, both class AA felonies.

[¶3] The district court scheduled a jury trial for April 3, 2024. On March 21, 2024, two weeks before trial, Kennedy’s counsel, William Skees, filed a motion to withdraw for non-payment of legal fees. The State opposed the motion. Kennedy requested a new lawyer be appointed to his case. After a hearing, the court denied Skees’s motion to withdraw and Kennedy’s request for a new lawyer.

[¶4] After commencing the trial on April 3, 2024, the district court continued the trial due to “late-discovered evidence that needs to be investigated.” A new trial was set for September 18, 2024. On September 2, 2024, Skees filed another motion to withdraw from representation because he was winding down his legal practice. During a status conference, the State opposed the motion. The court denied the motion.

[¶5] Kennedy proceeded to trial on September 18, 2024. At the close of trial, Kennedy made a motion for acquittal on both the murder charge and the conspiracy to commit murder charge. The district court granted the motion on the conspiracy to commit murder charge. The jury returned a guilty verdict on the murder charge. The court sentenced Kennedy to life without parole.

1 II

[¶6] Kennedy argues the district court erred by failing to exclude prior bad acts evidence. He asserts the evidence was introduced without proper notice under N.D.R.Ev. 404(b)(3). He further asserts the court did not perform the three-step analysis required under N.D.R.Ev. 404(b). See State v. Villazana, 2024 ND 211, ¶ 13, 14 N.W.3d 76 (discussing three-step analysis to determine whether the evidence of other crimes, wrongs, or acts is admissible). Finally, Kennedy asserts the court failed to conduct the balancing test under N.D.R.Ev. 403. See id. ¶ 21 (“Under Rule 403, relevant evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting of time, or needlessly presenting cumulative evidence.”). Kennedy concedes he did not object to the introduction of the evidence and requests this Court review the admission of the evidence under obvious error.

A

[¶7] “[I]ssues not raised at trial will not be addressed on appeal unless the alleged error rises to the level of obvious error under N.D.R.Crim.P. 52(b).” State v. Pemberton, 2019 ND 157, ¶ 8, 930 N.W.2d 125 (quoting State v. Lott, 2019 ND 18, ¶ 8, 921 N.W.2d 428). This Court’s obvious error standard is well-established:

To establish an obvious error, the defendant must show: (1) error; (2) that is plain; and (3) the error affects the defendant’s substantial rights. To constitute obvious error, the error must be a clear deviation from an applicable legal rule under current law. There is no obvious error when an applicable rule of law is not clearly established. When a defendant proves obvious error occurred, this Court has discretion whether to rectify it and will only do so when the error seriously affects the fairness, integrity or public reputation of judicial proceedings. In analyzing obvious error, our decisions require examination of the entire record and the probable effect of the alleged error in light of all the evidence.

State v. Woodman, 2025 ND 12, ¶ 5, 16 N.W.3d 164 (cleaned up).

2 B

[¶8] Kennedy argues the district court improperly allowed prejudicial character evidence, including evidence about Kennedy’s prior federal convictions, drug activities, and probation violations. The State contends obvious error review is not available because Kennedy invited the error.

[¶9] During voir dire, Kennedy’s counsel stated:

As you’ll learn during the trial, Mr. Kennedy is an African American male who hails from the Detroit, Michigan area, and he does have a criminal history that includes both violence and drugs. And you may also learn that he is currently serving a federal prison sentence and was also on federal supervised release when the alleged events in this case occurred. Knowing all of that, how many of you feel that you might have some difficulty presuming that Mr. Kennedy is innocent of the charges against him in this case?

[¶10] During trial and outside the presence of the jury, Kennedy stated he did not object to including information about his probation status in the jury instructions.

MR. SKEES: And Your Honor, we have no objection to there being an instruction that defendant is on probation and that no inference can be drawn but we would have an objection to the part that indicates that this goes to show that he had an opportunity to commit the offense charged in because he was not at all located within the area of the probation officer.

A final instruction read:

DEFENDANT ON PROBATION There is evidence in the case that the Defendant was previously arrested and convicted of a crime and placed on probation supervision. That evidence was introduced for the sole purpose to explain the facts surrounding the investigation. You are prohibited from using this information to assume that the Defendant is more likely to be guilty of this offense. He is to be judged on this offense based only on the evidence regarding this offense alone.

3 [¶11] “The obvious error analysis under N.D.R.Crim.P. 52(b) does not apply to errors waived through the doctrine of invited error.” State v. Wiese, 2024 ND 39, ¶ 8, 4 N.W.3d 242 (quoting State v. Yoney, 2020 ND 118, ¶ 12, 943 N.W.2d 791). “The rationale for that rule precludes a defendant from inviting error in the hope that if the defendant does not prevail in the trial court, he will prevail upon appellate review of the invited error.” Id. (quoting State v. Doppler, 2013 ND 54, ¶ 14, 828 N.W.2d 502). A party can invite error during voir dire. See Nix v. State, 158 N.E.3d 795, 800 (Ind. Ct. App. 2020) (defendant, who did not request voir dire be individualized, invited jurors’ exposure to his criminal history by inquiring about potential biases based on pretrial publicity); State v. Hohensee, 353 S.W.3d 445, 446-47 (Mo. Ct. App. 2011) (defense counsel’s statement in voir dire that “defendant may or may not testify” was invited error); State v. Deiterman, 271 Kan. 975, 981, 29 P.3d 411 (2001) (venireperson’s voir dire response to defense counsel’s question on media coverage—asked over the State’s objection and after being admonished and warned by the court that he would have to “live with the consequences”—was invited error); State v. Elmore, 139 Wash.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Davis
2026 ND 48 (North Dakota Supreme Court, 2026)
State v. Guthmiller
2025 ND 162 (North Dakota Supreme Court, 2025)
State v. Hendricks
2025 ND 143 (North Dakota Supreme Court, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 ND 130, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-kennedy-nd-2025.