State v. Luetzen

2026 ND 13
CourtNorth Dakota Supreme Court
DecidedJanuary 29, 2026
DocketNo. 20250223
StatusPublished
AuthorJensen, Jon J.

This text of 2026 ND 13 (State v. Luetzen) 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. Luetzen, 2026 ND 13 (N.D. 2026).

Opinion

IN THE SUPREME COURT STATE OF NORTH DAKOTA

2026 ND 13

State of North Dakota, Plaintiff and Appellee v. Deyan Robert Luetzen, Defendant and Appellant

No. 20250223

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

AFFIRMED.

Opinion of the Court by Jensen, Justice.

Kenessa R. Copeland, Assistant State’s Attorney, Minot, ND, for plaintiff and appellee.

Kiara C. Kraus-Parr, Grand Forks, ND, for defendant and appellant. State v. Luetzen No. 20250223

Jensen, Justice.

[¶1] Deyan Luetzen appeals from a criminal judgment entered after a jury found him guilty of illegally possessing a firearm. He argues the district court erred by failing to instruct the jury consistently with amendments to the law defining the term “possession” under N.D.C.C. tit. 62.1. He also argues the court obviously erred by not entering a judgment of acquittal because the State failed to present sufficient evidence to prove the gun in this case met the statutory definition of a “firearm.” We affirm.

I

[¶2] The State charged Luetzen with unlawful possession of a firearm by a felon. The State alleged law enforcement found a handgun in Luetzen’s vehicle while he was inside a bar where the vehicle was parked. During the trial, Luetzen objected to proposed jury instructions defining the term “possession,” asserting the instructions improperly informed the jury the State did not have to prove he acted intentionally. The district court overruled his objection. After the State rested its case, Luetzen moved for entry of a judgment of acquittal arguing there was insufficient evidence to connect him to the vehicle where the gun was found. The court denied his motion. The jury returned a guilty verdict. Luetzen appeals from the criminal judgment.

II

[¶3] Luetzen raises two issues with respect to the nature of the criminal charge in this case. The first issue requires interpretation of an amendment to N.D.C.C. § 62.1-01-01(11), which defines the term “possession.” The second issue requires us to decide whether, based on the meaning of the amendment, the district court improperly instructed the jury on the essential elements of illegally possessing a firearm.

1 A

[¶4] Luetzen argues the district court erred by treating the offense of felon in possession of a firearm as a strict liability crime. He asserts 2023 amendments to N.D.C.C. § 62.1-01-01(11) require the State to prove intent to possess a firearm. The State argues the amendments did not change the nature of the offense and it continues to be a strict liability crime.

[¶5] The interpretation of a criminal statute is a question of law fully reviewable on appeal. State v. Gaddie, 2022 ND 44, ¶ 17, 971 N.W.2d 811.

Our primary goal in interpreting statutes is to ascertain the Legislature’s intentions. In ascertaining legislative intent, we first look to the statutory language and give the language its plain, ordinary and commonly understood meaning. We interpret statutes to give meaning and effect to every word, phrase, and sentence, and do not adopt a construction which would render part of the statute mere surplusage. When a statute’s language is ambiguous because it is susceptible to differing but rational meanings, we may consider extrinsic aids, including legislative history, along with the language of the statute, to ascertain the Legislature’s intent. We construe ambiguous criminal statutes against the government and in favor of the defendant.

Id. (quoting State v. McCreary, 2021 ND 212, ¶ 8, 967 N.W.2d 447).

[¶6] A defendant must generally have a guilty mind before he or she can be convicted. State v. Gedrose, 2021 ND 111, ¶ 7, 961 N.W.2d 288. This is a concept commonly referred to as “mens rea, scienter, malice aforethought, guilty knowledge, and the like.” Id. (quoting Elonis v. United States, 575 U.S. 723, 734 (2015)). If an offense is in the criminal code, N.D.C.C. tit. 12.1, and no culpability is specified, the State must prove willfulness. N.D.C.C. § 12.1-02-02(2). The default willfulness requirement in the criminal code “will not be read into other chapters unless the Legislature has specifically so stated.” State v. Montplaisir, 2015 ND 237, ¶ 32, 869 N.W.2d 435 (quoting State v. Holte, 2001 ND 133, ¶ 8, 631 N.W.2d 595). “[W]hen a statute outside of Title 12.1, N.D.C.C., does not specify a culpability requirement, the offense is a strict liability offense for which no proof of intent is needed[.]” State v. Kleppe, 2011 ND 141, ¶ 14, 800 N.W.2d 311

2 (citing Holte, ¶ 10). “A strict liability offense requires no proof of the defendant’s intent, knowledge, willfulness, or negligence for conviction.” Gedrose, ¶ 8.

[¶7] Under N.D.C.C. § 62.1-02-01, individuals who have been convicted of certain felony offenses are “prohibited from owning a firearm or having one in possession . . . .” In State v. Buchholz, 2006 ND 227, ¶ 12, 723 N.W.2d 534, this Court explained, “[t]he offense of felon in possession of a firearm is a strict liability offense . . . .” In 2023, the North Dakota Legislature added the following definition for the term “possession” to N.D.C.C. tit. 62.1:

“Possession” means an individual has:

a. Direct physical control of something on or around the individual’s person; or

b. The power and intention to exercise control over something accessible to but not on or around the individual’s person.

N.D.C.C. § 62.1-01-01(11); see also 2023 N.D. Sess. Laws ch. 123, § 3; State v. Enriquez, 2024 ND 164, ¶ 11, 10 N.W.3d 777 (generally discussing the difference between actual and constructive possession).

[¶8] Luetzen argues the “amendment fundamentally changed the nature of the offense by requiring proof of a mental state, intention to exercise control.” He claims it has the same effect as an amendment this Court addressed in State v. Bell, 2002 ND 130, 649 N.W.2d 243, which concerned the offense of possessing a controlled substance with intent to deliver. In Bell, this Court recognized the offense was a strict liability offense until the Legislature amended the law to include willfulness. Id. ¶ 30. In Bell, this Court concluded the offense at issue, “as amended in 1989, now provides: ‘it is unlawful for any person to willfully, as defined in section 12.1–02–02, manufacture, deliver, or possess with intent to manufacture or deliver, a controlled substance.’” Id. Given the amendment, this Court determined the “offense in Bell’s case is no longer a strict liability offense . . . .” Id.

[¶9] The willfulness requirement the Legislature added in Bell applied to each type of conduct the law prohibited—namely manufacturing, possessing, and

3 delivering a controlled substance. Unlike Bell, the intent requirement the Legislature added to N.D.C.C. tit. 62.1 only applies to one type of conduct the law prohibits—constructively possessing a firearm. See generally State v. Gardner, 2023 ND 116, ¶ 18, 992 N.W.2d 535 (explaining offenses may be committed by alternative means). Now, to obtain a conviction based on constructive possession, the State must prove the person had “[t]he power and intention to exercise control . . . .” N.D.C.C. § 62.1-01-01(11). Actual possession, on the other hand, may be proven by establishing “[d]irect physical control . . . .” Id. Neither party’s characterization of the offense is correct. It is no longer exclusively a strict liability offense, but it also does not always require proof of intent.

B

[¶10] Luetzen argues the district court erred when it instructed the jury. He argues that prior to the amendment, unwitting possession was an affirmative defense.

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Related

State v. Holte
2001 ND 133 (North Dakota Supreme Court, 2001)
State v. Yineman
2002 ND 145 (North Dakota Supreme Court, 2002)
State v. Bell
2002 ND 130 (North Dakota Supreme Court, 2002)
State v. Buchholz
2006 ND 227 (North Dakota Supreme Court, 2006)
City of Fargo v. Lunday
2009 ND 9 (North Dakota Supreme Court, 2009)
State v. Kleppe
2011 ND 141 (North Dakota Supreme Court, 2011)
City of Fargo v. Lunday
2009 ND 9 (North Dakota Supreme Court, 2009)
Elonis v. United States
575 U.S. 723 (Supreme Court, 2015)
State v. Montplaisir
2015 ND 237 (North Dakota Supreme Court, 2015)
State v. Williams
2017 Ohio 5598 (Ohio Court of Appeals, 2017)
State v. Rodriguez
2020 ND 261 (North Dakota Supreme Court, 2020)
State v. Spillum
2021 ND 25 (North Dakota Supreme Court, 2021)
State v. Gedrose
2021 ND 111 (North Dakota Supreme Court, 2021)
State v. Johnson
2021 ND 161 (North Dakota Supreme Court, 2021)
State v. McCreary
2021 ND 212 (North Dakota Supreme Court, 2021)
State v. Gaddie
2022 ND 44 (North Dakota Supreme Court, 2022)
State v. Kleppe
2011 ND 141 (North Dakota Supreme Court, 2011)
State v. Dahl
2022 ND 212 (North Dakota Supreme Court, 2022)
State v. Gardner
2023 ND 116 (North Dakota Supreme Court, 2023)
State v. Enriquez
2024 ND 164 (North Dakota Supreme Court, 2024)

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2026 ND 13, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-luetzen-nd-2026.