State v. Moen

2025 ND 163
CourtNorth Dakota Supreme Court
DecidedOctober 9, 2025
DocketNo. 20250018
StatusPublished

This text of 2025 ND 163 (State v. Moen) 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. Moen, 2025 ND 163 (N.D. 2025).

Opinion

IN THE SUPREME COURT STATE OF NORTH DAKOTA

2025 ND 163

State of North Dakota, Plaintiff and Appellee v. Spencer Jay Moen, Defendant and Appellant

No. 20250018

Appeal from the District Court of Cass County, East Central Judicial District, the Honorable Nicholas W. Chase, Judge.

AFFIRMED.

Opinion of the Court by Jensen, Chief Justice.

Renata J.O. Selzer (argued), Katie M. Nechiporenko (on brief), and Nicholas S. Samuelson (on brief), Assistant State’s Attorneys, Fargo, ND, for plaintiff and appellee.

Samuel A. Gereszek, Grand Forks, ND, for defendant and appellant. State v. Moen No. 20250018

Jensen, Chief Justice.

[¶1] Spencer Moen appeals from a criminal judgment entered after a jury found him guilty of murder. Moen argues the district court violated his constitutional right to confront witnesses because it failed to comply with statutory requirements for allowing remote testimony by child witnesses. We affirm, concluding the court made the findings required to permit remote testimony, and those findings are not contrary to the manifest weight of the evidence.

I

[¶2] The State charged Moen with one count of murder and one count of contributing to the delinquency of a minor. The State alleged Moen killed his wife in their home while the couple’s five-year-old boy and girl were present. Prior to trial, the State filed a motion requesting permission for the children to testify outside the courtroom by reliable electronic means. The State claimed the children “witnessed portions of the domestic violence” that resulted in the victim’s death, and requiring the children to testify in the presence of the defendant would cause them emotional distress and impact their ability to testify.

[¶3] The district court held a hearing on the motion and received testimony from a clinical psychologist who provided therapy to the boy and a behavioral health counselor who provided therapy to the girl. The court held a subsequent hearing where the parties presented their arguments. The court orally granted the State’s motion at the conclusion of the second hearing, finding that remote testimony was necessary because, if the children were required to testify in front of Moen, they “would likely suffer serious emotional distress or trauma and it would impact their ability to reasonably communicate.”

[¶4] Moen entered a guilty plea to the contributing to the deprivation of a minor charge. At the murder trial, the district court instructed the jury that testimony by the children from a remote location is permissible by law, and the jury should not draw any inferences from their method of appearance. After the

1 court gave its instruction, the prosecutor, defense counsel, and the clerk of court left the courtroom and went to a different room where the children testified. The children were sworn in, and each child testified by electronic means that allowed two-way communication. The jury returned a guilty verdict, and the court entered a criminal judgment sentencing Moen to life imprisonment without the possibility of parole. Moen appeals.

II

[¶5] The Sixth Amendment to the United States Constitution, applicable to the states through the Fourteenth Amendment, ensures “[i]n all criminal prosecutions, the accused shall enjoy the right . . . to be confronted with the witnesses against him.” The North Dakota Constitution has a “similar guarantee.” City of Fargo v. Komad, 2006 ND 177, ¶ 5, 720 N.W.2d 619. “In criminal prosecutions in any court whatever, the party accused shall have the right . . . to appear and defend in person[.]” N.D. Const. art. I, § 12.

The Confrontation Clause reflects a preference for face-to-face confrontation at criminal trials. Ohio v. Roberts, 448 U.S. 56, 100 S.Ct. 2531, 65 L.Ed.2d 597 (1980). An accused’s right to confrontation is fundamentally a trial right which consists of the right to cross- examination. State v. Manke, 328 N.W.2d 799 (N.D. 1982). In addition to ensuring the accused the opportunity to cross-examine his accusers, the purpose of the Confrontation Clause is to ensure that a witness will give his statements in court under oath, thereby impressing upon him the seriousness of telling the truth as against penalty for perjury, and to permit the jury an opportunity to observe the demeanor of the witness in making his statement, thus aiding the factfinder in assessing credibility. California v. Greene, 399 U.S. 149, 90 S.Ct. 1930, 26 L.Ed.2d 489 (1970).

State v. Fischer, 459 N.W.2d 818, 820 (N.D. 1990); see also State v. Woinarowicz, 2006 ND 179, ¶ 8, 720 N.W.2d 635 (“The Confrontation Clause provides two protections to criminal defendants: the right to physically face someone who testifies against them, and the right to cross examine.”). Although the right to confront witnesses is of a constitutional magnitude, it “is not absolute and, in appropriate cases, may ‘bow to accommodate other legitimate interests in the

2 criminal trial process.’” Fischer, at 820 (quoting Chambers v. Mississippi, 410 U.S. 284, 295 (1973)).

[¶6] In Maryland v. Craig, 497 U.S. 836, 853 (1990), the Supreme Court decided “that a State’s interest in the physical and psychological well-being of child abuse victims may be sufficiently important to outweigh, at least in some cases, a defendant’s right to face his or her accusers in court.” The Supreme Court held child testimony provided by one-way closed-circuit television may satisfy the Confrontation Clause’s requirements under certain circumstances:

[I]f the State makes an adequate showing of necessity, the state interest in protecting child witnesses from the trauma of testifying in a child abuse case is sufficiently important to justify the use of a special procedure that permits a child witness in such cases to testify at trial against a defendant in the absence of face-to-face confrontation with the defendant. The requisite finding of necessity must of course be a case- specific one: The trial court must hear evidence and determine whether use of the one-way closed circuit television procedure is necessary to protect the welfare of the particular child witness who seeks to testify. The trial court must also find that the child witness would be traumatized, not by the courtroom generally, but by the presence of the defendant. Denial of face-to-face confrontation is not needed to further the state interest in protecting the child witness from trauma unless it is the presence of the defendant that causes the trauma. . . . Finally, the trial court must find that the emotional distress suffered by the child witness in the presence of the defendant is more than de minimis . . . . .... In sum, we conclude that where necessary to protect a child witness from trauma that would be caused by testifying in the physical presence of the defendant, at least where such trauma would impair the child's ability to communicate, the Confrontation Clause does not prohibit use of a procedure that, despite the absence of face-to-face confrontation, ensures the reliability of the evidence by subjecting it to rigorous adversarial testing and thereby preserves the essence of effective confrontation. . . .

Id. at 855-57 (cleaned up).

3 [¶7] North Dakota Century Code § 31-04-04.2 codifies requirements from Craig v. Maryland relating to trauma and its impact on a child’s ability to reasonably communicate. It states:

1.

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Related

California v. Green
399 U.S. 149 (Supreme Court, 1970)
Chambers v. Mississippi
410 U.S. 284 (Supreme Court, 1973)
Ohio v. Roberts
448 U.S. 56 (Supreme Court, 1980)
Maryland v. Craig
497 U.S. 836 (Supreme Court, 1990)
Serenko v. City of Wilton
1999 ND 88 (North Dakota Supreme Court, 1999)
State v. Woinarowicz
2006 ND 179 (North Dakota Supreme Court, 2006)
City of Fargo v. Komad
2006 ND 177 (North Dakota Supreme Court, 2006)
State v. Graf
2006 ND 196 (North Dakota Supreme Court, 2006)
State v. Whitman
2013 ND 183 (North Dakota Supreme Court, 2013)
State v. Fischer
459 N.W.2d 818 (North Dakota Supreme Court, 1990)
State v. Manke
328 N.W.2d 799 (North Dakota Supreme Court, 1982)
State v. Knox
2016 ND 15 (North Dakota Supreme Court, 2016)
State v. Stenhoff
2019 ND 106 (North Dakota Supreme Court, 2019)
State v. Rolland
2024 ND 175 (North Dakota Supreme Court, 2024)

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Bluebook (online)
2025 ND 163, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-moen-nd-2025.