North Dakota v. Neugebauer
Annotate this CaseMichael Neugebauer appealed a district court order denying his motion for a sentence reduction. In 1992, Neugebauer was charged with four counts of murder. Neugebauer pled guilty to all counts and was sentenced to life imprisonment on each count, running concurrently. On October 5, 2020, Neugebauer moved for a reduction of his sentence under N.D.C.C. § 12.1-32-13.1. After a hearing, the court denied his motion, concluding N.D.C.C. § 12.1-32-13.1 did not apply retroactively. Neugebauer argued to the North Dakota Supreme Court that N.D.C.C. § 12.1-32-13.1 should apply retroactively. He acknowledged the Court's holding in Garcia v. North Dakota, 925 N.W.2d 442, but argued its analysis “negates the very essence of N.D.C.C. § 12.1-32-13.1” and “presumes an idle act by the Legislature.” He also argued the application of the ameliorative penal legislation exception to the general rule against retroactivity applied because this case was not lessening punishment; it was simply giving an avenue to specific individuals to move the court for a reduction in sentence. The Supreme Court found no reversible error in the district court's judgment and affirmed.
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