The North Dakota Supreme Court has affirmed a district court eviction judgment against Jessica Gamel in a case involving allegations of improper property disposal and tenant retaliation. The court issued a per curiam decision in *Rent Daddy's, LLC v. Jessica Gamel* (2026 ND 33), summarily affirming the lower court's ruling under multiple appellate procedural rules.
Gamel, who represented herself in the appeal, had challenged an eviction judgment entered in November 2025 by the District Court of Cass County. She raised several serious allegations against her former landlord, Rent Daddy's, LLC, including violations of state civil procedure rules, unlawful disposal of personal property, and tenant retaliation.
According to court documents, Gamel argued that Rent Daddy's violated North Dakota Rule of Civil Procedure 62(a) by executing the eviction during an automatic stay period. She also claimed the company unlawfully disposed of her personal property valued at over $12,000, which would violate North Dakota Century Code Section 47-16-30.1.
Additionally, Gamel alleged that the landlord retaliated against her for raising habitability complaints about the rental property. She claimed Rent Daddy's wrongfully seized her emotional support animal and maintained uninhabitable conditions that ultimately resulted in the removal of her child from the premises.
Despite these serious allegations, the Supreme Court declined to address the merits of Gamel's claims. Instead, the court found that her appellate brief failed to meet basic procedural requirements under North Dakota Rule of Appellate Procedure 28.
The court noted that the section of Gamel's brief arguing the Rule 62(a) violation was "devoid of citations to the record" and that her argument was "conclusory and lacks sufficient factual or legal analysis." The justices emphasized that proper appellate briefs must include adequate record citations and legal analysis to support their arguments.
The Supreme Court referenced *State v. Noack* (2007 ND 82), which described the requirements of Rule 28 as "absolutely imperative." The court also cited *Hoff v. State* (2024 ND 235), reaffirming that the court does not address inadequately briefed issues, regardless of their potential merit.
The summary affirmance was issued under North Dakota Rule of Appellate Procedure 35.1(a)(1), (7), and (8), which allows the court to dispose of appeals without full briefing or oral argument when certain conditions are met, including when an appeal lacks merit or when briefing requirements are not satisfied.
This case highlights the challenges faced by self-represented litigants in appellate proceedings. While Gamel raised potentially serious claims about landlord misconduct, including the alleged disposal of thousands of dollars worth of personal property and the seizure of her emotional support animal, the procedural deficiencies in her brief prevented the court from considering these issues on their merits.
The original eviction case was handled by Judicial Referee Scott O. Diamond in the East Central Judicial District. The case proceeded through the typical eviction process, with Rent Daddy's, LLC obtaining judgment against Gamel and "All Others in Possession" as defendants.
The appellate decision underscores the importance of proper legal briefing in appeals, particularly in landlord-tenant disputes where procedural requirements can be complex. Self-represented parties often struggle to navigate these technical requirements, which can result in potentially valid claims being dismissed on procedural grounds rather than substantive review.
The case also raises broader questions about tenant protections in eviction proceedings, particularly regarding the handling of personal property and the treatment of tenants who raise habitability concerns. While the Supreme Court did not reach these issues, Gamel's allegations reflect common disputes that arise in landlord-tenant relationships.
North Dakota's landlord-tenant law includes specific protections for tenant property during eviction proceedings, and retaliation against tenants who raise legitimate habitability concerns is prohibited under state law. However, these protections can only be enforced if cases are properly presented to the courts with adequate legal support and record citations.
The affirmance of the eviction judgment means that Gamel's claims regarding property disposal, animal seizure, and retaliation remain unresolved at the appellate level. The decision serves as a reminder that while the legal system provides avenues for challenging landlord misconduct, proper procedural compliance is essential for meaningful judicial review.
For landlords and tenants alike, this case emphasizes the importance of understanding both substantive rights and procedural requirements in housing disputes. While self-representation is a constitutional right, the technical nature of appellate proceedings often requires careful attention to briefing requirements that can determine whether claims receive substantive consideration.