The North Dakota Supreme Court remanded a criminal case back to the district court after finding significant documentation errors in how a defendant's conditional plea was recorded in the official judgment.

In *State v. Medina* (2025 ND 234), the court addressed an appeal by Antonio Eugenio Medina, who claimed he had entered a conditional plea that reserved his right to appeal a district court's denial of his motion to suppress evidence. The case originated in the District Court of Grand Forks County under Judge Kristi P. Venhuizen.

The central issue arose from a disconnect between what the parties agreed happened during the plea proceedings and what was officially recorded in the criminal judgment. Both the prosecution and defense agreed that Medina had entered a conditional plea, but the resulting judgment failed to specify its conditional nature as explicitly required by North Dakota Rules of Criminal Procedure.

Justice Crothers, writing for the court, emphasized the importance of proper documentation in conditional plea agreements. The court cited North Dakota Rule of Criminal Procedure 11(a)(2), which states that "The resulting judgment must specify it is conditional." This rule allows defendants to preserve their right to appeal specific pre-trial rulings while still entering a guilty plea to resolve the case efficiently.

The Supreme Court found that the documentation failure created uncertainty about the defendant's appellate rights and the terms of his plea agreement. Rather than attempting to resolve the discrepancy at the appellate level, the court determined that remand was the appropriate remedy to ensure accurate record-keeping.

In its remand order, the Supreme Court instructed the district court to clarify the record regarding the nature of Medina's plea and to correct the judgment if necessary to reflect that it was indeed conditional. The court retained jurisdiction over the matter to oversee the resolution and ensure compliance with criminal procedure requirements.

This decision underscores the critical importance of precise documentation in criminal proceedings, particularly when defendants enter conditional pleas that preserve certain appellate rights. The ruling serves as a reminder to trial courts about the mandatory nature of the documentation requirements under Rule 11(a)(2).