Glaum v. State
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The case involves Joseph Glaum, who had pleaded guilty to various criminal charges in several cases between 1997 and 2008. In 2023, Glaum moved to reopen these cases and withdraw his guilty pleas. Around the same time, he made similar motions in four other closed cases. All these motions were denied by the district court. In April 2023, the presiding judge of the Northeast Central Judicial District entered a proposed pre-filing order under N.D. Sup. Ct. Admin. R. 58, finding Glaum to be a vexatious litigant. This order prohibited Glaum from filing any new litigation or new documents in existing litigation as a self-represented party without first obtaining leave of the court. Glaum appealed this pre-filing order.
The State moved to dismiss Glaum's appeal, arguing it was untimely. The State contended that Glaum's appeal of the pre-filing order was an appeal from an order in a criminal case, which should have been filed within 30 days after entry of the order being appealed. Glaum, however, argued that this was an appeal from an order in a civil case, which should be filed within 60 days from service of notice of entry of the judgment or order being appealed.
The Supreme Court of North Dakota denied the State’s motion to dismiss, concluding the appeal was timely. The court determined that the pre-filing order was not an order in a criminal case, but rather an order in a civil case or a postconviction proceeding. The court noted that the time for filing an appeal did not begin to run because Glaum was not served with the notice of entry of the pre-filing order, nor was there evidence of actual knowledge of entry. The court affirmed the pre-filing order, finding Glaum to be a vexatious litigant.
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