City brought action in small claims court against landlord to collect $100 fee for reinspection of rental property. Landlord removed action and filed § 1983 counterclaim. The East Central Judicial District Court entered summary judgment in favor of city. Landlord appealed.
The Supreme Court of North Dakota held that:
- City had authority to assess the fee;
- Fee was not a “bill of attainder”; and
- City’s attempt to collect fee following landlord’s guilty plea did not violate double jeopardy clause.