====== N.D. Const. art. XI, § 23 — Research ======

**Woman's Premarital Property Not Liable for Debts of Husband.** Text of the section: [[.:start|current and prior versions]].

Every citing reference in the corpus: **2** court opinions and **1** Attorney General opinion. Counts include the section's pre-1981 designation (§ 213), era-gated by the renumbering crosswalk.

//Generated from the citation graph of the validated corpus. Treatment groupings (construing / citing / recital) are heuristic reading aids, not editorial judgments — read the opinion before relying on any signal.//

===== Construing and quoting decisions (2) =====

  * Peters-Riemers v. Riemers (See Docket Memo), [[https://www.ndcourts.gov/supreme-court/opinions/151793|2002 ND 72]] (2002, Neumann, J.)  ·  quotes the provision
    * //¶ 21: “…%%Roland asserts the trial court erred by not dividing the parties' property as required by N.D. Const. art. XI, § 23. We quote Roland's entire argument on this issue: "[A]s a matter of law, Article 11, Section 23 of the North Dakota [sic] allows women to keep their pre-marital property. As a matter of state law (and probably Federa%%…”//
  * Keen v. Larson, [[https://www.courtlistener.com/opinion/1715983/keen-v-larson/|1964 ND 70]] (1964, Teigen, J.)  ·  quotes the provision
    * //“…%%the historic common law rule does not apply. Section 1-02-01, N.D.C.C. Our Constitution provides that the property of any woman in this State acquired before or after marriage shall be her separate property and she is not liable for the debts of her husband. Section 213, Constitution of North Dakota. The evidence establishes that the agreement was based on a forbearance to bring suit for the enforcement of a claimed legal right. This constitutes consideration to support a promise to le%%…”//

===== Attorney General opinions (1) =====

Advisory, not binding; included for the doctrine's full administrative history.

  * [[https://attorneygeneral.nd.gov/wp-content/uploads/2023/03/021387-Kloubec_0.pdf|N.D. Op. Att'y Gen. (Feb. 13, 1987) (to Kloubec)]]

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