North Dakota Code § 29-17-25

Challenge taken for officer's bias
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When a jury is formed from persons whose names are not drawn as jurors, a challenge may 
be taken to the panel on account of any bias of the officer who summoned them, which would 
be good ground of challenge to a juror. Such challenge must be made in the same form and 
determined in the same manner as if made to a juror.

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