North Dakota Code § 32-33-05

To officer whose term has expired
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A writ of certiorari may be issued to and a return to a writ of certiorari may be made by an 
officer whose term of office has expired. Such an officer may be punished for a failure to make a 
return to the writ as required thereby, or to make a further return as required by an order for that 
purpose.

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