Justia Montana Supreme Court Opinion Summaries

Mark French, representing himself, was convicted of a misdemeanor in the Sanders County Justice Court, which is not a court of record. He appealed the conviction to the Montana Twentieth Judicial District Court for a trial de novo. After Judge John W. Larson assumed jurisdiction over the appeal, French moved to disqualify him, citing perceived injustices related to the rescheduling of the trial. When that motion was denied, French filed an alternative motion for substitution of judge under Montana law.The Montana Supreme Court previously denied French’s motion to disqualify Judge Larson, finding the issue moot because the trial date had been vacated. The Supreme Court also clarified that Judge Larson had jurisdiction to determine the timeliness of French’s subsequent motion for substitution. Judge Larson then denied French’s motion for substitution, relying on precedent from D.H. v. Montana Fourth Judicial District Court, which addressed substitution in a different context. French then petitioned the Montana Supreme Court for supervisory control, arguing that his substitution motion was timely and authorized, that his right to a jury trial was denied, and that the District Court improperly relied on the Justice Court record.The Supreme Court of the State of Montana held that, when a criminal case is appealed from a justice court that is not a court of record for a trial de novo, the appellant is entitled to one substitution of a district judge under § 3-1-804, MCA, as if the case had originated in district court. The Court reversed the District Court’s denial of French’s motion for substitution and remanded for further proceedings. The Court also found that the Justice Court record was properly transferred and relied upon. French’s request for dismissal of the District Court proceeding was denied. View "French v. 20th Judicial District" on Justia Law

The defendant was convicted by a jury of sexual intercourse without consent in 2017 and sentenced to 40 years in prison, with 20 years suspended. After an appeal, the Montana Supreme Court reversed the conviction due to the improper admission of statistical evidence and remanded for a new trial. While awaiting retrial, the defendant was released on bail, returned to work, and cared for his mother. At the second trial, both parties presented expert witnesses who testified about general behaviors of sexual assault victims, but did not opine on the specific facts of the case. The State’s expert, Dr. Vanino, remained in the courtroom during the defense expert’s testimony, in violation of a witness exclusion order. The District Court allowed Dr. Vanino to be recalled as a rebuttal witness, and the defense was permitted to recall its own expert in response.After the second conviction, a new psychological evaluation indicated the defendant had made progress in treatment and matured. At resentencing, the defendant requested a sentence consistent with a prior plea offer, while the State sought a harsher sentence. The District Court increased the sentence to 50 years with 30 years suspended, citing the defendant’s decision to appeal, retry the case, lack of remorse, and the impact on the victim.The Supreme Court of the State of Montana reviewed two main issues. First, it held that the District Court erred in interpreting Montana Rule of Evidence 615 to categorically exempt expert witnesses from exclusion orders, but found the error harmless because both parties’ experts were allowed to rebut each other and neither testified to case-specific facts. Second, the Court held that the increased sentence after retrial violated due process, as it was based on the defendant’s exercise of constitutional rights and not on new, objective information. The Court affirmed the conviction, reversed the increased sentence, and remanded for amendment of the judgment to restore the original suspended term. View "State v. Grimshaw" on Justia Law

The plaintiffs, a law firm and its principal, challenged a Montana statute enacted in 2021 that prohibits discrimination based on an individual’s vaccination status or possession of an immunity passport. The law applies broadly to businesses, governmental entities, employers, and public accommodations, with certain exceptions for schools, daycare facilities, and healthcare providers. One provision of the law also prohibits requiring individuals to receive vaccines authorized only for emergency use or still undergoing safety trials. The plaintiffs alleged that the statute violated several provisions of the Montana Constitution, including rights to a clean and healthful environment, equal protection, inalienable rights, and the constitutional requirement that a bill’s subject be clearly expressed in its title.The case was first heard in the District Court of the Seventh Judicial District, Richland County. The District Court denied the plaintiffs’ request for a preliminary injunction and dismissed most of their constitutional claims, but allowed the claim regarding the bill’s title and single-subject requirement to proceed. On remand from the Montana Supreme Court’s earlier decision in Netzer Law Office, P.C. v. State, the District Court ultimately held that the main antidiscrimination provision of the law complied with the constitutional clear-title requirement, but that the provision prohibiting mandates for emergency use or trial vaccines did not, and voided that subsection.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal of the plaintiffs’ other constitutional claims. The Supreme Court held that the law’s title was sufficiently clear and not misleading as to its main antidiscrimination provision, affirming its validity. However, the Supreme Court reversed the District Court’s invalidation of the provision regarding emergency use and trial vaccines, holding that this subsection was germane to the bill’s general purpose and did not violate the clear-title or single-subject requirements. Thus, both challenged provisions of the statute were upheld. View "Netzer v. State" on Justia Law

Richard Mabee died from a methamphetamine overdose while confined in the Wheatland County Jail. He had traveled from Washington to Montana, violating his probation, and was arrested after a traffic stop. During booking, officers did not observe signs of drug use or find contraband, but video footage later showed Mabee disposing of a small object in his cell. Early the next morning, Mabee exhibited signs of methamphetamine intoxication, which were observed by Deputy Sweet, who monitored him via video but did not physically check on him until he was found unresponsive. Despite attempts at CPR, Mabee was pronounced dead from an overdose. The source of the methamphetamine was unclear, but the County theorized Mabee had concealed it prior to his confinement.The Estate of Richard Mabee sued Wheatland County for negligence, alleging the jailers failed to provide adequate medical care. The County asserted that Mabee’s own negligence contributed to his death and should diminish or bar recovery. The Fourteenth Judicial District Court, Wheatland County, allowed the County to present a comparative negligence defense and approved a special verdict form for the jury to apportion fault. The jury found both parties negligent, attributing 95% of the fault to Mabee and 5% to the County. As a result, the District Court entered judgment for the County, denying damages to the Estate.The Supreme Court of the State of Montana reviewed whether the District Court erred in permitting the comparative negligence defense. The Court held that, absent “special circumstances” where a jailer knows or should know a detainee is at risk of harm, comparative negligence applies and the factfinder may apportion fault. The Court affirmed the District Court’s judgment, concluding the Estate did not preserve any error regarding jury instructions on “special circumstances” and failed to show reversible error. View "Est. of Mabee v. Wheatland County" on Justia Law

A man was involved in a single-vehicle accident in Gallatin County, Montana, where his Jeep left the road, struck a sign, and then drove away. Witnesses reported the incident, and law enforcement traced the vehicle to the man’s residence using the license plate information. Upon arrival, officers observed damage to the Jeep and encountered the man, who exhibited signs of impairment such as bloodshot eyes and a dazed demeanor. The man admitted to purchasing and inhaling a can of Dust-Off, a product containing difluoroethane (DFE), and acknowledged that he had passed out while driving. Field sobriety tests indicated impairment, and a subsequent blood test confirmed the presence of DFE.The Gallatin County Justice Court denied the man’s motions to suppress evidence, which alleged a lack of particularized suspicion, unlawful search and seizure, and a Miranda violation. After a bench trial, the court found him guilty of misdemeanor DUI (third offense). The Eighteenth Judicial District Court, Gallatin County, affirmed the conviction and the denial of the suppression motions, concluding that law enforcement had particularized suspicion, that there was no reasonable expectation of privacy in the driveway or the exterior of the Jeep, and that no custodial interrogation requiring Miranda warnings had occurred.The Supreme Court of the State of Montana reviewed the case de novo. It held that law enforcement had particularized suspicion to investigate for DUI based on the totality of the circumstances, including the crash, the man’s behavior, and his admissions. The Court found no unlawful search or seizure, as there was no reasonable expectation of privacy in the areas searched, and the man voluntarily provided the Dust-Off can. The Court also determined that no custodial interrogation occurred before arrest, so Miranda warnings were not required. The Court declined to address an unpreserved evidentiary claim and found sufficient evidence supported the DUI conviction. The conviction was affirmed. View "State v. Ellis" on Justia Law

The State petitioned to involuntarily commit J.L.O., alleging she suffered from schizophrenia and posed a danger to herself or others. The petition relied on a report by a licensed clinical social worker (LCSW) who examined J.L.O. the day before the petition was filed. The District Court appointed a licensed professional counselor to examine J.L.O., and scheduled a hearing for January 2, 2024, within the statutory five-day window. J.L.O. was detained at the Montana State Hospital pending the hearing. The State provided J.L.O.’s counsel with the LCSW’s report only after the hearing, and it was discovered that the LCSW was not certified as a “professional person” under Montana law.J.L.O.’s counsel moved to dismiss the commitment petition, arguing that the State failed to have J.L.O. examined by a qualified professional person within the required timeframe. The State conceded the LCSW’s lack of certification but argued that J.L.O.’s request for a continuance waived the five-day hearing deadline. The Fourth Judicial District Court denied the motion to dismiss and proceeded with the commitment process, ultimately appointing a certified professional person who did not personally examine J.L.O. but relied on records and secondhand information. The District Court committed J.L.O. to the Montana State Hospital for up to ninety days and authorized involuntary medication.The Supreme Court of the State of Montana reviewed the case and held that the District Court erred by denying J.L.O.’s motion to dismiss. The Supreme Court found that the statutory requirements for involuntary commitment—including examination by a qualified professional person within the five-day hearing deadline—were not met, and that the error was not harmless. The Supreme Court reversed the District Court’s Order of Commitment. View "In re J.L.O." on Justia Law

The petitioner was charged with several felonies stemming from an incident in July 2024, including assault with a weapon, unlawful possession of a firearm by a convicted person, and tampering with evidence. He was arraigned on these charges in July 2024 and did not seek to substitute the presiding judge at that time. In June 2025, the State filed an Amended Information adding three new felony counts of criminal distribution of dangerous drugs, and the petitioner was arraigned again on these new charges. Within two days of this second arraignment, the petitioner moved to substitute the judge, arguing that the motion was timely because it was filed within ten days of the arraignment on the Amended Information.The Twentieth Judicial District Court, Lake County, denied the motion, holding it was untimely because the ten-day period for substitution under § 3-1-804(1)(b), MCA, began with the initial arraignment in July 2024, not the subsequent arraignment on the amended charges. The court reasoned that allowing substitution after any arraignment on amended charges could lead to manipulation of the process and disrupt judicial efficiency.The Supreme Court of the State of Montana reviewed the case on a petition for writ of supervisory control. The Court held that the right to substitute a judge in a criminal case under § 3-1-804(1)(b), MCA, is triggered by the initial arraignment, not by subsequent arraignments on amended informations, even if new charges are added. The Court concluded that the District Court did not err in denying the motion as untimely and denied the petition for writ of supervisory control, remanding the matter for further proceedings. View "Caye v. 20th Judicial District Court" on Justia Law

The case concerns an incident between Taylor Jean Carlson and her ex-boyfriend, Shane Dalke, following a wedding they both attended. After a series of arguments and confrontations at Dalke’s home, Carlson physically assaulted Dalke and attempted to take his phone, which he was using to record her behavior. During the struggle, the phone was dropped, and Carlson picked it up, unsuccessfully tried to access it, and then destroyed it by throwing it on the concrete multiple times, rendering it inoperable. Police were unable to recover any data from the phone due to the damage.The Eighth Judicial District Court, Cascade County, presided over Carlson’s trial. She was charged with misdemeanor Partner Family Member Assault and felony Tampering with or Fabricating Physical Evidence. At trial, Carlson’s attorney requested a jury instruction for the misdemeanor offense of Criminal Destruction of or Tampering with a Communication Device as a lesser included offense of the tampering charge. The State opposed, arguing the statutes required different elements. The District Court denied the request, reasoning that the communication device offense contained an element not present in the tampering statute, and thus was not a lesser included offense as a matter of law. Carlson was convicted of tampering with evidence.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in denying the lesser included offense instruction. The Supreme Court held that Criminal Destruction of or Tampering with a Communication Device is not a lesser included offense of Tampering with or Fabricating Physical Evidence because the two statutes have distinct elements, particularly regarding intent and the nature of the conduct criminalized. The Supreme Court affirmed the District Court’s decision. View "State v. Carlson" on Justia Law

A 70-year-old woman was the subject of a state petition for involuntary civil commitment, alleging she suffered from a severe mental disorder with manic and psychotic features. Over several months, she had multiple encounters with law enforcement and was charged with various offenses, including assault and disorderly conduct. The petition included a psychiatric evaluation and described significant behavioral changes affecting her safety and relationships. At the initial hearing, the woman was represented by counsel, who stated she did not want a trial and wished to be stabilized, and the court read her rights aloud.The Eighth Judicial District Court, Cascade County, presided over the hearing. The court relied on the representations of counsel and the woman’s brief affirmations to find that she knowingly and intentionally waived her procedural rights, including the right to contest the commitment. The court then ordered her commitment to the Montana State Hospital for up to 90 days, issuing findings that largely repeated the petition’s allegations. The order stated that the woman and her counsel agreed to waive her rights, but the court did not directly question her about the waiver or develop a record of her understanding.The Supreme Court of the State of Montana reviewed the case. It held that the district court erred by failing to make an adequate inquiry or develop a sufficient record to support a finding that the woman knowingly and intentionally waived her rights, as required by Montana law. The Supreme Court emphasized that merely informing a respondent of their rights or relying on general statements from counsel is insufficient. The order of commitment was reversed, reaffirming the necessity for strict compliance with statutory and due process requirements in involuntary commitment proceedings. View "In re P.G.J." on Justia Law

The case concerns an altercation that occurred after Jeffrey Burrington, while driving with his wife, began tailgating another vehicle driven by Ryan Williams. After both vehicles stopped, a verbal confrontation ensued, during which Burrington punched Williams in the face. Williams subsequently sought medical attention and was diagnosed with a fractured mandible, which required him to maintain a liquid diet for six weeks and limited his ability to perform certain job duties as a smokejumper. Burrington was charged with Aggravated Assault, a felony, and the State also proposed a jury instruction for the lesser included offense of Assault.In the Fourth Judicial District Court for Missoula County, Burrington moved to dismiss the case, arguing that Williams did not suffer a serious bodily injury and that he acted in self-defense. The District Court denied the motion, finding these were issues for the jury. At trial, Burrington presented a dual defense: justifiable use of force and lack of serious bodily injury. The jury heard testimony from Williams, medical experts, and both Burrington and his wife regarding prior incidents that shaped their perception of threat. After the State rested, Burrington moved for a directed verdict, which the District Court denied, concluding that the evidence was sufficient for the jury to decide.The Supreme Court of the State of Montana reviewed whether the District Court erred in denying the motion for a directed verdict, whether plain error review was warranted for unobjected-to trial incidents, and whether cumulative error required a new trial. The Supreme Court held that a rational jury could find Williams’s six-week mandibular injury constituted a “protracted loss or impairment” and thus a serious bodily injury under Montana law. The Court also found no plain error or cumulative error warranting reversal. The conviction and sentence were affirmed. View "State v. Burrington" on Justia Law