Justia Montana Supreme Court Opinion Summaries

The case concerns criminal charges against a man arising from two separate incidents involving his estranged wife and their children at their home in Missoula County, Montana. The first incident, in June 2022, involved a domestic dispute in which the man was alleged to have yelled at and threatened his children and wife, resulting in a 911 call and subsequent police investigation. The second incident, in October 2022, occurred while the couple was separated and involved a physical altercation during a visit by the man to drop off dog food, which escalated to allegations of assault, strangulation, and injury to the wife. Law enforcement responded on both occasions, collecting statements and evidence from the family.After the second incident, the State amended its charges to include multiple felonies and misdemeanors. The defendant initially entered into a plea agreement, pleading no contest to certain charges in exchange for dismissal of others. However, the Fourth Judicial District Court, after reviewing a presentence report, rejected the plea agreement, expressing concerns regarding the defendant’s criminal history and risk to public safety. The defendant then withdrew his pleas, and the matter proceeded to a jury trial. The jury found him guilty on all counts, including Partner or Family Member Assault, destruction/tampering with a communication device, aggravated assault, and strangulation.On appeal to the Supreme Court of the State of Montana, the defendant argued due process violations and cumulative error, including claims of police misconduct, judicial bias, and the State knowingly presenting false evidence. The Supreme Court held that the defendant’s claims were not preserved for appeal and declined to exercise plain error review. The Court further found no basis for cumulative error or denial of a fair trial, and affirmed the District Court’s judgment. View "State v. Stinger" on Justia Law

After a five-year marriage, a couple divorced and agreed on a parenting plan that divided time with their daughter, A.M. Following the divorce, Melissa, the mother, learned that her older daughter from a previous marriage accused Graham, her ex-husband, of sexually abusing her in 2019. Melissa then sought to modify the parenting plan to prevent Graham from having unsupervised visits with A.M., fearing for her safety. She also obtained a temporary order of protection barring Graham from contact with her older daughter and with A.M. for a limited period.The Fifth Judicial District Court initially granted Melissa’s request for a temporary supervised visitation arrangement. However, after a hearing at which key witnesses testified, including Melissa, Graham, and E.M. (another daughter), but not A.R.M. (the alleged victim), the District Court found that there was insufficient evidence to conclude by a preponderance that Graham had abused Melissa’s daughters or posed a danger to A.M. The court made minor amendments to the parenting plan, such as ordering counseling for A.M. and regulating exchanges and communications, but reinstated Graham’s right to unsupervised parenting time with A.M., vacating the interim supervised plan.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in finding insufficient evidence of risk to A.M. and in conducting the hearing with the judge appearing remotely via videoconference. The Supreme Court held that the District Court did not clearly err or abuse its discretion in determining that Melissa failed to meet her heavy burden for modifying the parenting plan. The Court further held that Melissa did not preserve her procedural objection to the judge’s remote appearance and that no manifest injustice or structural error occurred. The Supreme Court affirmed the District Court’s order. View "In re Marriage of Murphy" on Justia Law

The appellant was convicted by a jury in 2018 of several offenses, including aggravated assault, sexual assault, assault on a peace officer, escape, and criminal possession of dangerous drugs. After initially having court-appointed counsel, he retained private attorneys under a fixed-fee contract, with his grandmother paying $150,000 upfront. Ten months later, the relationship between the appellant and his retained counsel deteriorated to the point of a complete breakdown, leading counsel to seek withdrawal. The court held a hearing, found an irreconcilable breakdown, allowed withdrawal, and appointed new counsel. The appellant was then represented by court-appointed attorneys through his trial and sentencing. His conviction and subsequent claims of error, including those relating to ineffective assistance of counsel, were affirmed on direct appeal, and his petition for certiorari was denied by the United States Supreme Court.In postconviction proceedings before the Eighteenth Judicial District Court, the appellant asserted numerous grounds for relief, focusing on claims of ineffective assistance by retained trial counsel (for seeking withdrawal but keeping the fixed fee) and by appellate counsel (for not arguing that separate counsel should have been appointed at the withdrawal hearing). After a bench trial and extensive litigation, the District Court denied all claims, finding no constitutional violations. The court also noted that the appellant’s dispute over fees had been separately resolved through mediation and civil proceedings.The Supreme Court of the State of Montana reviewed the case. It held that the circumstances did not demonstrate a structural denial of counsel warranting a presumption of prejudice under United States v. Cronic, nor did the fixed-fee contract create an actual conflict of interest resulting in ineffective assistance under Strickland v. Washington. The Court further found that appellate counsel was not constitutionally ineffective for failing to raise the claim regarding appointment of separate counsel at the withdrawal hearing. The Supreme Court affirmed the District Court’s denial of postconviction relief. View "Briggs v. State" on Justia Law

After being stopped in a single traffic incident, the defendant was charged in the First Judicial District Court, Broadwater County, Montana, with four offenses: criminal possession of dangerous drugs (methamphetamine), criminal possession of drug paraphernalia, displaying fictitious license plates, and driving without a valid license. The charges stemmed from the discovery of a glass pipe containing methamphetamine residue; the pipe itself was the basis for the paraphernalia charge, and the residue formed the basis for the felony drug possession charge.The defendant pleaded guilty to the misdemeanor counts—possession of drug paraphernalia, displaying fictitious license plates, and driving without a license—but did not plead guilty to the felony drug possession charge. Immediately after his guilty pleas to the misdemeanors, he moved to dismiss the felony charge, arguing that Montana’s double jeopardy and same-transaction statutes—specifically § 46-11-503(1)(b), MCA—barred further prosecution because all charges arose from the same transaction and shared the same objective. The District Court denied this motion, holding that the offenses, though related, were distinct under Montana law and that the defendant had not yet been subjected to multiple prosecutions. The defendant then entered a conditional guilty plea to the felony, reserving his right to appeal the denial of his motion to dismiss.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decision. It held that § 46-11-503(1)(b), MCA, did not bar prosecution of the unresolved count because no conviction had been entered on the other counts at the time of the motion. The court also concluded that Montana law permits prosecution and conviction for both offenses arising from the same transaction unless one is a lesser-included offense of the other, which was not the case here. View "State v. Standifur" on Justia Law

The case centers on criminal charges against an individual who was accused of sexual intercourse without consent, aggravated kidnapping, and robbery. The complaining witness, Andrade, and the accused had a prior association within a homeless encampment. A series of events led to the accused suspecting Andrade of theft. Months later, an encounter in a tent resulted in Andrade alleging that the accused kept her against her will, threatened, assaulted, and forced her to perform oral sex, and stole her wallet. The accused admitted to receiving oral sex but maintained it was consensual and denied the other charges. Forensic evidence and multiple witness testimonies were presented at trial.The Fourth Judicial District Court in Missoula County presided over a jury trial, during which the prosecution and several witnesses repeatedly referred to Andrade as “the victim.” The defense objected to this terminology, arguing it undermined the presumption of innocence and prejudiced the jury, but the court overruled these objections. Additionally, over defense objections, the court permitted the prosecution to elicit testimony about the accused’s request to his girlfriend to “wipe” his phone, which the prosecution used to suggest consciousness of guilt and criminal propensity.The Supreme Court of the State of Montana reviewed the case on appeal. It held that the pervasive reference to Andrade as “victim” was improper in a case where the existence of a crime and the credibility of the complaining witness were central, thereby undermining the presumption of innocence and the right to a fair trial. Further, the court found that admitting evidence about the phone-wiping request violated evidentiary rules, as it was irrelevant, unduly prejudicial, and constituted inadmissible character evidence. The Supreme Court reversed the convictions and remanded for a new trial. View "State v. Sandberg" on Justia Law

Centron Services, Inc., a debt collector, brought suit against Christopher and Alyson Hollewijn to recover on five separate medical debt accounts assigned to Centron by three different medical providers for services rendered between December 2020 and March 2022. The Hollewijns received billing statements from the providers, with one account in particular involving Bozeman Health and a hospital bill for services rendered on November 4, 2021. After insurance paid a portion of the bill and applied a unilateral “provider discount,” Bozeman Health billed the Hollewijns for the remaining balance. The Hollewijns, through their health plan, disputed the charge in writing 93 days after the first billing statement.The Hollewijns moved for summary judgment in the Montana Eighteenth Judicial District Court, Gallatin County, focusing only on the Bozeman Health account for November 4, 2021. The District Court granted summary judgment in their favor and dismissed the entire suit, finding that Centron could not establish an account stated as a matter of law. The court determined that the Hollewijns’ written objection to the bill was timely, defeating Centron’s claim.On appeal, the Supreme Court of the State of Montana held that the District Court erred in dismissing all five accounts when only one was addressed in the Hollewijns’ motion, as no evidentiary or legal showing was made for the other four. The Supreme Court also found that whether the Hollewijns’ 93-day delay in objecting to the Bozeman Health bill was unreasonable presented a genuine issue of material fact for the jury, not an issue to be resolved by summary judgment. The Supreme Court reversed the District Court’s order and remanded for further proceedings. View "Centron v. Hollewijn" on Justia Law

Police discovered illegal drugs and drug paraphernalia at Felicia Marie Hinkle’s residence, resulting in charges against her for criminal possession of dangerous drugs and drug paraphernalia. Her initial trial in Cascade County was scheduled for August 2023, but procedural errors in juror notification and empanelment led the Eighth Judicial District Court to vacate the trial. The court issued detailed instructions to correct the juror selection process and rescheduled the trial for November 2023. Before the new trial, Hinkle moved to discharge the jury panel, arguing two individuals on the panel had moved out of the county, and requested a hearing supported by her attorney’s affidavit.The Eighth Judicial District Court reviewed Hinkle’s motion and noted that the revised jury selection procedures had been implemented, referencing findings from a hearing held before Judge Kutzman in State v. Burden, where substantial compliance with statutory requirements was found. The court took judicial notice of the Burden proceedings and concluded that the inclusion of nonresident names in the jury pool was a predictable but non-prejudicial outcome of the process, and that the panel for Hinkle’s case was drawn in accordance with statutory requirements. The court denied Hinkle’s motion and did not conduct a hearing.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred by denying Hinkle’s motion without a hearing. Applying the substantial compliance standard from State v. Hillious, the Supreme Court held that technical deviations in jury selection statutes that do not affect the randomness or objectivity of the pool, nor a defendant’s right to a fair and impartial jury, do not warrant reversal or a hearing. The court affirmed the District Court’s decision, finding no substantial failure or prejudicial error in the jury selection process. View "State v. Hinkle" on Justia Law

Police stopped the defendant’s vehicle after connecting it to a recent trespass and burglary. The investigation led to charges of felony criminal possession of dangerous drugs and misdemeanor possession of drug paraphernalia. The case proceeded to a jury trial. During jury selection, defense counsel questioned potential jurors about the presumption of innocence and the defendant’s right not to testify. Prospective juror M.W. expressed that, while he would prefer the defendant to rebut the State's evidence, he could acquit if the State’s case was weak and acknowledged the presumption of innocence. Defense counsel moved to strike M.W. for cause, arguing his statements raised concerns about his impartiality.The Twenty-First Judicial District Court, Ravalli County, denied the motion to strike M.W. for cause, finding M.W. had not expressed a fixed bias and could be fair. Haacke used a peremptory challenge to remove M.W. The jury ultimately found Haacke guilty, and the District Court imposed concurrent suspended sentences. Haacke appealed, arguing the court erred by not removing M.W. for cause, relying on Montana law that a juror should be excused if their state of mind raises serious doubts about impartiality.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in denying the challenge for cause. The Court held that, under the totality of the circumstances, M.W.’s statements did not amount to a fixed bias or raise a serious question about his ability to be impartial. The Court found no abuse of discretion by the District Court and affirmed Haacke’s conviction. The main holding is that the District Court did not err in refusing to strike M.W. for cause, as the record did not compel a finding of serious doubt about his impartiality. View "State v. Haacke" on Justia Law

A group of petitioners proposed a constitutional amendment, designated as Ballot Issue 8 (BI-8), which would add a new section to the Montana Constitution. This amendment would explicitly recognize a fundamental right to initiative and referendum and set forth procedural protections to ensure the timely, impartial, and unburdened exercise of those rights. BI-8 also contains limits on governmental interference, including a prohibition on the use of government resources to support or oppose ballot measures. The Attorney General determined that BI-8 was legally insufficient, arguing it violated the Montana Constitution’s separate-vote requirement by effecting multiple, unrelated constitutional changes. The Attorney General also appended a fiscal statement to BI-8, based on speculative litigation costs, despite the fiscal note indicating zero fiscal impact.The Montana Attorney General’s legal-sufficiency determination was challenged in the Supreme Court of the State of Montana under its original jurisdiction. The main arguments centered on whether BI-8 improperly combined multiple unrelated constitutional subjects and whether the Attorney General had statutory authority to append a fiscal statement when the fiscal note showed no fiscal impact.The Supreme Court of the State of Montana held that BI-8 constituted a single constitutional amendment because its provisions were closely related and collectively served to define and protect the right to initiative and referendum. The Court explained that procedural protections and government-resource limitations were integral components of the proposed right, not separate constitutional subjects. The Court further held that the Attorney General lacked authority to append a fiscal statement since the fiscal note did not indicate a fiscal impact. As a result, the Court reversed the Attorney General’s determination, struck the fiscal statement, and ordered the Attorney General to prepare ballot statements for submission to the Secretary of State. View "Kendrick v. Knudsen" on Justia Law

The case concerns a series of events beginning with a brief acquaintance between the defendant and a Helena, Montana resident, who had recently purchased a vehicle. The resident reported the vehicle stolen two days after the purchase. The following day, the resident’s son witnessed the defendant in possession of the vehicle, which led to a chase ending in a crash that caused property damage. The defendant fled on foot and entered a nearby home without permission, where he was eventually found and apprehended by law enforcement.The State charged the defendant with Criminal Mischief, Burglary, and later, Bail Jumping after he failed to appear for court proceedings. The trial was delayed for approximately 18 months, during which a key witness, the homeowner who discovered the defendant in his house, relocated to Washington State and faced significant family and health-related responsibilities. Because of these circumstances, the State sought and obtained permission from the First Judicial District Court, Lewis and Clark County, for the witness to testify at trial via two-way videoconferencing, over the defendant’s objection. The jury found the defendant guilty on all charges.On appeal, the Supreme Court of the State of Montana reviewed whether the district court violated the defendant’s right to confrontation under the Sixth Amendment and the Montana Constitution by allowing live, remote testimony. The Supreme Court held that the district court did not err, explaining that case-specific findings demonstrated that remote testimony furthered an important public policy, considering the witness’s caretaking responsibilities and the travel burden. The court clarified that the “Craig test” for remote testimony does not require a showing of unavailability or a good-faith prosecutorial effort to secure in-person testimony if the witness is otherwise available by video. The defendant’s conviction was affirmed. View "State v. Johnson" on Justia Law