Justia Montana Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of one count each of sexual intercourse without consent, sexual assault, and sexual abuse of children. Defendant appealed, arguing that the district court abused its discretion by failing to conduct an adequate inquiry into his request for substitute counsel and that he was denied the effective assistance of counsel. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by denying Defendant’s request for substitute counsel, and further investigation by the court was unnecessary; and (2) Defendant’s claim that he received ineffective assistance of counsel is dismissed without prejudice to raising it in a postconviction relief proceeding. View "State v. Cheetham" on Justia Law

Maggie Petaja was terminated from her position with Lewis and Clark County when she was age fifty-nine. After unsuccessfully pursuing relief on the administrative level, Petaja, a member of a collective bargaining unit represented by the Montana Public Employees’ Association (MPEA), filed a discrimination claim against the County. Petaja also filed suit against MPEA, alleging breach of the duty of fair representation. The jury returned a verdict in favor of the County on the discrimination claim and against MPEA on the breach of the duty of fair representation claim. The Supreme Court affirmed, holding (1) substantial evidence supported the jury verdict finding MPEA breached its duty of fair representation; (2) the jury verdict was not contrary to the instructions and law; and (3) the district court correctly found that it had no legal authority to award attorney fees. View "Petaja v. Mont. Pub. Employees’ Ass’n" on Justia Law

After a jury trial, Defendant was found guilty of driving under the influence, second offense. Defendant appealed, demanding a trial de novo. Defendant also filed a motion to dismiss, arguing that his constitutional rights had been violated by his trial being conducted by a non-lawyer judge in a court of record without trial de novo. The district court denied the motion to dismiss. The Supreme Court affirmed, holding that Defendant’s trial before a non-lawyer justice of the peace, even where a trial de novo was not available on appeal, did not violate his constitutional right to effective assistance of counsel or to due process. View "State v. Davis" on Justia Law

After Plaintiff’s employment with Butte-Silver Bow County was terminated, Plaintiff filed a complaint against the County alleging several counts. The district court granted summary judgment to the County on most of Plaintiff’s claims. The court, however, denied summary judgment with respect to Plaintiff’s claim that the County violated Mont. Code Ann. 39-2-904(1)(b), holding that factual questions remained as to whether the County had good cause for Plaintiff’s termination. The Supreme Court affirmed, holding that the district court did not err in (1) granting summary judgment in the County’s favor with respect to Plaintiff’s claims that the County violated Montana’s open meeting laws and public participation laws; (2) granting summary judgment in the County’s favor with respect to Plaintiff’s 42 U.S.C. 1983 claim; (3) ruling that the County did not discharge Plaintiff in violation of its own policies or for refusing to violate public policy; and (4) concluding that Plaintiff was entitled to a trial on her claim that the County terminated her employment without good cause. View "Moe v. Butte-Silver Bow Co." on Justia Law

After a jury trial, Defendant was found guilty of criminal possession. The district court sentenced him as a persistent felony offender to a term of twenty years, with ten of those years suspended. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress evidence of methamphetamine that law enforcement officers found on Defendant’s person after conducting a search incident to his lawful arrest for violating the terms of his parole; (2) Defendant was not prejudiced by his counsel’s failure to file proposed findings of fact and conclusions of law following the evidence hearing relating to his suppression motion; (3) the district court did not abuse its discretion by denying Defendant’s third discovery request; (4) the district court did not err by denying Defendant’s post trial motion to dismiss based upon the Court’s failure to arraign him on the second amended information; and (5) the district court conducted an “adequate initial inquiry” into Defendant’s complaints concerning his assigned counsel. View "State v. Crawford" on Justia Law

Appellant was convicted of deliberate homicide and related felonies and misdemeanors. Appellant was sentenced to life imprisonment for the deliberate homicide conviction. The Supreme Court affirmed the convictions on appeal. Thereafter, Appellant filed a petition for postconviction relief, alleging ineffective assistance of counsel during his trial. The district court denied postconviction relief. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on any of his claims of ineffective assistance of counsel; and (2) because there was no ineffective assistance of counsel on Appellant’s individual claims, there can be no cumulative error. View "Heavygun v. State" on Justia Law

After a jury trial, Defendant was convicted of felony murder, aggravated assault, and related charges. The Supreme Court reversed the conviction for aggravated assault because it was an included offense of the charge of felony murder and affirmed the remaining convictions. Defendant subsequently filed a petition for postconviction relief, asserting that his attorneys at trial and on appeal provided ineffective assistance. The district court denied Defendant’s petition for postconviction relief. The Supreme Court affirmed, holding that the district court did not err in deciding that Defendant did not receive ineffective assistance of counsel at trial and on appeal. View "Russell v. State" on Justia Law

After a warranted search of Defendant’s home, law enforcement officers seized sixty-seven live marijuana plants and numerous miscellaneous paraphernalia. Defendant moved to suppress the evidence seized during the search of his residence, arguing that the application for the warrant lacked sufficient facts to establish probable cause that his home contained drugs or drug-related evidence. The district court denied Defendant’s combined motion to suppress and dismiss. Thereafter, Defendant pled guilty to criminal possession with intent to distribute dangerous drugs. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress and dismiss, holding that the magistrate had a substantial basis for concluding there was a probability of criminal activity. View "State v. Kant" on Justia Law

After a jury trial, Defendant was found guilty of criminal possession of dangerous drugs. Defendant was sentenced to five years in prison. Defendant appealed, arguing that the district court erred in denying his motions to suppress evidence and to dismiss the case for lack of evidence, arguing that the arresting police officer did not have particularized suspicion to conduct a stop of Defendant. The Supreme Court affirmed, holding that the district court correctly denied Defendant’s motions to suppress and to dismiss, as, based on the totality of the facts and circumstances of this case, the police officer had particularized suspicion to conduct an investigatory stop of Defendant. View "State v. Ballinger" on Justia Law

After a jury trial at which Defendant represented himself, Defendant was found guilty of the felony offense of assault with a weapon. The district court sentenced Defendant to a twenty-year prison sentence with ten years suspended. The Supreme Court affirmed. Defendant later filed a petition for postconviction relief. The district court dismissed the petition, concluding that Defendant’s trial-related claims were procedurally barred because they could have been brought on direct appeal and that Defendant’s ineffective assistance of counsel claims were without merit. The Supreme Court affirmed in part and reversed in part, holding (1) the district court correctly determined that Defendant’s trial-related claims were procedurally barred; (2) the district court correctly dismissed most of Defendant’s ineffective assistance of counsel claims because they lacked merit; but (3) one of Defendant’s ineffective assistance of counsel claims could not be resolved, as neither the record nor the district court’s order is sufficient to review for correctness the district court’s general conclusions. Remanded. View "Chyatte v. State" on Justia Law