Justia Montana Supreme Court Opinion Summaries

A police officer stopped Defendant’s car after recognizing him as a person who had a suspended driver’s license. The officer placed Defendant under arrest and conducted a pat-down search leading to the discovery of a prescription medication bottle in the cuff of Defendant’s leg. Defendant later pleaded guilty to felony criminal possession of dangerous drugs. Defendant appealed the denial of his motion to suppress the contents of the prescription bottle seized at the time of his arrest, arguing that the opening of the pill bottle was an illegal search. The Supreme Court affirmed, holding that Defendant had no reasonable expectation of privacy in the pill bottle because he claimed no ownership of the bottle or its contents, and therefore, there was no search in the constitutional sense. View "State v. McKeever" on Justia Law

Plaintiff’s position of employment with the Emergency Services Division of the State of Montana Department of Military Affairs was eliminated during implementation of the Division’s reduction-in-force policy. After her position was eliminated, Plaintiff filed a grievance with the Department of Labor and Industry Hearings Bureau alleging that the Division terminated her in retaliation for her complaint that sexual favoritism had occurred within the Division. The Bureau dismissed the complaint, and Plaintiff chose not to appeal. Instead, Plaintiff filed a discrimination complaint with the Montana Human Rights Bureau of the Department of Labor and Industry, restating her claims. The Department dismissed the complaint. Plaintiff later filed the present complaint in the district court. The district court granted summary judgment in favor of Defendants, concluding that Plaintiff’s claims were time-barred under the Montana Human Rights Act (MHRA). The Supreme Court affirmed, holding that the district court did not err by holding that Plaintiff’s claims were subject to the procedures set forth in the MHRA, and as a result were time-barred. View "Lay v. Dep’t of Military Affairs" on Justia Law

Plaintiff was a veteran suffered from service-connected physical conditions, including a seizure disorder, and he had a service dog that alerted him to oncoming seizures. When staff at the C’Mon Inn, a hotel in Bozeman, Montana, staff refused to allow Plaintiff to register because he was accompanied by his service dog, Plaintiff called 911 and complained that the hotel was discriminating against him by refusing him entry, three Bozeman Police Department officers responded. The officers told Plaintiff he would have to leave but informed Plaintiff that he could file a complaint if he wished. Plaintiff filed this action against the Bozeman Police Department contending that the responding officers violated the Human Rights Act when they “aided, abetted and facilitated” the hotel’s discrimination against him. The district court granted summary judgment to the Bozeman Police Department. The Supreme Court affirmed, holding that there was no evidence that the officers aided or abetted C’Mon Inn’s conduct. View "Hansen v. Bozeman Police Dep’t" on Justia Law

Defendant was charged with two counts of attempted deliberate homicide. Before trial, Defendant moved to suppress statements he made while in custody, arguing that he was never informed of his right to remain silent and that all questioning by law enforcement should have ceased when he asked for an attorney. The district court denied the motion to suppress. Defendant was subsequently convicted on both counts of attempted homicide. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Defendant’s motion to suppress, as the statements he made after he was in custody, after he requested an attorney, and before he was notified of his Miranda rights were spontaneous; and (2) denied Defendant’s motion to exclude one of the victims of the crime from the courtroom. View "State v. Braulick" on Justia Law

M.K.S., who had a long history of treatment for schizophrenia and other mental health illnesses, was regularly subject to community commitments and hospitalizations. In 2013, M.K.S. stipulated to a six-month community commitment. Before the commitment was set to expire, the State filed a renewed petition for commitment. After a commitment hearing, the district court found that M.K.S. posed a danger to herself based on her recent suicidal threats and that a commitment to the Montana State Hospital was necessary to guarantee her safety. The Supreme Court affirmed based on the plain error doctrine, holding that because of a professional person’s failure to file a statutorily-required written report in M.K.S.’s civil commitment proceeding, M.K.S.’s right of due process was implicated in the proceedings. However, M.K.S. failed to demonstrate that the absence of a written report substantially impacted this right in a manner that would leave unsettled the fundamental fairness of the proceedings, compromise the integrity of the judicial process, or create a manifest miscarriage of justice. View "In re M.K.S." on Justia Law

Appellant pleaded guilty to the charge of deliberate homicide. After the matter had been set for sentencing, Appellant sought the appointment of new counsel and also filed a motion for withdrawal of his guilty plea. The district court denied Appellant’s request for the appointment of new counsel and further denied his motion to withdraw his plea. The court then sentenced Appellant to life in prison. The Supreme Court remanded for further proceedings on a limited issue, holding that the district court failed to adequately inquire into Appellant’s complaint that defense counsel had rendered ineffective assistance of counsel. View "State v. Schowengerdt" on Justia Law

After receiving treatment from St. Peter’s Hospital, Plaintiff filed suit alleging that the Hospital violated Montana anti-trust laws and the Montana Constitution by discriminating against her based on her lack of health insurance. After concluding that Plaintiff had standing, the district court awarded summary judgment to the Hospital, determining that uninsured persons are not a protected class under the Montana Constitution. The Supreme Court (1) affirmed the district court’s standing determination; but (2) reversed the court’s entry of summary judgment on the merits, holding that the determinations that the district court made in its summary judgment order did not resolve all of Plaintiff’s claims. Remanded. View "Gazelka v. St. Peter’s Hosp." on Justia Law

After a jury trial in 1984, Defendant was convicted of deliberate homicide for a crime committed when Defendant was seventeen. The district court imposed the maximum sentence of one hundred years’ imprisonment without the possibility of parole, a sentence that was within the discretion of the district court and that was not mandated by law. Defendant attempted in numerous filings to attack his conviction and sentence, to no avail. Defendant now petitioned for a writ of habeas corpus, challenging the constitutionality of his sentence under Miller v. Alabama. The Supreme Court denied the habeas petition, holding that the Miller sentencing consideration rule requiring a sentencing judge to consider a juvenile offender’s age when sentencing that offender to life without parole is not retroactive to Defendant’s claim on collateral review. View "Beach v. State" on Justia Law

Defendant was charged with criminal possession of dangerous drugs in violation of Mont. Code Ann. 45-9-102. Defendant moved to suppress the evidence resulting from the search of her purse by police officers, arguing that the tip the officers received failed to establish particularized suspicion and that her consent to search was involuntary, and therefore, the seizure and search were illegal. The district court denied the motion. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) did not err by concluding that the search of Defendant’s baggage was lawfully executed based upon Defendant’s voluntary consent; and (2) erred in its written judgment by altering Defendant’s sentence from its oral pronouncement. View "State v. Dupree" on Justia Law

Defendant was charged with aggravated assault, criminal mischief, and elder abuse for his conduct during one incident. Defendant filed a pretrial motion requesting that the court order the State to elect between prosecuting him for either aggravated assault or elder abuse, arguing that his federal double jeopardy protections and the protections of Montana’s “multiple charges” statute would be violated if he were prosecuted for both offenses. The district court denied the motion, concluding that the elder abuse statute was neither a lesser-included offense of aggravated assault nor a specific instance of aggravated assault. The Supreme Court dismissed Defendant’s appeal, holding (1) Defendant may be prosecuted for more than one offense arising out of the same transaction; and (2) Defendant’s double jeopardy claim and reliance on the protections of the multiple charges statute were premature. View "State v. Violette" on Justia Law