Justia Montana Supreme Court Opinion Summaries

The case revolves around Kyle Severson, who was convicted for mitigated deliberate homicide after shooting Tyler Hayden. Severson, his girlfriend, her sister, and his daughter were at a convenience store when Hayden and Dalton Watson arrived. Hayden approached Severson's car, and Severson shot him, claiming he feared Hayden would harm him or his daughter. Severson was charged with deliberate homicide and later found guilty of mitigated deliberate homicide, resulting in a forty-year prison sentence.Severson appealed his conviction, arguing that the District Court erred in denying his motion to dismiss based on the State's failure to disclose favorable evidence and that the cumulative effect of errors in the District Court denied him a fair trial. The undisclosed evidence included law enforcement investigative reports of a burglary at Severson's home and the contents of Watson's cell phone.The Supreme Court of the State of Montana concluded that the cumulative effect of errors in the proceedings denied Severson his constitutional rights to a fair trial and due process. The court found that the prosecutor's misconduct and the State's failure to disclose certain evidence had a direct bearing on the credibility of the witnesses at trial. The court reversed Severson's conviction and remanded the case for a new trial. View "State v. Severson" on Justia Law

The case involves a group of plaintiffs, including Forward Montana, Leo Gallagher, Montana Association of Criminal Defense Lawyers, and Gary Zadick, who challenged the constitutionality of two amendments to Senate Bill 319 (SB 319) passed by the Montana Legislature during the 2021 legislative session. The amendments, added during a closed-door committee meeting, were unrelated to the original subject of the bill, which was campaign finance. The plaintiffs argued that the amendments violated two sections of the Montana Constitution: Article V, Section 11(1), which requires that a law not be so altered or amended on its passage through the legislature as to change its original purpose, and Article V, Section 11(3), which requires that each bill contain only one subject, clearly expressed in its title.The District Court of the First Judicial District ruled in favor of the plaintiffs, finding that the amendments violated the aforementioned sections of the Montana Constitution. The court permanently enjoined the enforcement of the contested sections of SB 319. The State of Montana, the defendant in the case, did not appeal the decision, effectively acknowledging the unconstitutionality of the bill.The plaintiffs then sought attorney fees under the private attorney general doctrine and the Uniform Declaratory Judgments Act (UDJA). The District Court denied the request, finding that the case was a "garden-variety" constitutional challenge undeserving of attorney fees under the doctrine. The court also denied fees under the UDJA, finding that the circumstances did not make fees equitable.The Supreme Court of the State of Montana reversed the District Court's decision, ruling that the plaintiffs were entitled to attorney fees under the private attorney general doctrine. The court found that the plaintiffs had vindicated important constitutional rights and that private enforcement was necessary due to the State's defense of the unconstitutional law. The court remanded the case to the District Court for calculation of attorney fees. View "Forward Montana v. State" on Justia Law

The Supreme Court of the State of Montana ruled on a case involving a dispute over a proposed ballot initiative related to reproductive rights. In the case, Montanans Securing Reproductive Rights and Samuel Dickman, M.D. (MSRR) sought a declaratory judgment arguing that the Attorney General’s proposed ballot statement for Constitutional Initiative 14 (CI-14) was argumentative, prejudicial, and inaccurate. MSRR also contended that their own proposed ballot statement was clear and impartial and should have been approved by the Attorney General.The court considered whether MSRR could challenge the Attorney General’s ballot statement under relevant statutes and whether the Attorney General had violated certain sections of the Montana Code Annotated by submitting an argumentative, prejudicial, and/or inaccurate ballot statement for CI-14 and by declining to approve MSRR’s proposed ballot statement.The court concluded that the Attorney General’s interpretation of the statute led to an absurd result that abrogated due process. Therefore, MSRR could challenge the Attorney General’s ballot statement under the relevant statutes. The court also found the Attorney General’s ballot statement for CI-14 failed to comply with statutory requirements as it did not fairly present the voters with what was proposed within the Initiative.However, the court disagreed with MSRR’s contention that the Attorney General was required to approve its ballot statement. The court concluded that while the Attorney General’s statement was deficient, he had the statutory authority to determine if MSRR's ballot statement complied with the requirements. The court then crafted a new ballot statement that complied with statutory requirements. View "Montanans Securing Reproductive Rights v. Knudsen" on Justia Law

This case concerns the constitutionality of several Montana election laws. The plaintiffs, a variety of political and human rights organizations, sued the Montana Secretary of State, arguing that certain election laws were unconstitutional. The challenged laws included provisions restricting absentee voting, changing voter registration deadlines, banning paid absentee ballot collection, and revising voter ID requirements.The Montana Supreme Court affirmed the lower court's judgment, finding that each of the challenged statutes were unconstitutional. The Court held that the laws either impermissibly interfered with or minimally burdened the right to vote, a fundamental right under the Montana Constitution. The Court applied a strict scrutiny or a middle-tier analysis, depending on the extent of the burden on the right to vote, and determined that the state failed to show that the laws were the least onerous path to a compelling state interest or were reasonable and more important than the burden on the right to vote. The Court rejected the Secretary of State's argument that the laws were necessary for administrative efficiency and to ensure the integrity, reliability, and fairness of the election process. View "Democratic Party v. Jacobsen" on Justia Law

In Montana, Robert Murray Gibbons was found guilty of driving under the influence, his fifth or subsequent offense. On appeal to the Montana Supreme Court, Gibbons raised three issues. First, he argued that the District Court incorrectly instructed the jury that he did not need to be conscious to be in actual physical control of his vehicle. The Supreme Court disagreed, finding that the instruction was consistent with the preventative purpose of the state's DUI statute.Second, Gibbons argued that the State’s rebuttal argument, which suggested that he could have introduced photographic evidence that was available to him during discovery, violated his constitutional rights. The Supreme Court rejected this argument, concluding that the State was entitled to respond to Gibbons’ accusation that it had improperly withheld evidence.Finally, Gibbons challenged the constitutionality of the statute that imposed a mandatory minimum $5,000 fine for his offense, arguing that it did not take into account a defendant’s ability to pay. The Supreme Court agreed with Gibbons on this point, finding that the statute was facially unconstitutional because it required the imposition of a mandatory fine in every case without considering constitutionally required proportionality factors, such as the financial burden on the defendant and the defendant’s ability to pay.Thus, the Supreme Court affirmed Gibbons’s DUI conviction, but reversed the $5,000 fine and remanded the case to the District Court for recalculation of the fine in line with its opinion. View "State v. R. Gibbons" on Justia Law

In this case, petitioners Montanans Securing Reproductive Rights and Samuel Dickman, M.D., sought a declaratory judgment on original jurisdiction against the Montana Attorney General and the Montana Secretary of State. The petitioners argued that the Attorney General wrongly determined that their proposed ballot issue was legally insufficient, had no authority to attach a fiscal statement to the ballot issue, and that their ballot statements complied with Montana Code Annotated sections 13-27-212 and -213.The Supreme Court of Montana held that the Attorney General did err in concluding that the proposed ballot issue was legally insufficient, as it did not violate the separate-vote requirement of Article XIV, Section 11, of the Montana Constitution. The proposal effects a single change to the Montana Constitution on a single subject: the right to make decisions about one's own pregnancy, including the right to abortion.The court also found that the Attorney General exceeded his authority by appending a fiscal statement to the proposed ballot issue because the budget director's fiscal note did not indicate that the issue would have a fiscal impact.Finally, the court declined to rule on the compliance of the petitioners’ ballot statements with Montana Code Annotated sections 13-27-212 and -213, directing the Attorney General to prepare a ballot statement in line with statutory requirements and forward it to the Montana Secretary of State.The court essentially concluded that the proposed ballot issue was legally sufficient and did not require separate votes for its multiple components, as they were all closely related to the central issue of reproductive rights. The court also confirmed that the Attorney General had overstepped his authority by attaching a fiscal statement to the ballot issue. View "Montanans Securing Reproductive Rights v. Knudsen" on Justia Law

The Supreme Court of Montana overturned the conviction of Daniel Christopher Rowe for sexual assault, a felony. Rowe was initially charged with the offense for multiple instances of abuse that allegedly took place over several years against H.B., who was under sixteen years of age at the time of the offenses. The case was remanded for a new trial due to two significant issues.First, the court found the lower court erred in admitting a subsequent uncharged act of sexual assault as proof of motive or plan to commit the earlier sexual assaults charged under a "common scheme." The court reasoned that the State had charged Rowe with a non-existent offense not recognized under Montana law, which led to the improper admission of other bad acts evidence.Second, the court found that the lower court erred in giving the jury both conduct-based and result-based definitions of "knowingly" for the sexual assault charge without specifying to the jury which definition applied to which elements of the offense. The court determined that this lowered the State's burden of proof, which violated Rowe's right to due process. The Supreme Court of Montana reversed Rowe's sexual assault conviction and remanded the case for further proceedings. View "State v. Rowe" on Justia Law

In Montana, a group of plaintiffs, including Forward Montana, Leo Gallagher, Montana Association of Criminal Defense Lawyers, and Gary Zadick, challenged two amendments to Senate Bill 319 (SB 319) on the grounds that they violated Article V, Section 11 of the Montana Constitution. The amendments, added in the final days of the legislative session without public comment, expanded the bill's scope beyond its initial focus on campaign finance to include regulations on political activities on college campuses and judicial recusal requirements. The District Court found that the amendments violated the Single Subject Rule and Rule on Amendments of the Montana Constitution, and permanently enjoined their enforcement. However, the court declined to award attorney fees to the plaintiffs under the private attorney general doctrine, reasoning that the case was a "garden-variety" constitutional challenge.Upon appeal, the Supreme Court of the State of Montana disagreed, reversing and remanding the decision regarding attorney fees. The court held that the plaintiffs had satisfied all three factors required for attorney fees under the private attorney general doctrine: the societal importance of the public policy vindicated by the litigation (constitutional limitations on legislative power), the necessity for private enforcement and the burden on the plaintiffs, and the large number of people standing to benefit from the decision. Despite the District Court's finding that the case was a "garden-variety" constitutional challenge, the Supreme Court determined that the Legislature's willful disregard of constitutional duties and legislative rules and norms in adopting these amendments justified the award of attorney fees. The case was remanded to the District Court for calculation of attorney fees. View "Forward Montana v. State" on Justia Law

In the case, Jose Martinez Jr. was convicted by a jury in the Thirteenth Judicial District Court, Yellowstone County, for two counts of incest, criminal distribution of dangerous drugs, solicitation to commit tampering with witnesses or informants, and three counts of criminal contempt. This case arose from allegations by Martinez's stepdaughter, S.M., that he had been sexually abusing her since she was 10 years old. The trial court allowed the admission of statements made by S.M. to a Sexual Assault Nurse Examiner (SANE) and a physician, despite Martinez's objection that their admission violated his right of confrontation as S.M. was not present to testify at the trial.The Supreme Court of Montana affirmed Martinez's conviction. It held that S.M.'s statements to the physician were nontestimonial and made for purposes of medical treatment, and thus, were admissible under Montana Rule of Evidence 803(4). However, the court found that S.M.'s statements to the SANE were testimonial and their admission violated Martinez's right to confrontation. Nevertheless, the court ruled that this error was harmless given other evidence produced at trial and because the SANE's testimony was cumulative.The court's decision reflected the distinction between testimonial and nontestimonial statements in the context of the right to confrontation, and the admissibility of statements for purposes of medical treatment under the rules of evidence. The court also demonstrated the application of the harmless error doctrine in the context of a Confrontation Clause violation. View "State v. Martinez" on Justia Law

The case involves Tylor Buttolph who appealed his conviction of stalking. Buttolph had been charged with eight counts of felony stalking, allegedly occurring between October 17, 2019, and April 6, 2020. For each count of stalking, the State listed only one act of misconduct. However, the stalking statute requires a "course of conduct" involving two or more acts. The State used evidence of prior, uncharged conduct to prove the "course of conduct" element.The Supreme Court of the State of Montana reversed the conviction. The court held that Buttolph's constitutional right to due process was violated when the State used an act not charged in the information to prove "course of conduct" for the offense of stalking. The court reasoned that the State cannot shift its theory of criminality on the day of trial without violating Buttolph's fundamental right to due process. The charging document was silent as to the second act constituting the course of conduct element of the offense, and thus, there was no "statement of facts constituting the offense charged". View "State v. Buttolph" on Justia Law