Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the district court denying Defendant's motion to suppress evidence found during a probation search of the room Defendant rented from a person on probation, holding that Defendant had a legitimate expectation of privacy in his residence.Defendant rented a room from Parischere Hughes (Paris), who was on misdemeanor probation and subject to probation searches. During a probation search of Paris's residence, law enforcement officers searched Defendant's residence and found drugs and drug paraphernalia. Defendant was charged criminal possession of dangerous drugs, a felony. Defendant filed a motion to suppress, arguing that the search exceeded the scope of any lawful probation search of Paris's residence. The district court denied the motion. The Supreme Court reversed, holding that Defendant's rights to privacy in his person and residence were not diminished by Paris's probationary status. View "State v. Thomas" on Justia Law

The Supreme Court affirmed the order of the district court dismissing Appellants' complaint and denying Appellants' motion to amend their complaint, holding that Appellants' declaratory judgment claims challenging the constitutionality of Mont. Code Ann. 17-1-512 and amended Mont. Code Ann. 39-71-2320 did not present a justiciable controversy.Appellants sought a declaration that section 17-1-512 and the amended section 39-71-2320 violated several provisions of the United States and Montana Constitutions. Appellants further sought a permanent injunction enjoining the enforcement and authorization of the statutes. The district court dismissed the complaint. The Supreme Court affirmed, holding that Appellants' declaratory judgment claims challenging the constitutionality of section 17-1-512 and amended section 39-71-2320 did not present a justiciable controversy. View "Moody's Market, Inc. v. Montana State Fund" on Justia Law

The Supreme Court affirmed the order of the district court affirming the Acting Roosevelt County Superintendent of School's grant of a territory transfer from Poplar Elementary School District No. 9 to Froid Elementary School District No. 65 pursuant to Mont. Code Ann. 20-6-105, holding that the Acting Superintendent did not abuse her discretion, and that Poplar's constitutional challenges failed.On appeal, Poplar argued that the Acting Superintendent's decision granting the territory transfer petition constituted an abuse of discretion and that section 20-6-105, the territory transfer statute, is unconstitutional both facially and as applied. The Supreme Court affirmed, holding (1) the district court correctly determined that the Acting Superintendent did not abuse her discretion in granting the petition to transfer the transfer territory; (2) the doctrines of res judicata and collateral estoppel barred Poplar's facial constitutional challenge; and (3) Poplar's as-applied challenge failed because a school district does not have a constitutional right to due process. View "Poplar Elementary School District No. 9 v. Froid Elementary School District No. 65" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony strangulation of his girlfriend, holding the evidence was sufficient to support the conviction, and Defendant did not receive ineffective assistance of counsel.Specifically, the Supreme Court held (1) the evidence was sufficient to sustain Defendant's conviction of felony strangulation; (2) Defendant failed to meet the prejudice standard set forth in Strickland v. Washington, 466 U.S. on his claim that his counsel was ineffective by opening the door to evidence of Defendant's prior violence; and (3) this Court declines to review for plain error Defendant's argument challenging the district court's instruction on the mental state for strangulation. View "State v. Dineen" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of sexual intercourse without consent, holding that the district court did not err in denying Defendant's motion to strike a prospective juror for cause.After the district court denied Defendant's motion to remove the prospective juror for cause Defendant used a peremptory challenge to strike her from the panel and exhausted all of his peremptory challenges. Defendant appealed, arguing (1) the prospective juror's voir dire statements demonstrated an inability to act fairly and impartially in his trial, and therefore, the district court abused its discretion in denying his for-cause challenge; and (2) because he had to exercise a peremptory strike to remove the juror and subsequently exhausted his peremptory challenges, the error was prejudicial. The Supreme Court disagreed, holding that the district court did not abuse its discretion in accepting the prospective juror's assurances that she could fairly and impartially weigh the evidence despite her initial statements of prejudice. View "State v. Morales" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's motion to suppress the evidence discovered during a police officer's chemical "field test" on the contents of a syringe found in Defendant's jacket pocket, holding that a rudimentary chemical field test of a lawfully seized substance is not a constitutionally protected search requiring a warrant.Defendant was placed under arrest after driving with a suspended driver's license and without vehicle insurance. While searching Defendant incident to his arrest, the arresting officer located a used syringe in Defendant's front jacket pocket. When booking Defendant into jail, the officer conducted a field test on the contents of the syringe. The field test came back positive for methamphetamine. Defendant filed a motion to suppress, arguing that the field test of the syringe's contents without a warrant constituted an unlawful search that violated his reasonable expectations of privacy. The district court denied the motion to suppress. The Supreme Court affirmed, holding that Defendant had no reasonable expectation of privacy violated by a test for the presence of methamphetamine in a syringe lawfully seized from his person, and therefore, Defendant could not assert the constitutional protections afforded to a search. View "State v. Funkhouser" on Justia Law

The Supreme Court affirmed the district court's denial of Appellant's petition for postconviction relief and the court's order granting partial summary judgment in favor of the State, holding that the district court did not err.Defendant was convicted of vehicular homicide while under the influence, failure to stop immediately at the scene of an accident involving an injured person, and driving without a valid driver's license. Defendant later filed a petition for postconviction relief, alleging ineffective assistance of counsel (IAC), Brady violations, and newly discovered evidence of her innocence. The district court granted summary judgment on Defendant's newly discovered evidence claims and Brady claim and then denied the remainder of the claims after a hearing. The Supreme Court affirmed, holding that the district court did not err by (1) denying Defendant's postconviction petition based on her claim of ineffective assistance of counsel; (2) concluding that the State did not violate Defendant's due process rights by failing to disclose certain non-exculpatory photographs; and (3) dismissing Defendant's newly discovered evidence claim. View "Garding v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for attempted deliberate homicide and evidence tampering, both felonies, holding that the district court did not commit plain error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not commit plain error by not intervening sua sponte to limit or cure the State's closing argument that Defendant's failure to retreat or summon police prior to using deadly force was unreasonable; (2) the district court did not commit plain error by not intervening sua sponte to limit or cure the State's closing and rebuttal argument references to Defendant's post-Miranda silence; and (3) the State's closing argument regarding an alternative factual basis for the evidence tampering charge did not effect an improper de facto amendment of the substance of the charging information. View "State v. Trujillo" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for criminal possession of dangerous drugs, a felony, holding that the district court did not err by denying Defendant's motion to suppress evidence obtained from a warrantless search.On appeal, Defendant conceded that probable cause existed for law enforcement's entry into his hotel room but argued that the agents' warrantless entry was not justified because no exigent circumstances existed. The district court relied on specific and articulable facts from the agents that prompt action was necessary to prevent the probable destruction of drug evidence. The Supreme Court affirmed, holding that the district court did not err in determining that exigent circumstances existed justifying the agents' warrantless entry into Defendant's hotel rooms. View "State v. Vegas" on Justia Law

The Supreme Court reversed Defendant's conviction for sexual assault, holding that the municipal court erred when it instructed the jury on a definition of "consent" from the 2017 sexual assault statute and not the applicable 2015 statute, and the erroneous jury instruction prejudicially affected Defendant's substantial rights.At trial, the court instructed the jury, over Defendant's objection, on the definition of consent contained in recent amendments to the sexual assault statute. On appeal, Defendant argued that the municipal court failed to apply the correct law when instructing the jury on the elements of the claimed offense. The district court denied the appeal. The Supreme Court reversed, holding (1) the instructions, as a whole, did not fully and fairly instruct the jury on the law applicable to the case; and (2) Defendant's substantial due process right was prejudiced by the erroneous jury instruction. View "City of Missoula v. Zerbst" on Justia Law