Justia Montana Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of felony DUI, disorderly conduct, and driving with a suspended license, holding that Defendant was not entitled to relief on his unpreserved claim that the district court violated his fundamental right to be present when it discuss with counsel in his absence the potential substitution of an alternate juror.During trial, the trial was continued and the jury was excused. Several days later when the trial resumed a juror failed to appear. The court met with counsel to discuss the juror's absence, but counsel did not object to Defendant's absence. The court decided not to substitute an alternate juror, and the trial resumed that day after the juror arrived. The jury subsequently found Defendant guilty. On appeal, Defendant argued that by holding the conversations regarding the absent juror in his absence the district court violated his right to be present. The Supreme Court affirmed, holding that the violation of Defendant's right to be present did not result in a miscarriage of justice or call the fundamental fairness of his trial into question. View "State v. George" on Justia Law

The Supreme Court affirmed the order of the district court certifying three classes of more than 30,000 ratepayers of the City of Billings who challenged certain franchise fees that the City imposed on water, wastewater, and solid waste disposal services, holding that the district court did not abuse its discretion when it certified the classes.After the City ceased imposing the franchise fees in 2018 the Ratepayers sued the City alleging that the fees constituted unlawful sales taxes. Ratepayers brought claims for breach of contract and constitutional due process violations. The Ratepayers sought class action certification for those similarly situated persons who paid the water and wastewater fees since 2010 and the sold waste disposal fees since 2012. The district court granted the motion and certified three classes. The Supreme Court affirmed, holding that the district court did not err when it certified the classes under Mont. R. Civ. P. 23(b)(3). View "Houser v. City of Billings" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment for the Montana Department of Corrections (DOC) and dismissing Plaintiff's claims for wrongful discharge from employment, violation of Montana constitutional and administrative rights to privacy, and tortious defamation, holding that the district court did not err.Specifically, the Supreme Court held (1) no genuine issues of material fact existed as to whether DOC discharged Plaintiff for good cause, and therefore, the district court properly granted summary judgment on Plaintiff's wrongful discharge claim; (2) no genuine issues of material fact existed as to whether DOC discharged Plaintiff in violation of its written personnel policy, and therefore, the district court properly granted summary judgment on Plaintiff's wrongful discharge claim; (3) the district court did not err in granting summary judgment on Plaintiff's claim that DOC violated her right to privacy under Mont. Const. art. II, 10 and Admin. R. M. 2.21.6615; and (4) the district court did not err in concluding that derogatory statements made by DOC to the Montana Peace Officer Standards and Training Council were privileged under Mont. Code Ann. 27-1-804(2). View "Speer v. State, Department of Corrections" on Justia Law