Justia Montana Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court affirmed Defendant's conviction of aggravated kidnapping, sexual intercourse without consent, and partner or family member assault, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) Mont. Code Ann. 45-5-303(2) is not facially unconstitutional because it permits a judge, rather than a jury, to apply factors that reduce the maximum penalty; (2) Defendant's level three offender designation was objectionable, not illegal, and Defendant did not properly reserve his objection to the designation during sentencing; and (3) Defendant's counsel was not ineffective for failing to argue that the maximum sentence for kidnapping was ten years based on mitigating factors and failing to object to Defendant's level-three sex offender designation. View "State v. Pine" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress and dismiss, holding that Defendant's warrantless arrest was unlawful, and therefore, it was error for the district court not to suppress and exclude the evidence discovered as a result of the unlawful search.Defendant pled guilty to criminal possession of dangerous drugs, reserving his right to appeal the denial of his motion to suppress and dismiss. On appeal, Defendant argued that the underlying arrest was illegal and led directly to the discovery of the incriminating evidence. The Supreme Court agreed and reversed, holding that the district court erred by not suppressing and excluding the evidence at issue. View "State v. Price" on Justia Law

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The Supreme Court affirmed the order of the district court determining that there was no genuine dispute of material fact that a routine clothed body search did not violate Appellant's Eighth Amendment rights, holding that there was no error.Appellant, an inmate, filed an amended complaint alleging that Sergeant Larry Pasha's performance of a routine clothed body search of Appellant violated his Eighth Amendment rights. The district court granted summary judgment to Appellees on all claims. The Supreme Court affirmed, holding that there was no genuine dispute of material fact that Sergeant Pasha's search of Appellant was routine and did not violate Appellant's Eighth Amendment rights. View "Lawrence v. Pasha" on Justia Law

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The Supreme Court affirmed the judgment and orders approving a settlement between Robert Allum and Montana State Fund and dismissing Allum's claims for benefits, holding that Allum resolved all of his dispute benefits, and therefore, the Workers' Compensation Court (WCC) did not have jurisdiction over Allum's remaining stand-alone constitutional challenges.The State Fund accepted liability for the knee injury Allum received at work. Later, Allum notified State Fund that he also asserted a back condition resultant from his knee injury. Allum filed a petition seeking a hearing on his injury claims and also sought a hearing on his claims challenging the constitutionality of the Montana Workers' Compensation Act and the WCC. Allum and State Fund settled the injury claims prior to trial. The WCC approved the settlement agreement and then concluded that it lacked jurisdiction to address Allum's constitutional challenges because Allum had resolved all of his benefit disputes. The Supreme Court affirmed, holding that the WCC's conclusions of law were correct. View "Allum v. Mont. State Fund" on Justia Law

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The Supreme Court affirmed the order of the district court requiring Broadwater County to provide to Helena Independent Record (IR) or other interested persons redacted videographer and documentation records pertaining to Jason Ellsworth's May 2021 stop by and encounter with a Montana Highway Patrol officer, holding that there was no error.Ellsworth pleaded guilty to an obstructing a peace officer. Thereafter, a reporter with the IR requested from Broadwater County a copy of Ellsworth's investigative file. Petitioner, a county attorney, determined that the file contained confidential criminal justice information and filed a petition seeking a declaratory ruling to clarify and enforce the rights of recovery to redacted confidential criminal justice information (CCJI) contained in the file. Petitioner also filed a separate motion for leave to deposit the investigative file under seal. The district court (1) concluded that Ellsworth's criminal case had been completed and that the declaratory action was ripe for decision; and (2) held that Ellsworth's privacy rights outweighed the public's right to know regarding certain information irrelevant to the charge. The Supreme Court affirmed, holding that Ellsworth was given a proper opportunity to participate, and his due process right was not infringed regarding the release of the CCJI. View "Broadwater Co. v. Release of Confidential Criminal Justice Information" on Justia Law

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The Supreme Court affirmed in part and reversed the judgment of the district court convicting Defendant of aggravated burglary and obstructing a police officer and sentencing him to forty years for aggravated burglary and six months for obstructing a peace officer, holding that the case must be remanded for resentencing.Specifically, the Supreme Court held (1) Defendant's constitutional right to a speedy trial was not violated; (2) Defendant's claim of instructional error not warrant plain error review because he failed to show how he was prejudiced; (3) Defendant's ineffective assistance of counsel claim must fail because Defendant he to show any prejudice; and (4) Defendant was entitled to resentencing because the district court relied on incorrect information when it imposed the sentence. View "State v. Kirn" on Justia Law

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The Supreme Court reversed the decision of the district court concluding that Plaintiffs - a climate advocacy group and three NorthWestern Energy ratepayers - had standing to challenge Mont. Code Ann. 69-8-421 as unconstitutional and then invalidating the statute, holding that Plaintiffs' challenge to the preapproval statute was not justiciable.At issue was section 69-8-421, which effectively permitted NorthWestern, but no other public utility, to apply to the Montana Public Service Commission for preapproval of an electricity supply resource. Plaintiffs filed a complaint requesting declaratory judgment that the preapproval statute violated both Mont. Const. art. II, 31 and Mont. Const. art. V, 12. NorthWestern filed a motion to dismiss for both lack of standing and ripeness. The district court denied the motion. The Supreme Court reversed, holding (1) Plaintiffs lacked standing to raise the rights of non-party utilities; and (2) Plaintiffs' alleged consumer injuries were not yet ripe for consideration. View "350 Montana v. State" on Justia Law

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The Supreme Court affirmed the decision of the district court to deny Petitioner's petition to reinstate his driver's license, holding that the district court did not err in denying the petition because Petitioner did not meet his burden to prove that the suspension of his driver's license was improper.On appeal, Petitioner argued that his request to speak to an attorney prior to taking a preliminary breath test and a post-arrest blood test should not have been taken as an implied refusal to submit to either test and, therefore, he did not refuse to take the tests. The Supreme Court affirmed, holding (1) the record reflected that Petitioner explicitly refused to take the tests; and (2) the district court correctly denied Petitioner's petition. View "Turner v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court ruling that Mont. Code Ann. 50-20-109(1)(a), which restricts providers of abortion care to physicians and physician assistants (PAs), violates a woman's fundamental right of privacy, guaranteed by the Montana Constitution, to seek abortion care from a qualified health care provider of her choosing, holding that there was no error.In reaching its decision, the district court concluded that the State failed to "clearly and convincingly demonstrate a medically acknowledged, bona fide health risk which justifies interfering with a patient's fundamental right[....]to choose the health care provider who performs the [abortion] procedure[.]" The Supreme Court affirmed, holding (1) there is no medically acknowledged, bona fide health risk for the State to restrict the availability of abortion care by preventing Advanced Practice Registered Nurses (APRNs) from performing abortions; and (2) therefore, Montanans have the right to seek abortion care from certified APRNs. View "Weems v. State" on Justia Law

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The Supreme Court reversed the conclusion of the district court that the more than three-year delay between Defendant's arrest and his subsequent criminal trial did not violate his constitutional right to a speedy trial, holding that Defendant did not receive his guaranteed right to a speedy trial.Defendant was charged with assault with a weapon. After facing a lengthy wait to be evaluated for his mental fitness to stand trial Defendant received a bed at the Montana State Hospital (MSH), where his fitness for trial improved. Defendant's fitness, however, decompensated after he was sent back to jail, leading to a second admission to MSH before the case finally went to trial. A jury found Defendant guilty, and the district court denied Defendant's motion to dismiss for lack of speedy trial. The Supreme Court reversed, holding that the 1,179-day delay between Defendant's arrest and trial, due to systemic institutional problems, violated Defendant's constitutional right to a speedy trial. View "State v. Allery" on Justia Law