Justia Montana Supreme Court Opinion Summaries

In 2012, Montana voters passed Legislative Referendum 121 (LR 121). The referendum denied certain state services to “illegal aliens.” Before the law went into effect, Montana Immigrant Justice Alliance (MIJA) filed a complaint seeking declaratory and injunctive relief from LR 121, arguing that the referendum violated certain constitutional rights and was preempted by federal law. The district court denied Plaintiffs’ request for a preliminary injunction as to the majority of LR 121 but enjoined the use of the definition of “illegal alien” so as to preclude the State from using an individual’s unlawful entry into the United States as a factor in determining that individual’s entitlement to state benefits. The district court subsequently concluded that LR 121 was preempted by federal law. The court then awarded MIJA attorney fees. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in concluding that MIJA has associational standing to challenge LR 121; (2) did not err in concluding that LR 121 is preempted by federal law; and (3) erred in awarding “supplemental relief” to MIJA in the form of attorney fees. View "Montana Immigrant Justice Alliance v. Bullock" on Justia Law

After a jury trial, Defendant was found guilty of criminal possession. The district court sentenced him as a persistent felony offender to a term of twenty years, with ten of those years suspended. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress evidence of methamphetamine that law enforcement officers found on Defendant’s person after conducting a search incident to his lawful arrest for violating the terms of his parole; (2) Defendant was not prejudiced by his counsel’s failure to file proposed findings of fact and conclusions of law following the evidence hearing relating to his suppression motion; (3) the district court did not abuse its discretion by denying Defendant’s third discovery request; (4) the district court did not err by denying Defendant’s post trial motion to dismiss based upon the Court’s failure to arraign him on the second amended information; and (5) the district court conducted an “adequate initial inquiry” into Defendant’s complaints concerning his assigned counsel. View "State v. Crawford" on Justia Law

Appellant was convicted of deliberate homicide and related felonies and misdemeanors. Appellant was sentenced to life imprisonment for the deliberate homicide conviction. The Supreme Court affirmed the convictions on appeal. Thereafter, Appellant filed a petition for postconviction relief, alleging ineffective assistance of counsel during his trial. The district court denied postconviction relief. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on any of his claims of ineffective assistance of counsel; and (2) because there was no ineffective assistance of counsel on Appellant’s individual claims, there can be no cumulative error. View "Heavygun v. State" on Justia Law

After a jury trial, Defendant was convicted of felony murder, aggravated assault, and related charges. The Supreme Court reversed the conviction for aggravated assault because it was an included offense of the charge of felony murder and affirmed the remaining convictions. Defendant subsequently filed a petition for postconviction relief, asserting that his attorneys at trial and on appeal provided ineffective assistance. The district court denied Defendant’s petition for postconviction relief. The Supreme Court affirmed, holding that the district court did not err in deciding that Defendant did not receive ineffective assistance of counsel at trial and on appeal. View "Russell v. State" on Justia Law

The district court granted a permanent injunction against the enforcement of certain provisions of the 2011 Montana Marijuana Act. The State appealed the grant of the injunction, and Plaintiffs cross-appealed the district court’s refusal to enjoin other provisions of the Act. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) erred in determining that the Act’s provision requiring the Department of Public Health and Human Services to notify the Board of Medical Examiners of any physician who certifies twenty-five or more patients in a year for medical marijuana fails rational review; (2) did not err in determining that the Act’s commercial prohibitions fail rational basis review; (3) erred in applying strict scrutiny review to the Act’s provision prohibiting advertising by providers of medical marijuana; (4) did not err in determining that the Act’s provision prohibiting probationers from becoming registered cardholders for medical marijuana use withstands a facial challenge under rational basis scrutiny; and (5) did not err in determining that the Act’s provision allowing warrantless inspections of medical marijuana providers’ businesses comports with constitutional guarantees against unreasonable searches. View "Mont. Cannabis Indus. Ass’n v. State" on Justia Law

After a warranted search of Defendant’s home, law enforcement officers seized sixty-seven live marijuana plants and numerous miscellaneous paraphernalia. Defendant moved to suppress the evidence seized during the search of his residence, arguing that the application for the warrant lacked sufficient facts to establish probable cause that his home contained drugs or drug-related evidence. The district court denied Defendant’s combined motion to suppress and dismiss. Thereafter, Defendant pled guilty to criminal possession with intent to distribute dangerous drugs. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress and dismiss, holding that the magistrate had a substantial basis for concluding there was a probability of criminal activity. View "State v. Kant" on Justia Law

Plaintiff sought disclosure of a settlement agreement entered into by a Cascade County detention officer, Cascade County, and the officer’s collective bargaining unit (the Union). The only barrier to disclosure of the settlement agreement was the resistance of the Union. The district court ultimately granted Plaintiff’s motion and ordered the County to disclose the settlement agreement. Plaintiff subsequently filed a motion for an award of costs and attorney fees under Mont. Code Ann. 2-3-221. The request was directed solely against the Union. The district court awarded Plaintiff his costs but denied his request for attorney fees. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Plaintiff’s motion for attorney fees because the sole entity from which the fees were sought - the Union - is not a public or governmental body subject to Mont. Const. art. II, 9. View "Shockley v. Cascade County" on Justia Law

After a jury trial, Defendant was found guilty of criminal possession of dangerous drugs. Defendant was sentenced to five years in prison. Defendant appealed, arguing that the district court erred in denying his motions to suppress evidence and to dismiss the case for lack of evidence, arguing that the arresting police officer did not have particularized suspicion to conduct a stop of Defendant. The Supreme Court affirmed, holding that the district court correctly denied Defendant’s motions to suppress and to dismiss, as, based on the totality of the facts and circumstances of this case, the police officer had particularized suspicion to conduct an investigatory stop of Defendant. View "State v. Ballinger" on Justia Law

After a jury trial at which Defendant represented himself, Defendant was found guilty of the felony offense of assault with a weapon. The district court sentenced Defendant to a twenty-year prison sentence with ten years suspended. The Supreme Court affirmed. Defendant later filed a petition for postconviction relief. The district court dismissed the petition, concluding that Defendant’s trial-related claims were procedurally barred because they could have been brought on direct appeal and that Defendant’s ineffective assistance of counsel claims were without merit. The Supreme Court affirmed in part and reversed in part, holding (1) the district court correctly determined that Defendant’s trial-related claims were procedurally barred; (2) the district court correctly dismissed most of Defendant’s ineffective assistance of counsel claims because they lacked merit; but (3) one of Defendant’s ineffective assistance of counsel claims could not be resolved, as neither the record nor the district court’s order is sufficient to review for correctness the district court’s general conclusions. Remanded. View "Chyatte v. State" on Justia Law

After a jury trial, Defendant was found guilty of felony driving under the influence of alcohol (DUI). Defendant appealed, contending that the prosecution’s comments suggesting that she could have proven her innocence by providing a breath test to law enforcement constituted prosecutorial misconduct and impermissibly asserted that Defendant was responsible for establishing her innocence, thereby denying Defendant her due process right to a fair and impartial trial. The Supreme Court affirmed, holding (1) Defendant did not properly preserve her allegations of prosecutorial misconduct for appeal; and (2) the prosecutor’s remarks were improper but did not rise to a level sufficient to find plain error. View "State v. Favel" on Justia Law