Justia Montana Supreme Court Opinion Summaries

Martin Vincent Lau was charged with deliberate homicide. Lau claimed that the fatal shooting was an act of self-defense. Lau sought to offer his own out-of-court statement to prove that at the time of the shooting, he knew of specific instances of violence by the victim. The State moved in limine to prohibit Lau from introducing the statement on hearsay grounds. Lau, in turn, argued that the exclusion of his statement would limit his ability to put forth a defense and that he would be required to testify in order to establish his knowledge of specific instances of conduct by the victim. The district court ruled that Lau would be permitted to cross-examine witnesses about the victim's specific acts of violence and Lau’s knowledge of those acts, as contained in his statement. The Supreme Court granted the State’s petition for writ of supervisory control, holding that the Montana Rules of Evidence did not permit Lau to offer his own out-of-court statement in support of his claim of justifiable use of force.View "State v. District Court" on Justia Law

Defendant was charged with trespass to property and possession of dangerous drugs, both misdemeanor offenses. Defendant subsequently decided to enroll in the Mineral County Treatment Court. Defendant was aware that he could be sanctioned with incarceration if he was dishonest during his participation in the Treatment Court. During his participation in the Treatment Court Defendant tested positive for drug use and was interviewed by the Treatment Team regarding the results. Subsequently, a member of the Treatment Team sent a report to law enforcement detailing the information he learned from the interviews with Defendant. Defendant was subsequently charged with distribution of dangerous drugs and two counts of possession of dangerous drugs. Defendant filed motions to suppress and dismiss, arguing that the State violated the confidentiality provision of Mont. Code Ann. 46-1-1111(4) and his Fifth Amendment right against compelled self-incrimination by disclosing the confidential Treatment Court material to law enforcement. The district court denied the motions. The Supreme Court reversed the district court’s denial of Defendant’s motions to suppress and dismiss, holding that the State violated section 46-1-1111(4) by disclosing confidential drug testing information to law enforcement in order to investigate a new criminal offense.View "State v. Plouffe" on Justia Law

After a jury trial, Defendant was convicted of two counts of deliberate homicide. The Supreme Court affirmed the conviction on appeal. Defendant subsequently filed a petition for postconviction relief alleging that the State had failed to disclose exculpatory and impeachment evidence relevant to the case in violation of Brady v. Maryland and that his trial attorneys failed to provide effective assistance of counsel. The district court denied the petition. The Supreme Court affirmed, holding (1) the district court properly denied Defendant’s postconviction petition because the petition did not fulfill the elements of a Brady violation; and (2) any alleged error on the part of trial counsel did not prejudice Defendant, and therefore, the trial court did not err in concluding that Defendant had not received ineffective assistance of counsel.View "McGarvey v. State" on Justia Law

In 2011, Defendant was charged with driving under the influence of alcohol (DUI) and disorderly conduct. Defendant pleaded not guilty and requested a jury trial. The trial court later informed Defendant that his scheduled trial was rescheduled because an older case had been set for trial on the same day. Before his rescheduled trial, Defendant moved to have his case dismissed for lack of a speedy trial. The municipal court granted the motion. The district court reversed. On remand, Defendant was convicted of DUI and acquitted of disorder conduct. The Supreme Court reversed the district court ruling reversing the municipal court’s dismissal of the charges, holding that the City failed to meet its burden of showing “good cause” for the delay in bringing Defendant to trial.View "City of Helena v. Broadwater" on Justia Law

Defendant was charged with felony driving under the influence (DUI) and misdemeanor driving without valid liability insurance. Defendant entered pleas of not guilty and then filed a motion to dismiss for denial of his right to a speedy trial. After an evidentiary hearing, the district court denied Defendant’s motion to dismiss. Defendant then changed his plea to guilty on both charges, reserving the right to appeal the denial of his speedy trial motion. The Supreme Court reversed and remanded for dismissal of the charges, holding that the delay in bringing Defendant to trial violated his constitutional right to a speedy trial.View "State v. Zimmerman" on Justia Law

After a jury trial, Defendant was convicted of deliberate homicide. Defendant appealed, arguing that the district court erred by denying his motion to suppress statements he made to the police. The Supreme Court remanded with instructions to hold an evidentiary hearing. After a hearing on remand, the district court suppressed Defendant’s statements to the police on the grounds that the statements were made involuntarily and granted Defendant a new trial. The Supreme Court affirmed, holding that the district court did not err in concluding that Defendant’s statements were made involuntarily and in ordering a new trial.View "State v. OldHorn" on Justia Law

After a trial, Appellant was convicted of sexual intercourse without consent and sexual assault. The Supreme Court affirmed. Thereafter, Appellant filed a petition for postconviction relief raising numerous claims of ineffective assistance of counsel. The district court denied relief. The Supreme Court affirmed the district court’s denial of Appellant’s petition for postconviction relief, holding (1) counsel was not ineffective for failing to request dismissal of the charges against Defendant for the State’s alleged destruction of evidence or a jury instruction regarding the State’s failure to collect and preserve the subject evidence; and (2) counsel did not act unreasonably when he withdrew a proposed jury instruction on sexual assault as a lesser included offense.View "Taylor v. State" on Justia Law

After a jury trial, Defendant was convicted of felony sexual assault. Defendant later filed a petition for postconviction relief seeking DNA testing and alleging that he had received ineffective assistance of counsel (IAC). The district court denied the petition, but the Supreme Court reversed and remanded. Defendant subsequently filed a second petition requesting that he be allowed to conduct discovery. The district court denied both Defendant’s petition for DNA testing and his request to conduct discovery but granted relief as it pertained to his IAC claim. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in denying Defendant’s petition for DNA testing; and (2) erred in granting Defendant’s petition as it pertained to IAC of appellate counsel, as any error on appellate counsel’s part was harmless. View "Golden v. State" on Justia Law

Defendant pleaded guilty to tampering with witnesses and informants. Defendant subsequently filed a motion to withdraw his guilty plea, which the district court denied. Defendant appealed, arguing that he should be allowed to withdraw his guilty plea because his counsel misinformed him about his eligibility for a persistent felony offender designation. The Supreme Court affirmed the district court’s order denying Defendant’s motion to withdraw his guilty plea, holding (1) the district court correctly determined that Defendant was fully aware of the direct consequences of his plea and that the plea was not induced by misrepresentation; and (2) therefore, Defendant failed to show that, but for counsel’s deficient performance, he would not have entered a guilty plea.View "State v. Hendrickson" on Justia Law

In 1988, Appellant was convicted of misdemeanor assault and felony sexual intercourse without consent and was also designated a persistent felony offender (PFO). In 2013, Appellant filed a petition for writ of habeas corpus, claiming that he was wrongly sentenced for both the underlying felony and his PFO status. The Supreme Court granted the petition and remanded for correction of the illegal sentence. On remand, the district court resentenced Appellant during a status conference docketed under a newly-created civil cause number when neither Defendant nor his attorney were present. The Supreme Court reversed, holding that Appellant was sentenced with a complete lack of statutory or constitutional process. Remanded for a sentencing hearing.View "State v. McEvoy" on Justia Law