Justia Montana Supreme Court Opinion Summaries

Defendant was convicted of felony burglary and misdemeanor criminal mischief. Defendant was sentenced to five years incarceration, all suspended. One of the conditions of Defendant's probation was that he not use or possess illegal drugs. The State later filed a petition to revoke Defendant's suspended sentence for, inter alia, driving under the influence of drugs and crushing up his medications and snorting them, rather than taking them as directed by a physician. Defendant moved for a continuance of his revocation hearing, explaining that a "substantial amount of discovery" had not yet been produced. The district court denied the motion. After a hearing, the district court ordered Defendant's sentence revoked. The Supreme Court affirmed, holding that the district court did not abuse its discretion or violate Defendant's right to due process when it revoked Defendant's probation without requiring full disclosure of all evidence against him. View "State v. Sebastian" on Justia Law

After a jury trial, Appellant was convicted of theft and accountability to burglary. The Supreme Court reversed Appellant's conviction for theft and affirmed Appellant's conviction for accountability to burglary, holding (1) the district court did not err by instructing the jury on the theory of accountability when the State had not directly charged an accountability based offense; (2) Appellant's counsel's failure to object to an instruction on accountability that defined "purposely" as a conduct-based mental state rather than a result-based mental state caused no prejudice to Appellant; but (3) Appellant's counsel rendered ineffective assistance by failing to object to her theft conviction on the grounds that it violated Montana's statutory restriction on multiple charges. Remanded. View "State v. Tellegen" on Justia Law

After a jury trial, Appellant was convicted of the attempted deliberate homicide of her husband, Mike. The Supreme Court affirmed, holding that the district court did not err when it (1) excluded Appellant's proposed expert witness testimony from two expert witnesses about the behaviors of individuals in abusive relationships and the experts' diagnoses of Appellant with post-traumatic stress disorder; and (2) admitted Mike's alleged prior inconsistent statement to a volunteer firefighter responding to a medical emergency when Mike could not remember making the statement, as the statement was admissible under Mont. R. Evid. 801(d)(a)(A). View "State v. Lotter" on Justia Law

Five City employees were disciplined by the City for accessing pornography on their government computers. The local newspaper requested access to documents detailing the investigation of the misconduct and the employees' punishment. The City disclosed some documents, refused to release the disciplinary corrective action forms, and redacted all information that could be used to identify the disciplined employees or uninvolved third parties. The newspaper filed a petition for declaratory relief and writ of mandamus. The district court ordered that the City release copies of the investigative documents and disciplinary forms without redactions. The Supreme Court reversed, holding that the district court erred by ordering that identifying information for the five City employees be released to the newspaper, as the employees' reasonable expectation of privacy in their identities with regards to internal disciplinary proceedings clearly outweighed the limited merits of public disclosure. View "Billings Gazette v. City of Billings" on Justia Law

Appellant was convicted of criminal distribution of dangerous drugs and sentenced to a ten-year term of incarceration. On appeal, Appellant argued that insufficient evidence supported his conviction because the State did not produce sufficient evidence at trial that the substance given to a third party was marijuana, a dangerous drug. The State responded that although the substance was not tested, the third party's testimony and the fact that Appellant had a medical marijuana card were sufficient to prove that the substance was marijuana. The Supreme Court reversed Appellant's conviction, holding that the evidence presented at trial was insufficient to allow a rational trier of fact to conclude beyond a reasonable doubt that the substance in question was a dangerous drug. View "State v. Burwell" on Justia Law

Plaintiffs were covered by the State's employee healthcare benefit program established under Title 2, chapter 18, MCA ("the Plan"). Both Plaintiffs were injured in separate automobile accidents. All of the medical bills of both plaintiffs were paid by either the Plan or by third-party insurers. In both cases, medical care providers returned a claim payment to the Plan because the claim had been paid by other insurers. Plaintiffs asserted that the Plan should not have retained the payments returned by the medical providers but should have paid those amounts to Plaintiffs unless they had been made whole or fully compensated for all losses they incurred as a result of the automobile accidents. The district court concluded that the State's operation of the Plan was subject to the "made-whole" provisions Title 2, and thus, no insurer had a right to subrogation unless the insured was made whole for all losses. The Supreme Court affirmed, holding that the made-whole requirement of Mont. Code Ann. 2-18-902(4) applied to the Plan insofar as it had withheld payments or had retained payments returned by a healthcare provider because the medical expenses had been paid by a third party. View "Diaz v. State" on Justia Law

Appellant entered Alford pleas to the felony offenses of aggravated kidnapping, aggravated assault, assault with a weapon, intimidation, and aggravated burglary. Appellant later moved to withdraw his Alford pleas, contending that his mental state at the time of the pleas precluded him from knowingly and voluntarily making a plea decision, he was innocent to the changes against him, and the district court's colloquy was insufficient to determine whether the pleas were knowingly and voluntarily made. The district court denied Appellant's motion. The Supreme Court affirmed, holding (1) Appellant failed to establish that there was good cause to allow him to withdraw his prior Alford pleas to the charges against him; and (2) the matter should be remanded to the district court for a determination of the total amount of restitution for the victim's future counseling costs. Remanded. View "State v. Peterson" on Justia Law

After police officers knocked on the door to Defendant's residence to ask for directions they confiscated forty plants of marijuana. Defendant pled guilty to criminal production or manufacture of dangerous drugs, a felony. Defendant appealed the denial of his motion to suppress the results of the search of his residence, arguing that because officers had no reason to enter his property, they were not lawfully in a place where they could see the marijuana in plain view. The Supreme Court (1) affirmed the district court's denial of Defendant's motion to suppress, as the officers were lawfully on Defendant's property, and thus their observations of the marijuana in plain view were an appropriate basis for the charges; but (2) reversed the district court's imposition of the cost of court-appointed counsel, as the amount of that cost exceeded the statutorily allowed amount. View "State v. Phillips" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual assault and sentenced to concurrent 100 year sentences, with fifty years of each sentence suspended. The Supreme Court affirmed, holding that Defendant's trial counsel did not render ineffective assistance in (1) failing to object to the admission of certain incidences of hearsay testimony by various witnesses, as the testimony either fell among the hearsay exceptions provided for in the Montana Rules of Evidence or defense counsel may have had strategic reasons for not objecting; and (2) stipulating to the admission of multiple items of evidence that Defendant alleged contained otherwise inadmissible hearsay evidence, as Defendant's allegations implicated questions of trial strategy that exceeded the scope of the record. View "State v. Mederos" on Justia Law

Defendant pleaded no contest to one count of felony criminal endangerment pursuant to a plea agreement. Prior to sentencing, Defendant filed a motion to withdraw his plea, which the district court denied. The district court then imposed a ten-year suspended sentence. Defendant filed a motion to withdraw his plea, arguing that the district court failed to establish a sufficient factual basis for his no contest plea, and therefore, there was doubt as to whether Defendant entered his plea voluntarily. The Supreme Court affirmed, holding that the district court did not err by denying Defendant's motion to withdraw plea, as the district court established a sufficient factual basis for the offense, Defendant was made aware of the consequences of the plea, and the plea was made voluntarily. View "State v. Jackson" on Justia Law