Justia Montana Supreme Court Opinion Summaries

After a trial, Defendant was convicted for driving under the influence. The Supreme Court affirmed the conviction, holding (1) the district court erroneously allowed the results of a horizontal gaze nystagmus and preliminary breath test to be admitted at trial without expert testimony to establish the reliability of the tests, but the cumulative evidence of Defendant's intoxication presented at trial overcame any reasonable probability that the indirect admission of the test results contributed to Defendant's conviction; and (2) the district court properly exercised its discretion in excluding cross-examination regarding Defendant's blood alcohol content at the time that Defendant had been driving. View "State v. Chavez-Villa" on Justia Law

This was Defendant's second appeal to the Supreme Court. In the prior appeal, the Court affirmed Defendant's conviction of two counts of felony sexual assault and remanded the case for resentencing. The district court subsequently granted Defendant's petition for postconviction relief on the grounds of ineffective assistance of counsel and prosecutorial misconduct. In this interlocutory appeal, Defendant challenged the district court's order denying his motion to dismiss the criminal charges for which the State intended to re-prosecute him on double jeopardy grounds. The Supreme Court affirmed, holding that Defendant's constitutional right to be free from double jeopardy did not prohibit the State from re-prosecuting him after his conviction was overturned by the postconviction court's determination of prosecutorial misconduct and ineffective assistance of counsel. View "State v. Duncan" on Justia Law

A jury convicted Defendant of aggravated burglary and sexual intercourse without consent. Defendant argued on appeal that his convictions should be reversed because his standby counsel had a conflict of interest, the district court erred by modifying the jury instructions regarding aggravated burglary during jury deliberations, and his counsel was ineffective for failing to obtain an independent medical expert. The State conceded reversible error on the instruction issue and requested that Defendant's conviction for aggravated burglary be vacated on that basis. The Supreme Court reversed Defendant's conviction for aggravated burglary and affirmed Defendant's conviction for sexual intercourse without consent, holding (1) Defendant's standby counsel did not have an active conflict of interest that required reversal of Defendant's sexual intercourse without consent conviction; and (2) because the record did not fully explain why an independent medical examination or expert was not ultimately obtained by Defendant's counsel, Defendant's claim that his counsel rendered ineffective assistance by failing to obtain a medical expert could not be reviewed on appeal. View "Longjaw v. State" on Justia Law

Plaintiffs were employees of Defendant Kalispell Regional Medical Center (KRMC). Defendant Northwest Healthcare Corporation (NWHC) was the parent corporation of the remaining defendant entities. This case arose out of a dispute over the discontinuation of a sick leave buy-back program. Defendants appealed the order of the district court granting Plaintiffs' motion for class certification. The Supreme Court affirmed, holding (1) the district court properly determined that the named Plaintiffs had standing to bring claims against defendants they did not directly work for because the juridically linked Defendants were operating under a common scheme; and (2) the district court did not abuse its discretion in certifying the class under Mont. R. Civ. P. 23(a) and (b). View "Chipman v. Nw. Healthcare Corp." on Justia Law

After a bench trial in justice court, Defendant was convicted for DUI per se. At the close of the State's case-in-chief, Defendant moved the justice court to dismiss the charge on grounds of insufficient evidence, arguing that the margin of error in the Intoxilyzer breath test's result created reasonable doubt that Defendant's alcohol concentration had, in fact, reached the statutorily prohibited level. The district court affirmed the justice court's denial of Defendant's motion, concluding that Defendant had forfeited his right to challenge the veracity of his breath test. The Supreme Court affirmed, holding (1) Defendant had an evidentiary right to challenge the veracity of his Intoxilyzer breath test at trial, and the district court erred in concluding otherwise; but (2) the district court did not err in concluding that there was sufficient evidence to support Defendant's conviction, as a rational trier of fact could have found beyond a reasonable doubt that Defendant's alcohol concentration was over the statutorily proscribed limit. View "State v. Gai" on Justia Law

Plaintiff submitted an application for a 119-lot subdivision, which the Board of Missoula County Commissioners denied. Plaintiff petitioned for judicial review of the Board's action and alternatively claimed that the Board's actions constituted a regulatory taking that entitled him to just compensation. The district court granted summary judgment to the County on all of Richard's claims. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by not allowing Plaintiff to conduct further discovery before ruling on the summary judgment motion; (2) the district court properly granted summary judgment to the County on the Board's decision to deny the subdivision; and (3) the County was entitled to summary judgment on Plaintiff's regulatory taking claim. View "Richards v. County of Missoula" on Justia Law

At issue on review in this case was whether the State Board of Land Commissioners properly issued leases to Ark Land Co., a subsidiary of Arch Coal, Inc., without first conducting environmental review under the Montana Environmental Policy Act (MEPA). The State Land Board did not conduct environmental review prior to entering the leases, relying on Mont. Code Ann. 77-1-121(2). The district court granted summary judgment to the State Land Board, Ark Land Co., and Arch Coal (Defendants), determining that the State retained sufficient ability to require adequate environmental protections sufficient to meet its constitutional and trust responsibilities. The Supreme Court affirmed, holding (1) because the leases did not allow for any degradation of the environment and specifically required full environmental review and full compliance with applicable State environmental laws, the act of issuing the leases did not impact or implicate the right to a clean and healthful environment in Mont. Const. art II, 3; and (2) therefore, section 77-1-121(2) was not subject to strict or "middle-tier" scrutiny. View "N. Plains Res. Council, Inc. v. Bd. of Land Comm'rs" on Justia Law

Appellant appealed from his conviction in the district court of one count of felony aggravated assault. Appellant argued (1) his conviction should be reversed under the plain error doctrine because law enforcement failed to investigate his claim of justifiable use of force as required by Mont. Code Ann. 45-3-112; and (2) he received ineffective assistance of counsel because his attorney failed to move for dismissal of his charge. The Supreme Court affirmed, holding (1) Appellant failed to establish that any alleged failure of law enforcement officials to comply with section 45-3-112 prejudiced his defense requiring the Court to exercise plain error review; and (2) Appellant failed to establish that his counsel's representation was ineffective. View "State v. Mitchell" on Justia Law

After a jury trial, Appellant Bobby Cooksey was convicted of deliberate homicide. The district court sentenced Appellant to a term of fifty years in prison with credit for time served. The Supreme Court affirmed, holding (1) the district court properly denied Appellant's motion for a new trial; (2) the district court properly excluded Appellant's offered evidence concerning the presence of the drug Paxil in the deceased's blood; (3) the investigation of the crime was conducted in compliance with Mont. Code Ann. 45-12-112; and (4) Appellant failed to establish that the prosecution's statements during closing argument constituted unfairly prejudicial misconduct. View "State v. Cooksey" on Justia Law

Plaintiff filed an action against a district court judge, seeking damages for the judge's acts or omissions while presiding over a telephone pretrial conference in a civil action then pending before him. At all relevant times the judge was acting in his official capacity as a district court judge with regard to that case and the pretrial conference. The district court granted the judge's motion to dismiss on the grounds of judicial immunity. The Supreme Court affirmed, holding that because the acts of which Plaintiff complained occurred while the judge was conducting the pretrial conference and were clearly within the authority and responsibility of a district court judge, the judge was immune from suit, and the district court properly dismissed Plaintiff's complaint. View "Hartsoe v. McNeil" on Justia Law