Justia Montana Supreme Court Opinion Summaries

In the case, Jose Martinez Jr. was convicted by a jury in the Thirteenth Judicial District Court, Yellowstone County, for two counts of incest, criminal distribution of dangerous drugs, solicitation to commit tampering with witnesses or informants, and three counts of criminal contempt. This case arose from allegations by Martinez's stepdaughter, S.M., that he had been sexually abusing her since she was 10 years old. The trial court allowed the admission of statements made by S.M. to a Sexual Assault Nurse Examiner (SANE) and a physician, despite Martinez's objection that their admission violated his right of confrontation as S.M. was not present to testify at the trial.The Supreme Court of Montana affirmed Martinez's conviction. It held that S.M.'s statements to the physician were nontestimonial and made for purposes of medical treatment, and thus, were admissible under Montana Rule of Evidence 803(4). However, the court found that S.M.'s statements to the SANE were testimonial and their admission violated Martinez's right to confrontation. Nevertheless, the court ruled that this error was harmless given other evidence produced at trial and because the SANE's testimony was cumulative.The court's decision reflected the distinction between testimonial and nontestimonial statements in the context of the right to confrontation, and the admissibility of statements for purposes of medical treatment under the rules of evidence. The court also demonstrated the application of the harmless error doctrine in the context of a Confrontation Clause violation. View "State v. Martinez" on Justia Law

The case involves Tylor Buttolph who appealed his conviction of stalking. Buttolph had been charged with eight counts of felony stalking, allegedly occurring between October 17, 2019, and April 6, 2020. For each count of stalking, the State listed only one act of misconduct. However, the stalking statute requires a "course of conduct" involving two or more acts. The State used evidence of prior, uncharged conduct to prove the "course of conduct" element.The Supreme Court of the State of Montana reversed the conviction. The court held that Buttolph's constitutional right to due process was violated when the State used an act not charged in the information to prove "course of conduct" for the offense of stalking. The court reasoned that the State cannot shift its theory of criminality on the day of trial without violating Buttolph's fundamental right to due process. The charging document was silent as to the second act constituting the course of conduct element of the offense, and thus, there was no "statement of facts constituting the offense charged". View "State v. Buttolph" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to suppress evidence obtained during a probation home visit, holding that the district court did not err in denying the suppression motion.Defendant was convicted of bail jumping and received a deferred sentence of four years. After a probation home visit resulted in the discovery of a "significant amount of methamphetamine" by a probation officer the State petitioned to revoke Defendant's deferred sentence. Defendant filed a motion to suppress, arguing that the discovery of the drugs found in her home was the result of an unlawful search. The district court denied the motion, concluding that the officer did not violate the reasonable protocols for a probation home visit. The Supreme Court affirmed, holding that what began as a home visit turned into a search pursuant to the officer's plain view observation of drug paraphernalia, which provided probable cause for the search. View "State v. Thompson" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant to seventy years in Montana State Prison for deliberate homicide, a felony, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's claim that his trial attorney provided ineffective assistance when he advised Defendant and the court that mitigated deliberate homicide was not a lesser-included offense of deliberate homicide was more appropriate for postconviction relief; and (2) the district court did not err when it concluded that the State's offer of proof provided sufficient evidence to accept Defendant's Alford plea. View "State v. Bristow" on Justia Law

The Supreme Court affirmed the decision of the Attorney General rejecting a constitutional initiative proposed for the 2024 ballot (B12), of which Petitioner was a proponent, holding that the Attorney General correctly determined that the new facial content proposed by B12 violated the separate-vote requirement in Mont. Const. art. XIV, 11.The Attorney General concluded that B12, which would amend Mont. Const. art. VIII, 3, was legally insufficient due to a violation of the separate-vote requirement and ambiguity in the text of the initiative. The Supreme Court affirmed the decision and enjoined the Secretary of State from approving petitions for circulation to the electorate for signatures or otherwise submitting the measure for approval by voters, holding that the separate-vote issue was dispositive and that the Attorney General properly concluded that B12 violated the constitutional separate-vote requirement. View "Monforton v. Knudsen" on Justia Law

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

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

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

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

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