Justia Montana Supreme Court Opinion Summaries

Late one night, a Jefferson County reserve deputy came upon a car parked in a posted "day use only" fishing access site in Madison County. The deputy made contact with the car's driver, Floyd Updegraff, and ascertained that Updegraff was intoxicated. A second deputy Jefferson County deputy responded to the scene and placed Updegraff under arrest for DUI. A jury ultimately convicted Updegraff of felony DUI and other offenses. Updegraff appealed, arguing that the district court erred in denying his motion to suppress the evidence because (1) if the deputies were acting under color of law, they had no authority to make an arrest in Madison County, or (2) the deputies were acting as private citizens, in which case they failed to comply with the private person arrest statute. The Supreme Court affirmed, holding (1) in order to make a warrantless arrest, an out-of-jurisdiction officer must meet the arrest standard that would apply to a private person in the same circumstances, but if this standard is met, the officer may then follow the procedures applicable to peace officers in processing the arrest; and (2) applying this approach to the circumstances in this case, Updegraff's arrest was legal. View "State v. Updegraff" on Justia Law

Jesse Kirk was convicted by a jury of burglary and criminal possession of dangerous drugs. The district court issued a pre-trial order denying Kirk's motion to sever the counts, concluding that the counts in the amended information were properly joined and that severance was not required to avoid an unfair trial. The Supreme Court affirmed, holding (1) because the burglary and drug charges were linked by a common motive and because the burglary occasioned the second charge of criminal possession of dangerous drugs, the counts in the amended information were properly joined; and (2) the district court did not abuse its discretion in finding that severance was not required to avoid an unfair trial where Kirk did not prove that, while he may have faced some prejudice as a result of the joint trial, the prejudice was so great that it prevented a fair trial. View "State v. Kirk" on Justia Law

Defendant crashed into a car driven by a seventeen-year-old. The victim suffered several injuries, including a shattered ankle. Defendant subsequently entered a guilty plea to felony criminal endangerment and was sentenced to ten years' incarceration with all but 180 days suspended. The district court also ordered Defendant to pay restitution for the victim's summer wages, the victim's father's lost wages, and unpaid medical expenses. The Supreme Court affirmed, holding (1) the district court properly imposed restitution for lost wages, and (2) the district court did not exceed the bounds of reason or act arbitrarily under the circumstances in imposing the maximum length sentence allowed under statute. View "State v. Dodson" on Justia Law

Riley Styren's vehicle was struck by Sherry Roos's vehicle. Styren and the owner of her vehicle (collectively, Styren) filed a complaint against Roos, Roos's mother, Julia, and Curtis Stordahl, who together owned the car Roos was driving. The complaint alleged claims of negligence against Roos and negligent entrustment and liability under the family purpose doctrine against Julia and Stordahl. The district court granted summary judgment for Julia and Stordahl. A jury then found Roos was not negligent. The Supreme Court affirmed, holding that the district court properly (1) granted summary judgment to Julia on the negligent entrustment claim as there was no evidence that Julia knew that Roos was an incompetent driver or that Roos would drive in a manner that created an unreasonable risk to others; (2) granted summary judgment to Julia on the family purpose doctrine claim where Styren did not meet her burden to raise genuine issues of material fact in opposition to Julia's motion; and (3) denied Styren's motion for a new trial where Styren did not meet her burden on appeal to demonstrate that the district court erred and the jury's verdict was legal and supported by substantial evidence. View "Styren Farms v. Roos" on Justia Law

The State charged Michael Hass with three offenses, one of which was a DUI. The Stated alleged that Hass had three prior DUI convictions, making the DUI a felony. Hass filed a motion challenging the validity of one of his prior DUI convictions, arguing that his constitutional rights to counsel and to due process were violated when the trial judge in that case allowed Hass's counsel to withdraw on the day of trial and then proceeded to try and convict Hass in absentia. In the instant case, pursuant to a plea agreement, Hass pleaded guilty to fourth-offense DUI, and the remaining counts were dismissed. The Supreme Court reversed the district court's decision denying Hass's motion challenging the validity of his earlier DUI conviction and vacated the felony DUI sentence imposed by the district court, holding that the prior DUI conviction was constitutionally infirm and could not be used for sentence enhancement purposes. Remanded with instructions to resentence Hass for misdemeanor DUI. View "State v. Hass" on Justia Law

The City Police Department conducted an internal investigation of an administrative coordinator, who was placed on administrative leave after she allegedly misused public funds. The Department created a sixteen-page due process letter detailing the evidence against the coordinator, who subsequently resigned. The Billings Gazette requested the letter, but the City declined to release it. The Gazette sued the City. The district court ordered that the document be provided to the Gazette. The Supreme Court affirmed, holding (1) where two constitutional rights are implicated, including the public's right to know about the actions of public agencies and employees and the employees' right to privacy, the district court must balance the two rights to determine whether the employees' right to privacy outweighs the public's right to know; (2) in this case, the coordinator did not have a reasonable expectation of individual privacy to the document because she held a position of trust with the Department and she was accused of breaching that trust; and (3) the mere prospect of a criminal case will not deprive the public of its right to access a public document once that right has been balanced against the right to privacy. View "Gazette v. City of Billings" on Justia Law

Susan Overfield was charged with assault and disturbing the peace after appearing to speak at a City Commission meeting about perceived conflicts of interest between City officials and the Animal Foundation of Great Falls. Overfield subsequently sued the City. Before the City and Overfield settled the case, the district court concluded (1) the Animal Foundation, its trustee, and its attorney (Petitioners), who were non-parties in the underlying case, were in contempt for wrongfully redacting information from documents produced to Overfield, and (2) the Foundation was in contempt for failing to appear at a deposition with subpoenaed documents. After the case was settled, the district court entered an order awarding Overfield attorney fees against the Petitioners based on the contempt orders. The Supreme Court (1) affirmed the contempt orders of the district court, holding that the district court properly considered and decided the contempt issues below without referral to another judge, and the contempt orders were supported by substantial evidence; but (2) vacated the district court's order to arrest the trustee, the court's imposition of sanctions against an attorney who filed a protective order on behalf of the Foundation, and the court's order awarding attorney fees. Remanded. View "Animal Found. of Great Falls v. Dist. Court" on Justia Law

Charley Johnson entered a nolo contendere plea to intimidation for repeated sexually assaultive behavior against his stepdaughter. During sentencing, the district court (1) sentenced Johnson to a ten-year commitment to the department of corrections, (2) required Johnson to pay for counseling costs previously incurred by his stepdaughter as well as an undetermined amount for future counseling costs she would incur the period of Johnson's sentence, and (3) imposed a condition restricting Johnson from places where children can congregate. The Supreme Court (1) affirmed, holding that Johnson failed to preserve for appellate review the issue of whether the district court erred in imposing restitution for past and future counseling expenses incurred by the victim, but (2) remanded for calculation for future restitution in compliance with Mont. Code Ann. 46-18-244. View "State v. Johnson" on Justia Law

After a police officer arrested Jason Jenkins for driving a motorcycle under the influence of alcohol, Jenkins agreed to a breath test. Jenkins was subsequently convicted of driving under the influence (DUI). On appeal, Jenkins contended that the district court erred by admitting field certification documents as part of the foundation for the admission of the results of his breath test, alleging that they were hearsay because the officer who submitted the documents was not the author or custodian of the documents. The Supreme Court affirmed, holding that the district court did not abuse its discretion in admitting the results of the breath test because case law has established that when a district court is determining whether there is adequate foundation for admission of breath test results in a DUI prosecution, Mont. R. Evid. 104(4)(a) authorizes the court to do so without regard to whether the certification forms are hearsay. View "State v. Jenkins" on Justia Law

Bill Thomas was convicted and sentenced for deliberate homicide. Thomas subsequently field a petition for writ of habeas corpus, which the district court denied. Thomas filed a notice of appeal. At issue before the Supreme Court was whether the Court would continue to consider a party's appeal from a district court's denial of a petition for writ of habeas corpus as an original petition. The Supreme Court held (1) a district court's denial of a petition for writ of habeas corpus in a criminal proceeding is not appealable to the Court; (2) because a writ of habeas corpus may be granted by either a district court or the Supreme Court, the district court's denial of such a writ is not res judicata because it does not divest the Court of jurisdiction to grant a subsequent petition; and (3) a party must file an original petition for writ of habeas corpus for the Court to consider it. The Court then (1) granted Thomas's motion to proceed on appeal without payment of a filing fee; and (2) ordered that Thomas's appeal from the district court's order denying his petition for writ of habeas corpus be dismissed with prejudice. View "Thomas v. John Doe" on Justia Law