Justia Montana Supreme Court Opinion Summaries

Defendant John Finley's wife pleaded guilty to felony theft, and later, her probation officer conducted a valid search of her home. During a search of a safe in the couple's bedroom, the officer discovered drugs and drug paraphernalia. Defendant later entered conditional plea agreements to felony criminal possession of dangerous drugs and misdemeanor criminal possession of drug paraphernalia while reserving his right to appeal the district court's denial of his suppression motion. On appeal, Defendant challenged the district court's denial of his motion to suppress the evidence found in the safe, arguing that the probation officer exceeded the scope of the probationary search. The Supreme Court affirmed, holding that the probation officer legally searched the unlocked and open safe pursuant to the valid probationary search.

Defendant Hector Valdez-Mendoza pleaded guilty to one count of sexual assault. After the district court granted Defendant's request for new counsel, Defendant filed a motion to withdraw plea of guilty, asserting in part that he had good cause to withdraw his guilty plea because his previous defense counsel convinced him he could not get a fair trial. The district court denied Valdez-Mendoza's motion. The Supreme Court reversed Defendant's conviction, holding that Defendant had good cause to withdraw his guilty plea because his previous defense counsel shared her belief with Defendant that he could not get a fair trial and made no attempt to assuage Defendant's fear of an unfair trial. Remanded.

After a jury trial, Richard Edwards was found guilty of deliberate homicide. The Supreme Court affirmed the judgment of the district court, holding (1) the district court did not err when it permitted Edwards' wife's testimony because (a) her observations of Edwards' actions did not constitute spousal communications and therefore were not privileged, and (b) Edwards' marital communications regarding the murder that were accompanied by threats were not privileged because they were not communicated in reliance on the confidence of the marital relationship; (2) Edwards was not denied effective assistance of counsel because he failed to show he was prejudiced by defense counsel's admission of lack of preparation for cross-examination; and (3) while it was error for the district court not to inquire into Edwards' post-trial motion for new counsel, reversal in this case was not required because Edwards did not allege a conflict that resulted in a total lack of communication, nor did he claim that his attorneys were unable or unwilling to represent him at the sentencing hearing.

Rosina Spaulding pleaded guilty in district court to misdemeanor DUI per se. Spaudling reserved the right to appeal the district court's denial of her motion to suppress. On appeal, the Supreme Court affirmed, holding the district court correctly denied Spaulding's motion to suppress as (1) although Spaulding was temporarily seized when a deputy sheriff pulled her vehicle over, made contact with her, and inquired as to her and her passengers' well-being, (2) the warrantless seizure was constitutionally reasonable because it met the criteria of the community caretaker doctrine, which allows a government official to stop and investigate a citizen without a warrant when there are objective, specific, and articulable facts from which an experienced officer would suspect that citizen is in need of help or is in peril.

John Chaussee was charged with driving under the influence of alcohol. The offense was alleged to be Chaussee's fourth DUI conviction, making it a felony. Chaussee filed a motion to dismiss, arguing that two of his prior DUI convictions were constitutionally invalid. The district court denied the motion. Chaussee pleaded guilty, reserving his right to appeal the denial of his motion. At issue on appeal was whether Chaussee sufficiently demonstrated that his prior convictions were constitutionally infirm. The Supreme Court affirmed the district court's denial of Chaussee's motion to dismiss, holding that Chaussee failed in his burdens of production and persuasion to demonstrate that his prior convictions were constitutionally invalid.

In an effort to regulate gravel pits within the county, the Gallatin County Board of Commissioners (Commission) created an interim zoning district and proposed creation of four permanent zoning districts throughout the county. The Gateway Opencut Mining Action Group (GOMAG) sought an injunction against the Commission, claiming the public comment provision of the applicable zoning statute, Mont. Code Ann. 76-2-205(6), was unconstitutional. Subsequently, GOMAG and Gallatin County agreed to defer certain statutorily-required actions until GOMAG's injunction request was heard by the district court. Meanwhile, several county farms and ranchers and two gravel pit owners (Intervenors) intervened in the action, seeking summary judgment on the ground that the Commission had failed to act within the statutorily-required time and, therefore, the case was moot. The district court granted Intervenors' motions for summary judgment. On appeal, the Supreme Court affirmed, holding that because protests filed under the challenged statute had no impact on the course of the Commission proceedings and that no constitutional violation capable of repetition occurred here, the district court did not err in granting summary judgment to Intervenors on the basis of mootness.

A jury convicted John Hartsoe of aggravated assault and violation of an order of protection. On appeal, the Supreme Court affirmed in part and remanded in part, holding (1) the district court erred by by permitting Hartsoe to be shackled in a chair and brought into the courtroom during voir dire, but because the record was insufficiently developed to enable the Court to conduct a harmless error analysis, the matter was remanded to the district court to determine whether the violation was harmless in light of the interests that the right to remain free of physical restraints was designed to protect; and (2) the district court did not err in granting Hartsoe's request to represent himself as Hartsoe voluntarily, knowingly, and intelligently elected to proceed pro se.

A jury found Robert DaSilva guilty of failure to provide notice of address change as a sex offender, a felony, and resisting arrest, a misdemeanor. On appeal, the Supreme Court affirmed, holding (1) the district court did not violate DaSilva's due process rights by instructing the jury as a matter of law that DaSilva's previous Washington conviction of second degree assault with sexual motivation was a "sexual offense" under Montana law; and (2) the district court did not act arbitrarily or err in granting a continuance of trial that was requested by the State to permit an amendment to the information.

After James Patrick filed a petition for postconviction relief, the district court judge who presided over Patrick's previous trial and sentencing recused herself and ordered that Patrick's postconviction proceedings be reassigned. Patrick filed a motion to invalidate the State's judicial substitution, which the district court denied. On appeal, the Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err when it denied Patrick's motion to invalidate the State's judicial substitution because the substitution in this instance was permitted, Patrick received notice of the substitution, and Patrick was not denied due process when the district court issued its order denying Patrick's motion without waiting for Patrick's reply brief; and (2) Patrick should have been given the opportunity to file his own motion for judicial substitution. The Court concluded that equity demanded that Patrick be given twenty days to move for a judicial substitution.

Brandon Burns was charged with felony DUI or, in the alternative, felony DUI per se. Ultimately, Burns pled guilty to DUI per se, reserving his right to appeal. The district court designated Burns as a persistent felony offender and sentenced him to fifteen years' incarceration. On appeal, the Supreme Court affirmed, holding the district court did not err in (1) denying Burns' motion to dismiss for lack of a speedy trial; (2) denying Burns' motion to suppress evidence; (3) denying Burns' motion to dismiss the felony DUI charge on the grounds that his third prior DUI conviction was invalid; and (4) sentencing Burns as a persistent felony offender.