Justia Montana Supreme Court Opinion Summaries

Brent Wilson appealed from his conviction for involvement in a fraudulent scheme to illegally take possession of real property. Prior to and throughout the jury trial, Wilson invoked his constitutional right to represent himself. On appeal, Wilson argued, inter alia, that he was not competent to waive his constitutional right to counsel and the district court should have compelled standby counsel to represent him. The Supreme Court affirmed, holding (1) there was substantial credible evidence that Wilson unequivocally waived his right to counsel knowingly, voluntarily, and intelligently; and (2) Wilson's sentence was legal because the length of the commitment was within the district court's statutory authority, the court took the sentencing criteria of Mont. Code Ann. 46-18-225(2) into account, and the court did not punish Wilson for refusing to confess to his crimes. View "State v. Wilson" on Justia Law

Ross Habets pled guilty to aggravated assault. The district court sentenced Habets to a one-year commitment to the Department of Corrections followed by placement at the state prison for nineteen years. Habets appealed, arguing that (1) the district court failed to account for Habets's mental illness and his attempts to seek health treatment before the incident in violation of Montana's sentencing policy and principles, and (2) the court failed to comply with the rehabilitative section of the sentencing policy statute. The Supreme Court affirmed, holding that the district court followed the law in this case by properly considering the necessary factors in sentencing Habets. View "State v. Habets" on Justia Law

Following a jury trial, Larry Daniels was convicted of deliberate homicide. In defense, Daniels asserted justifiable use of force. Daniels' arguments on appeal pertained to the 2009 legislative changes to the justifiable use of force statutes. The Supreme Court affirmed, holding (1) justifiable use of force is still an affirmative defense, and the defendant has the initial burden of providing evidence to raise the defense, and then the burden of proof shifts to the State; (2) the district court correctly disallowed cross-examination concerning specific instances of the victim's violent acts under Mont. R. Evid. 405(a); (3) proper foundation was necessary before the victim's character evidence could be admitted, and under the facts of this case, the district court correctly required Daniels to lay a proper foundation by testifying; and (4) the district court correctly refused Daniels' proposed jury instructions on justifiable use of force in defense of an occupied structure and burglary as a forcible felony.

Rodrick Cameron was charged with driving under the influence (DUI). Cameron filed a motion to suppress, claiming that the deputy sheriff that stopped Cameron's vehicle lacked particularized suspicion to stop him. The justice court denied Cameron's motion. Cameron entered a guilty plea to DUI while reserving his right to appeal the justice court's denial of his motion to suppress. The district court affirmed. The Supreme Court affirmed, holding the district court did not err in affirming the justice court's denial of Cameron's motion to suppress because, based on the totality of the circumstances, the deputy sheriff had sufficient facts to form a particularized suspicion of wrongdoing to initiate an investigative stop.

Miles Kingman was charged with attempted deliberate homicide for the brutal assault of a man outside a bar. A jury acquitted Kingman of the homicide charge but convicted him of aggravated assault, a lesser-included offense. Kingman was sentenced to twenty years' incarceration. On appeal, Kingman (1) claimed that the publicity surrounding the incident had prejudiced the community to such an extent that he could not get a fair trial by jurors drawn from that community, and (2) argued that the prosecutor improperly characterized him at the sentencing hearing as an "animal" that "needed to be caged." The Supreme Court affirmed, holding (1) Kingman did not show a sufficient basis for presuming that the entire community jury pool was corrupted by the pre-trial publicity; and (2) although the prosecutor's remarks were inappropriate, there was no indication that the remarks had factored into the district court's decision to impose the maximum sentence for aggravated assault.

In this consolidated appeal, each Appellant was charged with DUI, and each took a breath test on the Intoxilyzer 8000. Each Appellant sought source code and other information related to the Intoxilyzer 8000 during the prosecution of their cases. The district court limited the requests of each Appellant. After these rulings, each Appellant pled guilty. The Supreme Court affirmed the district court on all issues, holding that the district court did not abuse its discretion (1) by giving full faith and credit to a Kentucky court's determination that the source code was a trade secret of CMI, Inc. and determining that Appellants did not show undue hardship requiring the court to order CMI to make the source code available to Appellants; and (2) by quashing portions of Appellants' subpoena duces tecum seeking information regarding the use of every Intoxilyzer 8000 in the state after finding the request was unreasonable and oppressive.

Mayson Simmons pleaded guilty to criminal distribution of dangerous drugs for providing medical marijuana to someone without a user card, distribution for providing oxycodone pills, and theft by insurance fraud. The district court sentenced Simmons to twenty years in prison with ten years suspended. Simmons appealed her sentence, arguing that the district court violated her right to due process by considering evidence of her behavior while incarcerated at the Ravalli County Detention Center (RCDC). The Supreme Court affirmed, holding that Simmons' due process rights were not violated when the district court referenced her negative behavior while at RCDC because (1) the court considered numerous pieces of evidence pertaining to Simmons' potential for rehabilitation and the severity of the crimes she committed, and (2) Simmons did not meet her burden of showing the sentencing court relief on materially false allegations in forming the sentence.

Alicia Hocter was caring for a six-month-old when she swung the child's head into the top bar of her crib and failed to seek medical attention for the child. Hocter pled guilty to charges of aggravated assault and criminal endangerment, after which she withdrew her guilty plea. A jury found Hocter guilty of both charges. The Supreme Court affirmed, holding (1) the district court did not err when it denied Hocter's motion to dismiss the charge of criminal endangerment as Hocter had actual notice of the facts that the State was obligated to prove to support its theories of criminal endangerment; and (2) the district court did not err in instructing the jury on criminal endangerment predicated on a defendant's omission or failure to act as the instructions properly required the jury to determine whether Hocter breached that duty.

Patrick Chesterfield was convicted in district court of driving or being in actual physical control of a motor vehicle while under the influence of alcohol or drugs (DUI), his fourth offense. Chesterfield appealed, arguing that the district court erred by denying his motion to dismiss without holding an evidentiary hearing concerning his claim that his three prior convictions for DUI were constitutionally infirm because he was denied his right to counsel. The Supreme Court affirmed, holding that Chesterfield failed in his burdens of production and persuasion to demonstrate that his three prior DUI convictions were constitutionally infirm, and accordingly, the district court did not err by denying Chesterfield's motion to dismiss.

Leslie Staebler was convicted by a jury in municipal court of misdemeanor driving while intoxicated and violation of the seatbelt law. The district court affirmed, holding that Staebler's fundamental right to a fair trial was not violated. The Supreme Court affirmed but on different grounds, holding that the district court did not err in affirming the municipal court where (1) the City attorney did not unfairly imply that Staebler's conduct was worse than it actually was; (2) comments of one juror did not inflame or prejudice other members of the jury against Staebler; (3) the City attorney did not err during rebuttal to Staebler's closing argument when she inferred that because Staebler was not able to brake appropriately for oncoming traffic, he would not have been able to brake properly had a child been playing in the road; and (4) the evidence was sufficient to support Staebler's conviction.