Justia Montana Supreme Court Opinion Summaries

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.

After child R.M.T. had been in the custody of the Montana Department of Public Health and Human Services for two years, the Department petitioned for termination of Father's and Mother's rights. After finding that Father's attempts to comply with his treatment plan failed to reach the level necessary to complete the plan, the court determined that the termination of Father's parental rights was in R.M.T.'s best interest. The court then terminated both Father's and Mother's parental rights. Father appealed. The Supreme Court affirmed, holding (1) the lower court did not abuse its discretion when it terminated Father's rights; and (2) the lower court violated Father's due process rights when at the termination hearing the court declined Father's request to cross-examine the guardian ad litem, who submitted a factual report to the court, but because the report provided no new information to the court, the exclusion of the guardian ad litem's testimony did not cause substantial injustice to Father.

Harold Caldwell was injured when he fell at an airport where he worked as manager. The airport's insurer, MACo, paid Caldwell's medical and wage-loss benefits. MACo, however, denied Caldwell rehabilitation benefits based on Mont. Code Ann. 39-71-710. Caldwell challenged the constitutionality of the statute on the basis that its categorical termination of benefits based on a claimant's eligibility for social security violated equal protection principles. The Workers' Compensation Court (WCC) agreed, concluding that the statute creates two similarly situated classes and treats them disparately without being reasonably related to a legitimate government interest. MACo appealed. The Supreme Court affirmed, holding (1) the statute creates two similarly situated classes and treats them differently, and (2) the categorical elimination of rehabilitation benefits in the statute based solely on age-defined eligibility for social security does not rationally relate to any governmental interest. Therefore, the statute violates the Equal Protection clause insofar as it deems disabled workers ineligible to receive rehabilitation benefits based on their eligibility for social security benefits.

Montana resident Robin Jordan petitioned for a temporary protective order in a Montana county court against Ohio resident Mark Kalin. The court issued the temporary protective order, and Kalin appealed. In the district court, Kalin moved to dismiss for lack of jurisdiction. The district court did not rule on the motion but found it had jurisdiction in its findings issued after the substantive hearing. The district court then adopted a permanent order of protection prohibiting Kalin from having any contact with Jordan or her husband. Kalin appealed. The Supreme Court affirmed, holding (1) the district court did not err in failing to grant Kalin's motion to dismiss as the allegations of the petition were sufficient to confer jurisdiction on the district court; (2) the evidence was sufficient for the district court to issue a permanent order of protection; and (3) the district court's order of protection did not punish Kalin for exercising his constitutional right to defend himself in court.

Following a jury trial, James Main Jr. was convicted of deliberate homicide and felony murder. Main appealed, arguing that (1) the district court erred in denying his motion to suppress statements he made to two police officers while he was being driven to the police station and while at the police station; (2) the district court erred by denying Main's motion to dismiss for insufficient evidence at the close of the state's case-in-chief; and (3) Main was denied effective assistance of counsel. The Supreme Court affirmed, holding that (1) Main voluntarily, knowingly, and intelligently waived his Miranda rights; (2) the evidence was sufficient to permit the jury to find the elements of the crime had been committed beyond a reasonable doubt; and (3) Main's ineffective assistance of counsel claims should be addressed in a postconviction proceeding.