Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions for partner or family members assault (PFMA), unauthorized use of a motor vehicle, and two counts of tampering with witnesses or informants but reversed the district court's imposition of various fees and costs on Defendant, holding that remand was required for an analysis of Defendant's ability to pay before imposing costs and fees.Specifically, the Supreme Court held (1) the admission of certain hearsay statements was not harmless error; (2) Defendant's right to a fair trial by an impartial jury was not violated; (3) Defendant was not entitled to relief on his argument that his right to confrontation was violated by the repeated emphasis on recorded jail phone calls; (4) the record was insufficient to review Defendant's claim of ineffective assistance of trial counsel; and (5) the district court erred in imposing jury and other costs on Defendant without first undertaking an ability to pay inquiry. View "State v. Oliver" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony driving a motor vehicle under the influence of alcohol or drugs (DUI), holding that there was no harmless error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not violate Defendant's right to equal protection by denying his Batson objection to the State's peremptory strike of the only racial minority member of the venire; (2) while one of the prosecutor's remarks during closing argument was erroneous, the prosecutor's remarks, considered cumulatively, did not violate Defendant's right to a fair trial; and (3) the district court did not err when it relied on one of Defendant's prior convictions to support enhancement of his DUI conviction to a felony offense and in determining that the prior conviction was constitutionally valid. View "State v. Wellknown" on Justia Law

The Supreme Court reversed Defendant's convictions for felony criminal possession of dangerous drugs and misdemeanor criminal possession of drug paraphernalia, holding that the district court erred in denying Defendant's motion to suppress.On appeal, Defendant argued that the district court abused its discretion in denying his motion to suppress evidence seized after a vehicle search that resulted from an unlawfully prolonged investigative driving under the influence (DUI) stop. The district court denied the motion to suppress on the ground that the initial stop of Defendant was lawful based on a reasonable particularized suspicion of DUI. The Supreme Court reversed, holding (1) while Defendant was lawfully stopped on a reasonable particularized suspicion of DUI, the officers unlawfully prolonged the duration of the stop before subjecting Defendant to the confirmatory DUI field sobriety testing; and (2) therefore, the district court erroneously denied Defendant's motion to suppress. View "State v. Zeimer" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of assault with a weapon, a felony, and misdemeanor possession of marijuana and drug paraphernalia and sentencing him to a nine-year prison term, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the State's peremptory strike of the only non-white member of the jury venire was not plain error under the three-prong equal protection analysis set forth by Batson v. Kentucky, 476 U.S. 79 (1986); (2) Defendant failed to establish plain error as to his arguments regarding various unpreserved assertions of error regarding the prosecutor’s closing argument and rebuttal comments; and (3) defense counsel's withdrawal of the Batson challenge and failure to object to certain statements by the prosecutor did not constitute ineffective assistance of counsel. View "State v. Miller" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained from a blood draw conducted pursuant to a search warrant, holding that there was no error.Defendant moved to suppress evidence obtained from a blood draw, arguing that Wheatland County Justice of the Peace Richard Egabakken lacked jurisdiction to issue the warrant because the crimes occurred in Golden Valley County. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err when it concluded that Justice of the Peace Egebakken had jurisdiction to issue a search warrant for Defendant's blood draw in Wheatland County. View "State v. Grussing" on Justia Law

The Supreme Court reversed the order of the district court affirming the justice court's denial of Defendant's motion to suppress, holding that particularized suspicion did not exist to support extending Defendant's traffic stop into a drug investigation.Defendant pleaded guilty to criminal possession of drug paraphernalia and criminal possession of marijuana. On appeal, Defendant challenged the denial of his motion to suppress the State's evidence as the product of an illegal extension of the stop, arguing that the police officer lacked particularized suspicion to justify extending the traffic stop and ordering a canine sniff search. The Supreme Court agreed and reversed, holding that the justice court erred in denying Defendant's motion to suppress. View "State v. Harning" on Justia Law

The Supreme Court affirmed the judgment of the district court in this litigation related to the expansion of an agricultural zoning district through citizen initiative to include the area where Montana Artesian Water Company had been developing a large-scale water bottling plant, holding that there was no error or abuse of discretion.At issue on appeal was whether Montana Artesian's water bottling facility was a valid nonconforming use under the Egan Slough Zoning District Regulations. Montana Artesian raised numerous issues on cross appeal. The Supreme Court affirmed, holding that the district court (1) properly denied Montana Artesian's motion for summary judgment on the validity of the ballot initiative process; (2) did not err in affirming the conclusion that Montana Artesian's facility was a legal nonconforming use; and (3) did not err in concluding that the initiative was not unconstitutional or illegal reverse spot zoning. View "Egan Slough Community, Yes! v. Flathead County Board of County Commissioners" on Justia Law

The Supreme Court affirmed the judgment of the district court denying relief to Appellant Advocates for School Trust Lands on its claim that House Bill 286 (HB 286), passed by the 2019 Montana Legislature and codified as Mont. Code Ann. 85-2-441, is unconstitutional, holding that there was no error.Appellant brought this action alleging that HB 286 is facially unconstitutional because it violates the State's trust obligations imposed by the 1889 Enabling Act and the Montana Constitution by creating a presumption against State ownership in ground water diverted from private property for use on leased school trust land, thereby reducing the value of those lands. The district court granted summary judgment to the State, concluding that Appellant's claim was unripe and that its proposed amendment was futile. The Supreme Court affirmed, holding that the district court (1) did not err by granting summary judgment to the State; and (2) did not abuse its discretion in denying Appellant's motion to amend its complaint. View "Advocates v. State" on Justia Law

The Supreme Court affirmed the orders of the district court denying the motion for judgment on the pleadings filed by the Associated Press and other news reporting outlets (collectively, the AP) and granting a motion to dismiss filed by Barry Usher, holding that the district court did not err.During the state's biennial legislative session in 2021, Usher, who was the Chair of the Judiciary Committee of the Montana House of Representatives, and other Republican members of the Committee met privately to discuss pending legislation. Because Usher denied the AP access to the gathering, the AP brought this lawsuit, seeking a declaratory judgment that this denial of access was a constitutional violation. The district court granted Usher's motion to dismiss, concluding that the gathering was controlled by the open meeting statute, Mont. Code Ann. 2-3-202, and that applying the statute in this case did not violate the AP's Mont. Const. art. II, 9 right to access a gathering of Judiciary Committee members. The Supreme Court affirmed, holding that the district court did not err in applying the statutory definition of a "meeting" to the AP's constitutional right to access a gathering of Judiciary Committee members. View "Associated Press v. Usher" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained as a result of warrantless search of his apartment, holding that the district court did not err in denying Defendant's motion to suppress.In this case, three probation officers and a deputy federal marshal made a warrantless entry into Defendant's apartment without his consent to investigate his reported methamphetamine use and possible drug overdose in violation of the law and Defendant's probation. The district court concluded that the warrantless entry into Defendant's apartment was a constitutional search. The Supreme Court affirmed, holding that the district court (1) correctly concluded that the warrantless entry and probation search of Defendant's apartment was lawful on reasonable suspicion under the probation search exception to the warrant requirement of Mont. Const. art. II, 10-11; and (2) did not err in denying Defendant's motion to suppress based on the manner in which the officers entered the apartment or treated Defendant thereafter. View "State v. Peoples" on Justia Law