Justia Montana Supreme Court Opinion Summaries

The case involves Lewis Leon Bryson, who was convicted of sexual intercourse without consent (SIWOC) following a jury trial. On May 2, 2020, Bryson's neighbor observed him spraying a naked and screaming Valerie Moreni with a hose in his backyard. When police arrived, Moreni was found unresponsive and covered by a blanket. She later claimed Bryson had raped her. Medical examination revealed she was highly intoxicated and had injuries consistent with her allegations. Bryson was arrested and charged with aggravated sexual intercourse without consent (ASIWOC), SIWOC, tampering with evidence, and obstructing a peace officer.The Eighth Judicial District Court, Cascade County, presided over the trial. Bryson and Moreni provided conflicting testimonies about their relationship and the events leading up to the incident. Bryson claimed their interactions were consensual and that Moreni was aware of their sexual activities. The jury found Bryson guilty of SIWOC and obstructing a peace officer.The Supreme Court of the State of Montana reviewed the case. Bryson argued that his trial counsel was ineffective for not proposing correct jury instructions and that the District Court erred by excluding evidence about Moreni’s drinking habits and alcohol withdrawal symptoms. The Supreme Court held that the jury instructions were correct and that Bryson’s counsel was not deficient. The court also found that the District Court did not abuse its discretion in excluding certain evidence about Moreni’s past drinking habits, as it allowed sufficient evidence regarding her condition and credibility.The Supreme Court affirmed Bryson’s conviction, concluding that the instructions and evidentiary rulings were appropriate and did not prejudice Bryson’s defense. View "State v. Bryson" on Justia Law

Christopher Ledeau was charged with Burglary and Partner or Family Member Assault (PFMA) after breaking into his ex-girlfriend's home and threatening her. He pled guilty to the PFMA charge, and the burglary charge was dismissed. At sentencing, the District Court imposed a three-year commitment to the Montana Department of Corrections, with all but 30 days suspended, and included several probation conditions, including conditions 29 and 31, which Ledeau objected to.The Eighth Judicial District Court in Cascade County imposed conditions 29 and 31 despite expressing reservations about their appropriateness. Condition 29 allowed for the search of Ledeau's electronic devices if there was reasonable suspicion he was attempting to contact the victim. Condition 31 required Ledeau to disclose his intimate partner relationships and sign an Intimate Partner Disclosure and Offensive Contact Contract. The District Court encouraged Ledeau to appeal these conditions to obtain input from the Montana Supreme Court.The Montana Supreme Court reviewed the case and found that the District Court abused its discretion in imposing conditions 29 and 31. The Court held that condition 29 was overly broad and lacked a nexus to Ledeau's offense, as there was no evidence he used electronic means to contact the victim. The Court also found that condition 31 was unnecessary, overly broad, and redundant to other probation conditions, such as registration as a violent offender and participation in counseling. The Court reversed the District Court's decision and remanded the case to strike conditions 29 and 31 from the Sentencing Order and Judgment. View "State v. C. Ledeau" on Justia Law

Yanbin Bao, a resident of South Carolina, was charged with seven counts of felony sex trafficking and one count of felony labor trafficking in Montana. Bao allegedly operated a prostitution ring out of a massage parlor in Missoula, Montana, with her husband, Richard Bushey. Law enforcement seized multiple electronic devices from Bao, Bushey, and another suspect, Hui Wang, during their investigation. The data extraction from these devices took longer than ten days due to the complexity of decrypting the devices.The Fourth Judicial District Court of Missoula County ordered the suppression of evidence obtained from four of the electronic devices, ruling that the State had violated the ten-day time limit for serving warrants as established by Montana Code Annotated § 46-5-225. The District Court interpreted the statute to mean that the search and analysis of the devices had to be completed within ten days of the warrant's issuance.The Supreme Court of the State of Montana reviewed the case and reversed the District Court's decision. The Supreme Court held that the warrant was served within the ten-day limit when it was delivered to the forensic analyst on July 11, 2023, the day after its issuance. The Court clarified that the process of decrypting and analyzing the data from the lawfully seized devices did not need to be completed within the ten-day period. The Supreme Court concluded that the District Court erred in its interpretation of the statute and reversed the order to suppress the evidence, remanding the case for continuation of proceedings. View "State v. Y. Bao" on Justia Law

Heather Rose Johnson was convicted of assault on a peace officer, driving under the influence, driving while suspended or revoked, and expired registration after a jury trial. The incident occurred on January 24, 2021, when Johnson, after drinking beer with a friend, drove to a gas station and was reported by a 911 caller for appearing intoxicated. Ravalli County Sheriff’s Office Sergeant Clarence Jessop stopped Johnson’s vehicle, observed signs of intoxication, and arrested her. During the arrest, Johnson kicked Sergeant Jessop, leading to the assault charge.The Twenty-First Judicial District Court, Ravalli County, admitted the 911 call in its entirety over Johnson’s hearsay objections. Johnson was convicted on all charges and sentenced. The court’s written judgment included an “Audit Hearing” condition not mentioned in the oral pronouncement of the sentence.The Supreme Court of the State of Montana reviewed the case. The court determined that the admission of the 911 call violated Johnson’s confrontation rights under the U.S. and Montana Constitutions because the caller’s statements that Johnson was intoxicated and about to commit DUI were testimonial. However, the court found this error to be harmless beyond a reasonable doubt due to the overwhelming evidence against Johnson, including video footage and testimony from law enforcement officers.The court affirmed Johnson’s convictions but remanded the case to the District Court to strike the “Audit Hearing” condition from the written judgment, as it conflicted with the oral pronouncement of the sentence. View "State v. H. Johnson" on Justia Law

Tyrone Lee Risher began serving a five-year sentence with the Montana Department of Corrections (DOC) in May 2018. In October 2021, he was conditionally released to the Butte Prerelease Center (BPRC). On February 18, 2022, Risher failed to return to BPRC, leading to an administrative warrant for his arrest. On February 22, 2022, the State charged Risher with escape, and a warrant was issued, stating he was not a flight risk and would be released on his own recognizance for the escape charge but held for his underlying sentence. Risher was arrested on April 29, 2022, and held in the Butte-Silver Bow County Detention Center until his return to Montana State Prison (MSP). He appeared before the Powell County Justice Court on May 24, 2022, and was released on his own recognizance for the escape charge but held for his underlying sentence.Risher was convicted of felony escape on March 6, 2023, and remanded to DOC custody pending sentencing. On April 25, 2023, the District Court sentenced him to 30 months in DOC custody, consecutive to his existing sentence, and denied his request for credit for time served, stating he was never held on the restriction of bail.The Supreme Court of the State of Montana reviewed the case. The court held that Risher was entitled to credit for time served from his arrest on April 29, 2022, until his release on his own recognizance on May 24, 2022. The court also noted that it was unclear whether Risher was entitled to credit for time served between his conviction and sentencing and remanded the case to the District Court to determine this. The decision was reversed and remanded for further proceedings consistent with the opinion. View "State v. T. Risher" on Justia Law

In January 2016, the State of Montana charged Lavodrick Terelle Hogues with felony aggravated promotion of prostitution involving a 17-year-old female, Jane Doe. The charge stemmed from an undercover operation where officers discovered Doe and another woman, Phylicia Zubia, offering escort services online. Evidence linked Hogues to the operation through phone records, MoneyGram transfers, and other communications.The Thirteenth Judicial District Court of Yellowstone County handled the initial proceedings. Hogues faced multiple delays due to changes in legal representation and his own absconding. He eventually requested to represent himself, which the court granted four days before trial. The court also allowed Jane Doe to testify via remote video due to travel burdens and pandemic concerns, despite Hogues' objections.The Montana Supreme Court reviewed the case. It affirmed the lower court's decision to allow Hogues to represent himself, finding that he had made a voluntary, knowing, and intelligent waiver of his right to counsel. However, the court reversed the decision to admit Jane Doe's remote testimony. The court held that the State failed to demonstrate that her in-person testimony was impracticable or that remote testimony was necessary to further an important public policy. The court emphasized the importance of face-to-face confrontation under the Sixth Amendment and Montana Constitution.The Montana Supreme Court concluded that the denial of Hogues' right to face-to-face confrontation was not harmless error, given Jane Doe's critical role as the alleged victim. Consequently, the court reversed Hogues' conviction and remanded the case for a new trial. View "State v. L. Hogues" on Justia Law

Dustin Lee Seyler was arrested on January 27, 2022, for two counts of burglary and was held without a warrant. The Justice Court held an initial appearance the next day and set a preliminary hearing for February 7, 2022, with bail set at $100,000. Seyler's counsel filed a notice of appearance and a request for discovery on February 1, 2022. The State filed a motion for leave to file an information on February 3, 2022, which the District Court granted on February 10, 2022. Seyler filed a motion to dismiss, arguing that the thirteen-day delay between his initial appearance and the District Court's grant of leave was unreasonable. The District Court denied the motion, and Seyler pleaded guilty while reserving his right to appeal. At sentencing, the District Court imposed various fees, which Seyler contested.The Twentieth Judicial District Court denied Seyler's motion to dismiss, finding the thirteen-day delay reasonable. Seyler appealed, arguing that the delay violated § 46-10-105, MCA, and that the District Court erred in imposing certain fees not mentioned in the oral pronouncement of his sentence.The Montana Supreme Court reviewed the case and held that the District Court did not abuse its discretion in denying Seyler's motion to dismiss. The Court found that the delay was not unreasonable given the circumstances and that Seyler had not demonstrated any prejudice resulting from the delay. However, the Court agreed with Seyler that the $50 pre-sentence investigation fee and the $200 cost of prosecution fee included in the written judgment conflicted with the oral pronouncement of his sentence. The Court affirmed Seyler's conviction but reversed and remanded for the District Court to amend the judgment by striking these fees. View "State v. Seyler" on Justia Law

Pablo Villalobos was arrested during a traffic stop for having two outstanding warrants and an expired license. During the arrest, he was found with a glass meth pipe, which he attempted to destroy. The residue on the pipe was confirmed to be methamphetamine. Villalobos initially entered a plea agreement to plead guilty to criminal possession of dangerous drugs in exchange for the dismissal of other charges and participation in a treatment court program. However, he was not accepted into the program due to his behavior, leading him to withdraw his plea and go to trial, where a jury found him guilty on all counts.The Seventh Judicial District Court sentenced Villalobos to three years at the Department of Corrections (DOC) for the drug possession charge, with a requirement to enroll in the treatment court. He was also sentenced to two years, all suspended, for tampering with evidence, with treatment court completion as a condition of the suspended sentence. For the misdemeanor charges, the court initially sentenced him to 30 days in jail, suspended for one year, but later changed this to six months in the written judgment.The Supreme Court of the State of Montana reviewed the case. It held that the District Court's requirement for Villalobos to complete the treatment court program as part of his DOC sentence was illegal, as the court can only recommend such placement. However, it upheld the requirement to complete the treatment court as a condition of the suspended sentence, provided Villalobos makes a good faith effort to qualify. The court also found the one-year suspension of the misdemeanor sentences exceeded the statutory maximum and reversed this part of the sentence, remanding for correction to align with the original 30-day sentence, suspended for no more than six months. View "State v. Villalobos" on Justia Law

Jeremy Christopher Holmquist was charged with failing to register as a sexual offender in Flathead County, Montana. The case proceeded to a jury trial on September 15 and 16, 2021. During the trial, Detective Buls testified about Holmquist's registration status in Missoula, despite not having personal knowledge of it. The defense objected to this as hearsay, but the court overruled the objection. Holmquist was convicted by the jury and sentenced to five years in Montana State Prison as a persistent felony offender.Holmquist appealed, arguing that the District Court erred in admitting the hearsay statement, which prejudiced his right to a fair trial. The State contended that any error in admitting the statement was harmless. The Montana Supreme Court reviewed the case and determined that even if the District Court erred, the error was harmless.The Montana Supreme Court held that the State provided sufficient admissible evidence proving Holmquist failed to register or keep his registration current. This included Holmquist's own admissions to a police officer that he was noncompliant and had not registered despite being informed of the requirement. The court found that the quality of the admissible evidence was superior to the hearsay statement and that there was no reasonable possibility that the hearsay statement contributed to Holmquist's conviction.The Montana Supreme Court affirmed Holmquist's conviction, concluding that the case was controlled by settled law and the clear application of applicable standards of review. View "State v. Holmquist" on Justia Law

Saul James Dooling was charged with felony theft and several misdemeanors after being apprehended following a high-speed chase in a stolen sedan in Ravalli County, Montana. The vehicle was initially stolen from Jerry’s Transmission in Missoula County. Dooling moved to dismiss the theft charge, arguing that he should be charged in Missoula County where the theft occurred. The District Court denied the motion, reasoning that the State could charge Dooling in Ravalli County because he exerted unauthorized control over the stolen vehicle there.The District Court of the Twenty-First Judicial District, Ravalli County, presided over the case. Dooling entered a plea agreement, pleading guilty to the theft charge and three misdemeanors while reserving the right to appeal the venue issue. The District Court sentenced him to three years with the Department of Corrections, with credit for 181 days served. Dooling did not appeal the misdemeanor convictions.The Montana Supreme Court reviewed the case. Dooling argued that the theft should be prosecuted in Missoula County, where the vehicle was stolen, citing State v. Eagle Speaker. The State countered that Dooling exerted unauthorized control in Ravalli County, making venue there appropriate. The Court held that under Montana law, a person commits theft by either obtaining or exerting unauthorized control over property. Since Dooling exerted unauthorized control in Ravalli County, the charge was proper there. The Court distinguished Eagle Speaker, noting it involved jurisdiction between sovereign nations, not venue within the state. The Court affirmed the District Court’s judgment, concluding that venue was proper in Ravalli County. View "State v. Dooling" on Justia Law