Justia Montana Supreme Court Opinion Summaries

The appellant was convicted in North Dakota for misdemeanor Sexual Assault after entering a guilty plea to having inappropriate contact with a person and having reasonable cause to believe the contact was offensive. He was originally charged with a more serious felony, but the plea agreement stipulated a lesser offense and specifically stated he was not required to register as a sex offender under North Dakota law. After relocating to Montana, the Department of Justice informed him that, based on Montana’s interpretation of his conviction and the age of the victim alleged in the charging documents, he was required to register as a sex offender under Montana law.The Nineteenth Judicial District Court of Montana reviewed his petition for a writ of prohibition seeking to prevent the Montana DOJ from requiring registration. The court denied his petition, reasoning that the proper remedy was to register and then later petition for removal under Montana Code Annotated § 46-23-506. The District Court also concluded that the facts alleged in the North Dakota charging document, though not proved beyond a reasonable doubt or admitted by the appellant, were sufficient to impose the registration duty.On appeal, the Supreme Court of the State of Montana reversed the District Court. The Supreme Court held that a writ of prohibition was an appropriate remedy because there was no statutory or administrative process for contesting the DOJ’s determination, and registration requirements under Montana law are punitive. The Court further held that Montana courts may not rely on facts not proved to a jury beyond a reasonable doubt or admitted by the defendant when determining registration duties. Finally, the Court concluded that the North Dakota misdemeanor Sexual Assault statute is not reasonably equivalent to the Montana sexual offense statute that triggers registration, due to the lack of an age element in the North Dakota statute. The case was remanded for further proceedings. View "Cooper v. Department of Justice" on Justia Law

A 16-year-old individual was criminally charged in Montana with several offenses, including aggravated burglary and assault on a peace officer. The prosecution filed an Information in the District Court, and a hearing was scheduled to decide whether the matter should be transferred to Youth Court, as permitted by Montana law for certain juvenile defendants. Before being arraigned, the defendant moved to substitute the presiding judge, arguing the motion was timely since arraignment had not yet occurred.The Montana Fourth Judicial District Court, Missoula County, denied the substitution motion without prejudice, reasoning that such motions are prohibited in Youth Court actions and would only be considered if the case remained in District Court following the transfer hearing. The court also issued an order for evaluation to assist in the transfer determination, but the order was initially filed under an incorrect cause number. The defendant then petitioned the Montana Supreme Court for a writ of supervisory control, claiming the denial of the substitution motion was erroneous because the case was pending in District Court as a criminal action, not a Youth Court matter.The Supreme Court of the State of Montana reviewed the case. It held that after the State files an Information in District Court, jurisdiction over the criminal matter rests with the District Court, and the action is not a Youth Court case at that stage. The court further clarified that under Montana law, a defendant’s right to substitute a judge in criminal cases may be exercised any time before arraignment, and that the 10-day window for substitution closes at arraignment rather than opening at that point. The Supreme Court granted the petition for supervisory control, set aside the District Court’s order denying substitution, and remanded for further proceedings consistent with its opinion. View "S.L. v. 4th Judicial District Court" on Justia Law

Francisco Padilla-Canales, a Spanish-speaking undocumented immigrant, was arrested after breaking into a residence where his estranged wife was staying with another man, Lesman Escobar Andara. Upon discovering them together, Padilla-Canales stabbed Andara, who died at the scene. Padilla-Canales attempted to have his wife report the incident as a suicide and performed CPR until emergency services arrived. He was advised soon after arrest, in Spanish, that a conviction could lead to deportation, and signed documentation acknowledging this warning. More than a year later, he pled guilty to mitigated deliberate homicide under a nonbinding plea agreement.The Eighteenth Judicial District Court in Gallatin County, Montana, accepted Padilla-Canales’s guilty plea after confirming he understood the charges and potential penalties, and that there were no communication barriers due to language. However, at the change-of-plea hearing, the court did not specifically advise Padilla-Canales of the immigration consequences of his plea or confirm his understanding of those consequences, as required by Montana law. Both the State and defense counsel referenced his immigration status during sentencing, discussing that deportation would likely follow his prison term. The District Court sentenced Padilla-Canales to forty years in prison without parole restrictions.On appeal to the Supreme Court of the State of Montana, Padilla-Canales argued for the first time that his guilty plea was involuntary due to the District Court’s failure to properly advise him about potential deportation. The Supreme Court recognized the advisement failure but concluded that, in this case, Padilla-Canales was aware of the immigration consequences through discussions in open court and with counsel. The Court declined to exercise plain error review, holding that the record did not reveal a manifest miscarriage of justice or compromise the fairness of the proceedings, and affirmed the District Court’s sentencing order. View "State v. Padilla-Canales" on Justia Law

In this case, a woman was accused of participating in a staged burglary intended to facilitate an insurance fraud scheme. The orchestrator of the scheme, seeking funds to pay her son's legal fees, enlisted several individuals to help remove and conceal items from her home, including a refrigerator and a boat, while her husband was away. Law enforcement initiated an investigation after the orchestrator’s husband discovered the apparent burglary and contacted police. The accused woman was alleged to have assisted in disassembling and moving the refrigerator and in storing the stolen items at her own residence, knowing that an official investigation was imminent.The Seventh Judicial District Court in Richland County presided over the case. Before trial, the defendant requested that a witness be allowed to testify by video due to travel difficulties, but the court required in-person testimony. The defendant also requested an “accomplice instruction” for the jury, arguing that a key witness’s testimony should be viewed with distrust as that witness was allegedly an accomplice. The court denied both requests, finding the accomplice instruction inapplicable because the relevant charges had been amended. After hearing testimony from the orchestrator, other involved parties, and law enforcement, the jury acquitted the defendant of conspiracy to commit insurance fraud but convicted her of tampering with evidence. The defendant then appealed, arguing errors in jury instructions, witness testimony procedures, and sufficiency of corroborating evidence.The Supreme Court of the State of Montana reviewed the case. It held that the district court did not commit reversible error in denying the accomplice instruction, as it would have been inconsistent with the defendant’s claim of innocence on the tampering charge. The court further determined there was no abuse of discretion in denying the video testimony request and that sufficient evidence supported the conviction. Accordingly, the Supreme Court affirmed the conviction for tampering with evidence. View "State v. Lord" on Justia Law

An individual was accused of sexually assaulting his fiancée’s seven-year-old niece while visiting the child’s home. The child reported the incident to her sibling, who then informed their mother. Law enforcement conducted interviews with the child, her family, and the accused, and collected physical evidence, including a blanket identified by the child. DNA analysis of the blanket matched the accused. The accused was charged with sexual assault and sexual intercourse without consent. At trial, the child, family members, law enforcement, and crime lab personnel testified. The defense focused on challenging the investigation rather than the child’s credibility. The accused was found guilty on both charges.After conviction, the accused appealed directly to the Supreme Court of Montana, raising several issues including claims of ineffective assistance of counsel. The Supreme Court of Montana affirmed the conviction. The accused then sought postconviction relief in the District Court of the Sixteenth Judicial District, Fallon County, arguing that his trial counsel was ineffective, particularly in the cross-examination of a law enforcement officer. The District Court denied the petition, finding the claims both procedurally barred and without merit. The defense attorney was later disbarred and did not participate in the postconviction proceedings.The Supreme Court of the State of Montana reviewed the denial of postconviction relief. The Court held that the accused did not establish ineffective assistance of counsel under the standard set by Strickland v. Washington. The Court found that the defense counsel’s cross-examination strategy fell within the wide range of reasonable professional assistance and did not prejudice the outcome, given the strong physical evidence and the content presented to the jury. The Supreme Court of Montana affirmed the District Court’s denial of postconviction relief. View "Kapps v. State" on Justia Law

In this case, a man was charged with multiple felony counts arising from sexual abuse allegations involving two victims: his adopted daughter, who disclosed in 2021 that she had been repeatedly molested by him from age 10 to 14, and his sister-in-law, who reported a 2009 incident in which he sexually assaulted her when she was 17. After investigations and forensic interviews, the defendant was charged with one count of felony sexual assault and three counts of felony sexual intercourse without consent. The charges related to both victims were tried together before a jury.Prior to trial in the Thirteenth Judicial District Court, Yellowstone County, neither party objected to the joinder of charges or moved to sever them. During voir dire, a Yellowstone County Undersheriff, whose office had investigated the case, was seated as a juror without objection or peremptory strike from either party. During trial, the State raised concerns about the Undersheriff’s impartiality, but the defendant’s counsel argued against removing him, and the District Court declined any implied motion to strike. The jury found the defendant guilty on all counts, and he was sentenced to 100 years in prison.On appeal to the Supreme Court of the State of Montana, the defendant raised three issues: whether the presence of the Undersheriff as a juror or the joinder of charges should be reviewed under the plain error doctrine, and whether he received ineffective assistance of counsel for failing to object to either issue. The Supreme Court held that neither issue merited plain error review because the defendant had affirmatively waived challenges below, and there was no manifest miscarriage of justice. The Court further determined that the record was insufficient to review the ineffective assistance of counsel claim on direct appeal, leaving that question for postconviction proceedings. The Court affirmed the conviction. View "State v. Soapes" on Justia Law

A convenience store employee in Plentywood, Montana, discovered a small bag containing methamphetamine on the store floor during her shift and called law enforcement. Surveillance footage was reviewed, and a deputy identified Shawn Andersen as a person who had been in the area where the bag was found. The deputy did not watch all of the footage but focused on the time around when the bag appeared. Later, another bag of methamphetamine was found in Andersen’s pocket when he was arrested at the county jail. Both baggies tested positive for methamphetamine. At trial, the State’s case relied heavily on the surveillance footage and related testimony to link Andersen to the drugs found at the store.The Fifteenth Judicial District Court in Sheridan County presided over Andersen’s jury trial. During deliberations, the jury asked to review the surveillance footage. While they watched, the State’s legal assistant audibly commented, “There it is,” as the video showed the disputed moment. Andersen’s counsel immediately moved for a mistrial, arguing that the comment could have improperly influenced the jury. The District Court denied the motion, and the jury convicted Andersen on all counts. Andersen was sentenced to a combination of suspended and consecutive sentences for possession of dangerous drugs and possession of drug paraphernalia.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by denying Andersen’s motion for mistrial. The Supreme Court held that the legal assistant’s comment constituted improper third-party jury misconduct, creating a presumption of prejudice. Because the District Court neither declared a mistrial nor conducted an inquiry to rebut this presumption, the Supreme Court found this to be an abuse of discretion. The conviction was reversed, and the case was remanded for a new trial on all counts. View "State v. Andersen" on Justia Law

A man was originally convicted of felony burglary for breaking into a bar in Montana and received a twenty-year prison sentence with five years suspended. After serving time and being released, he began the suspended portion of his sentence. The State later filed a petition to revoke his suspended sentence based on several alleged probation violations, including failing to register as a sex offender. While represented by counsel, he admitted to the failure-to-register allegation, and the court set a dispositional hearing to determine the consequences.The Montana Ninth Judicial District Court presided over the revocation proceeding. At the dispositional hearing, the man appeared without counsel after his attempts to retain private counsel failed and after his appointed counsel was allowed to withdraw. He requested reappointment of a public defender but none was assigned before the hearing. The court conducted no inquiry into whether he knowingly and voluntarily waived his right to counsel and proceeded with resentencing him to five years in prison. The man appealed, arguing he was denied his right to counsel at a critical stage and that he did not waive that right.The Supreme Court of the State of Montana held that the district court erred by conducting the dispositional hearing and resentencing without counsel and without a valid waiver of the right to counsel. The Court found this to be a structural error requiring automatic reversal, noting the man’s consistent efforts to obtain representation and the absence of any meaningful waiver inquiry. The Court vacated the dispositional order and remanded for a new hearing at which the man must be represented or must validly waive representation. The Court declined to resolve his request to withdraw his earlier admission, leaving it for further proceedings if appropriate. View "State v. Lambert" on Justia Law

A man was charged with felony criminal possession of dangerous drugs after being found with methamphetamine and paraphernalia following a single-vehicle crash in Sanders County, Montana. During his hospital treatment after the crash, law enforcement recovered drugs and a pipe from his clothing, and further investigation at the scene yielded additional drugs, firearms, and related items. He was prosecuted for possession of dangerous drugs, while several other related charges were dismissed prior to trial.At his jury trial in the Twentieth Judicial District Court, the defendant participated in the morning proceedings but failed to return after the lunch break. The court, over his attorney’s objection, continued the trial in his absence under Montana law, which allows the trial to proceed if a felony defendant is voluntarily absent and the crime is not punishable by death. The jury found him guilty while he was absent. He was later arrested and sentenced to five years in prison. On appeal, he argued that the trial court erred by proceeding in his absence and that his attorney was ineffective for not moving to suppress evidence found in his clothing.The Supreme Court of the State of Montana held that the district court did not err in resuming the trial in the defendant’s absence, concluding that he voluntarily absented himself and thereby waived his right to be present. The Court further held that, when voluntary absence is established, there is no need for the trial court to exercise additional due diligence to secure a defendant’s presence for the verdict. The Court also determined that the record was insufficient to review his ineffective assistance of counsel claim on direct appeal. The district court’s judgment was affirmed. View "State v. McKnight" on Justia Law

On November 23, 2019, the appellant was driving an Acura with three children, including her own, when her vehicle was rear-ended by another driver. Witnesses testified that after this collision, the Acura accelerated rapidly, left the road, then reentered it and collided head-on with a Yukon. The crash resulted in the death of one child and serious injury to another. At the time, the appellant’s driver’s license was suspended, and she was not permitted unsupervised contact with her children due to prior involvement with Child Protective Services.The State of Montana charged the appellant with multiple offenses, including negligent homicide, criminal endangerment, and driving with a suspended license. The Thirteenth Judicial District Court, Yellowstone County, presided over a six-day jury trial. The jury found the appellant guilty on all counts. The appellant’s defense argued that the initial rear-end collision was the cause of the subsequent crash, while the prosecution maintained that the appellant’s actions, including improperly restraining the children and fleeing the scene, were negligent and directly led to the fatal incident.On appeal to the Supreme Court of the State of Montana, the appellant challenged the sufficiency of the evidence for the negligent homicide conviction, asserted ineffective assistance of counsel, objected to the admission of certain expert testimony, sought a mistrial based on inadmissible testimony, and disputed the order of restitution for lost wages. The Montana Supreme Court affirmed the District Court’s judgment. It held that there was sufficient evidence for the negligent homicide conviction, found no ineffective assistance of counsel, ruled that the District Court did not abuse its discretion in admitting expert testimony or denying a mistrial, and upheld the restitution award, finding it legally appropriate under Montana law. View "State v. Mullendore" on Justia Law