Justia Montana Supreme Court Opinion Summaries

A man was convicted in 2012 of felony murder following the death of a two-year-old child for whom he was the primary caretaker. The child had suffered severe head injuries consistent with nonaccidental trauma and was pronounced brain dead after being transported to a hospital. Law enforcement interviewed the man, who was advised of his Miranda rights and did not confess but offered alternative explanations for the injuries. He received a 100-year sentence without parole.After his conviction, the man filed a petition for postconviction relief in the Montana Eighth Judicial District Court, primarily alleging ineffective assistance of counsel on several grounds, including failure to move to suppress his statements to police, not hiring an independent medical expert, conceding in closing argument that the child’s injuries were not accidental, and not allowing him to testify. Initially denied without counsel, the case was remanded for appointment of counsel and a new hearing. With counsel, he renewed his claims and added an allegation that the State had not produced certain discovery related to a drug investigation at the residence. After a second evidentiary hearing, the District Court denied all claims, finding either they were procedurally barred, unsupported by evidence, or reflected reasonable trial strategy.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s findings for clear error and its legal conclusions de novo. Applying the two-prong test from Strickland v. Washington, the Supreme Court held that the man failed to demonstrate deficient performance by either his trial or appellate counsel, or resulting prejudice. The Court found that counsel’s actions were reasonable strategic decisions under the circumstances and that no meritorious claims for ineffective assistance or other postconviction relief were established. Accordingly, the Supreme Court affirmed the District Court’s denial of the petition. View "Hyslop v. State" on Justia Law

The defendant was arrested in October 2021 and charged with robbery and disorderly conduct. Initial proceedings raised concerns about his mental fitness, and he was evaluated at Montana State Hospital. Multiple evaluations between December 2021 and April 2023 determined that he was unfit to proceed, largely due to his refusal to take medication. In October 2022, the court authorized involuntary medication following a Sell v. United States hearing. By April 2023, the defendant was found fit to proceed, and at a subsequent hearing, he was arraigned and entered a plea of not guilty to both charges. In July 2023, a plea agreement was reached where the defendant pleaded guilty to attempted robbery in exchange for dismissal of the disorderly conduct charge.The Fourth Judicial District Court accepted the defendant’s guilty plea after confirming it was entered voluntarily, knowingly, and intelligently. At the change of plea hearing, the defendant expressed concern about a potential speedy trial violation and asked to have it noted for the record. The court acknowledged the statement but declined to accept briefing on the issue, and neither the defendant nor his counsel filed a motion or objected further. The defendant was subsequently sentenced to ten years, with credit for time served.On appeal, the Supreme Court of the State of Montana considered whether the lower court abused its discretion by refusing to accept briefing on the speedy trial issue and whether the issue was preserved for review. The Supreme Court held that by voluntarily and knowingly pleading guilty without first obtaining an adverse ruling on a timely filed motion, the defendant waived all nonjurisdictional defects, including claims of speedy trial violations. The Court also declined to review the claim under the plain-error doctrine, finding no manifest miscarriage of justice. The judgment was affirmed. View "State v. Hill" on Justia Law

Police investigated a domestic disturbance in December 2020 involving the appellant, who was subsequently charged in Yellowstone County, Montana, with his fourth DUI-related offense. The State later amended the charges to include DUI per se for operating a noncommercial vehicle with a blood alcohol concentration of 0.08 or more, fourth or subsequent offense. The appellant entered a plea agreement, pleading guilty to the amended charge in exchange for dismissal of the original DUI charge. At sentencing, both parties recommended specific incarceration and treatment conditions, and agreed to a $5,000 fine. The appellant requested that certain fees be waived due to his financial circumstances.The Thirteenth Judicial District Court accepted the plea, dismissed the original charge, and imposed the recommended sentence, including the mandatory-minimum $5,000 fine under § 61-8-731(1)(a)(iii), MCA (2019). The court also orally stated it would waive several fees. However, the written judgment subsequently entered required the appellant to pay a variety of fees and surcharges, contrary to the oral pronouncement. The appellant appealed, arguing that the mandatory fine was unconstitutional and that the imposition of fees conflicted with the oral pronouncement.The Supreme Court of the State of Montana reviewed the case. Guided by its recent decision in State v. Cole, the Court held that sentencing courts must consider a defendant’s ability to pay when imposing the mandatory-minimum fine and may suspend the portion a defendant is unable to pay. Because the District Court made no findings regarding the appellant’s ability to pay, the Supreme Court reversed the fine and remanded for further proceedings consistent with Cole. The Court also ordered the written judgment to be amended to conform to the fees waived in open court. View "State v. C. Horn" on Justia Law

The defendant was charged in three separate cases with felony offenses in Lake County, Montana, including driving under the influence for a fourth or subsequent offense. The State also sought to revoke a previously imposed suspended sentence in another DUI case. A global plea agreement was reached, and the Twentieth Judicial District Court conducted a combined sentencing hearing. The court imposed consecutive prison terms and, as relevant here, imposed a $5,000 fine for the felony DUI, which it fully suspended after considering the defendant’s financial situation. The written judgment also included a condition allowing the probation office to reinstate suspended fines and fees if the defendant failed to comply with probation terms.The defendant appealed, challenging only two aspects of the judgment: the legality of the $5,000 fine, and the condition permitting the probation office to reinstate suspended financial penalties. The State conceded that the delegation to the probation office was improper but otherwise defended the judgment. The defendant argued that the mandatory minimum fine was unconstitutional, relying on a recent Montana Supreme Court decision. The State countered that the statute at issue was not addressed in that case and urged affirmance.The Supreme Court of the State of Montana reviewed the case. The court held that, consistent with its more recent decision in State v. Cole, it is permissible for a sentencing court to impose the statutory $5,000 minimum fine for felony DUI, provided the court determines the defendant’s ability to pay and uses its authority to suspend the fine as appropriate. The court affirmed the imposition and suspension of the fine, finding the sentence lawful. However, the court held that the district court lacked authority to delegate to the probation office the power to reinstate suspended fines and fees. The case was remanded for entry of an amended judgment striking that condition. View "State v. Trombley" on Justia Law

The defendant was charged with operating a motor vehicle with a blood alcohol concentration of .08% or greater (DUI per se), first offense, in the City of Whitefish, Montana. He pleaded guilty pursuant to a plea agreement that recommended a fine and surcharge, but also requested the court consider his ability to pay and suspend the fine if warranted. At sentencing, the defendant, then 73 years old, testified about his limited financial means, relying solely on Social Security income. The Municipal Court, while sympathetic, imposed the statutory $600 minimum fine, finding it lacked discretion to suspend it, but waived the surcharge.The defendant appealed to the Eleventh Judicial District Court, which affirmed the Municipal Court’s decision. On further appeal, the Montana Supreme Court, in a prior decision (City of Whitefish v. Curran, 2023 MT 118), found that the Municipal Court had the authority to consider alternatives to full payment of the fine and remanded for consideration of such alternatives. On remand, the Municipal Court held a new hearing, again reviewed the defendant’s financial circumstances, and suspended the $600 fine in its entirety, conditioned on the defendant’s completion of court-ordered alcohol education.The Supreme Court of the State of Montana reviewed the case. It held that the applicable sentencing statutes require sentencing courts to determine a defendant’s ability to pay fines and allow courts to suspend mandatory minimum fines to the extent a defendant cannot pay. The Supreme Court found that the Municipal Court complied with these statutory requirements by considering the defendant’s ability to pay, imposing the statutory fine, and then suspending it. The Supreme Court affirmed the District Court’s order upholding the Municipal Court’s sentence and judgment. View "City of Whitefish v. Curran" on Justia Law

The case concerns a defendant who was released from custody on the express condition that he appear at a scheduled adjudicatory hearing related to an unrelated felony. He failed to appear at the specified time and place, leading the State to charge him with the felony offense of Bail Jumping under Montana law. The defendant was arrested about ten weeks after missing the hearing. He pled not guilty and subsequently moved to dismiss the charge, arguing both that the statute was unconstitutionally vague—particularly regarding the requirement that his failure to appear be “without lawful excuse”—and that the State had failed to allege sufficient facts to establish probable cause, since it did not affirmatively show he lacked a lawful excuse.The Twentieth Judicial District Court of Montana denied the defendant’s motion to dismiss. The defendant then entered a plea agreement, reserving his right to appeal the denial of his motion. He admitted to the facts constituting the offense, including that he did not have a lawful excuse for missing the hearing.On appeal, the Supreme Court of the State of Montana reviewed whether Montana’s bail-jumping statute is unconstitutionally vague and whether the State must allege facts negating the existence of a lawful excuse to establish probable cause. The Supreme Court held that the statute provides fair notice and sufficient guidelines to defendants and law enforcement, and is not unconstitutionally vague as applied to the defendant’s conduct. The Court also held that the State is not required to allege or prove the absence of a lawful excuse in its charging documents; rather, the existence of a lawful excuse is an affirmative defense for which the defendant carries the initial burden of production. The Court affirmed the judgment of the District Court. View "State v. Trombley" on Justia Law

The defendant was originally arrested for felony DUI in 2019 and sentenced to two years in the custody of the Montana Department of Corrections, followed by four years of suspended time, with credit for time served. After completing a residential treatment program, the remainder of his custodial sentence was to be served on probation, with the four-year suspended period to follow. The defendant later violated probationary terms, leading to a first revocation, where the district court imposed a suspended sentence except for placement into a treatment program and credited time served.Following additional probation violations, a second revocation proceeding occurred. After a hearing, the Fifth Judicial District Court found further violations and imposed a new disposition of five years, three months to the Department of Corrections, with credit for 505 days previously served. This resulted in a net DOC sentence of 1,410 days. Both the defendant and the State asserted that the district court improperly included the probationary portion of the original custodial sentence as part of the suspended time available for revocation, contrary to Montana law.The Supreme Court of the State of Montana held that the district court erred by revoking and converting the remaining probationary period from the custodial portion of the sentence into a DOC commitment. The court determined that, under Montana statutes, only the suspended portion of a sentence may be revoked upon a petition, and the district court’s authority did not extend to the probationary period remaining on the custodial portion. The court reversed the disposition in part and remanded for correction, instructing the district court to revoke only the 1,204 days of remaining suspended time, and clarified that credit for time served must be properly applied as required by law. View "State v. Sanchez" on Justia Law

In this case, the defendant was convicted in Oregon in 2001 of attempted unlawful sexual penetration in the first degree and sexual abuse in the second degree. After completing his sentence, including probation, in 2014, he moved to Montana in 2016 and registered as a sexual offender as required by law. In 2023, the Montana Department of Justice attempted to verify his address, but the verification was returned undeliverable. The defendant left a voicemail reporting a new address but did not update his registration in person, as required by the current statute.The State of Montana charged the defendant in 2024 with failure to register as a sexual offender, expressly citing the 2023 version of the Sexual or Violent Offender Registration Act (SVORA) in its charging documents. The defendant moved to dismiss, arguing that retroactive application of the 2023 SVORA to his pre-2007 conviction violated the Ex Post Facto Clause of the Montana Constitution. The Second Judicial District Court agreed and dismissed the charge, concluding that applying the 2023 SVORA retroactively was unconstitutional.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s dismissal de novo. The Supreme Court affirmed, holding that because the State charged the defendant under the 2023 SVORA—and this Court has previously held that the post-2007 version of SVORA is punitive and cannot be applied retroactively to convictions predating its enactment—the prosecution could not stand. The Court emphasized that the State could not rely on older versions of SVORA not cited in the charging documents and did not address arguments regarding restoration of rights, limiting its decision to the ex post facto violation. The order of dismissal was affirmed. View "State v. Pratt" on Justia Law

The case arose after the defendant was charged in July 2020 with felony driving under the influence (DUI) in Missoula County, Montana. He entered a plea agreement with the State, pleading guilty to the DUI charge in exchange for dismissal of another case. The parties jointly recommended a 13-month commitment to the Department of Corrections with specific placement and a subsequent suspended sentence. Although they agreed the court could impose the mandatory minimum $5,000 fine, the defendant’s financial circumstances showed he could not pay most of it, as he subsisted primarily on Social Security and had very limited resources.The Fourth Judicial District Court, Missoula County, presided over sentencing. The defendant’s counsel requested the fine be stricken due to the defendant’s inability to pay. The court conducted an inquiry into his financial circumstances, then imposed the $5,000 fine but credited $100 for jail time and suspended the remaining $4,900, contingent on the defendant’s compliance with probation. The court’s judgment reflected an order for the defendant to pay $0 of the fine.On appeal, the Supreme Court of the State of Montana considered whether the District Court legally imposed the mandatory minimum fine by suspending the portion the defendant could not pay. The Supreme Court overruled its prior holding in State v. Gibbons, which had found such mandatory minimum fines facially unconstitutional. The Court held that sentencing courts must impose the statutory minimum fine but are required, under the ability-to-pay statute, to suspend any portion the defendant is unable to pay. The Court concluded that, when the fine is imposed and suspended consistent with the defendant’s ability to pay, the statutory scheme is constitutional, and the sentence is legal. The Supreme Court of Montana affirmed the District Court’s judgment. View "State v. Cole" on Justia Law

The case concerns a defendant who was arrested on March 18, 2022, after leading police on a high-speed chase in a stolen vehicle while intoxicated. He was charged with several felonies, including felony driving under the influence, criminal endangerment, and theft. At the time of the incident, he was already subject to release conditions in other pending cases. Following his arrest, he was unable to post a substantial bond and was detained until he became a Department of Corrections inmate in November 2022 for an unrelated case. Over the following months, the scheduling of his trial was affected by continuances, plea negotiations, overlapping trial dates with his other pending cases, and court docket priorities.The Twenty-First Judicial District Court denied the defendant’s motion to dismiss for lack of a speedy trial after approximately 476 days elapsed between his arrest and his no-contest plea. The District Court attributed a significant portion of the delay to institutional reasons but also found that the defendant was responsible for numerous delays, including his requests for continuances, his actions during plea negotiations, and his acquiescence in having multiple cases scheduled for trial on the same dates. The District Court concluded that the defendant’s right to a speedy trial had not been violated.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s decision de novo, applying the four-factor test set out in State v. Ariegwe. The Supreme Court held that although the delay was lengthy and primarily institutional, the defendant was responsible for significant portions of it, and his conduct did not display a genuine desire for a speedy trial. The Court further found that the defendant suffered no actual prejudice from the delay. The Supreme Court affirmed the District Court’s denial of the motion to dismiss for lack of a speedy trial. View "State v. Larson" on Justia Law