Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the sentence imposed by the district court follow revocation of Appellant's suspended sentence, holding that the district court erred by denying credit for elapsed time served on probation without basing the denial on specific probation violations.At issue was whether the district court violated Mont. Code Ann. 46-18-203(7)(b) by denying credit for elapsed time served on probation without basing the denial on specific probation violations. The Supreme Court answered the question in the positive, holding that the district court erred by denying Defendant's requested elapsed-time credit under Mont. Code Ann. 46-18-203(7)(b). View "State v. Gudmundsen" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual intercourse without consent, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by excluding evidence related to Defendant's accuser's pending DUI charge in another county; (2) the district court did not violate Defendant's constitutional right to confront the witnesses against him or present his defense by limiting cross-examination of Defendant's accuser regarding alleged leniency she may have received related to her pending DUI case in return for her testimony against Defendant; and (3) the chief prosecutor’s prior representation of Defendant did not deprive the entire Lake County Attorney’s Office of authority to prosecute Defendant. View "State v. James" on Justia Law

The Supreme Court affirmed the sentencing order and judgment following Defendant's conviction of incest, holding that the district court did not err in excluding evidence of the complaining witness's prior statements regarding an alleged "false accusation" of sexual assault.After a jury trial, Defendant was convicted of incest and sentenced to imprisonment for a 100-year sentence. On appeal, Defendant argued that the district court erred when it excluded evidence of prior statements regarding an alleged "false accusation" of sexual assault made by K.O., the complaining witness. The Supreme Court affirmed, holding that the district court did not abuse its discretion by excluding evidence of K.O.'s statements regarding the prior statements at issue. View "State v. Hansen" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Appellant of incest for the sexual abuse of T.N. and sentencing her to 100 years in prison, holding that there was no error or abuse of proceedings in the proceedings below.Specifically, the Supreme Court held (1) the district court did not violate Defendant's "right to access witnesses" in denying her motion to to conduct pretrial interviews with T.N. and J.M.; (2) the State's failure to lodge with the district court forensic interviews from a different case did not violate Defendant's right to a fair trial, and Defendant was not entitled to a new trial on this ground; and (3) based on the totality of the evidence, this Court declines to employ the doctrine of plain error to review Defendant's claim that the district court should have given a specific unanimity instruction. View "State v. Mathis" on Justia Law

The Supreme Court affirmed Defendant's convictions of deliberate homicide and attempted deliberate homicide, holding that the district court did not err in denying Defendant's motion for new counsel.Defendant was convicted of murdering his estranged wife and attempting to murder her roommate. The district court imposed a 100-year sentence for each count, to run consecutively, and imposed a ten-year consecutive weapon enhancement for each offense. On appeal, Defendant argued that the district court abused its discretion when it concluded that Defendant's complaints regarding his counsel did not warrant a hearing on his motion to substitute counsel. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Defendant's request to substitute counsel. View "State v. Dewise" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Petitioner's petition for postconviction relief, holding that the district court correctly denied the postconviction relief petition.After a jury trial, Petitioner was found guilty of theft by common scheme for embezzling a sizable amount of money from a youth softball organization. The Supreme Court affirmed. Petitioner later brought this postconviction petition alleging, among other claims, ineffective assistance of his trial counsel. The district court denied the petition. The Supreme Court affirmed, holding that the district court did not err in concluding that Petitioner failed to demonstrate deficiency in his appellate counsel's representation and that his remaining complaints were unsuitable grounds for postconviction relief. View "Crabtree v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of five felony sexual offenses against his former stepdaughter and one count of sexual intercourse without consent against his former wife, B.J., holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) the district court's denial of Defendant's motion to remove a prospective juror for cause was not a structural error requiring reversal of Defendant's convictions or a new trial; (2) the district court did not err by giving a conduct-based jury instruction defining mental state for the offense against B.J. rather than a results-based definition; and (3) this Court declines to exercise plain error review of an incorrect jury instruction on the definition of consent offered by Defendant. View "State v. Deveraux" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to suppress and remanded this case to the district court to vacate Defendant's conviction of criminal possession of dangerous drugs and use or possession of property subject to criminal forfeiture, holding the district court erred in denying Defendant's motion to suppress.In his motion to suppress, Defendant claimed that law enforcement exceeded the scope of a lawful traffic stop by asking Defendant for his license and then questioning him behind the vehicle after learning that the license was valid. The district court denied the motion, concluding that the officer lawfully escalated his investigation from a traffic stop to an investigation of other criminal activity. The Supreme Court reversed, holding that the officer did not possess the requisite particularized suspicion to expand the scope of the traffic stop into a criminal investigation. View "State v. Carrywater" on Justia Law

The Supreme Court affirmed the judgment and sentence of the district court in this criminal case, holding that the district court adequately considered evidence of Defendant's post-offense rehabilitation under Miller v. Alabama, 567 U.S. 460 (2012), and imposed a constitutional sentence by striking a parole restriction.When he was seventeen years old, Defendant was charged with burglary and three counts of deliberate homicide. Defendant was convicted of all counts and sentenced to three consecutive life sentences without parole. Defendant later filed a successful postconviction petition seeking resentencing under Miller. After a resentencing hearing, the district court sentenced Defendant to three consecutive life terms at MSP without the possibility of parole. The Supreme Court remanded the case. On remand, the district court resentenced him to three life sentences and did not restrict Defendant's eligibility for parole. The Supreme Court affirmed, holding that the district court complied with the Court's instructions on remand in Keefe II and imposed a legal sentence. View "Keefe v. State" on Justia Law

The Supreme Court affirmed the judgment and commitment issued by the district court following Defendant's convictions for two counts of deliberate homicide and one count of tampering with or fabricating physical evidence, holding that there was no error.On appeal, Defendant argued that the district court erred in admitting any and all text messages at trial and by not giving Defendant's proposed instruction regarding reasonable doubt. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by admitting testimony regarding certain text messages at trial; and (2) did not abuse its discretion by declining to give Defendant's proposed jury instruction regarding reasonable doubt. View "State v. Wienke" on Justia Law