Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment entered by the district court after a jury trial adjudging Defendant guilty of incest in violation of Mont. Code Ann. 45-5-507(1), holding that the district court did not err in admitting evidence of other acts.On appeal, Defendant argued that the district court erred by denying his pre-trial motion in limine to exclude evidence of other acts committed between Defendant and the victim in Wyoming on the grounds that the evidence showed motive, opportunity and Defendant's pattern of behavior and the absence of mistake or accident. The Supreme Court affirmed, holding (1) the district court did not err by denying Defendant's motion in limine to exclude the evidence on the grounds that it relevant and admissible to prove motive, plan, and preparation under Mont. R. Evid. 404(b); and (2) the danger of unfair prejudice was cured by the district court's numerous and repeated limiting instructions. View "State v. Stryker" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's untimely post-conviction relief (PCR) petition and his motion for a new trial, holding that the district court did not abuse its discretion in finding that Appellant failed to present any evidence that would justify an exception to the time bar and denying his claims of ineffective assistance of counsel.In June 2016, Appellant was convicted of the felony aggravated assault of his son and was sentenced to twenty-two years in prison. In June 2020, Appellant filed a petition for a new trial and his PCR petition. The district court denied relief, holding (1) Appellant fell short of providing an equitable reason to depart from the determination that the PCR petition was time barred; and (2) Appellant did not offer newly-discovered evidence justifying granting his motion for new trial. The Supreme Court affirmed, holding that the district court (1) properly concluded that Appellant's PCR petition did not allege the existence of any newly-discovered evidence that would allow an exception to the one-year limitation; and (2) correctly denied Appellant's petition for a new trial based upon the alleged ineffective assistance of his trial counsel. View "Oliphant v. State" on Justia Law

The Supreme Court reversed Defendant's sentence for driving under the influence (DUI), holding that the district court erred by sentencing Defendant to the Montana State Prison (MSP) and by requiring him to pay a $100 statutory surcharge.Defendant was charged with felony DUI for a sixth offense. After a trial, the jury found Defendant guilty of DUI. The district court sentenced Defendant to serve a five-year term at the MSP and ordered him to pay a $100 surcharge pursuant to Mont. Code Ann. 46-18-236(1). The Supreme Court reversed in part, holding (1) the district court did not err by determining that permitting a certain witness to appear by video was supported by appropriate public policy considerations; and (2) as conceded by the statute, Defendant should have been sentenced to the Department of Corrections up to a maximum of five years and not to MSP, and the district court should have assessed Defendant a surcharge of $50. View "State v. Walsh" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for two counts of felony tampering with witnesses, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) the State presented sufficient evidence to support Defendant's convictions for witness tampering pursuant to Mont. Code Ann. 45-7-206; (2) this Court declines to exercise plain error review of Defendant's claims of prosecutorial misconduct; and (3) trial counsel's failure to object to a alleged misconduct by the prosecutor did not constitute ineffective assistance of counsel. View "State v. Palafox" on Justia Law

The Supreme Court reversed the conclusion of the district court that the more than three-year delay between Defendant's arrest and his subsequent criminal trial did not violate his constitutional right to a speedy trial, holding that Defendant did not receive his guaranteed right to a speedy trial.Defendant was charged with assault with a weapon. After facing a lengthy wait to be evaluated for his mental fitness to stand trial Defendant received a bed at the Montana State Hospital (MSH), where his fitness for trial improved. Defendant's fitness, however, decompensated after he was sent back to jail, leading to a second admission to MSH before the case finally went to trial. A jury found Defendant guilty, and the district court denied Defendant's motion to dismiss for lack of speedy trial. The Supreme Court reversed, holding that the 1,179-day delay between Defendant's arrest and trial, due to systemic institutional problems, violated Defendant's constitutional right to a speedy trial. View "State v. Allery" on Justia Law

The Supreme Court reversed the judgment of the district court revoking Defendant's deferred sentence and sentencing him to a five-year term with the Montana Department of Corrections (DOC) and giving him credit for 138 days of time served, holding that's the district court imposed an illegal sentence.After an adjudicatory hearing, the district court found that Defendant committed several violations of his probation, as alleged by the State. The district court imposed the sentence after holding a dispositional hearing. The Supreme Court reversed, holding that the district court lacked authority to revoke Defendant's previous deferred sentence and to resentence him to a five-year DOC commitment because the deferred sentence expired before the State filed a petition to revoke. View "State v. Ellsworth" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of bail-jumping and sentencing him to ten years in prison with no time suspended, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not violate Defendant's constitutional right to confrontation by admitting minute entries by the clerk of court stating that Defendant was present at his arraignment but absent from his omnibus hearing; and (2) the trial court did not commit reversible error when it denied Defendant's motion to continue the trial date because Defendant's substantial right were not prejudiced. View "State v. Staudenmayer" on Justia Law

The Supreme Court affirmed the judgment and commitment of the district court sentencing Appellant to fifty-five years in the Montana State Prison, including a consecutive ten-year commitment to the Department of Corrections, for his two criminal endangerment convictions, holding that there was no error.On appeal, Defendant argued that his two criminal endangerment convictions violated Mont. Code Ann. 46-11-410(2)(a), the multiple charges statute, because his convictions arose from the same transaction. The Supreme Court affirmed, holding that Defendant's convictions of criminal endangerment were based on two distinct criminal offenses and therefore did not violate the multiple charges statute. View "State v. McNamara" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant for robbery, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that he did not knowingly and voluntarily waive his right to counsel during his criminal trial. Defendant also argued, for the first time, that the district court compromised his right to a unanimous jury verdict by not giving a specific unanimity instruction requiring the jury to agree that either or both victims were in fear of immediate bodily injury. The Supreme Court affirmed, holding (1) Defendant knowingly and voluntarily waived his right to counsel; and (2) this Court declines to exercise plain error review to address Defendant's second argument on appeal. View "State v. Winzenburg" on Justia Law

The Supreme Court affirmed Defendant's conviction and judgment of guilty for the offense of escape, holding that Defendant was not entitled to relief on his claims of error.The State charged Defendant with felony escape after he failed to report to his probation offense. The jury returned a guilty verdict, and Defendant was sentenced to six years' imprisonment. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant's motion to dismiss for insufficient evidence; and (2) did not err in declining to provide Defendant's requested jury instruction for criminal contempt as a lesser-included offense. View "State v. Ohl" on Justia Law