Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of sexual intercourse without consent, tampering with witnesses and informants, privacy in communications, and stalking, holding that there was no prejudicial error in the proceedings below.At issue on appeal was whether the district court abused its discretion by allowing the State to file a third amended information in the middle of trial and whether the district court's jury instruction on consent warranted reversal for plain error. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it allowed the State to file its third amended information mid-trial; and (2) the district court did not abuse its discretion in instructing the jury on consent. View "State v. Lafournaise" on Justia Law

The Supreme Court reversed the judgment of the district court finding Defendant guilty of attempted deliberate homicide and sentencing him to serve an eighty-year prison term with no time suspended, holding that the district court prejudicially erred in one of its evidentiary rulings.On appeal, Defendant argued that the district court abused its discretion by allowing the State to reference and elicit testimony regarding Defendant's prior child sex abuse comments and references in an explicit and repetitive manner. The Supreme Court agreed and remanded this case for a new trial, holding that the district court (1) did not abuse its discretion in denying Defendant's motion in liming to categorically exclude all references to Defendant's prior child sexual abuse comments and references; but (2) erred by failing to carefully limit the subject prior bad acts evidence to avoid its manifestly inherent risk of unfair prejudice. View "State v. Lake" on Justia Law

The Supreme Court reversed Defendant's conviction for sexual intercourse without consent, a felony, and affirmed his remaining convictions for aggravated kidnapping and assault with a weapon, holding that defense counsel's deficient performance undermined this Court's confidence in the outcome of the proceedings as it pertained to Defendant's conviction for sexual intercourse without consent.At issue on appeal was whether Defendant received ineffective assistance of counsel when his attorney failed to object to expert testimony on the statistical likelihood that Defendant's accuser was lying. The Supreme Court held that while the testimony may have improperly bolstered the complaining witness's testimony regarding the element of consent as to the sexual intercourse without consent charge it had no bearing on the kidnapping and assault with a knife charges. View "State v. Quiroz" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of nine counts of assault on a minor and one count of perjury, holding that sufficient evidence existed to support Defendant's conviction for perjury and that the district court did not err in denying Defendant's motion to dismiss due to a speedy trial violation.Specifically, the Supreme Court held (1) viewing the light most favorable to the State, a rational trier of fact could have found the essential elements of perjury beyond a reasonable doubt based on Defendant's testimony, a jail phone call made by Defendant, and trial testimony; and (2) the district court did not err in concluding that the State did not violate Defendant's right to a speedy trial. View "State v. Burnett" on Justia Law

The Supreme Court affirmed Defendant's conviction of theft and burglary for stealing merchandise from the Ravalli Services Corporation donation intake center, holding that the district court did not err or abuse its discretion.Specifically, the Supreme Court held that the district court (1) did not abuse its discretion by excluding F.Z., a developmentally disabled witness, as a witness on the ground that he was incompetent to testify; (2) did not err in instructing the jury to disregard testimony that Defendant applied for a job at a motel one year before committing the charges; and (3) did not abuse its discretion in permitting the State to call a certain rebuttal witness. View "State v. Wilson" on Justia Law

The Supreme Court reversed the judgment of the district court finding two officials with the Montana Department of Public Health and Human Services (hereinafter, MDPHHS) in indirect contempt of referenced orders in the underlying matter and imposing a sanction pending subsequent compliance with the subject orders, holding that the district court erred.The referenced orders at issue directed the Montana State Hospital to accept custody and care of the underlying criminal defendant for fitness rehabilitation pursuant to Mont. Code Ann. 46-14-221(2)-(3) and thus imposing a $500 per-day coercive civil sanction pending future compliance with the orders. The district court adjudicated MDPHHS in indirect contempt for failing to transport the defendant as required and imposed a $500 per-day coercive civil sanction. The Supreme Court reversed, holding (1) the district court's threshold contempt finding and resulting imposition of a coercive civil sanction were both erroneously based on a clearly erroneous finding of material fact; and (2) the court's imposition of a continuing or cascading per-day fine was further erroneous in excess of the limiting language of Mont. Code Ann. 3-1-501(3). View "Fouts v. Eighth Judicial District Court" on Justia Law

The Supreme Court reversed the order of the district court reinstating dismissed criminal charges against Defendant over Defendant's counsel's objection, holding that the court erred in resuming the dismissed criminal case after Defendant spent years in civil commitment following an earlier finding of his lack of fitness to proceed.In 2005, Defendant was charged with felony sexual assault and misdemeanor indecent exposure. The district court found Defendant unfit to proceed and suspended the criminal process to determine whether Defendant could gain competency to stand trial. The district court later found that Defendant met the requirements for civil commitment, and for years thereafter, the State successfully filed petitions for recommitment in Defendant's civil case. In 2017, Defendant requested a hearing regarding his recommitment and time to complete another psychological evaluation. In return, the State entered a new motion in its dismissed criminal case from 2005. The district court reinstated Defendant's criminal case so that Defendant could remain committed while the criminal case moved forward. Defendant pleaded guilty to sexual assault while reserving issues for appeal. The Supreme Court reversed the district court's decisions granting the State's motion to reevaluate Defendant's fitness to proceed and reopening his criminal case, holding that double jeopardy and other due process considerations precluded the State from resuming Defendant's criminal case. View "State v. Mosby" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained as a result of warrantless search of his apartment, holding that the district court did not err in denying Defendant's motion to suppress.In this case, three probation officers and a deputy federal marshal made a warrantless entry into Defendant's apartment without his consent to investigate his reported methamphetamine use and possible drug overdose in violation of the law and Defendant's probation. The district court concluded that the warrantless entry into Defendant's apartment was a constitutional search. The Supreme Court affirmed, holding that the district court (1) correctly concluded that the warrantless entry and probation search of Defendant's apartment was lawful on reasonable suspicion under the probation search exception to the warrant requirement of Mont. Const. art. II, 10-11; and (2) did not err in denying Defendant's motion to suppress based on the manner in which the officers entered the apartment or treated Defendant thereafter. View "State v. Peoples" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for assault on a peace officer, holding that there was no error in the proceedings below.Defendant's first trial ended in a mistrial after the jury failed to reach a verdict. After a second trial, a jury found Defendant guilty. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in denying Defendant's motion for continuance after setting the trial during his counsel's pre-planned vacation; (2) abused its discretion when it denied Defendant's motion to allow his witness to testify in shackles, handcuffs, and a jail jumpsuit; and (3) did not err in sentencing Defendant as a persistent felony offender. View "State v. Rossbach" on Justia Law

The Supreme Court reversed the order of the district court affirming the denial of Defendant's motion to suppress evidence, holding that law enforcement officers lacked particularized suspicion to justify their investigatory stop of Defendant.Defendant was stopped by law enforcement officers based solely on his "flicking" his high beams on and off once. Defendant entered a conditional guilty plea to aggravated driving under the influence, third offense, reserving the right to appeal the justice court's denial of his motion to suppress. The district court affirmed. The Supreme Court reversed, holding that the totality of the circumstances did not give rise to particularized suspicion, and therefore, the seizure violated Defendant's constitutional right to be free from unreasonable searches and seizures. View "State v. Gardner" on Justia Law