Justia Montana Supreme Court Opinion Summaries

The defendant pleaded guilty to burglary, theft, and criminal mischief in 2017 and was sentenced to concurrent terms with a portion suspended, as well as ordered to pay restitution and various fees. After serving time in corrections and being released, he began the suspended portion of his sentence in 2020. In 2023, the State petitioned to revoke his probation, citing a new drug charge and several compliance violations, including failure to pay restitution and fees. The defendant admitted to the new criminal charge, and the other alleged violations were dismissed. At issue was whether he should receive credit for the time he spent on probation (“street time”) before revocation, given his failure to make restitution payments during a specific period.The Montana Eighth Judicial District Court found that, despite the lack of documented violations between August 2020 and January 2023, the defendant’s ongoing failure to pay restitution and fees constituted continuous noncompliance. The court denied him any credit for street time, reasoning that his nonpayment reflected a pattern of disregard for court-ordered conditions.The Supreme Court of the State of Montana reviewed the case de novo, focusing on whether the defendant’s nonpayment of restitution, absent evidence of a clear payment schedule or corrective interventions by his probation officer, constituted a violation sufficient to deny street time credit under § 46-18-203(7)(b), MCA. The Court held that, without a specific directive or record of interventions regarding payment, the State failed to establish a violation during the relevant period. Therefore, the District Court erred in denying street time credit. The Supreme Court reversed the lower court’s decision and remanded the case, directing that the defendant be credited with 883 days of street time. View "State v. Powell" on Justia Law

On May 29, 2003, two Blaine County Sheriff’s deputies responded to a domestic disturbance involving Laurence Dean Jackson Jr. in Harlem, Montana. During a pursuit through a field, both deputies were shot; Deputy Rutherford died from a gunshot wound to the chest, and Deputy Janis was severely injured. Jackson, claiming an alcohol-induced blackout, could not recall the events, leaving Janis as the sole eyewitness. At trial, the State relied on Janis’s testimony and physical evidence to argue that Jackson shot both deputies after a struggle. Jackson’s defense presented expert testimony challenging the State’s account, including a theory that the fatal bullet may have been fired by Janis, not Jackson.Following a 17-day trial in October 2004, Jackson was convicted of deliberate homicide and attempted deliberate homicide, receiving life sentences without parole. The Montana Supreme Court affirmed his conviction in 2009, and the U.S. Supreme Court denied certiorari in 2010. In 2011, Jackson filed a petition for postconviction relief in the Seventeenth Judicial District Court, Blaine County, alleging ineffective assistance of counsel. The District Court allowed for additional evidence and expert review but ultimately denied the petition without an evidentiary hearing, finding Jackson’s claims lacked specific factual support as required by Montana law.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by denying Jackson’s petition without a hearing. Applying the Strickland v. Washington standard, the Court held that Jackson failed to present established facts showing deficient performance or prejudice by counsel. The Court found Jackson’s claims speculative and unsupported by the record, concluding the District Court acted within its discretion. The Supreme Court affirmed the denial of postconviction relief. View "Jackson v. State" on Justia Law

The defendant was cited for a third offense of driving under the influence (DUI) and for driving with a suspended license, both misdemeanors, in November 2021. He was initially convicted in Justice Court and then sought a trial de novo in the District Court. At trial, a jury found him guilty of both offenses. During sentencing, the defendant’s counsel informed the court that the defendant was on a limited income, receiving disability and social security, and requested that the court consider his financial situation when imposing fines and fees, including a request to waive the public defender fee.After the jury verdict in the Twenty-First Judicial District Court, the court sentenced the defendant to jail time, most of which was suspended, and imposed a $3,000 fine with statutory surcharges and a $250 public defender fee. The written judgment also included a $10 technology fee and $50 in prosecution costs, which were not mentioned in the oral pronouncement. The defendant appealed, arguing that the written judgment conflicted with the oral sentence and that the court failed to consider his ability to pay the fines and fees.The Supreme Court of the State of Montana reviewed the case. It held that when there is a conflict between the oral sentence and the written judgment, the oral sentence controls, and thus the $10 technology fee and $50 prosecution costs should not have been included. The court further held that the District Court erred by failing to inquire into the defendant’s ability to pay the public defender fee, the $3,000 fine, and the statutory surcharges, as required by Montana statutes. The Supreme Court reversed the sentence and remanded the case for a new sentencing hearing consistent with its opinion. View "State v. Post" on Justia Law

The case concerns the fatal shooting of Brett Ness in Billings, Montana, following a series of drug-related disputes. Alexander Garrett LaForge III, along with several others, was involved in confrontations with Ness over an alleged shortfall in a methamphetamine transaction. After escalating tensions and threats, LaForge and a group of associates returned to Ness’s trailer, where LaForge shot Ness in the head with a .45 caliber pistol. Ness died later that day. Multiple co-defendants received plea deals in exchange for their testimony against LaForge.The Thirteenth Judicial District Court, Yellowstone County, presided over LaForge’s trial. LaForge requested a substitution of counsel shortly before trial, citing communication issues and dissatisfaction with his attorney’s preparation. The District Court conducted an inquiry and denied the request, finding no substantial breakdown in communication. During trial, LaForge also requested a cautionary jury instruction regarding the credibility of co-defendants’ testimony, which the District Court declined, instead providing standard witness credibility instructions and a specific instruction regarding one co-defendant’s accountability. The jury convicted LaForge of deliberate homicide. At sentencing, the court ordered LaForge to pay $72,000 in restitution to the victim’s mother for lost business income, based on her testimony about canceled jobs following her son’s death.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not abuse its discretion in denying LaForge’s request for substitute counsel or in its jury instructions regarding co-defendant testimony. However, the Supreme Court found that the $72,000 restitution award was not supported by sufficient evidence and that the record was unclear as to whether the victim’s mother, as a business representative, qualified as a “victim” under the restitution statutes. The Supreme Court affirmed the conviction and other aspects of the judgment, reversed the restitution award, and remanded for a new hearing to determine the proper amount and recipient of restitution. View "State v. LaForge" on Justia Law

The case concerns a defendant who was charged with multiple offenses, including attempted deliberate homicide, criminal endangerment, obstructing a peace officer, and tampering with evidence, following a shooting incident at his home involving law enforcement. The defendant had been target shooting on his property, which led to complaints from neighbors and multiple interactions with police. After a SWAT team arrived and attempted to arrest him, the defendant fired several rounds toward officers and their armored vehicle, believing he and his family were under threat. He was ultimately taken into custody after a standoff.The First Judicial District Court, Lewis and Clark County, presided over the trial. The defendant was represented by appointed counsel, who did not pursue a justifiable use of force defense or request instructions for attempted mitigated deliberate homicide as a lesser included offense. The jury convicted the defendant on all charges. After trial, the defendant raised concerns about his counsel’s performance, particularly regarding the lack of mental health evaluation and failure to present certain defenses. The District Court appointed new counsel for sentencing. At sentencing, the court orally pronounced a sentence totaling 46 years of incarceration with 5 years suspended, but the written judgment imposed a longer sentence and included additional conditions not stated orally.The Supreme Court of the State of Montana reviewed the case. It held that the ineffective assistance of counsel claims related to the failure to present certain defenses or request lesser included offense instructions were not record-based and should be pursued, if at all, in post-conviction proceedings, with counsel appointed for that purpose. The court affirmed the denial of the ineffective assistance claim regarding failure to object to the prosecutor’s misstatement of the mental state element, finding no prejudice. The court reversed the written judgment to the extent it exceeded the oral pronouncement and remanded for entry of an amended judgment consistent with the oral sentence. View "State v. Arvidson" on Justia Law

In 2006, the defendant pled guilty to criminal possession with intent to distribute after a traffic stop revealed marijuana, cash, and drug paraphernalia, and police discovered an outstanding warrant. He was sentenced to a 10-year term with 8 years suspended, to run consecutively to a separate sentence from another county. After beginning the suspended portion of his sentence in 2017, he repeatedly failed to comply with probation conditions, leading to a first revocation in 2018 and a new sentence of 8 years with 5 years suspended. While serving this suspended sentence, he again violated conditions, including new arrests for drug offenses and failing to report, prompting a second revocation proceeding.The Twentieth Judicial District Court, Lake County, held hearings on the second revocation. Testimony from the probation officer and law enforcement detailed the defendant’s ongoing noncompliance, including substance use, lack of employment, and failure to maintain a residence. The court revoked the suspended sentence, imposed a 5-year commitment to the Department of Corrections with no time suspended, and denied credit for both time served in detention and for “street time” (elapsed time on probation without incarceration). The court’s oral and written pronouncements did not grant any credit for time served.On appeal, the Supreme Court of the State of Montana held that the district court erred by not granting credit for time served in detention, as required by statute, and remanded for a factual determination of the correct number of days to be credited. However, the Supreme Court affirmed the denial of credit for elapsed street time, finding the record supported continuous noncompliance. The court also rejected the defendant’s claim of ineffective assistance of counsel, concluding there was no prejudice since the district court considered and properly denied street time credit. The judgment was affirmed in part, reversed in part, and remanded. View "State v. Shewalter" on Justia Law

Cissy Deen Manyhides was placed on probation after pleading guilty to Endangering the Welfare of a Child. As a condition of her probation, she agreed to make her residence open and available to probation officers for home visits or searches upon reasonable suspicion, and to refrain from possessing illegal drugs. In February 2022, probation officers conducted a home visit at her apartment. During a walkthrough for safety and compliance, one officer observed drug paraphernalia in plain view in her bedroom. This led to a further search of her belongings, revealing additional contraband and suspected methamphetamine. Manyhides was subsequently charged with drug possession and possession of drug paraphernalia.The Eighth Judicial District Court of Montana reviewed Manyhides’s motion to suppress the evidence, arguing that the officers’ actions constituted an unlawful search. The District Court denied the motion, finding that the officers’ conduct during the home visit did not amount to a search under the law. Manyhides then pleaded guilty to felony drug possession while reserving her right to appeal the suppression ruling.The Supreme Court of the State of Montana reviewed the District Court’s decision. The Supreme Court held that a standard probation home visit, conducted pursuant to explicit probation conditions, does not constitute a search requiring reasonable cause. The Court found that Manyhides had no reasonable expectation of privacy precluding such visits, as she had agreed to the conditions of her probation. The officers’ actions remained within the permissible scope of a home visit until contraband was observed in plain view, at which point reasonable cause existed for a further search. The Supreme Court affirmed the District Court’s denial of the motion to suppress. View "State v. Manyhides" on Justia Law

The defendant was charged with multiple felony and misdemeanor violations for repeatedly contacting his estranged wife in violation of a temporary order of protection issued in May 2022. After the order was dismissed due to the protected party’s absence at a hearing, the defendant continued his prohibited communications, including sending over 100 text messages in a short period. He was arrested and later entered into a plea agreement, acknowledging the State’s intent to seek Persistent Felony Offender (PFO) status but securing a promise that the State would not pursue the PFO designation if he complied with certain conditions, including not committing further offenses or violating bail.The Eighth Judicial District Court, Cascade County, presided over the case. After the defendant pled guilty, he was released on his own recognizance. However, prior to sentencing, the State alleged that the defendant violated release conditions by continuing to contact the protected party. The State then sought to pursue the PFO designation, arguing that the defendant’s breach of the plea agreement allowed it to deviate from its original sentencing recommendation. The District Court continued the sentencing hearing to allow briefing and argument on whether the State’s PFO notice was timely and whether the defendant had breached the agreement. The District Court found that the State’s notice, although sent two minutes after the deadline, was sufficient and that the defendant suffered no prejudice from the timing.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in accepting the State’s PFO notice and imposing a PFO sentence, and whether plain error review should be conducted regarding the court’s omnibus hearing procedure. The Supreme Court held that the State’s PFO notice was compliant and timely for statutory purposes, and that the defendant was not prejudiced by the minor delay. The Court also declined to exercise plain error review over the omnibus hearing procedure. The judgment of the District Court was affirmed. View "State v. Anderson" on Justia Law

Erin Holcomb was convicted of deliberate homicide following an incident at a friend’s house near Fairfield, Montana. On the night in question, Holcomb and two friends arrived at the home after drinking and shooting guns earlier in the day. Holcomb brought a handgun into the house and was seen handling it repeatedly. After a dispute over driving due to intoxication, Holcomb refused to leave the driver’s seat of a truck, leading to a heated argument with the host, Trysten Fellers. Later, Fellers called his father for help, and after further attempts to get the guests home, Fellers drove his farm truck out to where Holcomb was in a field. Fellers stopped the truck, illuminating Holcomb, and a gunshot was heard. Fellers was found with a fatal gunshot wound, and Holcomb was arrested the next morning.The State of Montana charged Holcomb with deliberate homicide in the Ninth Judicial District Court. At trial, Holcomb’s defense requested a jury instruction on justifiable use of force, arguing that evidence showed Holcomb feared imminent harm from Fellers, who allegedly assaulted and pursued him. The District Court denied this request, finding insufficient evidence that Holcomb was in imminent danger of death or serious bodily injury. After a five-day trial, the jury found Holcomb guilty.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in refusing the justifiable use of force instruction. The Supreme Court held that the trial record did not support the instruction, as there was no evidence that Fellers physically assaulted Holcomb, drove threateningly, or fired a weapon at him. The Court concluded that Holcomb’s fear was not reasonable or supported by the evidence, and affirmed the conviction. View "State v. Holcomb" on Justia Law

The case concerns a defendant who was charged with felony distribution of dangerous drugs in Montana, based on alleged conduct between July 2017 and February 2018. During pretrial proceedings, the State redacted portions of discovery materials, including a police report and a witness interview transcript, to exclude information not related to the defendant or not considered impeachment evidence. The witness in question, Ferguson, was facing federal charges and ultimately testified at trial that she had supplied the defendant with methamphetamine but denied receiving any promises or benefits for her testimony, aside from immunity from state charges.At trial in the Eighth Judicial District Court, several witnesses testified to the defendant’s involvement in drug transactions. Ferguson’s testimony was corroborative but not the sole evidence against the defendant. After the defendant’s conviction, a federal prosecutor filed a motion to reduce Ferguson’s sentence, citing her assistance in the defendant’s case. The defendant’s counsel was unaware of this at the time of trial and sentencing. The defendant later filed a petition for postconviction relief, arguing that the State violated its obligations under Brady v. Maryland by failing to disclose potential benefits to Ferguson and under Napue v. Illinois by not correcting her allegedly false testimony regarding those benefits. The District Court denied the petition, finding no evidence of a pretrial agreement or expectation of benefit that could be imputed to the State, and concluded that any non-disclosure was not material to the outcome.The Supreme Court of the State of Montana affirmed the District Court’s denial of postconviction relief. The Court held that, while evidence of a witness’s expectation of a benefit may be subject to disclosure, the record did not establish that such an expectation existed or that it could be imputed to the State prosecutor. Furthermore, the Court found that any non-disclosure was not material, as other substantial evidence supported the conviction. The Court also rejected the Napue claim, finding no basis to conclude the State knowingly allowed false testimony. View "Temple v. State" on Justia Law