Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the district court, holding that the proceedings must be remanded for Defendant to receive credit for time served.Defendant was convicted and sentenced for criminal endangerment and was sentenced to a five-year suspended sentence. After Defendant committed several probation violations, the district court revoked his suspended sentence and imposed a new sentence. The order denied Defendant's request that he be credited for a sixty-day period that he served as a sanction at the Sanction, Treatment, Assessment, Revocation, and Transition (START) facility. The Supreme Court held (1) Defendant's first argument was not preserved for appeal; and (2) Defendant was entitled to credit for time served at the START facility. View "State v. Tippets" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained from a blood draw conducted pursuant to a search warrant, holding that there was no error.Defendant moved to suppress evidence obtained from a blood draw, arguing that Wheatland County Justice of the Peace Richard Egabakken lacked jurisdiction to issue the warrant because the crimes occurred in Golden Valley County. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err when it concluded that Justice of the Peace Egebakken had jurisdiction to issue a search warrant for Defendant's blood draw in Wheatland County. View "State v. Grussing" on Justia Law

The Supreme Court reversed the order of the district court affirming the municipal court's denial of Defendant's motion to dismiss the charge of obstructing a peace officer for insufficient evidence, holding that the district court erred.Defendant was charged with obstructing a peace officer by attempting to walk away from officers while being questioned. Defendant moved to dismiss the charge for insufficient evidence, arguing that she could not knowingly obstruct the officer's enforcement of the law where the officer failed to inform her that she was being detained or otherwise required to remain on scene to answer questions. The municipal court denied the motion, and the district court affirmed. The Supreme Court reversed, holding that there was insufficient evidence to sustain the obstruction charge. View "State v. Bennett" on Justia Law

The Supreme Court affirmed the judgment of the district court committing Appellant to the Montana State Hospital (MSH) to regain fitness after a psychologist determined Appellant was not fit to stand trial on pending criminal charges, holding that the district court correctly denied Appellant's motion to dismiss.Appellant pleaded guilty to drug-related charges. Before sentencing, the district court ordered that Appellant be committed to MSH to regain fitness. Appellant's counsel later filed a motion to dismiss, arguing that both charges should be dismissed pursuant to Mont. Code Ann. 46-14-221(3)(a). The district court denied the motion to dismiss and later found Appellant fit to proceed. Appellant subsequently pleaded guilty through an Alford plea. The Supreme Court affirmed Appellant's conviction but remanded the case for the district court to conform its written judgment to the oral pronouncement of Appellant's sentence, holding that Appellant did not demonstrate that she was entitled to have the charges against her dismissed. View "State v. Rich" on Justia Law

The Supreme Court reversed the order of the district court affirming the justice court's denial of Defendant's motion to suppress, holding that particularized suspicion did not exist to support extending Defendant's traffic stop into a drug investigation.Defendant pleaded guilty to criminal possession of drug paraphernalia and criminal possession of marijuana. On appeal, Defendant challenged the denial of his motion to suppress the State's evidence as the product of an illegal extension of the stop, arguing that the police officer lacked particularized suspicion to justify extending the traffic stop and ordering a canine sniff search. The Supreme Court agreed and reversed, holding that the justice court erred in denying Defendant's motion to suppress. View "State v. Harning" on Justia Law

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