Justia Montana Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment and sentencing order of the district court that sentenced Defendant to ten years at the Montana State Prison (MSP) for assault on a peace officer and eighty years at MSP for attempted deliberate homicide after he was convicted of both charges, holding there was insufficient evidence to convict Defendant of attempted deliberate homicide.Specifically, the Supreme Court held (1) the State did not present sufficient evidence to convict Defendant of the crime of attempted deliberate homicide; and (2) the district court erred when it orally imposed conditions in its oral pronouncement of sentence in this case. The Supreme Court remanded the case for the district court to strike the conditions it orally stated as conditions of parole. View "State v. Boyd" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to suppress evidence obtained when law enforcement officers entered Defendant's private property without a warrant, holding that that the State did not prove exigent circumstances permitting a warrantless search.At issue was whether Defendant had a reasonable expectation of privacy in his residence's driveway when he told a sheriff's deputy, who was attempting to effectuate a traffic stop, that he was trespassing and needed a warrant and whether exigent circumstances existed to allow the sheriff's deputy to conduct a warrantless investigation on the property. The Supreme Court held (1) the deputy sheriff properly entered the driveway when he already had initiated a traffic stop but exceeded his authority after Defendant asked him to leave; and (2) Defendant's failure to stop for a minor traffic violation did not create an exigency allowing the deputy sheriff to conduct a warrantless investigation after Defendant invoked his right to privacy. View "State v. Smith" on Justia Law

The Supreme Court reversed the judgment of the district court convicting and sentencing Defendant for felony driving under the influence (DUI), holding that Defendant sufficiently objected regarding his inability to pay a statutory surcharge imposed by the district court at sentencing.After a hearing, the district court ordered Defendant to pay a $5000 mandatory fine for a felony DUI and also ordered him to pay fees and costs, a $500 surcharge, a witness fee, a prosecution fee, and a technology fee. On appeal, Defendant argued that the district court should have waived the $500 surcharge due to his inability to pay. The State argued in retort that the colloquy between Defendant and the district court was too nonspecific to count as an objection to the surcharge. The Supreme Court reversed in part, holding that Defendant's objection was sufficient to notify the district court that the required ability-to-pay inquiry was at play. View "State v. Steger" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant for theft of property exceeding $1,500 in value, holding that the district court committed harmless error in allowing a State witness to appear by two-way video at trial.Before trial, the State moved the district court to allow the witness to testify by two-way video, arguing that transporting a witness, whose testimony was expected to last only several minutes, almost 500 miles would be overly burdensome and costly. The district court granted the motion. On appeal, Defendant argued that the district court violated his right to confront witnesses against him by allowing the witness to appear by two-way video at trial. The Supreme Court affirmed, holding (1) because the court made no finding establishing an important public policy reason for the video testimony apart from judicial economy, allowing the witness to testify by video violated Defendant's constitutional right to confrontation; but (2) the State met its burden to show that the error was harmless. View "State v. Martell" on Justia Law

The Supreme Court affirmed Defendant's conviction for assault on a peace officer, holding that the district court did not err by denying Defendant's motion for mistrial based upon a prosecutor's comment made during opening statement and a prosecution witness's remark about Defendant's prior prison incarceration.On appeal, Defendant argued that the district court erred in denying his motion for mistrial based on two alleged incidents of prosecutorial misconduct. The Supreme Court affirmed the conviction, holding (1) the prosecutor's improper actions in this case did not prejudicially affect Defendant's right to a fair and impartial trial; and (2) therefore, the district court did not abuse its discretion in denying Defendant's motion for mistrial. View "State v. Erickson" on Justia Law