Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the judgment issued by the district court denying Defendant full credit for all days he spent incarcerated from the date he was served with an arrest warrant through sentencing, holding that Defendant was entitled to credit against his sentence from the date he was served with the arrest warrant to the date he was sentenced.Defendant was charged with felony driving under the influence of alcohol or drugs (DUI). Defendant pleaded guilty to the DUI. After he was sentenced, Defendant appealed, asserting that, pursuant to Mont. Code Ann. 46-18-403(1), he was entitled to credit for the time he was served with the arrest warrant to the date he was sentenced. The Supreme Court agreed and remanded the matter to the district court to amend the judgment and provide Defendant credit according to this opinion, holding that Defendant was entitled to credit for each day he was incarcerated from his arrest to sentencing, regardless of whether he was also being held in connection with another matter in a different county. View "State v. Mendoza" on Justia Law

The Supreme Court reversed the order of the district court granting Defendant's motion to dismiss the criminal endangerment charge against him, holding that, under a de novo standard of review, the State alleged sufficient facts in support of its charge of criminal endangerment to withstand a motion to dismiss.The State filed an information charging Defendant with felony criminal endangerment under Mont. Code Ann. 45-5-207(1). Defendant filed a motion to dismiss the charge on the grounds that there were no facts establishing probable cause that he had committed the offense of criminal endangerment. The district court granted the motion to dismiss without providing reasons for its decision. The Supreme Court reversed, holding that the State established a probability that Defendant committed the offense of criminal endangerment. View "State v. Giffin" on Justia Law

The Supreme Court affirmed in part and reversed in part the order and judgment issued by the district court following Defendant's convictions for sexual assault, three counts of sexual intercourse without consent, and sexual abuse of children, holding that the district court erred by misapplying Montana's rape shield statute, Mont. Code Ann. 45-5-511(2), and violated Defendant's constitutional confrontation rights.After the State charged Defendant with sexually assaulting I.A., a female minor, law enforcement received a tip that Cody Hill and I.A. were involved in an inappropriate sexual relationship. The State subsequently charged Hill was sexually abusing I.A. Defendant sought a motion to compel seeking confidential criminal justice information from the criminal file regarding Hill. The district court denied Defendant's motion to compel and convicted Defendant. The Supreme Court reversed in part, holding that the district court (1) did not abuse its discretion by not requiring the State to provide additional confidential criminal justice information from the Hill investigation; but (2) erred by misapplying the rape shield statute and violated Defendant's constitutional right to confront his accuser and present evidence in his defense by disallowing evidence that Hill abused I.A. in an identical manner less than two weeks before the incident at issue in this case. View "State v. Twardoski" on Justia Law

The Supreme Court reversed the judgment of the district court revoking the suspended portion of Appellant's sentence, holding that the district court did not err in denying Appellant's motion to dismiss for lack of subject matter jurisdiction.When Appellant was sixteen, the youth court found Appellant to be a delinquent youth, and Appellant received a juvenile disposition consisting of both a juvenile sentence and an adult sentence. After Appellant admitted to violations of the conditions of his sentence the judge implemented the adult sentence in modified form. The State later filed a second petition to revoke, and the judge revoked Appellant's deferred adult sentences and sentenced him to a term of incarceration. When Appellant was twenty-seven years old the State filed a third petition to revoke. Appellant filed a motion to dismiss, arguing that the youth court's jurisdiction over him ended when he reached the age of twenty-five and that the judge had not transferred the case to the district court. The judge denied the motion. The Supreme Court reversed, holding (1) the youth court lost jurisdiction over Appellant when he reached his twenty-fifth birthday and the case was not transferred to a district court; and (2) the lower court lacked jurisdiction and imposed an illegal sentence. View "In re S.G.-H.M. Jr." on Justia Law

The Supreme Court affirmed the judgment and commitment of the district court following Defendant's felony convictions of sexual intercourse without consent and sexual assault, holding that the district court did not commit reversible error by answering a question posed by the jury without consulting the parties.On appeal, Defendant argued (1) he received ineffective assistance of counsel; (2) the Court should exercise plain error review regarding his claims about expert testimony undermining his presumption of innocence; and (3) the district court erred by answering a jury question during deliberation without consulting the parties. The Supreme Court affirmed, holding (1) this Court declines to consider Defendant's ineffective assistance of counsel claim on direct appeal; (2) this Court declines to exercise plain error review regarding Defendant's claims about expert witness testimony; and (3) the district court did not commit reversible error by answering the jury's question without consulting the parties. View "State v. Sinz" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming Defendant's judgment of conviction on the offense of criminal possession of drug paraphernalia, holding that the justice court did not illegally impose a ten-day jail term as a condition of a deferred imposition of sentence.Defendant was found guilty of criminal possession of drug paraphernalia, as charged. The court deferred imposition of sentence for a period of six months subject to the conditions that Defendant pay a $350 fine and various statutory surcharges, complete twenty hours of community service, and serve ten days in the county jail. On appeal, Defendant argued that the jail-time condition was an illegal condition of a deferred sentence, in violation of Mont. Code Ann. 45-10-103. The district court affirmed. The Supreme Court affirmed, holding that the justice court did not erroneously impose ten days of jail time as a condition of Defendant's deferred imposition of sentence. View "State v. Thibeault" on Justia Law

The Supreme Court affirmed the order of the district court affirming Defendant's jury conviction for driving with a blood alcohol concentration exceeding the legal limit, holding that Defendant was denied his confrontation rights.On appeal, Defendant challenged the denial of his motion to suppress evidence stemming from the stop of the vehicle and argued that the justice court improperly allowed a State witness to appear by two-way video at trial. The Supreme Court (1) affirmed the denial of Defendant's motion to suppress, holding that the trooper lawfully stopped and detained Defendant; and (2) reversed Defendant's conviction, holding that the justice court violated Defendant's right to confrontation when it allowed Defendant to testify via two-way video. View "State v. Bailey" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court sentencing Plaintiff to pay restitution to the Montana State Fund (MSF) for benefits it paid to a sergeant from the Gallatin County Detention Center related to an on-the-job injury, holding that the district court failed to appropriately apply Mont. Code Ann. 46-18-246 to conclude it would otherwise be unjust to require Defendant to pay the restitution imposed.Defendant was charged with felony assault on a peace officer for her actions in striking the sergeant after the sergeant requested that Defendant sit down while waiting for an initial appearance in court. Defendant pleaded guilty to misdemeanor assault. In sentencing Defendant, the district court concluded that MSF qualified as a victim and was thus entitled to restitution. The Supreme Court affirmed, holding that the district court (1) correctly concluded the MSF was an insurer victim entitled to restitution for pecuniary loss; and (2) erred by failing to adjust or otherwise waive payment by Defendant of the restitution ordered. View "State v. Lodahl" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress his text message conversation with an undercover federal agent and to dismiss the charge of patronizing prostitution, holding that the district court did not err.From his cell phone, Defendant responded to an ad placed in a warrantless internet sting operation. Thereafter, Defendant engaged in a text message conversation with "Lily," an undercover law enforcement officer. Defendant was subsequently charged with patronizing prostitution, a misdemeanor. Defendant filed a motion to suppress his text conversation with "Lily" and for dismissal of the case due to a lack of evidence. The district court denied the motions, and Defendant entered a conditional guilty plea. The Supreme Court affirmed, holding that the warrantless use of a cloaked law enforcement officer under a fake internet advertisement for sexual services and the responsive text message conversation did not intrude upon an objectively reasonable expectation of privacy and therefore did not effect a constitutional search in violation of Defendant's right to privacy under Mont. Const. art. II, 10-11. View "State v. Staker" on Justia Law

The Supreme Court affirmed Defendant's conviction of the sexual abuse of a nine-year-old girl and upheld the constitutionality of his sentence requiring lifetime GPS monitoring, holding that there was no reversible error.Specifically, the Supreme Court held (1) the district court erred to the extent it admitted the victim's taped forensic interview as a prior consistent statement, but there was not a reasonable possibility that the forensic interview contributed to Defendant's conviction; (2) Defendant did not sustain his burden to demonstrate that the prosecutor's closing arguments justified reversal of his conviction for plain error; and (3) the requirement for GPS monitoring imposed by Mont. Code Ann. 45-5-625(4)(b) is not facially unconstitutional under either the Montana or the United States Constitutions. View "State v. Smith" on Justia Law