Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the jury verdict of the district court following Defendant's conviction of incest against his ten-year-old stepdaughter, holding that the district court erred when it granted the State's motion in limine excluding the testimony of Defendant's expert witness regarding general information of false reports in child sexual abuse cases.In granting the State's motion in limine, the district court deemed Defendant's expert witness unqualified to testify under State v. Scheffelman, 820 P.2d 1293 (Mont. 1991), which allows a party to elicit expert testimony that directly comments on an alleged victim's credibility if the expert satisfies certain criteria. The Supreme Court reversed, holding that the district court erred by applying the Scheffelman exception criteria to exclude the expert witness's testimony, and the error was not harmless. View "State v. Reams" on Justia Law

The Supreme Court affirmed in part and reversed in part the sentence and financial assessments imposed by the district court in connection with Defendant's conviction for driving under the influence (DUI), fourth or subsequent offense, holding that the district court erred by assessing a $500 surcharge in compliance with Mont. Code Ann. 46-18-236(1)(b).The district court imposed the statutory minimum fine of $5,000 for felony DUI and sentenced him to a thirteen-month commitment to the Department of Corrections, followed by a three-year suspended sentence subject to certain terms and conditions. Defendant appealed, challenging the denial of his sentencing objections. The Supreme Court affirmed, holding that the district court (1) did not err by assessing the $5,000 fine; (2) did not err by assessing the cost of imprisonment, probation, and alcohol treatment pursuant to Mont. Code Ann. 61-8-731(4)(b); (3) did not err by assessing a $100 fine pursuant to Mont. Code Ann. 46-18-232(1); but (4) erred by assessing the $500 surcharge without considering Defendant's ability to pay. View "State v. Ingram" on Justia Law

The Supreme Court affirmed the ruling of the district court that the Montana Board of Pardons and Parole did not violate Appellant's statutory or constitutional rights in denying Appellant's parole request, holding that the district court did not err.Appellant sought judicial review of the Board's decision, claiming that the Board denied him his right to know, right to participate, or right to due process when it denied him parole without first furnishing him a copy of documents on which the Board relied in making its decision. Appellant further argued that the Board unlawfully relied on a guideline without having adopted it as an administrative rule pursuant to the Montana Administrative Procedure Act. The district court granted summary judgment for the Board. The Supreme Court affirmed, holding (1) where the guideline was not the reason for the Board's decision, Appellant could not demonstrated the likelihood of a different outcome; and (2) the Board did not violate Appellant's right to know, right to participate, or due process rights. View "Miller v. Montana Board of Pardons & Parole" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated sexual intercourse without consent, holding that the district court did not abuse its discretion in failing to find Defendant's concerns of ineffective assistance of counsel "seemingly substantial" or by declining to grant a trial continuance.On appeal, Defendant argued that the district court abused its discretion by (1) denying his request for a continuance of the jury trial, and (2) failing to open a formal inquiry into the effectiveness of counsel following Defendant's pretrial expressions of lack of confidence. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by declining to grant Defendant's request for a continuance before trial; and (2) even if Defendant's lack of confidence did constitute a request for substitute counsel, the district court's response was an adequate initial inquiry to determine whether Defendant's concerns were "seemingly substantial." View "State v. Dillingham" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to dismiss the charge of vehicular homicide while under the influence, holding that Mont. Code Ann. 61-8-411 does not violate either the substantive due process or equal protection guarantees of the state and federal constitutions.Defendant filed a motion to dismiss the charges, arguing that section 61-8-411 was facially unconstitutional as a violation of his substantive due process rights. The district court denied the motion to dismiss. On appeal, Defendant argued that the legislature could have made a more scientifically based policy choice to keep drivers impaired by THC off the road and that the statute unconstitutionally creates classifications. The Supreme Court affirmed, holding that Mont. Code Ann. 61-8-411 is rationally related to the government's compelling interest in keeping drug-impaired drivers off the road. View "State v. Jensen" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of solicitation of witness tampering and sentencing him to prison for ten years with four years suspended, holding that the district court made numerous errors during trial amounting to cumulative error requiring reversal.Specifically, the Supreme Court held that Defendant's conviction resulted, at least in part, from the prejudice of the irrelevant and extrinsic bad acts evidence erroneously admitted from void dire through the entire evidentiary presentation and that Defendant did not receive a fair trial as a result of the district court's erroneous rulings, mandating reversal of Defendant's conviction under the doctrine of cumulative error. View "State v. Smith" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated promotion of prostitution of B.M. and promoting prostitution of Z.T., holding that the district court did not abuse its discretion.On appeal, Defendant argued that the district court erred in granting the State's motion in limine prohibiting Defendant from eliciting any testimony concerning B.M. and/or Z.T.'s prior sexual conduct. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it excluded evidence related to Z.T.'s prior involvement with prostitution under Mont. R. Evid. 401, 402, and 404(b). View "State v. Thomas" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony theft, felony altering an identification number, and misdemeanor violation of license plate requirement, holding that the district court did not err.Specifically, the Supreme Court held (1) the district court did not err in denying Defendant's motion to dismiss based on the state's alleged failure to preserve exculpatory evidence; (2) the district court did not err when it allowed an out-of-court statement offered for the limited purpose of explaining an officer's conduct; and (3) after correctly instructing the jury, the district court did not abuse its discretion in referring the jury to instructions already provided. View "State v. Fillion" on Justia Law

The Supreme Court affirmed the order of the district court revoking Defendant's deferred sentence for criminal endangerment, holding that the district court did not abuse its discretion by revoking Defendant's deferred sentence after he failed to report to his probation officer for five months.Defendant pleaded guilty to criminal endangerment. The district court sentenced Defendant to five years' incarceration, with all time suspended, and imposed standard conditions of probation. The State later filed a petition to revoke Defendant's sentence, alleging that Defendant violated four conditions of his suspended sentence. The district court found that Defendant committed the violations alleged in the State's petition to revoke and imposed a five-year commitment with two years suspended. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it revoked Defendant's deferred sentence. View "State v. Fjelsted" on Justia Law

The Supreme Court affirmed the revocation of his suspended sentence by the district court, holding that the district court's sentence revocation was supported by sufficient evidence that Defendant had violated the conditions of supervision by engaging in a new criminal offense.Defendant pled guilty to aggravated assault and endangering the welfare of a child. After completing the unsuspended portion of his sentence Defendant was released to serve the suspended portion of his sentence. Later, the county attorney filed a petition for revocation of Defendant's suspended sentence, alleging that Defendant had violated a condition of probation. The district court found by a preponderance of the evidence that Defendant had committed non-compliance violations of the probationary conditions of his sentence. The court then revoked Defendant's sentence and resentenced him. The Supreme Court affirmed, holding that the district court did not err by determining that Defendant violated a sentencing condition by committing sexual abuse of children. View "State v. Howard" on Justia Law