Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the district court's imposition of certain conditions on Defendant's sentence and reversed the court's determination that Defendant must pay the costs of his public defender, holding that the district court erred.Defendant pled guilty sexual assault and evidence tampering. In sentencing Defendant, the district court imposed conditions limiting Defendant's ability to possess a phone, a computer, or access to the internet. The district court further ordered Defendant to pay the cost of his public defender without conducting a meaningful inquiry into his ability to pay such expense. The Supreme Court reversed in part, holding (1) the sentencing conditions were overbroad insofar as they completely restricted Defendant's ability to access the internet and certain electronic devices; and (2) the district court erred in ordering Defendant to pay the cost of his public defender without conducting a meaningful inquiry into his ability to pay. View "State v. Hotchkiss" on Justia Law

The Supreme Court dismissed the charges against Defendant, holding that Defendant was denied his constitutional right to a speedy trial and was presumptively prejudiced by the delay.The State filed an information charging Defendant with burglary and theft of more than $800. Nearly five years after his arrest Defendant had still not been brought to trial. Defendant filed a pro se motion to dismiss the charges, arguing that the five-year delay violated his right to a speedy trial. The district court denied the motion. Defendant pleaded guilty, reserving the right to appeal the denial of his speedy trial motion. The Supreme Court dismissed the charges against Defendant, holding that Defendant was denied his constitutional right to a speedy trial. View "State v. Chambers" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to exclude evidence obtained during a traffic stop and to dismiss the charges against him, holding that an officer has a lawful right of access to reach into a vehicle and seize plainly visible contraband observed by the officer during a lawful traffic stop.Defendant was charged with criminal possession of dangerous drugs and criminal possession of drug paraphernalia. Defendant moved to exclude the evidence obtained during the traffic stop and to dismiss the charges, arguing that the deputy sheriff's warrantless seizure of a plastic bag found on Defendant's lap was unlawful. The district court denied the motion. Defendant then pled guilty, preserving his right to appeal the denial. The Supreme Court affirmed, holding that because the officer's warrantless seizure of the bag was not unlawful because the officer was lawfully present next to Defendant's truck during the traffic stop, could plainly see readily apparent contraband fall onto Defendant's lap, and had a lawful right of access to that contraband. View "State v. Tenold" on Justia Law

The Supreme Court affirmed Defendant's felony conviction of criminal possession with intent to distribute, holding that the district court did not err in determining that the State was not required to disclose the identity of its confidential informant.After Defendant was charged, he moved to dismiss the case on the basis that the State had failed to disclose the confidential informant's identity within the discovery timeframe. The district court summarily denied Defendant's motion to dismiss, declining to require disclosure of the confidential informant's identity. Defendant pled guilty, reserving his right to appeal the denial of his motion to dismiss. The Supreme Court affirmed, holding that the district court did not err as a matter of law in denying Defendant's motion to dismiss and did not abuse its discretion in denying disclosure of the confidential informant's identity. View "State v. Soto" on Justia Law

The Supreme Court affirmed the order of the district court revoking Defendant's deferred sentence for criminal possession of dangerous drugs, holding that the district court did not violate Defendant's Sixth Amendment right to confront witnesses during his revocation and did not abuse its discretion in determining that Defendant absconded.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confront witnesses against him by relying on statements made in a report of violation by Defendant's previous probation officer; and (2) the State presented sufficient evidence at Defendant's revocation hearing to establish that Defendant failed to report for the purpose of avoiding supervision and that the probation office made reasonable efforts to contact him. View "State v. Fetveit" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual intercourse without consent (SIWC), a felony, holding that the district court abused its discretion in allowing the State to cross-examine Defendant regarding a prior SIWC allegation as rebuttal evidence and in precluding Defendant from impeaching the testimony of the State's complaining witness with evidence of marijuana use prior to reporting the alleged offense.On appeal, Defendant argued, among other things, that the district court abused its discretion in allowing the State to cross-examine him regarding an unsubstantiated 2003 SIWC allegation for the purpose of rebutting his self-serving good character testimony and erroneously precluded him from impeaching the testimony of the State's complaining witness with evidence of marijuana use prior to reporting the alleged offense. The Supreme Court agreed and remanded the case for a new trial, holding that, under the circumstances of this case, the district court erred as to both issues and that the errors were prejudicial. View "State v. Pelletier" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to suppress testimony regarding statements he made during a phone conversation with the victim, holding that the testimony was not subject to exclusion.A.O. and her friend Tricia alleged that Defendant had committed sexual offenses against A.O. While A.O. was at the police department, Defendant called A.O. Police officers listened in on the conversation, during which Defendant admitted to raping A.O. Defendant moved to suppress the evidence. The district court ruled that the officer testimony regarding the conversation would be excluded but that A.O. and Tricia, as private actors, could testify as to the conversation. Defendant appealed, arguing that the testimony of A.O. and Tricia as to the contents of the conversation must be excluded as attributable to an unconstitutional privacy intrusion by a government actor. The Supreme Court affirmed, holding that the district court correctly denied the motion to suppress because A.O. and Tricia's testimony resulted from their own private actions, not from unconstitutional monitoring and recording by police. View "State v. Wolfe" on Justia Law

The Supreme Court reversed the judgment of the district court ordering Defendant to pay $31,903 in restitution for losses resulting from offenses committed by another, holding that the district court erred in ordering Defendant to pay restitution.Defendant pled guilty to criminal possession of dangerous drugs and criminal possession of drug paraphernalia. At sentencing, the parties disagreed as to restitution for costs associated with remediating a co-defendant's apartment from methamphetamine contamination. The district court imposed the restitution requested by the State. On appeal, Defendant argued that the court erred in requiring him to pay restitution for losses committed by another absent evidence of criminal accountability or a causal connection between his offense and those losses. The Supreme Court agreed, holding that the State failed to establish a causal link between Defendant's admitted possession of methamphetamine and the rehabilitation claimed. View "State v. Cole" on Justia Law

In a split decision, the Supreme Court reversed Defendant's negligent homicide convictions but upheld his convictions on nine counts of criminal endangerment and eleven counts of criminal distribution of dangerous drugs, holding that there was insufficient evidence to establish that Defendant's actions in prescribing narcotics was the cause in fact of the deaths of two of his patients.After a jury trial, Defendant, a licensed medical doctor, was convicted of several crimes related to the repeated prescribing of copious amounts of opiates and other narcotics to eleven individuals. Two of Defendant's patients died from drug overdoses. The Supreme Court reversed in part and affirmed in part the convictions, holding (1) the State did not present sufficient evidence to establish that Defendant's actions were the direct cause of the two drug overdose deaths; and (2) Defendant was operating outside the bounds of a professional medical practice, and therefore, the exemption for medical practitioners acting within the course of a professional practice did not apply to the facts of this case. View "State v. Christensen" on Justia Law

The Supreme Court held that Mont. Code Ann. 46-5-105 prohibits detention center employees who are booking a person into the general population of a detention facility from conducting a visual body cavity search without reasonable suspicion to believe that person is concealing contraband, a weapon, or evidence of the commission of a crime.William Rogers, leading ninety-six named plaintiffs, brought this action challenging the Lewis and Clark County Detention Center policy to conduct an unclothed visual body cavity search of every detainee prior to placement in the general population of the facility as a violation of Mont. Const. art. II, 10 and 11 and Mont. Code Ann. 46-5-105. The district court granted summary judgment for Defendants as to ninety-two of the named plaintiffs and denied the motion as to four plaintiffs who were never placed in the general population of the facility after they were strip searched. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs' diminished privacy interests did not outweigh the legitimate penological interests of the Detention Center; and (2) the plain language of section 46-5-105 unequivocally prohibits suspicionless strip searches of those arrested for minor offenses in any situation. View "Rogers v. Lewis & Clark County" on Justia Law