Justia Montana Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's petition for a writ of habeas corpus asserting that he was entitled to relief because he entered an "Alford plea" to sexual assault and solicitation for sexual assault in violation of Mont. Code Ann. 46-12-204(4), holding that, under Montana law, an Alford plea is not synonymous to a nolo contendere plea, which, under section 46-12-204(4), a court may not accept in a case involving a sexual offense.Petitioner pleaded guilty to two sexual offenses pursuant to North Carolina v. Alford, 400 U.S. 25, 91 (1970). In his habeas petition Petitioner argued that his guilty pleas violated Mont. Code Ann. 46-12-204(4), which provides that a court may not accept a plea of nolo contendere in a case involving a sexual offense. The Supreme Court disagreed, holding that Petitioner's Alford pleas were guilty pleas, not nolo contendere pleas, and therefore, section 46-12-204(4) did not prohibit the district court from accepting the Alford pleas to the sexual offenses. View "Lawrence v. Salmonsen" on Justia Law

The Supreme Court reversed Defendant’s conviction on the misdemeanor offenses of negligent endangerment and reckless driving in the municipal court, holding that the municipal court erred in refusing to instruct the jury and allow evidence and argument on the authority of private citizens to make a citizen’s arrest as a factual consideration in determining whether Defendant committed the charged offenses as alleged.Defendant was prosecuted after he pulled his pickup and towed boat across a main thoroughfare in the City of Helena to block the escape of a motorcyclist fleeing from pursuing police in a high-speed chase through the City. At Defendant’s ensuing jury trial, the municipal court precluded him from presenting evidence and argument that he acted reasonably under the circumstances to assist police in apprehending the fleeing motorcyclist as authorized by Mont. Code Ann. 46-6-501, which establishes citizen arrest authority. The Supreme Court reversed, holding that the municipal court erroneously precluded the evidence, jury instruction, and argument on Defendant’s asserted statutory authority and intent to make a citizen’s arrest because these were factual considerations materially relevant on the record to whether Defendant acted in negligent, willful, or wanton disregard for the safety of others beyond a reasonable doubt. View "City of Helena v. Parsons" on Justia Law

The Supreme Court affirmed Defendant’s convictions of two counts of criminal endangerment, one count of driving under the influence of alcohol, and one count of open container violation, holding that the district court did not err in refusing to give Defendant’s proposed jury instruction.During trial, Defendant proposed jury instructions on the lesser included offense of negligent endangerment. The district court declined to give the proposed instruction, concluding that the evidence did not support a finding that Defendant did not act knowingly. The Supreme Court affirmed, holding that the district court did not abuse its discretion in refusing to give Defendant’s proposed jury instruction. View "State v. Jensen" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a two-year suspended sentence in connection with Defendant’s conviction, holding that the district court correctly determined that Mont. Code Ann. 46-18-201(1)(b) barred it from deferring Defendant’s sentence.In 2017, Defendant pleaded guilty to felony criminal possession of dangerous drugs. The State and Defendant agreed to jointly recommend a two-year deferred sentence if Defendant was eligible and, if he was not eligible, a two-year suspended sentence. At issue was whether Defendant’s previous conviction in Arizona was a felony under Mont. Code Ann. 46-18-201(1)(b), which provides that a court may not defer an offender’s sentence in a felony case if she was previously convicted of a felony. The district court ultimately concluded that Defendant’s Arizona conviction was a felony that barred her from receiving a deferred sentence and, accordingly, imposed a two-year suspended sentence. The Supreme Court affirmed, holding that the district court correctly determined that section 46-18-201(1)(b) barred it from deferring Defendant’s sentence. View "State v. Nelson" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of offense of partner or family member assault, holding that the district court abused its discretion in denying Defendant’s motion to excuse a prospective juror for cause.In this case, a prospective juror spontaneously asserted that she would have a “hard time,” a personal “problem,” and a “real problem” with requiring the State to prove an essential element of the charged offense. The Supreme Court held that where the prospective juror’s multiple spontaneous statements were consistent, clear, unequivocal, and emphatic and where the record unequivocally manifested the juror’s bias, the district court abused its discretion in denying Defendant’s motion to disqualify the prospective juror for cause. Further, the error was structural, requiring automatic reversal. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the order of the district court upholding the denial of Defendant’s motion to dismiss her driving under the influence (DUI) charge, holding that Montana’s statutory protections against double jeopardy did not bar Defendant’s charge.In 2016, Defendant pleaded guilty to careless driving. After reviewing Defendant’s toxicology report, the Helena Attorney’s Office additionally charged Defendant with DUI. Defendant moved to dismiss her DUI charge as a subsequent prosecution barred by Mont. Code Ann. 46-11-504(1). The municipal court denied the motion to dismiss. The district court upheld the denial of Defendant’s motion to dismiss. Thereafter, Defendant pleaded guilty to negligent endangerment pursuant to a plea agreement, preserving her right to appeal. The Supreme Court affirmed, holding (1) Mont. Code Ann. 46-11-503 applied in this case; but (2) because no probable cause existed to charge Defendant with DUI before resolution of her careless driving charge, section 46-11-503 did not bar the subsequent DUI charge from prosecution. View "City of Helena v. O'Connell" on Justia Law

The Supreme Court affirmed Defendant’s conviction of three felony counts of aggravated animal cruelty, five felony counts of cruelty to animals, and a misdemeanor count of cruelty to animals, holding that the district court did not err in the proceedings below.Specifically, the Court held that the district court (1) did not err by denying Defendant’s motion to suppress evidence obtained in warrantless searches of her commercial kennel property; (2) did not err by denying Defendant’s Batson challenge; and (3) did not err in imposing the costs to be reimbursed by Defendant under Mont. Code Ann. 45-8-211(3). View "State v. Warren" on Justia Law

The Supreme Court affirmed the judgment of the district court designating Defendant a repeat persistent felony offender (PFO) and sentencing him as a repeat PFO under Mont. Code Ann. 46-18-502(2), holding that there was no error in the proceedings below.Defendant pled guilty to robbery by accountability and assault with a weapon. The district court concluded that, based on Defendant’s prior felony convictions and PFO designation, it had no choice but to sentence him under section 46-18-502(2) to a minimum of ten years incarceration on both the robbery by accountability and assault charges and that the sentence must run consecutively to a three-year suspended sentence for Defendant’s probation violation in a separate case. The Supreme Court affirmed, holding that the district court did not err when it sentenced Defendant as a repeat PFO under section 46-18-502(2). View "State v. Martin" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant’s motion to suppress, holding that the denial of Appellant’s motion to suppress was not erroneous.Defendant was charged with criminal possession of dangerous drugs. Defendant filed a motion to suppress his statements on the basis that he was detained without reasonable suspicion and arrested without probable cause. The district court denied the motion to suppress. The Supreme Court affirmed, holding (1) the district court did not err in its determination that the officers’ initial investigation was supported by particularized suspicion; (2) the immediate use of handcuffs did not elevate the investigatory stop into an arrest; and (3) the district court did not err in its determination that the arrest was supported by probable cause. View "State v. Stevens" on Justia Law

The Supreme Court affirmed the jury verdict and sentencing order of the district court finding Appellant guilty of criminal possession of dangerous drugs, holding that there was no error that required reversal of Appellant’s conviction.Specifically, the Supreme Court held that the district court (1) properly exercised its discretion in denying Appellant’s motion for directed verdict; (2) correctly instructed the jury on the charge of criminal possession of dangerous drugs; (3) did not abuse its discretion by denying Appellant’s requested instruction on “mere presence”; and (4) did not abuse its discretion by overruling Appellant’s hearsay objection regarding his traveling companions’ conflicting statements to officers during Appellant’s second jury trial. View "State v. Ellerbee" on Justia Law