Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court finding Defendant guilty of criminal possession of dangerous drugs and drug paraphernalia and driving under the influence of alcohol or drugs (DUI), holding that the district court did not err.Specifically, the Court held that the district court did not err when it (1) denied Defendant's motion in limine to prevent the arresting officer from testifying at trial; (2) denied Defendant's motion to suppress evidence seized from his vehicle where probable cause existed to issue a warrant authorizing a search of his truck; and (3) denied Defendant's motion to dismiss the DUI charge due to the State's failure to preserve video evidence where there was no reasonable probability that the outcome of Defendant's DUI charge would be different had the video not been overwritten. View "State v. Robertson" on Justia Law

The Supreme Court reversed the judgment of the district court affirming Defendant's sentence, including conditions restricting Defendant's contact with minors upon his release, holding that the court abused its discretion in ruling that there was a sufficient nexus between the conditions prohibiting contact with minors and Defendant or his offense.Defendant raped an unconscious woman in the parking lot of a bar. Defendant later pleaded guilty to sexual intercourse without consent. The district court imposed sentencing conditions restricting Defendant's contact with minors. On appeal, Defendant argued that because the victim was not a minor there was not a sufficient nexus between Defendant or his offense and the conditions protecting minors. The Supreme Court agreed and remanded the case for the limited purpose of striking the conditions regarding contact with minors, holding that the State presented insufficient arguments to establish the required nexus. View "State v. Mehan" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of deliberate homicide and two counts of attempted deliberate homicide, holding that Defendant's ineffective assistance of counsel claim was not appropriately considered on direct appeal.On appeal, Defendant argued that his counsel provided ineffective assistance by failing to object to irrelevant, highly prejudicial evidence concerning his criminal past in two video interviews admitted at trial. The Supreme Court affirmed the judgment without prejudice to Defendant raising his ineffective assistance of counsel claim in a postconviction relief proceeding, holding that the record was not sufficient to address Defendant's claim on direct appeal. View "State v. Sawyer" on Justia Law

The Supreme Court affirmed the order of the district court denying Plaintiff's motion to suppress evidence that was obtained when a highway patrol trooper, after noticing Plaintiff's vehicle parked on the side of the road, stopped to see if Plaintiff needed assistance, holding that the district court did not err when it denied Plaintiff's motion to suppress.On appeal, Plaintiff argued that the test set forth in State v. Lovegren, 51 P.3d 471 (Mont. 2002), to ensure that application of the community caretaker doctrine comports with constitutional protections was not met in this case. The Supreme Court disagreed, holding that the contact began as a welfare check, which met the first prong of the Lovegren test. The contact then shifted to a criminal investigation supported by particularized suspicion only after additional information became available to the trooper. View "State v. Grmoljez" on Justia Law

The Supreme Court affirmed the order of the district court dismissing Appellant's petition for post conviction relief without an evidentiary hearing, holding that the district court correctly determined that Appellant's petition for post conviction relief was time barred under Mont. Code Ann. 46-21-102(1) and (2).Appellant pleaded guilty to felony partner or family member assault and was required to register as a violent offender. Appellant later entered a plea of nolo contenders to the charge of failure to register as a violent offender. Appellant's appeal was dismissed when the appeal was deemed frivolous. Appellant then filed his petition for post conviction relief. The district court summarily dismissed the petition, concluding that Appellant's claims were time barred and finding no equitable grounds to extend the deadline. The Supreme Court affirmed, holding that Appellant's petition fell outside the one-year deadline set forth in section 46-21-102(1) and that the evidence did not fall under the newly discovered evidence exception delineated in section 46-21-102(2). View "Mascarena v. State" on Justia Law

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