Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction upon a nolo contendere plea for driving under the influence (DUI), holding that the arresting officer did not unreasonably impede Defendant’s right to obtain an independent blood test, and therefore, the district court did not err in denying Defendant’s motion to dismiss the DUI charge.On appeal, Defendant argued that not releasing her at the police station and instead driving her home, ten miles from the hospital, was a deviation from standard procedure that frustrated her ability to obtain an independent blood test. The Supreme Court disagreed, holding that, under the facts of this case, the officer did not unreasonably impede Defendant’s right to obtain an independent blood test. View "State v. Neva" on Justia Law

The Supreme Court affirmed Defendant’s conviction upon a nolo contendere plea for driving under the influence (DUI), holding that the arresting officer did not unreasonably impede Defendant’s right to obtain an independent blood test, and therefore, the district court did not err in denying Defendant’s motion to dismiss the DUI charge.On appeal, Defendant argued that not releasing her at the police station and instead driving her home, ten miles from the hospital, was a deviation from standard procedure that frustrated her ability to obtain an independent blood test. The Supreme Court disagreed, holding that, under the facts of this case, the officer did not unreasonably impede Defendant’s right to obtain an independent blood test. View "State v. Neva" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence discovered in the course of a probationary search of the vehicle in which Defendant was a passenger, holding that, under the facts of this case, Defendant had no reasonable expectation of privacy in the vehicle or its contents. Therefore, there was no search.Defendant’s counsel moved to suppress the evidence seized as a result of the vehicle search on the grounds that there was no inquiry to determine if Defendant was the owner of or if he had control over the vehicle. The district court denied the motion, concluding that a probationer need not be a driver or owner of a vehicle in order for officers to initiate a probationary search of the vehicle, so long as the probationer was a passenger immediately prior to the search. The Supreme Court affirmed, holding (1) Defendant failed to show he had an actual expectation of privacy as a passenger in the vehicle; and (2) even though the vehicle was not Defendant’s, the probation officer had the authority to search it. View "State v. Conley" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence discovered in the course of a probationary search of the vehicle in which Defendant was a passenger, holding that, under the facts of this case, Defendant had no reasonable expectation of privacy in the vehicle or its contents. Therefore, there was no search.Defendant’s counsel moved to suppress the evidence seized as a result of the vehicle search on the grounds that there was no inquiry to determine if Defendant was the owner of or if he had control over the vehicle. The district court denied the motion, concluding that a probationer need not be a driver or owner of a vehicle in order for officers to initiate a probationary search of the vehicle, so long as the probationer was a passenger immediately prior to the search. The Supreme Court affirmed, holding (1) Defendant failed to show he had an actual expectation of privacy as a passenger in the vehicle; and (2) even though the vehicle was not Defendant’s, the probation officer had the authority to search it. View "State v. Conley" on Justia Law

The Supreme Court affirmed the district court’s denial of Appellant’s petition for postconviction relief based on Appellant’s claim of actual innocence and held that the district court correctly determined that Appellant did not establish that his counsel was ineffective.Appellant pleaded guilty to the attempted mitigated homicide of his brother. Appellant later filed this petition for postconviction relief alleging that he had newly discovered evidence of his actual innocence and that his attorney was ineffective during plea negotiations. At the evidentiary hearing, Appellant’s brother testified that the incident in which he was injured was an accident. The district court denied the petition. The Supreme Court affirmed, holding (1) Appellant’s brother’s testimony, to which the district court attributed little value based on the brother’s lack of credibility, did not establish that Appellant’s sentence was constitutionally invalid because he was actually innocent of the crime; and (2) the district court properly found that Appellant’s guilty plea was not involuntary because he received ineffective assistance of counsel. View "Guillen v. State" on Justia Law

The Supreme Court affirmed the district court’s denial of Appellant’s petition for postconviction relief based on Appellant’s claim of actual innocence and held that the district court correctly determined that Appellant did not establish that his counsel was ineffective.Appellant pleaded guilty to the attempted mitigated homicide of his brother. Appellant later filed this petition for postconviction relief alleging that he had newly discovered evidence of his actual innocence and that his attorney was ineffective during plea negotiations. At the evidentiary hearing, Appellant’s brother testified that the incident in which he was injured was an accident. The district court denied the petition. The Supreme Court affirmed, holding (1) Appellant’s brother’s testimony, to which the district court attributed little value based on the brother’s lack of credibility, did not establish that Appellant’s sentence was constitutionally invalid because he was actually innocent of the crime; and (2) the district court properly found that Appellant’s guilty plea was not involuntary because he received ineffective assistance of counsel. View "Guillen v. State" on Justia Law

The Supreme Court affirmed Defendant’s sentence for three separate cases involving partner or family member assault against three different women to a combined twenty years, with eight suspended. The district court included conditions in all three cases that restricted contact between Defendant and his victims. On appeal, Defendant argued that the condition prohibiting contact between him and his second victim was an unreasonable sentencing condition and an unconstitutional restriction on his common-law marriage. The Supreme Court held (1) the contested condition was not an unreasonable sentencing condition; and (2) Defendant’s general objection to the restricted contact conditions was insufficient to preserve his argument that the conditions unconstitutionally infringe upon his marriage, privacy, and due process rights. View "State v. Parkhill" on Justia Law

The Supreme Court affirmed Defendant’s sentence for three separate cases involving partner or family member assault against three different women to a combined twenty years, with eight suspended. The district court included conditions in all three cases that restricted contact between Defendant and his victims. On appeal, Defendant argued that the condition prohibiting contact between him and his second victim was an unreasonable sentencing condition and an unconstitutional restriction on his common-law marriage. The Supreme Court held (1) the contested condition was not an unreasonable sentencing condition; and (2) Defendant’s general objection to the restricted contact conditions was insufficient to preserve his argument that the conditions unconstitutionally infringe upon his marriage, privacy, and due process rights. View "State v. Parkhill" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of deliberate homicide committed with a dangerous weapon, holding that the district court made numerous erroneous rulings amounting to cumulative error and requiring reversal. Specifically, the Court held (1) the district court erred by excluding statements the victim made to Defendant as hearsay; (2) the district court erred by prohibiting a limited inquiry into the State’s expert witness’s credibility; (3) the district court acted within its discretion in resolving the jury’s concern about media publicity; and (4) the cumulative effect of the first two errors denied Defendant of his right to a fair trial. View "State v. Cunningham" on Justia Law

The Supreme Court affirmed Defendant’s conviction of aggravated assault and reversed his conviction for violating a no-contact order. The Court held (1) the State did not present sufficient evidence for the jury to find Defendant guilty of violating a no-contact order; and (2) the prosecutor’s comment during rebuttal closing argument that the jury’s “job” was to ensure the alleged victim’s safety was improper, and the nature of the remark implicated Defendant’s right to a fair trial, but this isolated incident of alleged misconduct did not result in a miscarriage of justice or compromise the integrity of Defendant’s trial. View "State v. Ritesman" on Justia Law