Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant of criminal endangerment. On appeal, Defendant asserted judicial bias and argued that his appointed counsel violated their duty of loyalty. The Supreme Court held (1) this court declines to undertake consideration of the merits of Defendant’s bias allegation pursuant to the plain error doctrine because Defendant’s assertion of bias did not implicate a fundamental right or convince the court that failure to review the claim would result in a manifest miscarriage of justice, leave unsettled the question of the fundamental fairness of the trial proceedings, or compromise the integrity of the judicial process; and (2) Defendant’s ineffective assistance of counsel claims were not reviewable on direct appeal because they were not factually established in the record. View "State v. Howard" on Justia Law

The Supreme Court held that the district court did not err in dismissing Defendant’s motion to dismiss the State’s petition to revoke her suspended sentence on the ground that there had been a four-year delay in executing the arrest warrant.In 2009, the district court issued a “Montana only” warrant for the arrest of Defendant, who was on probation. Thereafter, Defendant was convicted of another offense in Colorado, where, several times, Defendant was paroled and then her sentence was revoked. Defendant discharged her Colorado sentences in 2013. That same year, Defendant was arrested on the 2009 warrant. Defendant moved to dismiss the petition to revoke her suspended sentence, arguing that the State violated her right to due process by failing to bring her to court without unnecessary delay. The district court concluded that Defendant had not suffered a deprivation of due process and then determined that Defendant had violated the terms of her original sentence. The Supreme Court affirmed, holding that the district court did not err in denying Defendant’s motion to dismiss the revocation petition. View "State v. Koon" on Justia Law

The Supreme Court affirmed the order of the district court affirming the municipal court’s denial of Defendant’s motion to suppress blood evidence in a driving under the influence of alcohol (DUI) proceeding against him, holding (1) the district court did not err in denying Defendant’s motion to suppress a telephonic search warrant issued pursuant to Mont. Code Ann. 61-8-402(5) to draw Defendant’s blood; and (2) this court declines to address Defendant’s argument that the warrant was invalid because Defendant did not receive the implied consent advisory prior to his blood draw. View "City of Missoula v. Williams" on Justia Law

The Supreme Court vacated the sentence imposed upon Defendant following his plea of no contest to sexual assault, holding that the district court erred in accepting Defendant’s no contest plea, and therefore, the district court could not have imposed a valid sentence upon Defendant. The district court erred in accepting Defendant’s no contest plea because generally, a court may not accept a plea of nolo contendere in a case involving a sexual offense, and the term sexual offense is statutorily defined to include sexual assault. The Supreme Court voided the plea agreement and remanded the matter to the district court to allow Defendant to enter a legal plea to the original charges, enter a new plea agreement, or to proceed to trial. View "State v. Hansen" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s two motions to dismiss the charges against him for sexual abuse of children.Pursuant to a plea agreement, Defendant pleaded guilty to one count of sexual abuse of children. Defendant reserved the right to appeal the district court’s denial of his two motions to dismiss. The Supreme Court affirmed, holding (1) the district court properly found that there was sufficient evidence that a rational jury could have found Defendant guilty of sexual abuse of children because he knowingly possessed child pornography; and (2) Montana’s statutory definition of possession under Mont. Code Ann. 45-2-101(59) is not unconstitutionally vague as applied to Defendant’s conduct. View "State v. Harrington" on Justia Law

The Supreme Court affirmed the district court’s determination that Defendant, who pled guilty to deliberate homicide, was competent to stand trial and that, at the time of the offense, Defendant was able to appreciate his behavior and conform to the requirements of the law. The court held (1) the district court did not err when it found that Defendant was competent to stand trial and was competent when he entered his guilty plea; (2) the district court did not err when it found that, at the time of the offense, Defendant was able to appreciate his behavior and conform his conduct to the requirements of the law; and (3) sentencing Defendant to prison did not violate his constitutional rights to be free from cruel and unusual punishments and to human dignity. View "State v. Spell" on Justia Law

The Supreme Court reversed the municipal court’s order denying Petitioner’s motion to dismiss the charge against him, holding that the municipal court abused its discretion in declaring a mistrial and in concluding that double jeopardy did not bar Petitioner’s retrial.Petitioner was charged with partner or family member assault (PFMA). The City of Billings moved for a mistrial, and the trial judge declared a mistrial based on the purportedly inconsistent testimony of a City’s witness. The judge then rescheduled Petitioner’s trial. Petitioner filed a motion to dismiss the PFMA on double jeopardy grounds. The municipal court denied the motion. The Supreme Court reversed, holding (1) there was no manifest necessity to discontinue the trial, and Petitioner’s conduct did not demonstrate a waiver of his right to object to termination of the proceedings and to a retrial; and (2) therefore, retrying Petitioner for the PFMA charge would violate his federal and state fundamental constitutional rights to be free from double jeopardy. View "Billings ex rel. Huertas v. Billing" on Justia Law

The Supreme Court affirmed Defendant’s conviction for felony driving under the influence (DUI), concluding that the district court did not err in denying Defendant’s motion to dismiss on the grounds that two of his prior convictions upon which the State based its felony enhancement were obtained in violation of his constitutional right to counsel. The district court denied the motion to dismiss on the ground that Defendant had not met his burden of rebutting the presumption of regularity that attached to the prior convictions. The Supreme Court affirmed, holding (1) the district court did not clearly err in finding that Defendant failed to satisfy his burden to rebutting the presumption of regularity in his two prior convictions; and (2) therefore, the district court’s determination that those convictions could be used for felony enhancement purposes was correct. View "State v. Rasmussen" on Justia Law

The Supreme Court affirmed the district court’s imposition of a seven and one-half year parole restriction on Defendant’s sentence for obstructing justice but remanded for the purpose of striking the condition that Defendant register as a violent offender.Defendant was convicted of criminal endangerment and obstructing justice. Defendant was sentenced to ten years imprisonment, parole restricted for the entire term, on her criminal endangerment conviction and ten years imprisonment, parole restricted for seven and one-half years, on her conviction for obstructing justice, to be served consecutively to her criminal endangerment sentence. The Supreme Court held that the district court (1) did not err by imposing a parole eligibility restriction on Defendant’s sentence for obstructing justice; but (2) erred in requiring Defendant to register as a violent offender where neither of the crimes of which Defendant was convicted are included among the crimes requiring violent offender registration. View "State v. Old Bull" on Justia Law

The district court erred by concluding that particularized suspicion did not exist for the investigatory stop of Defendant.The Supreme Court reversed the order of the district court reversing the municipal court’s order denying Defendant’s motion to suppress evidence related to his arrest for driving under the influence of alcohol (DUI). The district court concluded that the trial court’s finding that Defendant was apprehended for a technical violation was clearly erroneous. The Supreme Court disagreed, holding (1) the district court erred in finding from the evidence that Defendant was stopped for “alleged behavior,” which required its own assessment and speculation about the record; and (2) there was substantial evidence in the record to support the municipal court’s findings of fact about the reasons that Defendant’s vehicle was stopped. View "City of Helena v. Brown" on Justia Law