Justia Montana Supreme Court Opinion Summaries

On February 13, 2009, Defendant was charged with motor vehicle offenses. On May 21, 2009, the justice court issued a warrant for Defendant’s arrest for failing to appear. On April 13, 2012, Defendant was arrested on the warrant. Defendant pled not guilty, and trial was set for August 23, 2012. Defendant moved to dismiss the charges against him for lack of a speedy trial. The justice court concluded that while there was a lengthy delay of 1288 days between the initial charges and the trial date, Defendant’s constitutional right to a speedy trial had not been violated. Defendant then pled guilty to driving with a suspended license. The district court upheld the justice court’s determination that Defendant was not denied his right to a speedy trial. The Supreme Court affirmed, holding that, under the facts of this case, Defendant was not denied his right to a speedy trial. View "State v. Eystad" on Justia Law

On August 3, 2013, Defendant was charged with criminal endangerment, driving under the influence of alcohol or drugs, and other offenses. On March 12, 2015, Defendant filed a motion to dismiss the charges for lack of a speedy trial. The trial court denied the motion. On April 20, 2015, Defendant’s trial commenced. The Supreme Court affirmed, holding that the district court correctly denied Defendant’s motion to dismiss for lack of a speedy trial where (1) while the State bore some responsibility for the days of delay beyond the 200-delay threshold, the primary responsibility for this delay lay with Defendant; and (2) the overall balancing clearly weighed against Defendant’s claim. View "State v. Stewart" on Justia Law

After a jury trial, Defendant was convicted of deliberate homicide. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by instructing the jury on justifiable use of force in defense of a person; (2) did not abuse its discretion when it denied Defendant’s motions to change venue based on pretrial publicity; (3) did not abuse its discretion when it declined to remove a prospective juror for cause based on her marriage to a former police officer; (4) did not abuse its discretion when it admitted rebuttal evidence of Defendant’s bad character to rebut evidence of Defendant’s good character; and (5) abused its discretion when it allowed lay opinion testimony regarding blood spatter evidence, but the error was harmless. View "State v. Kaarma" on Justia Law

After a jury trial, Defendant was convicted of securities fraud. Defendant appealed, arguing that he was denied his right to a speedy trial guaranteed by the Montana Constitution and that the district court erred when it refused his proposed jury instructions, which included language regarding exemptions to the statutes under which he was charged. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant’s motion to dismiss for lack of a speedy trial; and (2) did not err in denying Defendant a new trial on the basis that the jury was not properly instructed. View "State v. Reynolds" on Justia Law

Petitioner pled guilty to four counts of felony Sexual Intercourse Without Consent and two counts of felony Sexual Assault. On appeal, petitioner challenges the district court's holding that all of petitioner's claims of ineffective assistance of counsel were either procedurally barred or failed to state a claim. The court concluded that, although petitioner's suppression claims are barred by the procedural and substantive requirements for postconviction petitions, his claims regarding a writ of supervisory control and double jeopardy are not; under the state law when petitioner's trial and appellate counsel defended petitioner, neither provided ineffective assistance regarding the writ of supervisory control and double jeopardy issues; the district court correctly determined that petitioner failed to state a claim for relief in his petition and, as such, did not abuse its discretion in denying petitioner's motion to hold an evidentiary hearing; and there are no considerations requiring petitioner be appointed counsel in the interests of justice. Accordingly, the court affirmed the judgment. View "Lacey v. State" on Justia Law

After a jury trial, Defendant was found guilty of assault with a weapon and driving while license suspended or revoked. The Supreme Court reversed, holding (1) the district court erred when it denied Defendant’s request that the State be ordered to produce a videotaped witness interview based on the claim that it was work product and not exculpatory; and (2) the district court erred in imposing an information technology user surcharge per count and not per user in violation of Mont. Code Ann. 3-1-317(a). Remanded to the district court to determine the appropriate sanctions for the State’s discovery abuse. View "State v. Pope" on Justia Law

After a jury trial, Defendant was convicted of felony theft. Defendant was sentenced to ten years in prison. Defendant appealed, arguing, among several other arguments, that the prosecutor committed plain error requiring reversal by stripping Defendant of the presumption of innocence. Specifically, Defendant challenged the prosecutor’s comment during closing arguments that the presumption of innocence had been removed from Defendant. The Supreme Court agreed with Defendant. The Court reversed the judgment and remanded the cause for a new trial, holding that the prosecutor’s comments during closing arguments constituted prosecutorial misconduct and required reversal of Defendant’s conviction. View "State v. Lawrence" on Justia Law

Defendant was charged with his fifth Partner Family Member Assault (PFMA) felony for conduct occurring in 2014. The State filed a notice to classify Defendant as a persistent felony offender (PFO) based on two previous PFMA convictions. Pursuant to a plea agreement, Defendant pleaded guilty to a PFMA, a felony, and the State withdrew the PFO notice. Defendant subsequently filed a brief challenging his prior convictions and the constitutionality of Montana’s PFMA statute. The Supreme Court affirmed, holding that Defendant waived his right to appeal the constitutionality of the prior PFMA statute. View "State v. Watts" on Justia Law

After the conclusion of a bench trial, Defendant was found guilty of aggravated driving under the influence with a breath alcohol concentration (BAC) of 0.239. Defendant appealed to the district court and filed a motion to suppress the evidence gathered after the vehicle he was driving was stopped by an officer of the Motor Carrier Services Division, Montana Department of Transportation (MDT). The district court denied the motion. The Supreme Court affirmed, holding that the MDT officer acted properly and within the requirements of law in stopping Defendant’s truck, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Beaver" on Justia Law

After a jury trial, Defendant was convicted of felony obstructing justice. Defendant appealed, claiming (1) the district court improperly instructed the jury regarding the “knowing” element of obstructing justice, thus violating Defendant’s due process rights; and (2) defense counsel was ineffective for failing to submit a jury instruction defining the statutory term “knowing.” The Supreme Court affirmed, holding (1) the jury was properly instructed on all of the elements of the offense even without an instruction defining “knowing” because the word “knowing,” within the stated elements of the offense, fulfilled a limited purpose that was commonly understood by the jurors; and (2) Defendant failed to establish that he received ineffective assistance of counsel. View "State v. Nuessle" on Justia Law