Justia Montana Supreme Court Opinion Summaries

Defendant was charged with criminal possession of dangerous drugs with intent to distribute and criminal possession of dangerous drugs/opiates. Defendant moved to suppress the evidence found in his vehicle during a search pursuant to a search warrant, arguing that the police lacked particularized suspicion to initiate a traffic stop. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err in determining that the stop of Defendant was supported by a particularized suspicion that Defendant’s tail light covers violated Mont. Code Ann. 61-9-204(5). View "State v. Massey" on Justia Law

Defendant was charged with driving under the influence (DUI) in violation of Mont. Code Ann. 61-8-401. Defendant filed a motion to suppress the results of a blood test taken at Marcus Daly Memorial Hospital, conceding that he verbally consented to the blood test but arguing that he withdrew his consent by not signing a patient consent form at the hospital. The Supreme Court affirmed the district court’s order denying Defendant’s motion to suppress the results of his blood test, holding that the district court did not err by rejecting Defendant’s argument and in finding that the patient consent form has no bearing on consent under Montana’s DUI law. View "State v. Shepp" on Justia Law

Defendant was arrested and charged with felony criminal possession. The district court granted the State’s motion for a continuance and reset Defendant’s trial for a day 285 days after his arrest. Defendant filed a motion to dismiss for speedy trial violations. The district court denied the motion. Defendant pleaded guilty but reserved the right to appeal the denial of his speedy trial motion. The Supreme Court reversed, holding that Defendant was denied his right to a speedy trial, considering the State’s reason for the delay, the simplicity and nature of the charges, and the prejudice to Defendant by his inability to participate in drug rehabilitation programs and community placement because of his unduly lengthy incarceration in county jail, in conjunction with Defendant’s need for treatment. Remanded for dismissal of the charges. View "State v. Mayes" on Justia Law

After a jury trial, Defendant was convicted of sexual intercourse without consent and sexual assault. Defendant appealed, arguing that the district court erred in denying his motion for discovery sanctions, specifically the denial of a continuance, and Defendant’s motion for mistrial. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it denied Defendant’s request for a sanction, in the form of a continuance; and (2) the district court did not abuse its discretion when it denied Defendant’s motion for mistrial on grounds that the State made improper comments or suggestions during opening statements. View "State v. Pierce" on Justia Law

Defendant was convicted of disorderly conduct in the Bozeman Municipal Court. Defendant was sentenced to pay a $100 fine and $135 in surcharges and fees. Defendant appealed his sentence to the district court, asserting eight grounds for appeal. The district court declined appellate jurisdiction and remanded the matter to the municipal court for enforcement of Defendant’s sentence, determining that Defendant’s $100 fine did not satisfy the threshold amounts for appellate jurisdiction set forth in the applicable rules or statutes and that it was unlikely that Defendant would prevail on any of the issues raised. The Supreme Court affirmed, holding that the district court’s denial of Defendant’s motion to appeal did not constitute an abuse of discretion or error. View "City of Bozeman v. King" on Justia Law

Cory Patterson and Jesse Alma King each pleaded guilty to two counts of burglary. As part of his sentence, Patterson was ordered to pay, jointly and severally with King, $28,592 in restitution. Patterson challenged the restitution ordered for one of the victim’s lost wages, damages to firearms that were stolen, mileage expenses, and copying costs. The Supreme Court affirmed, holding that the district court did not err in granting the victim’s restitution requests for lost wages, mileage, copying costs, and personal property damage, and the claims were supported by sufficient evidence. View "State v. Patterson" on Justia Law

In 2014, the State charged Defendant with felony driving under the influence (DUI). The probable cause affidavit alleged that Defendant had three prior DUI convictions, one from North Dakota in 1988. Defendant filed a motion arguing that the 1988 conviction was not a qualifying conviction because it was impossible to determine whether the conviction was a “blood alcohol concentration” conviction or an “under the influence” conviction because the same North Dakota statute governed both offenses. The district court denied Defendant’s motion, concluding that it was Defendant’s burden to prove the nature of the 1988 conviction. The court then ruled that the conviction could be used to support the felony charge. Defendant pleaded guilty to the felony, reserving his right to appeal the denial of his motion. The Supreme Court reversed, holding that the State bore the burden of proving that the 1988 conviction could be used to support its felony charge against Defendant and that the State failed to meet this burden. Remanded. View "State v. Krebs" on Justia Law

Defendant was convicted of criminal possession of dangerous drugs after police officer discovered Oxycodone residue on a spoon in Defendant’s possession. During trial, the court instructed the jury that Defendant could assert as a defense that he had obtained the Oxycodone pursuant to a valid prescription. When, during deliberations, the jury asked the court whether crushing prescription Oxycodone violated the law, the court responded that the jury was to rely “on the instructions previously given.” Defendant appealed, contending that the court abused its discretion in refusing to further instruct the jury on the legality of crushing prescription Oxycodone. The Supreme Court affirmed, holding that the district court did not abuse its discretion in deciding to refer the jury back to its original instructions. View "State v. Temple" on Justia Law

Defendant was convicted of five felony charges stemming from his illegal baiting, killing, and transportation or assistance in illegal baiting, killing, and transportation of nine black bears. The district court imposed a ten-year suspended prison sentence and twenty-six conditions. Thereafter, the State filed a motion to conform the district court’s written judgment to its oral pronouncement of Defendant’s sentence. The district court denied the motion. The Supreme Court affirmed in part and reversed in part, holding (1) the district court incorrectly applied the law when it denied the State’s petition to conform its written judgment to its oral pronouncement by striking the provision in Condition 23 that allows Defendant to petition for early termination of his lifetime hunting, fishing, and trapping prohibition; and (2) the district court correctly determined that Defendant may petition for early termination of his lifetime prohibition on accompanying any hunter, angler, or trapper. View "State v. Harrison" on Justia Law

After a jury trial, Defendant was convicted of reckless driving and failing to yield to an emergency vehicle. Defendant appealed, arguing that the victim’s in-court identification was impermissibly suggestive and unreliable and that a police officer’s testimony regarding vehicle registration information received from dispatch was inadmissible hearsay. The district court denied the appeal. The Supreme Court affirmed, holding that the trial court (1) did not err in allowing the victim’s in-court identification of Defendant at trial; and (2) did not abuse its discretion in admitting testimony concerning vehicle registration information received from police dispatch. View "City of Billings v. Nolan" on Justia Law