Justia Montana Supreme Court Opinion Summaries

The State appealed an order granting Daniel Colvin's motion to dismiss. In 2014, the State charged Colvin by information with attempted deliberate homicide in the September 4, 2014 shooting of Michael Aja. At the time of the incident Aja was sitting in his Jeep vehicle. Colvin claimed that he was holding the pistol inside the driver’s side window when it accidentally fired and hit Aja. On the same day as the shooting, law enforcement officers seized and impounded the Jeep as evidence. As the case developed, the position of the pistol and its distance from the victim when fired became important issues to the prosecution and the defense. The State’s theory was that the pistol shot came from several feet outside the vehicle, while Colvin’s theory was that it came from very near or inside the window. Colvin also contends that each eyewitness to the incident, including the victim, supports his theory that the shot was fired from near or inside the vehicle window. The District Court entered an order granting a defense discovery motion, requiring disclosure of “all materials known or discovered . . . pertinent to this case.” That same day the State filed a motion for leave to return a wallet and keys to Michael Aja. A few days later, the State returned the vehicle to Aja. The State did not notify the defense or the District Court that it intended to release the vehicle and did not seek leave of the District Court to do so. The District Court determined that after release of the vehicle and Aja’s daily use, the defense had no means to obtain evidence as it existed at the time the State’s expert gathered his evidence. The District Court concluded that the State’s “negligent” release of the impounded vehicle in the face of an order requiring disclosure “deprived the defense of the opportunity to investigate and prove their theory of the case. This is a fundamental violation of due process.” Finding no reversible error in the District Court's judgment, the Supreme Court affirmed granting Colvin's motion to dismiss. View "Montana v. Colvin" on Justia Law

After a jury trial, Defendant was found guilty of driving under the influence, second offense. Defendant appealed, demanding a trial de novo. Defendant also filed a motion to dismiss, arguing that his constitutional rights had been violated by his trial being conducted by a non-lawyer judge in a court of record without trial de novo. The district court denied the motion to dismiss. The Supreme Court affirmed, holding that Defendant’s trial before a non-lawyer justice of the peace, even where a trial de novo was not available on appeal, did not violate his constitutional right to effective assistance of counsel or to due process. View "State v. Davis" on Justia Law

After a jury trial, Defendant was found guilty of criminal possession. The district court sentenced him as a persistent felony offender to a term of twenty years, with ten of those years suspended. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress evidence of methamphetamine that law enforcement officers found on Defendant’s person after conducting a search incident to his lawful arrest for violating the terms of his parole; (2) Defendant was not prejudiced by his counsel’s failure to file proposed findings of fact and conclusions of law following the evidence hearing relating to his suppression motion; (3) the district court did not abuse its discretion by denying Defendant’s third discovery request; (4) the district court did not err by denying Defendant’s post trial motion to dismiss based upon the Court’s failure to arraign him on the second amended information; and (5) the district court conducted an “adequate initial inquiry” into Defendant’s complaints concerning his assigned counsel. View "State v. Crawford" on Justia Law

Defendant was charged with one count of arson, a felony. Pursuant to a plea agreement, Defendant pleaded no contest to arson. Defendant subsequently filed a motion to withdraw his no contest plea, asserting that the district court did not comply with the statutory procedures for rejecting plea agreements. The district court denied Defendant’s motion to withdraw his plea, concluding that Defendant entered the plea voluntarily and knowingly. The district court then sentenced Defendant to ten years’ imprisonment with five years suspended. The Supreme Court reversed and remanded with instructions for the district court to conduct another sentencing hearing, holding that the plea agreement in this case should be construed as a Mont. Code Ann. 46-12-211(1)(b) agreement and that the district court erred by not following the required procedures for rejecting the parties’ plea agreement. View "State v. Langley" on Justia Law

Defendant was charged with one count of arson, a felony. Pursuant to a plea agreement, Defendant pleaded no contest to arson. Defendant subsequently filed a motion to withdraw his no contest plea, asserting that the district court did not comply with the statutory procedures for rejecting plea agreements. The district court denied Defendant’s motion to withdraw his plea, concluding that Defendant entered the plea voluntarily and knowingly. The district court then sentenced Defendant to ten years’ imprisonment with five years suspended. The Supreme Court reversed and remanded with instructions for the district court to conduct another sentencing hearing, holding that the plea agreement in this case should be construed as a Mont. Code Ann. 46-12-211(1)(b) agreement and that the district court erred by not following the required procedures for rejecting the parties’ plea agreement. View "State v. Langley" on Justia Law

Appellant was convicted of deliberate homicide and related felonies and misdemeanors. Appellant was sentenced to life imprisonment for the deliberate homicide conviction. The Supreme Court affirmed the convictions on appeal. Thereafter, Appellant filed a petition for postconviction relief, alleging ineffective assistance of counsel during his trial. The district court denied postconviction relief. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on any of his claims of ineffective assistance of counsel; and (2) because there was no ineffective assistance of counsel on Appellant’s individual claims, there can be no cumulative error. View "Heavygun v. State" on Justia Law

After a jury trial, Defendant was convicted of felony murder, aggravated assault, and related charges. The Supreme Court reversed the conviction for aggravated assault because it was an included offense of the charge of felony murder and affirmed the remaining convictions. Defendant subsequently filed a petition for postconviction relief, asserting that his attorneys at trial and on appeal provided ineffective assistance. The district court denied Defendant’s petition for postconviction relief. The Supreme Court affirmed, holding that the district court did not err in deciding that Defendant did not receive ineffective assistance of counsel at trial and on appeal. View "Russell v. State" on Justia Law

Three defendants (jointly, Appellants) were convicted in municipal court of various traffic violations, including driving with a suspended license. The district court affirmed the convictions. Appellants appealed separately to the Supreme Court. The Supreme Court consolidated the cases and affirmed, holding (1) Mont. Code Ann. 61-5-212 imposes absolute liability, and a conviction under this statute does not require a culpable mental state; (2) because the evidence presented in each of Appellant’s trials met the requirements for conviction under section 61-5-212, the district court did not err in affirming Appellants’ convictions; and (3) the district court did not abuse its discretion by concluding that the letters notifying Appellants of their suspensions were admissible as certified copies of public records under Mont. R. Evid. 904. View "City of Kalispell v. Omyer" on Justia Law

After a jury trial, Defendant was convicted of incest, sexual assault, and sexual intercourse without consent against a child age sixteen or younger, sexual intercourse without consent against a child age twelve or younger, and sexual assault against a child age sixteen or younger. The Supreme Court affirmed, holding (1) the district court properly excluded evidence that three of the four victims suffered prior sexual abuse by others; and (2) Defendant failed to demonstrate that certain statements made by the prosecutor rose to a level that triggered the threshold for undertaking plain error review. View "State v. Awbery" on Justia Law

After a jury trial, Defendant was convicted of incest, sexual intercourse without consent, and sexual assault. The district court sentenced Defendant to terms of imprisonment on each of the convictions. The Supreme Court reversed the convictions, holding (1) the district court abused its discretion in excluding Defendant’s expert witness from testifying at trial, as Defendant was qualified in both education and experience to provide the testimony sought by Defendant; and (2) the district court abused its discretion by mechanistically applying the Rape Shield Law to exclude evidence that Defendant offered at trial. Remanded for a new trial. View "State v. Colburn" on Justia Law