Justia Montana Supreme Court Opinion Summaries

Defendant failed to yield while making a left turn and collided with a motorcycle. The driver of the motorcycle and his passenger (together, the Boots) suffered injuries as result of the accident. Defendant pleaded guilty to negligent vehicular assault. After a sentencing hearing, the district court issued a judgment and sentence ordering Defendant to pay restitution to the Boots and to the Crime Victim Compensation Program for a total restitution amount of $618,816. Defendant appealed, arguing that the district court erred in ordering him to pay restitution. The Supreme Court affirmed, holding that the district court did not err in awarding restitution. View "State v. Passwater" on Justia Law

After he crashed a truck into a light post Defendant was arrested for driving under the influence (DUI). Defendant consented to a blood draw for toxicological testing, which revealed that his blood contained 6.2 mcg/ml of 1,1-difluoroethane (DFE), a chemical found in dust-remover. Defendant filed a motion to dismiss the DUI charge, arguing that DFE does not fit within the statutory definition of “drug.” The district court denied the motion to dismiss. Defendant subsequently entered into a plea agreement, and the court accepted his guilty plea. The Supreme Court affirmed, holding (1) the district court did not err when it did not apply the pharmacy definition of “drug” and instead used a commonly understood plain meaning definition; and (2) under that definition, DFE could be considered a drug, and driving while under the influence of DFE a violation of the DUI statute. View "State v. Pinder" on Justia Law

Defendant was charged with two counts of attempted deliberate homicide. Before trial, Defendant moved to suppress statements he made while in custody, arguing that he was never informed of his right to remain silent and that all questioning by law enforcement should have ceased when he asked for an attorney. The district court denied the motion to suppress. Defendant was subsequently convicted on both counts of attempted homicide. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Defendant’s motion to suppress, as the statements he made after he was in custody, after he requested an attorney, and before he was notified of his Miranda rights were spontaneous; and (2) denied Defendant’s motion to exclude one of the victims of the crime from the courtroom. View "State v. Braulick" on Justia Law

Appellant pleaded guilty to the charge of deliberate homicide. After the matter had been set for sentencing, Appellant sought the appointment of new counsel and also filed a motion for withdrawal of his guilty plea. The district court denied Appellant’s request for the appointment of new counsel and further denied his motion to withdraw his plea. The court then sentenced Appellant to life in prison. The Supreme Court remanded for further proceedings on a limited issue, holding that the district court failed to adequately inquire into Appellant’s complaint that defense counsel had rendered ineffective assistance of counsel. View "State v. Schowengerdt" on Justia Law

Petitioner was stopped for crossing the center line of a road with his vehicle. When Petitioner refused to perform a breath alcohol test he was arrested for driving under the influence of alcohol or drugs. Petitioner’s driver’s license was subsequently suspended. Thereafter, Petitioner petitioned the district court to reinstate his driver’s license. The district court denied the petition, concluding that Petitioner violated Mont. Code Ann. 61-8-328 when his vehicle “slightly crossed over the yellow center line.” The Supreme Court affirmed, holding that the district court did not err by deciding that Petitioner violated section 6-18-328 when he directed his vehicle across the yellow center line. View "Mitchell v. State" on Justia Law

After a jury trial in 1984, Defendant was convicted of deliberate homicide for a crime committed when Defendant was seventeen. The district court imposed the maximum sentence of one hundred years’ imprisonment without the possibility of parole, a sentence that was within the discretion of the district court and that was not mandated by law. Defendant attempted in numerous filings to attack his conviction and sentence, to no avail. Defendant now petitioned for a writ of habeas corpus, challenging the constitutionality of his sentence under Miller v. Alabama. The Supreme Court denied the habeas petition, holding that the Miller sentencing consideration rule requiring a sentencing judge to consider a juvenile offender’s age when sentencing that offender to life without parole is not retroactive to Defendant’s claim on collateral review. View "Beach v. State" on Justia Law

After a trial, Defendant was found guilty of two counts of assault on a peace officer or judicial officer, in violation of Mont. Code Ann. 45-5-210(1)(b). Defendant appealed, arguing that the district court erred by failing to instruct the jury that the state was required to prove mental state as to every element of the offense. The Supreme Court reversed, holding (1) the given jury instruction was a misstatement of the law because it required the jury to find the deputies were peace officers but not that Defendant knew them to be peace officers; and (2) the error clearly prejudiced Defendant. View "State v. Carnes" on Justia Law

Defendant was convicted of failing to register as a sex offender and and theft was sentenced to a net sentence of ten years in the Montana State Prison with five years suspended. Defendant appealed, arguing that the district court judge was disqualified from hearing his case due to personal knowledge of facts in dispute in the sentencing proceeding and therefore should have recused himself. The Supreme Court affirmed, holding that because Defendant’s counsel knew of the factual basis for Defendant’s disqualification claim before sentencing but did not raise disqualification, Defendant’s claim was waived. View "State v. Dunsmore" on Justia Law

After initiating a traffic stop of the vehicle Appellant was driving, the deputy administered a preliminary breath test to Appellant, which reported an elevated blood alcohol concentration. Appellant was arrested for driving under the influence of alcohol (DUI). Because Appellant refused to take a breath test, his driver’s license was seized. Appellant subsequently filed a petition to have his license reinstated. The trial court concluded that Appellant was properly arrested for DUI and denied his petition for reinstatement of his driver’s license. The Supreme Court affirmed, holding (1) the district court properly found that the deputy had reasonable grounds to stop Appellant’s vehicle; (2) the district court did not err in concluding that the State was not estopped from suspending Appellant’s license because of a statement made by the arresting officer regarding the consequences of Appellant providing a breath sample; and (3) Appellant’s refusal to submit to the blood test constituted a refusal within the meaning of Mont. Code Ann. 61-8-402 because Appellant failed to establish that he suffered from a psychological fear of needles rendering him physically unable to perform the test. View "Kummerfeldt v. State" on Justia Law

Defendant was charged with criminal possession of dangerous drugs in violation of Mont. Code Ann. 45-9-102. Defendant moved to suppress the evidence resulting from the search of her purse by police officers, arguing that the tip the officers received failed to establish particularized suspicion and that her consent to search was involuntary, and therefore, the seizure and search were illegal. The district court denied the motion. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) did not err by concluding that the search of Defendant’s baggage was lawfully executed based upon Defendant’s voluntary consent; and (2) erred in its written judgment by altering Defendant’s sentence from its oral pronouncement. View "State v. Dupree" on Justia Law