Justia Montana Supreme Court Opinion Summaries

After county animal control officers responded to a complaint that three horses were being confined in a trailer without adequate food or water, Defendant was charged and found guilty of three misdemeanor counts of cruelty to animals. Defendant was sentenced to three years in a detention facility and ordered to pay $3,000 in restitution to animal control for the care of the horses. The horses were forfeited to the county. The Supreme Court affirmed the conviction and sentence, holding (1) sufficient evidence supported the convictions; and (2) the district court did not err by ordering the forfeited horses to be either sold or adopted in the county’s discretion. View "State v. Beaudet" on Justia Law

In 1991, Appellant was convicted of two counts of deliberate homicide and sentenced to life imprisonment. Attorney James Goetz attempted to help Appellant with his parole eligibility claim. Displeased with Goetz's assistance, Appellant filed a complaint against Goetz. Appellant was assisted by attorneys Allan Baris and Todd Stubbs in this action. In 2010, Appellant filed a complaint against Goetz, Baris, and Stubbs, asserting claims related to the alleged withholding of discovery in Appellant’s previous action against Goetz. The district court granted Defendants’ motion for summary judgment without a hearing. The Supreme Court affirmed, holding that the district court did not abuse its discretion (1) by denying Appellant’s motion for a summary judgment hearing; and (2) by denying Appellant’s motion to stay judgment pending completion of discovery.View "Miller v. Goetz" on Justia Law

After a trial, Appellant was convicted of sexual intercourse without consent and sexual assault. The Supreme Court affirmed. Thereafter, Appellant filed a petition for postconviction relief raising numerous claims of ineffective assistance of counsel. The district court denied relief. The Supreme Court affirmed the district court’s denial of Appellant’s petition for postconviction relief, holding (1) counsel was not ineffective for failing to request dismissal of the charges against Defendant for the State’s alleged destruction of evidence or a jury instruction regarding the State’s failure to collect and preserve the subject evidence; and (2) counsel did not act unreasonably when he withdrew a proposed jury instruction on sexual assault as a lesser included offense.View "Taylor v. State" on Justia Law

After a jury trial, Defendant was convicted of felony sexual assault against his girlfriend’s four-year-old daughter. The Supreme Court affirmed the conviction, holding (1) the district court did not err when it found that the victim was unable to testify in open court in the presence of Defendant; and (2) the district court properly applied Montana law and did not abuse its discretion when it allowed the State to present the testimony of a forensic interview about the victim’s statements that were inconsistent with the victim’s trial testimony.View "State v. Pound" on Justia Law

After a jury trial, Defendant was convicted of sexual intercourse without consent for engaging in a continual sexual relationship with his stepdaughter, who was twelve years old at the time the offenses began. Defendant appealed, arguing that the district court abused its discretion by denying his challenge for cause of a juror whose daughter had been the victim of sexual violence. The Supreme Court affirmed, holding that, under the facts of this case, the district court did not abuse its discretion in denying the challenge for cause. View "State v. Cudd" on Justia Law

After a jury trial, Defendant was convicted of felony sexual assault. Defendant later filed a petition for postconviction relief seeking DNA testing and alleging that he had received ineffective assistance of counsel (IAC). The district court denied the petition, but the Supreme Court reversed and remanded. Defendant subsequently filed a second petition requesting that he be allowed to conduct discovery. The district court denied both Defendant’s petition for DNA testing and his request to conduct discovery but granted relief as it pertained to his IAC claim. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in denying Defendant’s petition for DNA testing; and (2) erred in granting Defendant’s petition as it pertained to IAC of appellate counsel, as any error on appellate counsel’s part was harmless. View "Golden v. State" on Justia Law

After a jury trial, Defendant was convicted of felony sexual intercourse without consent, misdemeanor partner or family members assault, and felony tampering with witnesses and informants. The Supreme Court affirmed the convictions, holding (1) the district court did not abuse its discretion when it admitted evidence that Defendant had previously assaulted and harassed the victim; (2) plain error review was not warranted for the Court to review the district court’s jury instruction regarding the evidence of the previous bad acts; and (3) Defendant did not receive ineffective assistance of counsel due to his counsel’s failure to object to the State’s use of the previous bad acts.View "State v. Crider" on Justia Law

After Defendant accused her ex-boyfriend of raping her, the State charged Defendant with one count of tampering with or fabricating physical evidence in violation of Mont. Code Ann. 45-7-207(1)(b). Defendant filed a motion to dismiss the charge, arguing that the Information did not allege a cognizable basis to find probable cause that the charged offense had occurred. The district court granted the motion. The Supreme Court reversed, holding that, based on the State’s allegations, there were sufficient facts from which a rational trier of fact could conclude that each element of the charged offense had been proven. View "State v. Nelson" on Justia Law

Defendant pleaded guilty to tampering with witnesses and informants. Defendant subsequently filed a motion to withdraw his guilty plea, which the district court denied. Defendant appealed, arguing that he should be allowed to withdraw his guilty plea because his counsel misinformed him about his eligibility for a persistent felony offender designation. The Supreme Court affirmed the district court’s order denying Defendant’s motion to withdraw his guilty plea, holding (1) the district court correctly determined that Defendant was fully aware of the direct consequences of his plea and that the plea was not induced by misrepresentation; and (2) therefore, Defendant failed to show that, but for counsel’s deficient performance, he would not have entered a guilty plea.View "State v. Hendrickson" on Justia Law

Defendant pleaded guilty to one count of assault with a weapon and one count of criminal mischief. An affidavit by the victim indicated that he suffered $6,418 in medical and dental expenses related to the assault, but the victim’s insurer paid for some portion of that total. The district court required Defendant to pay $6,418 in restitution to the victim. Defendant appealed, arguing that his restitution to the victim should be reduced by the amount paid by the insurer. The Supreme Court affirmed, holding that the district court correctly applied the law in determining that Defendant was not entitled to an offset in his restitution based on the victim’s insurance compensation, as the victim and his insurer were entitled to any damages that could be pursued against Defendant in a civil action, regardless of any subrogation issues between them. View "State v. Fenner" on Justia Law