Justia Montana Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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Defendant was charged with felony driving under the influence (DUI) and misdemeanor driving without valid liability insurance. Defendant entered pleas of not guilty and then filed a motion to dismiss for denial of his right to a speedy trial. After an evidentiary hearing, the district court denied Defendant’s motion to dismiss. Defendant then changed his plea to guilty on both charges, reserving the right to appeal the denial of his speedy trial motion. The Supreme Court reversed and remanded for dismissal of the charges, holding that the delay in bringing Defendant to trial violated his constitutional right to a speedy trial.View "State v. Zimmerman" on Justia Law

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Defendant was charged with two counts of felony partner or family members assault (PFMA), one charge pertaining to his brother and one charge pertaining to his niece. The case proceeded to trial. At the close of the State’s case, Defendant moved for judgment of a matter of law as it pertained to the second count, arguing that his niece was not a “family member” as that term is defined in the applicable statute, Mont. Code Ann. 45-5-206. The district court denied the motion. The jury subsequently convicted Defendant PFMA for his assault on his niece. The Supreme Court reversed, holding that Defendant’s niece was not a family member as defined by section 45-5-206 because no evidence was presented that Defendant and his niece resided together in the same household at any time.View "State v. Gregori" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of deliberate homicide. Defendant appealed, arguing that the district court erred by denying his motion to suppress statements he made to the police. The Supreme Court remanded with instructions to hold an evidentiary hearing. After a hearing on remand, the district court suppressed Defendant’s statements to the police on the grounds that the statements were made involuntarily and granted Defendant a new trial. The Supreme Court affirmed, holding that the district court did not err in concluding that Defendant’s statements were made involuntarily and in ordering a new trial.View "State v. OldHorn" on Justia Law

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After a jury trial, Defendant was convicted of aggravated assault for allegedly intentionally submerging his young son in scalding water. The Supreme Court reversed Defendant’s conviction, vacated the district court’s judgment, and remanded the matter for a new trial, holding that the district court erred in denying Defendant’s motion for a continuance based on an absent witness, as (1) Defendant met the diligence requirement contained in Mont. Code Ann. 46-13-202, (2) the interests of justice and Defendant’s right to a fair trial necessitated the grant of his motion for a continuance in order to allow the witness at issue to testify, and (3) the witness intended to testify.View "State v. Gleed" on Justia Law

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

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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

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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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