Justia Montana Supreme Court Opinion Summaries

In 1993, Defendant pled guilty to three felony offenses in Cause No. 10893. Defendant’s resulting sentence required, among other things, that he pay restitution to his assault victim and pay the uninsured portion of his detox treatments. In 2012, Defendant was sentenced for probation violations stemming from an unrelated 2002 felony drug possession conviction. Since Defendant’s most recent incarceration, the Department of Corrections (DOC) had been garnishing Defendant’s prison wages and applying the garnished funds to his restitution obligation. In 2013, Defendant filed a motion to compel DOC to stop garnishing his account, claiming that he owed no further restitution because he had discharged his sentence in Cause No. 10893 in 2001. The district court denied Defendant’s motion. The Supreme Court affirmed, holding that Defendant’s restitution obligations did not extinguish at the time he discharged his prison sentence. View "State v. Ferre" on Justia Law

In two separate cases, Appellants were injured in the course and scope of their employment. Montana State Fund (SMF) paid Appellants indemnity and medical benefits. Appellants were subsequently incarcerated for various crimes, after which MSF terminated or denied payment of permanent partial disability (PPD) benefits. Appellants each appealed their ineligibility to receive PPD benefits. The Workers’ Compensation Court (WCC) granted MSF’s motions for summary judgment as to both Appellants. The Supreme Court affirmed, holding (1) the WCC properly determined that Mont. Code Ann. 39-71-744 rendered incarcerated claimants ineligible for disability or rehabilitation compensation benefits; and (2) section 39-71-744 did not violate Appellants’ constitutional rights to equal protection, to substantive due process, to procedural due process, or to be from excessive fines. View "Goble v. Mont. State Fund" on Justia Law

The municipal court found Defendant guilty of disorderly conduct after Defendant and her daughter directed profane ad abusive language toward a thirteen-year-old boy from their vehicle on a public street. The district court affirmed Defendant’s conviction. The Supreme Court affirmed, holding, among other things, that (1) the disorderly conduct statute does not require proof that the peace of more than one person was disturbed; (2) Defendant’s speech constituted “fighting words” and was not constitutionally protected; (3) Defendant’s constitutional rights were not violated by the responding officer’s initial report of his investigation; and (4) the municipal court did not err by considering the victim’s age during sentencing. View "City of Billings v. Nelson" on Justia Law

Defendant entered a plea of nolo contendere to driving under the influence. Defendant appealed, arguing that the municipal court erred in denying his motion to suppress evidence obtained by a blood draw following the DUI stop and in denying his subsequent “request for hearing.” The Supreme Court affirmed, holding that the district court did not err by (1) affirming the municipal court’s determination that law enforcement properly withdrew Defendant’s blood against his will after obtaining a valid search warrant, as probable cause existed to issue the search warrant, and Defendant’s constitutional challenge to the forced blood draw was without merit; and (2) affirming the municipal court’s decision to deny Defendant’s “request for hearing” as untimely. View "State v. Giacomini" on Justia Law

Defendant pled guilty in justice court to DUI and reckless driving, second offense, after driving off the road and colliding with Barbara Turcotte’s garage. After a restitution hearing at which the justice court considered a victim’s loss statement as evidence, the court ordered that Defendant owed an additional $1,911 in restitution above the amount covered by his insurance. The district court affirmed. At issue on appeal was whether the district court erred in affirming the award of restitution, where there was a difference between Defendant’s insurance company’s estimate of the damage to the garage and Turcotte’s estimate. The Supreme Court reversed, holding that substantial evidence did not support the award of restitution in this case, where the evidence before the court was conflicting and no other testimony or evidence was available to be examined or reviewed as to the discrepancy. Remanded. View "State v. Aragon" on Justia Law

Defendant was charged with felony burglary in 2007. The Flathead County District Court issued a warrant for Defendant’s arrest, but shortly afterward, Defendant was arrested and sentenced on unrelated federal charges. Defendant was subsequently committed to a federal correctional institution. In 2013, Defendant filed a pro se motion to dismiss the Flathead County arrest warrant, arguing that the county attorney’s failure to take action on his pending burglary charge violated his Sixth Amendment right to a speedy trial. The county attorney argued in response that Defendant’s motion must be denied because an inmate may invoke the provisions of the Interstate Agreement on Detainers Act (IAD) only after a detainer is filed. The District Court denied Defendant’s motion. The Supreme Court reversed, holding (1) Defendant’s motion was premised on an alleged denial of his constitutional right to a speedy trial, not the IAD; and (2) the district court improperly denied Defendant’s motion without addressing his speedy trial rights. Remanded. View "State v. Nickerson" on Justia Law

After a jury trial, Defendant was convicted of charges stemming from the sexual assault of his stepdaughter. Defendant subsequently filed a petition for post-conviction relief (PCR). One day before his reply brief was due, Defendant sought leave to file an amended petition. The district court granted the motion but prohibited him from asserting new claims. Defendant then filed his amended PCR petition, which the district court denied. The Supreme Court (1) affirmed the district court’s limitation of new claims in Defendant’s amended PCR petition; but (2) reversed the district court’s denial of Defendant’s PCR petition and remanded for reconsideration of Defendant’s amended PCR petition by a new judge because the judge that ruled on the petition had an impermissible conflict of interest based on his previous representation of Defendant’s wife in a divorce proceeding. View "Bullman v. State" on Justia Law

The State charged Defendant with felony criminal endangerment and felony DUI. The jury was unable to reach a unanimous verdict on the charges, and a mistrial was declared. At the second trial, defense counsel offered a jury instruction on negligent endangerment as a lesser included offense of criminal endangerment, but the court declined to give the instruction. The jury subsequently found Defendant guilty of criminal endangerment. The Supreme Court reversed, holding that the district court abused its discretion when it failed to give Defendant’s proposed jury instruction of negligent endangerment as a lesser included offense of criminal endangerment, and Defendant was prejudiced by this error. View "State v. Shegrud" on Justia Law

Defendant was arrested after law enforcement officers responded to a report that Defendant had stolen a purse and, after conducting a warrant check, learned that Defendant had an outstanding city warrant. At the detention center, officers conducted an inventory search of Defendant’s purse and found drugs and drug paraphernalia. The State charged Defendant with criminal possession of dangerous drugs with intent to distribute and criminal possession of drug paraphernalia. Defendant filed a motion to suppress or dismiss, which the district court denied. Defendant pleaded guilty to both counts. Defendant subsequently appealed the denial of her motion to suppress and dismiss, asking the Supreme Court to overturn State v. Pastos, in which the Court held that a compelling state interest justifies a routine, administrative inventory search of the personal property in the possession of the arrestee at the station house following a lawful arrest. The Supreme Court affirmed the denial of Defendant’s motion and, in so doing, reaffirmed its decision in Pastos, holding (1) safety concerns and procedural safeguards justify the inventory searches at issue; and (2) the search of Defendant’s purse was a valid inventory search under Pastos. View "State v. Demontiney" on Justia Law

After a jury trial, Defendant was found guilty of accountability for criminal distribution of dangerous drugs and committed to the custody of the Department of Corrections for fifteen years, with ten years suspended. Defendant appealed, arguing that his attorney provided ineffective assistance by moving to preclude evidence of accountability or conspiracy, which Defendant alleged alerted the State to its “charging error," thus prompting the State to amend the charges and thereby assuring his conviction. The Supreme Court affirmed, holding that Defendant’s argument was entirely without merit and that the efforts of Defendant’s attorney were well within the wide range of reasonable professional conduct. View "State v. Carter" on Justia Law