Justia Montana Supreme Court Opinion Summaries

After a jury trial that was held in absentia, Appellant was convicted of obstructing a peace officer, resisting arrest, failing to carry motor vehicle liability insurance, and speeding. Appellant appealed. Appellant subsequently failed to appear at an indigence hearing to determine Appellant’s eligibility for appointed counsel. The district court dismissed the appeal for Appellant’s failure to appear for the scheduled court date. The Supreme Court affirmed, holding that the district court did not abuse its discretion in dismissing Appellant’s appeal from the justice court because (1) Appellant failed to appear for a scheduled court date; and (2) there was not good cause precluding the district court from dismissing Appellant’s appeal. View "State v. Ziolkowski" on Justia Law

After a jury trial, Appellant was convicted of disorderly conduct, a misdemeanor, and two counts of felony assault with a weapon. The Supreme Court affirmed, holding (1) sufficient evidence supported Appellant’s convictions for felony assault with a weapon; (2) the district court did not abuse its discretion in limiting a justifiable use of force defense to the felony assault with a gun charge; (3) the district court did not abuse its discretion in allowing the State to present rebuttal evidence to impeach defense witness testimony; and (4) the district court did not err in denying Appellant’s motion to dismiss for lack of a speedy trial. View "State v. Redlich" on Justia Law

After a bench trial, Appellant was convicted of exploiting an older person, a felony. Prior to the commencement of the trial, the district court held a hearing on the competency of the victim to testify at trial. The court determined that the victim was competent to testify, but by the time of trial, the victim’s health had deteriorated and she was unable to testify. At trial, Appellant asked the district court to admit a transcript of the victim’s testimony at the competency hearing. The district court denied the request, determining that the victim’s competency hearing did not pertain to the issues in the bench trial. The Supreme Court affirmed, holding that the district court properly applied Mont. R. Evid. 804(b)(1) and did not abuse its discretion in determining that the prior testimony was not sufficiently reliable to come within the exception to the rule excluding hearsay. View "State v. Homer" on Justia Law

After Petitioner was involved in an accident from allegedly hitting a building with his truck, Petitioner was cited for DUI, third offense. Petitioner’s driver’s license was seized based on his refusal to submit to a blood or breath test. Defendant subsequently filed a petition to reinstate his driver’s license. The hearing on Petitioner’s petition was continued several times. Meanwhile, a jury found Defendant not guilty of the underlying DUI charge. Based on this acquittal and “res judicata and/or collateral estoppel” principles, Petitioner filed a petition asking the district court to enter judgment against the State on his petition and to permanently reinstate his license. The district court denied the petition. The Supreme Court affirmed, holding that the district court did not err in denying Petitioner’s petition for reinstatement of his driver’s license, as the acquittal in municipal court did not establish res judicata or collateral estoppel in Petitioner’s reinstatement proceeding. View "Ditton v. Dep't of Justice Motor Vehicle Div." on Justia Law

The State charged Defendant with aggravated assault against his wife and criminal endangerment. After a jury trial, Defendant was convicted of criminal endangerment and the lesser offense of assault. Defendant appealed, arguing (1) criminal endangerment is a lesser-included offense of aggravated assault, and charging both crimes is prohibited by statute, and (2) his counsel provided ineffective assistance when he failed to invoke Mont. Code Ann. 46-18-225, which requires a sentencing court to evaluate specific criteria when assessing imprisonment alternatives for non-violent offenders. The Supreme Court affirmed, holding (1) Defendant was not simultaneously convicted on a lesser and greater offense; and (2) Defendant suffered no prejudice from his counsel’s conduct at sentencing. View "Zink v. State" on Justia Law

After a jury trial, Defendant was convicted of felony theft by insurance fraud. The Supreme Court affirmed the conviction, holding (1) the district court did not err when it instructed the jury that an insurance administrator is a person who adjusts or settles claims; (2) the Court declines to exercise plain error review of the State’s remarks during closing argument; (3) the district court did not err by ordering Defendant to pay restitution when the affidavit of loss was prepared by an independent adjuster; and (4) Defendant’s claim that he received ineffective assistance of counsel must be raised in a postconviction proceeding before a district court, where an evidentiary record may be developed. View "State v. Schaeffer" on Justia Law

After a jury trial, Appellant was convicted of incest in violation of Mont. Code Ann. 45-5-507. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the district court correctly interpreted the Court’s decision in State v. Anderson, and did not abuse its discretion, when it prohibited Appellant from examining the victim regarding alleged false accusations of sexual assault; (2) the jury instructions fairly and fully instructed the jury as to the applicable law; (3) the district court did not abuse its discretion in denying Appellant’s motion for a new trial on grounds of juror misconduct; and (4) several portions of Appellant’s sentence were illegal, including conditions of parole, the order to pay restitution, and the requirement to pay “all future costs of incarceration and medical costs while incarcerated.” View "State v. Ring" on Justia Law

After a jury trial, Defendant was convicted of felony incest involving his fourteen-year-old son and six-year-old daughter and of tampering with the evidence. The Supreme Court affirmed. Defendant later petition for postconviction relief, setting forth three grounds upon which he claimed that his trial counsel provided ineffective assistance. The district court denied Defendant’s petition for postconviction relief, concluding that even if Defendant’s representation was deficient, it would not have created a reasonable probability that the outcome of the trial would have been any different. The Supreme Court affirmed, holding that the district court did not err in concluding that even if counsel’s conduct was constitutionally deficient, Defendant failed to show that he was prejudiced. View "Stock v. Montana" on Justia Law

After a jury trial, Defendant was convicted of one count of sexual assault, a felony, and sentenced to twenty years imprisonment. The Supreme Court affirmed, holding (1) the prosecutor’s statements during closing argument regarding the truthfulness of witness testimony did not rise to the level of plain error; and (2) the district court did not deny abuse its discretion when it determined that a new trial was not warranted in the interest of justice after the court sua sponte questioned a key defense witness, as the inquiry did not serve to deny Defendant a fair trial. View "State v. Walton" on Justia Law

In 2007 and 2008, Defendant was convicted of four felonies. In 2010, Defendant absconded from a pre-release center. Several months later, Defendant was extradited from Idaho to Montana. Defendant pled guilty to escape. Defendant was sentenced to ten years imprisonment and ordered to pay restitution to the State for the costs incurred in extraditing him back to Montana from Idaho. On appeal, Defendant challenged the restitution requirement. The Supreme Court reversed, holding that the district court erred when it ordered Defendant to pay restitution to the State for expenses incurred in extraditing him from Idaho to Montana, as the court lacked the statutory authority to impose restitution for extradition costs. View "State v. Macy" on Justia Law