Justia Montana Supreme Court Opinion Summaries

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

Between December 11, 2011 and January 1, 2012, the Billings Police Department responded to more than 200 reports of vandalism. B.W., a youth, admitted to having committed acts of vandalism on December 22, 2011 and December 29, 2011. The youth court adjudicated B.W. a delinquent youth for having committed criminal mischief, common scheme and ordered B.W. to pay $78,702 in restitution, which represented the total damages sustained over the eleven-day vandalism spree. The Supreme Court reversed, holding that the youth court erred in concluding that B.W. was jointly and severally liable for the full amount of restitution for damages where the State did not establish that B.W. was accountable for the crimes of others in which Defendant did not participate. Remanded for a new restitution hearing. View "In re B.W." on Justia Law

After a jury trial, Defendant was convicted of accountability to burglary and theft. The Supreme Court affirmed Defendant’s conviction and sentence for accountability to burglary and reversed Defendant’s conviction for theft, holding (1) the district court did not err by instructing the jury on the theory of accountability when the State had not directly charged an accountability based offense, as the circumstances surrounding the trial put Defendant on notice that the State would pursue an accountability theory; (2) defense counsel’s submission of a jury instruction defining “purposely” in Montana’s accountability statute as a conduct-based rather than result-based mental state resulted in no prejudice to Defendant’s position at trial; and (3) defense counsel rendered ineffective assistance by failing to object to Defendant’s theft conviction on the grounds that it violated Montana’s statutory restriction on multiple charges. View "State v. Tellegen" on Justia Law

On November 26, 2011, the State charged Defendant with five misdemeanor offenses. On June 13, 2012, Defendant moved to dismiss the case on the ground that trial was being held beyond the six-month deadline imposed by Mont. Code Ann. 46-13-4013(2). The justice court denied Defendant’s motion, reasoning that good cause existed for holding Defendant’s trial past the deadline. The district court affirmed. The Supreme Court affirmed, holding that the lower courts did not err in finding that good cause existed for holding Defendant’s trial eight days past the six-month deadline. View "State v. Luke" on Justia Law

After a jury trial, Defendant was convicted of criminal distribution of dangerous drugs, a felony. Defendant appealed, arguing that the district court erred by instructing the jury on the elements of the offense prior to the delivery of opening statements. The Supreme Court affirmed, holding (1) the district court erred by, before opening statements, reading the jury instructions regarding the elements of the offense of criminal distribution of dangerous drugs without finding good cause; but (2) under the circumstances, Defendant’s substantial rights were not prejudicially affected by the error. View "State v. Otto" on Justia Law

Defendant was charged with one count of burglary and two counts of misdemeanor assault. Defendant pleaded guilty to the assaults but proceeded to a jury trial on the burglary charge. Defendant filed a motion to excuse a certain juror for cause based on the juror’s answers during voir dire to questions as to whether the juror inherently thought a law enforcement officer was more believable than a non-officer. The trial court denied the motion, and Defendant was subsequently convicted of burglary. The Supreme Court affirmed, holding that the district court did not err in denying Defendant’s motion to excuse the juror for cause. View "State v. Johnson" on Justia Law

Defendant pled guilty to one count of felony assault with a weapon. The district court sentenced Defendant to a ten-year term commitment to the Department of Corrections (DOC) with five years suspended. After Defendant’s probation officer filed a report of violation, a petition for revocation was filed in district court. Following a hearing, the district court sentenced Defendant to a five-year commitment to DOC with recommended placement at a prerelease facility. The Supreme Court affirmed, holding (1) the district court did not err when it denied Defendant’s motion to dismiss the petition for revocation; and (2) the district court did not violate Defendant’s due process rights by considering the criminal history information in the presentencing investigation report, nor did it abuse its discretion by requiring Defendant to serve the remainder of his original sentence. View "State v. Edmundson" on Justia Law