Justia Montana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of one count of incest. On appeal, the Supreme Court affirmed, holding (1) Defendant was not entitled to a new trial due to law enforcement's warrantless monitoring and recording of his telephone conversations with his daughter, the victim, where (i) the recordings of Defendant's conversations with his daughter violated his rights under the Montana Constitution as interpreted by the Court in State v. Allen, but (ii) the admission of the recordings at trial was harmless error; and (2) the district court did not abuse its discretion in admitting sexually oriented photographs that Defendant took of his daughter. View "State v. Stewart" on Justia Law

Defendant was charged with DUI, fourth or subsequent offense. The information provided that Defendant was previously convicted of qualifying DUI offenses in 2009, 1999, and 1992. Defendant filed a motion to dismiss due to invalidity of prior DUI convictions, challenging his 1992 DUI conviction on the basis of constitutional infirmity. The district court denied Defendant's motion, concluding that Defendant failed to meet his burden to come forward with affirmative evidence establishing that his 1992 conviction was obtained in violation of the Constitution. Defendant subsequently entered a no contest plea to the DUI charge, reserving his right to appeal the denial of his motion. On appeal, the Supreme Court affirmed the district court's order denying Defendant's motion to dismiss, holding that the court correctly concluded that Defendant failed to meet his burden to persuade the court that his 1992 conviction was constitutionally infirm. View "State v. Nixon" on Justia Law

Defendant pled guilty to one count of sexual abuse of children pursuant to a plea agreement. The district court sentenced Defendant to the Department of Corrections (DOC) for seven years, with two years suspended upon several terms and conditions. The district court later revoked Defendant's suspended sentence after an evidentiary hearing at which it found Defendant in violation of the conditions of his sentence. The court then imposed a two-year commitment to the DOC and ordered that Defendant be designated a Level 3 sexual offender. The Supreme Court affirmed, holding that the district court did not err by elevating Defendant's sexual offender level designation from Level 1 to Level 3 upon revocation. View "State v. Claassen" on Justia Law

After a jury trial, Defendant was found guilty of incest and attempted incest involving his daughter, incest and sexual intercourse without consent involving his step-daughter, and sexual intercourse without consent involving his sister-in-law. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the district court did not abuse its discretion when it did not conduct a hearing on Defendant's posttrial allegation that some jurors slept through critical portions of the trial testimony; (2) Defendant was not subjected to double jeopardy when he was convicted of both incest and attempted incest, as the State charged and proved two separate and distinct transactions between Defendant and his daughter; and (3) the district court did not commit structural error when it failed to arraign Defendant on the amended charge of attempted sexual intercourse without consent. View "State v. Geren" on Justia Law

After a jury trial, Defendant was convicted of driving under the influence. Defendant appealed, arguing that the district court abused its discretion by partially denying his motion in limine to exclude video footage depicting administration of the Preliminary Alcohol Screening Test (PAST) administration without sound over Defendant's objection. The Supreme Court reversed, holding that the admission of the PAST evidence by video was prejudicial error, as (1) the video was impermissibly used as substantive evidence of Defendant's intoxication without the State satisfying the requirement of State v. Damon and Mont. R. Evid. 702 to call an expert to testify regarding the reliability and accuracy of the PAST; (2) the potential of unfair prejudice in admitting the evidence outweighed its probative value, as it prompted the inference that Defendant failed the PAST; and (3) the error was not harmless. View "State v. Lozon" on Justia Law

After an agent with the Tri-Agency Safe Trails Task Force purchased quantities of marijuana from Defendants in excess of what was legal under the Medical Marijuana Act, law enforcement arrested Defendants. Officers executed search warrants for Defendants' vehicles, their residence, and the garage Defendants frequented, retrieving four times the amount of marijuana Defendants were allowed to possess as caregivers and patients under the Act. Defendants were charged with several drug-related counts. Defendants filed a joint motion to suppress and dismiss, arguing that the state engaged in "outrageous government conduct" by obtaining evidence against them in violation of their federal due process rights. The district court granted the motion because the agent broke numerous laws under the banner of law enforcement. The Supreme Court reversed, holding that because the agent's conduct stopped short of violating the fundamental fairness shocking to the universal sense of justice mandated by the due process clause, the district court erred in dismissing Defendants' charges based on the outrageous government conduct defense. View "State v. Fitzpatrick" on Justia Law

After a jury trial, Defendant was convicted of attempted theft and sentenced to ten years imprisonment. Defendant appealed, arguing that the district court abused its discretion in finding a sufficient chain of custody for the admission of latent fingerprint evidence and forensic analysis. At issue was two fingerprint cards used to take the prints. In specific, in contention was discrepancies between dates written on the back of the cards and their storage in a law enforcement officer's patrol car and office. The Supreme Court affirmed, holding that because the State adequately established the chain of custody of the prints cards, the district court did not abuse its discretion by admitting the latent print evidence. View "State v. McCoy" on Justia Law

Plaintiffs in this case were individuals who were in committed same-sex relationships. Plaintiffs sued the State, contending that there was a statutory structure in Montana law that prohibited them from enjoying significant relationships and family protections and obligations provided to similarly-situated different-sex couples who marry. Plaintiffs expressly did not challenge Montana law's restriction of marriage to heterosexual couples and did not seek the opportunity to marry. Instead, Plaintiffs sought a declaration that the State's failure to provide them access to the statutory scheme available to different-sex couples denied them the rights guaranteed by Mont. Const. art II. The district court granted the State's motion to dismiss, noting that Plaintiffs did not seek the declaration of the unconstitutionality of a specific statute but rather a direction to the legislature to enact a statutory arrangement, which was unprecedented in Montana law. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the district court did not err in finding Plaintiffs' requested relief exceeded the bounds of a justiciable controversy; but (2) Plaintiffs should be afforded the opportunity to amend their complaint. View "Donaldson v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual intercourse without consent and one count of sexual assault. Defendant appealed. The Supreme Court affirmed, holding (1) under the circumstances presented here, the district court's application of Montana's rape shield statute did not violate Defendant's right to a fair trial under the Montana and United States Constitutions; and (2) the district court did not err in refusing to dismiss Counts I and IV on grounds that the State failed to prove venue, as the State showed that the only rational conclusion to be drawn from the facts and testimony was that the crime was committed in the county alleged. View "State v. Patterson" on Justia Law

Defendant pled guilty to the felony offense of criminal possession with intent to distribute. The district court sentenced him to a three-year deferred imposition of sentence. Defendant appealed his conviction and sentence, contending that the district court erred in denying his motion to suppress and dismiss because a drug task force agent did not have probable cause to believe a crime was occurring in his residence, and thus there was no basis for the agent to contact Defendant and request to search his residence. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to suppress and dismiss, as (1) the information Defendant's neighbor provided to law enforcement officers was reliable; and (2) the court's findings regarding Defendant's consent to the initial search of his home and the court's findings regarding the validity of the search warrant were supported by substantial credible evidence and were not clearly erroneous. View "State v. Deshaw" on Justia Law