Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the order of the youth court denying Appellant's motion to dismiss the State's petition to revoke his probation, holding that the youth court erred when it revoked Appellant's probation under a consent decree without Appellant's youth court petition having been reinstated.The youth court relied on the findings from its order to grant two dispositional orders that (1) granted the State's petition to revoke Appellant's probation and imposed a suspended sentence to the Montana Department of Corrections for placement in a secure juvenile facility, and (2) granted the State's second petition to revoke Appellant's probation and committed Appellant to Pine Hills Youth Correctional Facility. The Supreme Court reversed, thus vacating the youth court's two dispositional orders, holding that because the State failed to reinstate Appellant's original youth court petition, the youth court failed to follow the appropriate statutory procedure for a violation of a consent decree. View "In re C.L." on Justia Law

The Supreme Court affirmed the jury verdict and dispositional order finding J.W. guilty of the offense of sexual intercourse without consent - a felony if committed by an adult, adjudicating J.W. a delinquent youth, and designating J.W. a serious juvenile offender, holding that there was no error or abuse of discretion.Specifically, the Supreme Court held (1) the Youth Court did not abuse its discretion when it refused to instruct the jury to consider youth characteristics in determining J.W.'s guilt; (2) the Youth Court did not abuse its discretion when it refused to instruct the jury on the legal age of consent; and (3) there was sufficient evidence to convict J.W. of the offense of sexual intercourse without consent. View "In re J.W." on Justia Law

The Supreme Court reversed the judgment of the district court revoking the suspended portion of Appellant's sentence, holding that the district court did not err in denying Appellant's motion to dismiss for lack of subject matter jurisdiction.When Appellant was sixteen, the youth court found Appellant to be a delinquent youth, and Appellant received a juvenile disposition consisting of both a juvenile sentence and an adult sentence. After Appellant admitted to violations of the conditions of his sentence the judge implemented the adult sentence in modified form. The State later filed a second petition to revoke, and the judge revoked Appellant's deferred adult sentences and sentenced him to a term of incarceration. When Appellant was twenty-seven years old the State filed a third petition to revoke. Appellant filed a motion to dismiss, arguing that the youth court's jurisdiction over him ended when he reached the age of twenty-five and that the judge had not transferred the case to the district court. The judge denied the motion. The Supreme Court reversed, holding (1) the youth court lost jurisdiction over Appellant when he reached his twenty-fifth birthday and the case was not transferred to a district court; and (2) the lower court lacked jurisdiction and imposed an illegal sentence. View "In re S.G.-H.M. Jr." on Justia Law

Seventeen-year-old Defendant was charged with two counts of sexual intercourse without consent. Defendant filed two motions to transfer each charge to Youth Court. The district court denied both transfer motions. Defendant ultimately pleaded guilty to one count of sexual intercourse without consent. Defendant was sentenced to fifty years in prison, with ten years suspended. The Supreme Court (1) affirmed the district court’s refusal to transfer the charges to Youth Court, holding that the district court did not err in denying the transfer motions; and (2) remanded for entry of an amended judgment and review of the sentence as provided by law, holding that the district court erred by not including the requirements found in Mont. Code Ann. 41-5-2503(1) in Defendant’s sentence. View "State v. Talksabout" on Justia Law

The State charged twelve-year-old K.J.R. with seven felony and misdemeanor offenses. The district youth court subsequently adjudicated K.J.R. to be a delinquent youth. The youth court committed K.J.R. to the supervision of the youth court until age eighteen, or sooner released, for placement at a specific therapeutic group home. Over the next three years, the juvenile probation officer moved K.J.R. in and out of a sequence of juvenile facilities and foster care homes. When K.J.R. was fifteen years old, the State filed a petition to revoke his youth court probation. After a dispositional hearing, the youth court revoked K.J.R.’s original commitment to the youth court and committed K.J.R. to the supervision of the Montana Department of Corrections (DOC) at a state youth correctional facility until age eighteen or sooner released. The Supreme Court affirmed, holding (1) the court did not err when it revoked K.J.R.’s original youth court commitment and recommitted him to DOC for placement at a state youth correction facility; and (2) K.J.R.’s claim that he received ineffective assistance of counsel during the delinquency proceedings was without merit. View "State v. K.J.R." on Justia Law

J.W. was designated a delinquent youth and serious juvenile offender and placed on probation, subject to several conditions. On June 30, 2014, the Youth Court issued a disposition order revoking J.W.’s probation, committing him to placement within a Montana Department of Corrections (DOC) facility, and requiring him to complete certain phases of the facility’s juvenile SOTP. The State filed a motion to revoke the disposition order and transfer J.W.’s case to the District Court pursuant to Mont. Code Ann. 41-5-208. The Youth Court granted the motion. The Youth Court and District Court imposed house arrest with restrictive conditions on J.W. pending a final disposition of his case. The Supreme Court affirmed, holding (1) the Youth Court did not err in granting the State’s motion to transfer; and (2) the lower courts did not err in imposing house arrest with restrictive conditions on J.W. View "In re J.W." on Justia Law

A.D.T. was adjudicated as a delinquent youth and juvenile offender. A.D.T. was later transferred to district court pursuant to Mont. Code Ann. 41-5-208 for supervision by the Department of Corrections when he reached his eighteenth birthday. Thereafter, the district court imposed forty-one new conditions to A.D.T.’s probation and supervision. The State subsequently filed a petition to revoke A.D.T.’s probation. A.D.T. moved to dismiss the State’s revocation petition, arguing that imposition of the forty-one conditions violated section 41-5-208(4) and exceeded the scope of the youth court’s disposition and transfer order. The district court denied the motion to dismiss, found that A.D.T. had violated terms of his probation, and placed him on formal probation with Adult Probation and Parole. The Supreme Court affirmed, holding that the district court (1) erred in denying A.D.T.’s motion to dismiss the petition regarding those conditions which were not originally set forth in the youth court’s disposition or transfer order; but (2) correctly determined that there were conditions of the underlying youth court disposition that were violated and thus did not err in imposing conditions pursuant to Mont. Code Ann. 46-18-201 through -203. View "In re A.D.T." on Justia Law

When E.G. was fifteen years old, the Youth Court found him to be delinquent and ordered that he be committed to the Department of Corrections until age eighteen. After remand, the Youth Court stated that it would retain jurisdiction until E.G. was twenty-one and consider transfer of the case to the district court. When E.G. turned eighteen, the Youth Court, after a hearing, transferred supervision of E.G. to the district court. E.G. subsequently violated his probation, and the district court sentenced him to the Department of Corrections until age twenty-five. E.G. appealed, arguing that the district court lacked jurisdiction to revoke his probation and sentence because his parents did not receive notice of the hearing on the State’s motion to transfer supervision of his probation from the Youth Court to the District Court. The Supreme Court affirmed, holding that the statutory parental notice requirement did not withdraw, circumscribe, limit or affect the Youth Court’s jurisdiction over the issue of transferring supervision of E.G. to the District Court. View "In re E.G." on Justia Law

The Youth Court declared A.S.M. a delinquent youth and serious juvenile offender. The Youth Court later issued an order under Mont. Code Ann. 41-5-208 ("section 208 order") transferring jurisdiction over A.S.M. to the district court and transferring supervisory responsibility of A.S.M. to the Department of Corrections (DOC). Pursuant to the order, A.S.M. was transferred to to Montana State Prison (MSP) on his eighteenth birthday and was not eligible for parole until he completed MSP’s sexual offender program. A.S.M. filed a motion to modify the order, requesting that the DOC send him to Whitney Academy in Massachusetts. The district court partially modified the section 208 order to remove the parole eligibility requirement but refused further to modify the order, thus keeping A.S.M. in the adult corrections system. A.S.M. appealed, requesting that the district court modify its order to facilitate his placement at the Academy by suspending his sentence and terminating supervision by the DOC. The Supreme Court affirmed, holding that the district court did not err by refusing to further modify the section 208 order.View "In re A.S.M." 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