Justia Montana Supreme Court Opinion Summaries

Robert Lee Colton Dietsch appealed his conviction for sexual assault of a twelve-year-old girl. Dietsch was seventeen at the time of the alleged assault. The State charged Dietsch as an adult. Dietsch moved to transfer prosecution from the district court to the youth court. The district court denied the motion. Dietsch later entered into a plea agreement whereby he agreed to plead guilt to one count of sexual assault in exchange for the State's agreement to drop a sexual consent without consent charge. Ultimately Dietsch received a deferred sentence of six years and sixty days. On appeal to the Supreme Court, Dietsch argued the district court abused its discretion in refusing to transfer his case to the youth court. The Supreme Court concluded sufficient evidence supported the district court's decision. However, the Court concluded the district court erred in its imposition of certain conditions on Dietsch, including setting an indeterminate amount for restitution, and failing to retain jurisdiction over the case until Dietsch reached age 21. Accordingly, the Court remanded the case for further proceedings. View "Montana v. Dietsch" on Justia Law

K.E.G., a fifteen-year-old male, admitted to committing acts of vandalism on two consecutive nights. The county attorney then filed a petition alleging that K.E.G. was a delinquent youth for having committed criminal mischief. Other youths involved in the vandalism were similarly charged. K.E.G. admitted to the allegations. At issue before the youth court was whether the State should hold K.E.G. jointly and severally liable for all damages caused by the vandalism, given that K.E.G. participated in only two of the eleven nights of vandalism. The youth court adjudicated K.E.G. a delinquent youth and ordered him to pay $78,702 in restitution, concluding that K.E.G. was jointly and severally liable for the full amount of restitution for damages caused by the youths. The Supreme Court reversed, holding that the youth court's failure to fully consider K.E.G.'s ability to pay prior to imposing aggregate restitution constituted plain error. Remanded for a new restitution hearing. View "In re K.E.G." on Justia Law

After a jury trial, the youth court found that E.M.R., a youth under the age of eighteen, had committed five misdemeanor offenses of "dog at large" and one felony offense of aggravated animal cruelty. The convictions stemmed from E.M.R.'s treatment of her dogs and horses. E.M.R. appealed. The Supreme Court affirmed in part, reversed in part and remanded, holding (1) the youth court's instruction to the jury on the legislative purpose of the Youth Court Act was prejudicial error and required reversal of the aggravated animal cruelty adjudication; and (2) the youth court correctly declined to dismiss the "dog at large" charges.View "State v. E.M.R." on Justia Law

After a youth violated the terms of his initial probation agreement, the judicial district youth court revoked that agreement and entered a dispositional order that extended the youth's probationary period for an additional three years. The youth appealed. The Supreme Court affirmed, holding (1) the youth court did not exceed its statutory authority and correctly and interpreted and applied the Youth Court Act by imposing on revocation an additional three-year probationary term that lasted until the youth's twenty-first birthday; and (2) the imposition of an additional three-year term of probation did not violate the youth's constitutional right to equal protection of the laws. View "In re S.M.K." on Justia Law

This matter involved two cases, one involving two youths who appeared in youth court for detention hearings and one involving an adult who pled guilty to driving under the influence in justice court. After appearing in district court, the youths filed motions to substitute district court judge, and the court denied the motions as untimely. After the adult pled guilty in justice court, she appealed only the justice court's denial of her pretrial suppression motion, which the district court denied as untimely. The Supreme Court granted a petition for writ of supervisory control for the youths and denied it for the adult, holding (1) the district court improperly determined that the youths had filed untimely motions for substitution of district judge; and (2) the district court correctly denied the adult's motion for substitution of district court judge, as no right exists under Mont. Code Ann. 3-1-804 to substitute a district judge in an appeal of a specific pre-trial legal ruling from justice court. View "Bledsoe v. Dist. Court" on Justia Law

At issue in these two consolidated appeals was whether the district court properly calculated the time period in which to file a motion for substitution of district judge in youth court and on an appeal from justice court. Petitioners, two youths who appeared in court or detention hearings and a defendant who pled guilty in justice court to driving under the influence, petitioned for writ of supervisory control, claiming that the district court incorrectly denied as untimely their motions for substitution of district court judge in those cases. The Supreme Court reversed in part and affirmed in part, holding (1) the district court improperly determined that the youths had filed untimely motions for substitution of district judge; and (2) the district court properly calculated the time period in which to file a motion for substitution of district court on the appeal from justice court. View "Bledsoe v. Judicial Dist. Court" on Justia Law

M.W., a juvenile who admitted that he committed sexual assault, was adjudged as delinquent and placed on probation until the age of eighteen, subject to numerous conditions. After M.W. was unsuccessfully discharged from sexual offender treatment, the youth court required him to register as a sexual offender. The case was subsequently transferred to the district court, which later denied M.W.'s petition to be relieved of the registration requirement. The Supreme Court affirmed, holding that the district court correctly analyzed the issue by concluding that it did not have the statutory authority, at the present time, to relieve M.W. from the registration requirement. View "In re M.W." on Justia Law

T.M.L. was seventeen when he pled guilty to felony burglary and misdemeanor criminal trespass to vehicles. The youth court entered a dispositional order providing that T.M.L. be placed on probation until he reached age eighteen, after which supervision was to be transferred to the district court and adult probation and parole department. After T.M.L. turned eighteen, the youth court transferred T.M.L.'s matter to district court and transferred T.M.L.'s supervision to adult supervision under the department of corrections. The Supreme Court (1) affirmed the youth court's denial of T.M.L.'s motion to dismiss where the youth court had jurisdiction over T.M.L.; and (2) remanded the matter for the limited purpose of striking the condition that T.M.L. register as a sexual offender as a condition of T.M.L.'s sentence, as the youth court did not have the power to require T.M.L. to register as a sexual offender. View "In re T.M.L." on Justia Law

Defendant Sebastian Olivares-Coster pled guilty to deliberate homicide and attempted deliberate homicide and was sentenced to three life sentences. The district court did not orally impose any parole restrictions but presumed that Defendant would be eligible for parole after sixty years of incarceration. On appeal, the Supreme Court reversed the judgment and commitment of the district court to the extent it provided that Defendant would be eligible for parole after sixty years, holding that because Defendant was a juvenile at the time he committed the offenses, the sixty-year restriction on Defendant's parole eligibility pursuant to Mont. Code Ann. 46-23-201(4) was expressly prohibited by Mont. Code Ann. 46-18-222(1), which provides that restrictions on parole eligibility do not apply if the offender was less than eighteen years old at the time of the commission of the offense.

J.A. was charged with burglary by common scheme and theft by common scheme when he was 17-years-old and placed on probation until February 2009 by the Youth Court. In December 2008, the State filed a petition to revoke probation and transfer supervision of J.A. to district court. The Youth Court issued a summons and, when J.A. did not appear, the court issued a warrant for his arrest. J.A. was not picked up on the warrant until May 2010, when he was 21-years-old. J.A. appealed the order entered by the Youth Court denying his motion for release from custody due to lack of jurisdiction. The court held that the Youth Court Act, section 46-18-203(2), MCA, did not provide for continuing jurisdiction in youth court over revocation proceedings after youth turned 21, even where a petition to transfer had previously been filed and therefore, the court held that it could not extend the Youth Court's jurisdiction beyond what the Legislature had clearly provided. Accordingly, the court held that the Youth Court erred in denying J.A.'s motion and reversed the Youth Court's order, remanding for further proceedings.