Justia Montana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of accountability for arson, a felony, and accountability for theft, a felony. The Supreme Court reversed, holding (1) defense counsel’s failure to offer a “mere presence” jury instruction constituted deficient performance under the first prong of Strickland v. Washington, counsel’s conduct fell below an “objective standard of reasonableness,” and Defendant was prejudiced by her counsel’s inadequate performance; and (2) the prosecutor committed misconduct by telling the jurors to base their decision on factors other than the law and evidence. Remanded for a new trial. View "State v. Chafee" on Justia Law

After a jury trial, Defendant was convicted of one count of misdemeanor assault. Defendant appealed, arguing that the justice court erred in admitting testimony regarding threats and an assault allegedly committed by Defendant prior to the charged assault, and the error entitled him to a new trial. The Supreme Court affirmed, holding that the justice court properly determined that the State met its discovery obligation to disclose to Defendant the witnesses it may call and the evidence it may introduce and did not abuse its discretion by allowing the evidence at trial. View "State v. Lamarr" on Justia Law

After a jury trial, Defendant was convicted of the offenses of felony DUI and criminal endangerment. Defendant appealed, arguing that the district court erred by denying his motion to suppress the results of a blood alcohol test taken pursuant to a search warrant because once he refused to cooperate in sobriety tests, Montana law prohibited law enforcement officers from taking any action to obtain a blood sample for testing. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress, holding that the law enforcement officers in this case acted in accordance with the principles of Montana law in obtaining a search warrant for Defendant’s blood. View "State v. Minett" on Justia Law

After a jury trial, Defendant was convicted of assault with a weapon, criminal endangerment, and tampering with or fabricating physical evidence. The district court sentenced Defendant to a total of thirty years in prison with five years suspended. The Supreme Court affirmed, holding (1) plain error review of Defendant’s contention that the failure to immediately assign him counsel violated his constitutional and statutory rights was not warranted here; (2) the district court did not err in refusing Defendant’s proposed jury instructions regarding factors affecting the reliability of eyewitness identification; (3) the district court erred by admitting evidence of condoms found in Defendant’s van, but the error was harmless; and (4) the district court did not abuse its discretion when it refused to declare a mistrial based on the court’s comments to a co-conspirator. View "State v. Zlahn" on Justia Law

Within thirty days of the Town of Eureka’s passage of an annexation ordinance Darrell Sharp filed a petition naming himself, his wife, and “John Does 1-200” as petitioners. After the thirty-day deadline for filing the petition had passed, Sharp filed an amended petition naming himself, his wife, eighty-nine other individuals, and “John Does 1-10” as petitioners. Eureka filed a motion to dismiss. The district court converted Eureka’s motion to dismiss to a motion for summary judgment and granted summary judgment for Eureka, concluding that Mont. Code Ann. 7-2-4741 does not allow relation back of amended pleadings. The Supreme Court affirmed, holding (1) the requirements of section 7-2-4741 do not contemplate relation back of an amendment adding the names of a majority of real property owners to the petition after the thirty-day deadline has passed; and (2) Eureka was entitled to judgment as a matter of law because the petition in this case was not filed within thirty days of the passage of the annexation ordinance by a majority of real property owners in the area to be annexed. View "Sharp v. Eureka" on Justia Law

Christine Deafenbaugh and Jeremy Anderson had one child together, G.J.A. After Anderson and Deafenbaugh separated, Anderson filed a petition for a parenting plan and child support. The district court referred the matter to a Standing Master, who issued a final decree establishing a final parenting plan that awarded primary custody to Deafenbaugh. The district court affirmed the Master’s findings of fact, conclusions of law, and decree and adopted the decree as the judgment of the court. The Supreme Court affirmed, holding that the district court (1) correctly applied a clear error standard of review to the Standing Master’s findings of fact; (2) did not err in adopting the Master’s findings of fact; and (3) did not err in determining that the parenting plan was in the best interests of G.J.A. View "In re Parenting of G.J.A." on Justia Law

Plaintiffs filed claims against the Montana Fish, Wildlife & Parks Commission (FWP) for violating their rights to know and participate under Sections 8 and 9, Article II, of the Montana Constitution by, among other things, failing to provide prior public notice and opportunity to participate in FWP’s decision to close certain areas to wolf hunting during a meeting. The district court issued a preliminary injunction prohibiting FWP from further enforcing its decision. Thereafter, the Legislature acted to ban these types of closures in the future, and the FWP ultimately allowed the wolf season to expire on its own. Subsequently, the court granted FWP’s motion to dismiss Plaintiffs' claims as moot. The court then awarded attorney’s fees and costs to Plaintiffs after determining that it had prevailed on its constitutional claims by obtaining the preliminary injunction. The Supreme Court affirmed the award of attorney’s fees and costs to Plaintiffs, holding that because Plaintiffs obtained the relief they sought to procure through litigation, they must be considered a “prevailing party” under the relevant statute. View "Citizens for Balanced Use v. Fish, Wildlife & Parks Comm’n" on Justia Law

Westmoreland Resources Inc. (WRI) mines coal owned by the Crow Tribe and pays coal severance and gross proceeds taxes to the Tribe. In 2005, WRI filed a tax return with the Department of Revenue for coal produced and sold at its Absaloka Mine, located on the Crow Reservation, during tax year 2004. The return deducted the coal severance and gross proceeds taxes it had paid to the Tribe. The Department disallowed WRI’s deduction. WRI filed a complaint with the State Tax Appeal Board. WRI and the Department later filed a joint petition for an interlocutory adjudication of a substantive question of law with the district court. At issue was whether WRI’s coal severance and gross proceeds deduction was proper. The district court held in favor of the Department, concluding that WRI may not deduct taxes paid to the Tribe as “taxes paid on production” from the “contract sales price” when calculating the Resource Indemnity Trust and Ground Water Assessment Tax. The Supreme Court affirmed, holding that the phrase “any tax paid to the federal, state, or local governments” within Mont. Code Ann. 15-35-102(11) does not include those taxes WRI pays to the Tribe. View "Westmoreland Res., Inc. v. Dep’t of Revenue" on Justia Law

Defendant entered pleas of nolo contendere to five offenses committed in 2007, including theft. On the theft offense, the district court sentenced Defendant to imprisonment for ten years, with five years suspended. After Defendant was released from prison, the State filed a petition to revoke Defendant’s suspended sentence on grounds that Defendant had violated the terms of his probation by possessing or using illegal drugs, failing to attend weekly AA/NA meetings, and failing to obtain a chemical dependency evaluation. After a revocation hearing, the district court revoked the theft sentence and sentenced Defendant to five years in prison. The Supreme Court affirmed, holding that the district court did not abuse its discretion in revoking Defendant’s sentence where the evidence established that Defendant used illegal drugs while on probation in violation of his sentencing conditions. View "State v. Carter" on Justia Law

Defendant was arrested for and convicted of obstructing a peace officer. Defendant appealed, and the district court conducted a trial de novo. During trial, Defendant moved to dismiss the charge for insufficient evidence. The district court denied the motion. A jury subsequently found Defendant guilty of obstructing a peace officer. Defendant appealed the denial of his motion to dismiss for insufficient evidence. The Supreme Court affirmed the district court’s order denying Defendant’s motion to dismiss, holding that Defendant engaged in conduct under circumstances that made Defendant aware that it was highly probable that his conduct would impede the performance of the officer’s lawful duties. View "State v. Eisenzimer" on Justia Law