Justia Montana Supreme Court Opinion Summaries

An eighteen-year-old defendant attended a post-high school graduation event at the Sweet Grass County fairgrounds, where alcohol and drug use were prohibited. A chaperone reported to the Sweet Grass County Sheriff’s Office that the defendant appeared intoxicated. Deputy Whaley arrived later, conducted alcohol tests on attendees, and observed the defendant and another individual walking towards a vehicle. The deputy, familiar with the defendant’s prior offenses and court-ordered conditions, approached and requested consent to search the vehicle, which the defendant refused. Using a flashlight, the deputy saw a marijuana smoking device in plain view inside the vehicle. The vehicle was seized, and a search warrant was obtained, leading to the discovery of marijuana, paraphernalia, and alcoholic beverages. The defendant was charged with two counts of underage possession of an intoxicating substance (UPIS), one for alcohol and one for marijuana.The defendant pled guilty in justice court and was sentenced for UPIS (3rd and 4th offenses), with sentences running concurrently. He appealed to the District Court, filing motions to suppress evidence for lack of particularized suspicion and to dismiss one count for double jeopardy. The District Court denied both motions, ruling that the plain view doctrine justified the seizure of the vehicle and that the two charges did not violate the multiple conviction statute.The Supreme Court of the State of Montana reviewed the case. It held that Deputy Whaley’s initial approach did not constitute a seizure requiring particularized suspicion and that the use of a flashlight to view the marijuana device did not violate the plain view doctrine. The court also held that the two charges for possession of different intoxicating substances did not violate the multiple conviction statute. The court affirmed the District Court’s rulings. View "State v. Roberts" on Justia Law

Donna Elizabeth Summers was stopped by Ravalli County Detective Nick Monaco for speeding in May 2022. During the stop, Summers appeared nervous, and Monaco discovered she had a history of drug possession. After issuing a warning for speeding and returning her documents, Monaco asked if he could ask additional questions, to which Summers consented. She admitted to past drug use and allowed Monaco to search her vehicle, where he found methamphetamine and paraphernalia. Summers was charged with felony possession of dangerous drugs and misdemeanor possession of drug paraphernalia. She filed a motion to suppress the evidence, arguing the stop was unlawfully prolonged without particularized suspicion.The Twenty-First Judicial District Court denied Summers’s motion to suppress, finding that Monaco had particularized suspicion to extend the stop and that Summers consented to the additional questioning and search. Summers then pleaded no contest to the charges but reserved the right to appeal the suppression ruling.The Supreme Court of the State of Montana reviewed the case and concluded that Detective Monaco lacked particularized suspicion to transition the traffic stop into a drug investigation. However, the court held that under the totality of the circumstances, Summers’s constitutional rights were not violated because she voluntarily consented to the additional questioning and search. The court affirmed the District Court’s denial of Summers’s motion to suppress evidence. View "State v. D. Summers" on Justia Law

On July 17, 2021, Whitefish Police Officer Chase Garner confronted Paul Kermit Gysler for urinating in public. The encounter escalated, resulting in Gysler assaulting Officer Garner. Gysler claimed self-defense, asserting that Officer Garner approached him aggressively. The State charged Gysler with felony assault on a peace officer. Gysler was arrested and released on bond but was later re-arrested for unrelated charges, leading to multiple delays in his trial.The Eleventh Judicial District Court issued an arrest warrant for Gysler for violating his release conditions. The court ordered a competency evaluation due to concerns about Gysler's mental fitness, which delayed the trial further. Gysler's trial was eventually set for December 12, 2022. He filed a motion to dismiss for lack of a speedy trial, which the court denied. The jury found Gysler guilty of assaulting a peace officer.The Supreme Court of the State of Montana reviewed the case. The court analyzed the four factors of a speedy trial claim: length of delay, reasons for delay, the accused’s response to the delay, and prejudice to the accused. The court found that most of the delay was institutional and not due to the State's negligence. The court concluded that Gysler did not suffer oppressive pretrial incarceration, undue anxiety, or impairment of his defense.The court also reviewed the jury instructions. It held that the District Court did not err in instructing the jury on resisting arrest and justified use of force, as the instructions were supported by the evidence and did not nullify Gysler's self-defense claim. The court affirmed the District Court's judgment, finding no violation of Gysler's right to a speedy trial and no error in the jury instructions. View "State v. Gysler" on Justia Law

Joseph Edward Knowles, at age 16, and his girlfriend planned to steal marijuana from Megan Meriwether. During the theft, a fight ensued, and Knowles stabbed Meriwether, resulting in her death. Knowles was charged as an adult with deliberate homicide and tampering with evidence. He pled guilty to deliberate homicide under a plea agreement, and the tampering charge was dismissed. The District Court sentenced him to 60 years in prison without parole restrictions.Knowles appealed the original judgment, which did not reflect his status as a criminally convicted youth under the Criminally Convicted Youth Act (CCYA). The Montana Supreme Court ordered the District Court to amend the judgment to include CCYA provisions, requiring the Department of Corrections (DOC) to submit status reports every six months and for the court to review Knowles’s sentence before he turned 21. However, the District Court did not receive this order until Knowles was 22, and no status reports were filed during the statutory period.The Montana Supreme Court reviewed whether the District Court abused its discretion by reimposing Knowles’s original sentence without the benefits of the CCYA. The Court found that the District Court and DOC failed to follow the CCYA, denying Knowles the rehabilitative opportunities intended by the Act. The Court held that the District Court abused its discretion by determining Knowles had not been substantially rehabilitated without the benefit of ongoing status reports and meaningful rehabilitative programs.The Montana Supreme Court reversed the District Court’s decision and remanded the case, instructing the DOC and District Court to apply the CCYA provisions. Knowles is allowed to request a CCYA sentence review hearing within two years of the opinion date. View "State v. Knowles" on Justia Law

In July 2022, Robert Brady was charged with felony Assault with a Weapon after an incident involving his wife, stepdaughter, and stepdaughter's husband. Brady allegedly pointed a shotgun at his stepdaughter's husband and threatened to kill him. Brady appeared intoxicated and claimed self-defense. He was released on the condition of no contact with the victims. In August 2022, Brady pleaded not guilty, and the case proceeded to trial. In December 2022, the State petitioned to revoke Brady's release for noncompliance with alcohol monitoring conditions, and he was jailed in January 2023.Brady and the State then signed a plea agreement where Brady would plead guilty in exchange for a three-year deferred sentence recommendation. The agreement restricted Brady from seeking early discharge until two years after sentencing. At the change of plea hearing, Brady pleaded guilty, and the court accepted the plea. However, the court later expressed concerns about following the plea agreement due to Brady's violations and lack of accountability. The prosecutor's comments during sentencing suggested the plea deal was too lenient, leading the court to impose a five-year deferred sentence with additional conditions.The Montana Supreme Court reviewed the case and found that the prosecutor breached the plea agreement by undermining the recommended sentence. The court held that a district court does not have unilateral authority to restrict a defendant's right to seek early termination of a sentence under Montana law. However, a defendant may agree to such a restriction in a plea agreement. The court vacated Brady's sentence and remanded for resentencing before a different judge, directing specific performance of the plea agreement in its entirety. View "State v. Brady" on Justia Law

In September 2021, the Montana Department of Public Health and Human Services removed J.T.L. and D.L.L. from their parents' care due to drug use and poor home conditions. This was the fourth removal for J.T.L. and the third for D.L.L. The children were enrolled in the Little Shell Tribe of Chippewa Indians in February 2022, and the Department notified the Tribe of the proceedings. The District Court adjudicated the children as youths in need of care in July 2022 and granted the Department temporary legal custody. In August 2022, the court ordered the mother to complete a treatment plan addressing substance use, mental health, parenting, and housing issues. The Department sought termination of her parental rights in October 2023 due to her failure to complete the treatment plan.The Montana Eighth Judicial District Court held a two-day hearing in July 2024 and terminated the mother's parental rights. The mother appealed, arguing that the Department did not make "active efforts" under the Indian Child Welfare Act (ICWA) and that guardianship, not termination, was in the children's best interests. The District Court found that the Department made active efforts to place the children with ICWA-preferred placements and to support their cultural connections. The court also found that the mother failed to comply with her treatment plan and that her condition was unlikely to change within a reasonable time.The Montana Supreme Court reviewed the case and affirmed the District Court's decision. The court held that the Department made active efforts under ICWA and that the termination of parental rights was in the children's best interests. The court found that the Department consulted with the Little Shell Tribe and sought input from various parties to support the children's cultural engagement. The court also found that the mother failed to complete her treatment plan and that her continued custody would likely result in serious emotional or physical damage to the children. View "Matter of D.L.L. & J.T.L." on Justia Law

William James Pillans was arrested on February 12, 2018, and charged with Assault with a Weapon. He was released on his own recognizance but was later re-arrested for violating release terms. Subsequently, he faced additional charges for assaulting an officer and threatening corrections officers, leading to multiple arrests and bench warrants. Pillans entered plea agreements in three cases, resulting in concurrent suspended sentences. However, his sentences were revoked multiple times due to further arrests and violations, leading to additional periods of incarceration.The Eleventh Judicial District Court of Flathead County initially sentenced Pillans to concurrent five-year suspended sentences in three cases. After multiple revocations, the court recalculated his credit for time served and elapsed time, ultimately sentencing him to five years with the Department of Corrections with no time suspended. Pillans appealed the District Court's calculation of his credit for time served and elapsed time.The Supreme Court of the State of Montana reviewed the case. The court held that Pillans was not entitled to credit for time served in DC-18-098 between his third arrest and his third release on recognizance, as he was not detained in that case during that period. The court also found that the District Court erred in calculating credit for time served in DC-18-329, as Pillans was not detained in that case until served with a bench warrant. Additionally, the court corrected the calculation of time served between Pillans's original sentencing and first revocation, and between his first and second revocations. The court also determined that Pillans was entitled to additional elapsed time credit for specific periods where no violations were recorded.The Supreme Court reversed and remanded the case to the District Court to adjust Pillans's credit for time served and elapsed time accordingly. View "State v. Pillans" on Justia Law

Charles Ament was charged with felony DUI, his fourth or subsequent offense, after a single-vehicle crash in Flathead County. Montana Highway Patrol Trooper Jon Raymond testified that Ament smelled of alcohol, had difficulty balancing, made strange statements, admitted to drinking three beers, and asked not to be investigated for DUI. Field sobriety tests indicated Ament was under the influence, and a blood draw showed a 0.187 blood alcohol content. Ament represented himself at trial with standby counsel and did not testify or offer any witnesses.The District Court of the Eleventh Judicial District allowed Ament one day to enter a plea, after which he pleaded not guilty. At a pretrial hearing, the court granted Ament’s motion to represent himself, advising that standby counsel could not interrupt proceedings to issue advice. During trial, Ament objected to Trooper Raymond’s testimony as leading, which the judge overruled. During closing arguments, Ament attempted to discuss his version of the facts, leading the court to instruct the jury to disregard statements not made under oath.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s judgment. The court held that the District Court did not abuse its discretion in allowing Ament one day to enter his plea. The court also found that Ament did not preserve his objections to Trooper Raymond’s testimony and thus applied plain error review, concluding that Ament did not demonstrate that the admission of this evidence denied him a fundamental right. Regarding the District Court’s comments during closing arguments, the Supreme Court held that the comments did not compromise the fundamental fairness of the trial or the integrity of the judicial process. Finally, the court found that the jury instructions on the presumption of innocence were proper and did not warrant reversal for plain error. View "State v. Ament" on Justia Law

M.H.W. has been involuntarily committed to the Montana Mental Health Nursing Care Center (NCC) since June 16, 2020, due to paranoid schizophrenia and an inability to manage his diabetes. The Tenth Judicial District Court extended his commitment several times, with the most recent extension being on January 6, 2022. On December 14, 2022, a petition was filed to extend his commitment for another year. Notice was served, indicating that if a hearing was requested less than 10 days before the termination of the previous commitment, the commitment would be extended until the hearing. However, the court did not issue an order extending the commitment beyond January 6, 2023.On February 8, 2023, M.H.W.'s counsel requested a contested hearing, which was scheduled for April 6, 2023, and later rescheduled to June 1, 2023. The District Court ordered that M.H.W. remain committed until the hearing. At the hearing, the court found that M.H.W. continued to exhibit symptoms of schizophrenia and could not manage his basic needs, including his diabetes. The court ordered his recommitment to NCC for up to one year.The Montana Supreme Court reviewed the case. The court held that the expiration of M.H.W.'s commitment did not deprive the District Court of jurisdiction, as the commitment was extended by operation of law when no hearing was requested before January 6, 2023. The court also held that the District Court's failure to enter an order extending the commitment did not constitute plain error, as M.H.W. received due process through the contested hearing. The Supreme Court affirmed the District Court's order of recommitment. View "In re M.H.W." on Justia Law

In 2014, Susan Joanne Pajnich was driving with a .280 blood alcohol content and hit a woman who was stopped on the side of the road, causing severe injuries. Pajnich left the scene without providing aid. She pleaded guilty to negligent vehicular assault and received a ten-year sentence with seven years suspended, along with an order to pay restitution.In December 2017, Pajnich began the suspended portion of her sentence. Less than a year later, the State petitioned to revoke her suspended sentence due to violations, including driving under the influence, consuming alcohol, and failing to pay restitution. Pajnich entered a plea agreement admitting to the violations in exchange for the State dropping the DUI charge. The agreement included a recommendation for a seven-year commitment with five years suspended and 111 days of credit for elapsed time. The District Court revoked her suspended sentence and imposed the agreed-upon sentence.Pajnich completed the non-suspended portion of her sentence and returned to community supervision in June 2020. In March 2022, a report of violation was filed alleging further violations, including consuming alcohol and methamphetamine, and failing to make restitution payments. Pajnich admitted to all violations, and the District Court imposed a five-year commitment with credit for ten months of elapsed time and time served. Pajnich appealed this order.The Supreme Court of the State of Montana reviewed the case and held that Pajnich could not challenge the calculation of elapsed time on appeal because she did not object to it during the revocation proceedings and there was no mistake of fact. The court affirmed the District Court's decision, concluding that the sentence was legal and the calculation of elapsed time was supported by the record. View "State v. Pajnich" on Justia Law