Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court denying Defendant's motion for a new trial on the offense of partner or family members assault (PFMA), third or subsequent offense, holding that the district court committed reversible error.The State charged Defendant with third or subsequent offense PFMA based on incriminating audio-video camera footage capturing Defendant's belligerent verbal and physical interaction with his teenage son and subsequent incriminating statements made in a post-arrest interrogation interview conducted by a sheriff's deputy. After he was convicted, Defendant filed a motion for a new trial on the ground that the court erroneously allowed the video playbacks to the jury without notice to the parties. The district court denied the motion. The Supreme Court reversed, holding that the district court erred in denying Defendant's motion for a new trial based on a violation of Mont. Code Ann. 46-16-503(2) and the related common law rule limiting the rehearing or replay of testimonial evidence during jury deliberations. View "State v. Hoover" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of sexual assault, holding that the district court did not err or abuse its discretion.After a jury trial, Defendant was convicted of sexually assaulting his minor stepdaughters. On appeal, Defendant argued that the district court deprived him of his right to present a complete defense and requested either dismissal of his case or a new trial. The Supreme Court affirmed, holding that the district court (1) did not err when it ruled that the State did not deliberately destroy potentially exculpatory evidence; (2) did not err when it prevented Defendant from presenting evidence to the jury relating to the State's alleged destruction of evidence; and (3) did not abuse its discretion when it limited the scope of testimony by Defendant's expert witness. View "State v. Villanueva" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Defendant's motion to suppress illegal drug evidence seized as a result of a protective pat-down search for weapons and in a subsequent search of his vehicle, holding that the district court erred in concluding that the protective pat-down search of Defendant was justified.Specifically, the Supreme Court held (1) the district court erroneously held that the pat-down search of Defendant was justified under Terry v. Ohio, 392 U.S. 1 (1968) and Mont. Code Ann. 46-5-401(2)(b), whether incident to a valid Terry investigative stop or analogous community caretaker doctrine stop, but did not err in concluding that the exclusionary rule did not apply to the illegal drug evidence seized in the warrantless pat-down and vehicle searches at issue; and (2) therefore, the district court erred in denying Defendant's motion to suppress evidence found in his coat pocket as a result of the initial pat-down search but correctly denied Defendant's motion to suppress evidence found in the subsequent consent search of his vehicle. View "State v. Laster" on Justia Law

The Supreme Court affirmed the order of the district court convicting Defendant of sexual intercourse without consent, holding that the district court did not abuse its discretion by permitting admission of evidence regarding other acts and statements made by Defendant.Defendant filed a motion in liming to preclude the admission of evidence involving the occurrence of any other sexual acts or statements regarding the victim. The district court denied the motion, concluding that evidence of Defendant's sexual conduct with the victim, apart from the conduct alleged in the information, was relevant and admissible. The Supreme Court affirmed, holding that the district court did not abuse its discretion in admitting the evidence. View "State v. Murphy" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to suppress based on its determination that Defendant had not been seized, holding that the district court clearly erred when it concluded that Defendant was not seized.Defendant was found guilty of felony possession with intent to distribute. The district court order denying Defendant's motion to suppress concluded that Defendant voluntarily engaged with the law enforcement officer and was not seized because a reasonable person would have felt free to disengage and leave. Further, the order concluded that Defendant validly consented to the officer searching his vehicle. The Supreme Court reversed, holding (1) Defendant was seized in this case; and (2) the officer did not have particularized suspicion to justify the seizure. View "State v. Pham" on Justia Law

The Supreme Court affirmed the order of the district court denying the Ekalaka Volunteer Fire Department, Inc.'s (Department) motion for summary judgment, holding that the district court did not err in finding that the Town of Ekalaka's fire department was municipally owned as a matter of law.The Department claimed it had always been a private fire company that existed as an unincorporated association until 2016, when it filed its incorporation paperwork following the town attorney's advice. The Town, in response, filed for a declaratory judgment that the Department was municipally owned. The district court granted summary judgment for the Town. The Supreme Court affirmed, holding that the evidence overwhelmingly weighed toward declaratory judgment affirming the duly established municipal department. View "Ekalaka v. Ekalaka Volunteer Fire Department, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony criminal endangerment, misdemeanor stalking, and felony stalking, holding that the district court did not err.The first trial in this case resulted in a hung jury. A year later, a second trial was held, and Defendant was convicted. At issue on appeal was whether the admission of a railroad tie at the second trial was proper because it was not in the same condition as the first trial. The Supreme Court affirmed, holding that the district court (1) did not err by not dismissing the stalking charges for insufficient evidence; and (2) did not err by admitting the railroad tie into evidence at the second trial after it had been exposed to the elements following the first trial and its condition deteriorated. View "State v. Hren" on Justia Law

The Supreme Court reversed the judgment of the district court involuntarily committing Respondent to the Montana State Hospital, holding that the waiver of Respondent's presence at the initial hearing on the State's petition was invalid.The Flathead County Attorney filed a petition for involuntary commitment, and the district court convened an initial appearance. Respondent, who suffered from vascular dementia and was hard of hearing, was not present in court, and his counsel asked to waive his presence at the initial hearing. The district court agreed to waive the initial appearance. After a hearing, the court found that Respondent suffered from a mental disorder and required commitment. The Supreme Court reversed, holding (1) the district court did not meet the statutory standards when it accepted counsel's waiver of Respondent's presence; and (2) the error prejudiced Respondent's substantial rights and compromised the integrity of the judicial process required in commitment proceedings. View "In re F.S." on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony assault on a peace officer, holding that the district court did not abuse its discretion when it decided not to instruct the jury on the defense of justifiable use of force.On appeal, Defendant challenged the district court judge's determination that there was not sufficient evidence to warrant justifiable use of force instructions. The Supreme Court affirmed, holding (1) the evidence presented did not demonstrate unlawful force by the officer that would justify self-defense; and (2) therefore, the denial of Defendant's proposed justified use of force instructions was not an abuse of discretion. View "State v. Marquez" on Justia Law

The Supreme Court affirmed the order issued by the district court concerning the conservatorship and estate planning efforts of Appellant's elderly mother, H.D.K., holding that the district court did not err or abuse its discretion.Specifically, the Supreme Court held that the district court (1) did not abuse its discretion when it declined to issue a scheduling order; (2) did not abuse its discretion in declining to quash a subpoena for the file of H.D.K.'s attorney; (3) did not abuse its discretion when it concluded the conservatorship hearing after three days; (4) did not err when it issued findings regarding how H.D.K. intended to allocate her estate; (5) did not err by determining the present values of the properties in H.D.K.'s estate; and (6) did not err when it found H.D.K. had testamentary capacity. View "In re H.D.K." on Justia Law