Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count of partner or family member assault (PFMA), holding that the district court did not err by permitting Defendant's ex-girlfriend to testify and that there was sufficient evidence to support the conviction.Defendant was charged with two counts of PFMA, both misdemeanors, and one count of strangulation of partner or family member, a felony. Defendant was found guilty of the second count of PFMA and was acquitted of the strangulation offense. On appeal, Defendant argued, among other things, that the State violated Mont. Code Ann. 46-15-322 and -327 by not disclosing his ex-girlfriend as a witness before trial. The Supreme Court affirmed, holding (1) the admission of the ex-girlfriend's testimony on a prior strangulation was error, but the error was harmless; and (2) there was sufficient evidence to sustain Defendant's conviction for the second count of PFMA. View "State v. Torres" on Justia Law

The Supreme Court affirmed Defendant's conviction of criminal distribution of dangerous drugs, holding that there was sufficient evidence to support the conviction and that the district court did not otherwise err.Defendant was convicted of criminal distribution of dangerous drugs and endangering the welfare of a child. Defendant appealed his drug offense conviction, arguing that insufficient evidence supported the conviction and that the district court deprived him of his right of allocution during his sentencing hearing. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to support Defendant's drug conviction; and (2) Defendant failed to preserve the allocution issue. View "State v. McCoy" on Justia Law

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 judgment of the district court denying Defendant's petition to expunge or predesignate as a civil infraction his felony conviction of criminal possession of dangerous drugs, holding that the district court did not err by denying Defendant's petition.Defendant pled guilty to possessing over sixty grams of marijuana. After voters passed the Montana Marijuana Regulation and Taxation Act (MMRTA), now codified as Title 16, chapter 12, MCA, Defendant petitioned for expungement or redesignation of his marijuana conviction. The district court denied the petition, concluding that Defendant was not eligible for expungement or redesignation because the MMRTA does not permit the marijuana-related conduct for which Defendant was convicted. The Supreme Court affirmed, holding that, on its face, Defendant's conviction did not qualify for expungement or redesignation under the MMRTA. View "Maier v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the municipal court revoking Defendant's deferred sentence and imposing a six-month suspended sentence, holding that the municipal court did not err or abuse its discretion.When he violated an order of protection Defendant violated a condition of his deferred six-month sentence for misdemeanor sexual assault. The district court affirmed the municipal court's decision revoking Defendant's deferred sentence and imposing a suspended sentence. The Supreme Court affirmed, holding that the municipal court (1) correctly applied the law when it revoked Defendant's sentence; and (2) did not abuse its discretion when it revoked Defendant's six-month deferred sentence and imposed a six-month suspended sentence. View "City of Missoula v. Sadiku" on Justia Law

The Supreme Court affirmed the orders of the district court (1) resolving the parties' summary judgment motions, ruling in favor of Defendant, Plaintiff's former employer, in Plaintiff's wrongful discharge lawsuit; and (2) denying Plaintiff leave to amend his complaint in that case to add an age discrimination claim, holding that there was no error.Specifically, the Supreme Court held that the district court (1) did not err in holding that Defendant's failure to exhaust internal grievance procedures precluded his wrongful discharge case as a matter of law; and (2) did not abuse its discretion in finding Defendant's age discrimination claim futile and therefore denying his motion for leave to amend the complaint. View "Hathaway v. Zoot Enterprises, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant on the offense of partner or family member strangulation, holding that the district court did not commit plain error by failing to make a record inquiry and determination as to whether Defendant validly waived his right to testify at trial.On appeal, Defendant argued that the district court committed plain error by allowing defense counsel to waive Defendant's right to testify at trial through counsel without a record inquiry and judicial finding that he knowingly, voluntarily, and intelligently chose not to do so. The Supreme Court affirmed, holding that there was no evidence that the district court erred as to this issue. View "State v. Abel" 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 affirmed the judgment of the district court convicting Defendant of felony sexual intercourse without consent, holding that Defendant received constitutionally effective assistance of counsel.At issue was whether Defendant's trial counsel rendered ineffective assistance when counsel allowed prior consistent statements from a forensic interview into evidence without challenge. The Supreme Court affirmed, holding (1) the record before the Court implied at least a plausible justification for counsel's actions; and (2) without more evidence, it cannot be determined whether defense counsel did not perform effectively for Defendant. View "State v. Mikesell" on Justia Law

The Supreme Court reversed in part and affirmed in part the judgment of the district court concluding that Appellant was not entitled to underinsured motorist (UIM) and medical payment (MP) coverages under his automobile policy with USAA Casualty Insurance Company, holding that the court erred in part.The district court granted summary judgment for USAA on both coverages. The Supreme Court reversed in part, holding (1) as to the UIM coverage, the district court erred by interpreting the contract and determining its terms were not contrary to public policy; and (2) as to the MP coverage, the district court properly granted summary judgment in favor of USAA. View "Goss v. USAA Casualty Insurance Co." on Justia Law