Justia Montana Supreme Court Opinion Summaries

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

The Supreme Court affirmed the order of the district court recommitting B.A.F. to the Montana Mental Health Nursing Care Center (MMHNCC) for a period of one year, holding that the district court did not err.In 2016, B.A.F., who had been diagnosed with paranoid schizophrenia and antisocial personality disorder, was involuntarily committed to the MMHNCC for his mental illness. The district court extended B.A.F.'s initial commitment period by one year each in 2017, 2018, and 2019. In this case, B.A.F. appealed the district court's 2019 order for recommitment, arguing that the court erred when it recommitted him without a post-petition mental health evaluation by a court-appointed professional, as statutorily required. The Supreme Court affirmed, holding that B.A.F. failed to establish that the district court's error resulted in substantial prejudice, and therefore, B.A.F. did not meet the second prong of plain-error review. View "In re B.A.F." on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court denying Appellant's motion to dismiss the deliberate homicide case against him, holding that the district court erred when it ordered Appellant to pay his public defender fees.Appellant was convicted of the deliberate homicide of his father and for tampering with evidence. The district court imposed a seventy-year prison year for the two offenses and ordered Appellant to pay $25,250 in costs for the assistance of assigned counsel. The Supreme Court affirmed, holding (1) Defendant's due process rights were not violated by the State's conduct investigating and relating the crime scene; (2) the prosecutor's comments at trial did not improperly distort Appellant's presumption of innocence or the State's burden of proof; but (3) the imposition of costs must be stricken in the interests of justice. View "State v. Fisher" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of bail-jumping, one count for each scheduled trial he missed, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the district court erred in granting the State's Gillham motion to allow his former attorney to testify and that he received ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the District Court did not err by allowing Defendant's former attorney to testify as a state witness in his bail-jumping trial, and the testimony did not violate Defendant's right to effective assistance of counsel; and (2) Defendant's remaining ineffective assistance of counsel claims were unavailing. View "State v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual assault and incest involving his biological son, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that sexual assault is a lesser included offense of incest and that his conviction violated double jeopardy. The Supreme Court affirmed, holding (1) Defendant's convictions for sexual assault and incest did not violate the double jeopardy clause of the United States Constitution, the Montana Constitution, and Mont. Code An. 46-11-410; and (2) Defendant failed to demonstrate that his counsel's representation was deficient. View "State v. Valenzuela" on Justia Law