Justia Constitutional Law Opinion Summaries

Appellant was convicted of robbery with the use of a deadly weapon and first-degree murder with the use of a deadly weapon and was sentenced to death. Appellant subsequently filed numerous post-conviction motions. This appeal involved the denial of Appellant's fourth post-conviction petition for a writ of habeas corpus challenging his conviction and sentence. Appellant's counsel sought to file a substitution of counsel motion under seal. The motion was filed under seal. The State opposed the motion and moved to unseal it. Appellant responded by filing a motion to seal the State's opposition. The Supreme Court denied the State's motion and granted Appellant's motion. The State filed a motion for reconsideration of that order. Appellant then filed a motion to seal the reconsideration motion and any pleadings related to the substitution. Later, Appellant filed a motion to strike the motion for reconsideration and to direct the State's conduct respecting the various pleadings filed regarding the substitution motion. The Supreme Court granted the State's motion for reconsideration and denied Appellant's competing motions, holding that the documents Appellant sought to have sealed did not meet the requirements for sealing. View "Howard v. State" on Justia Law

Plaintiffs alleged that their autistic son was not provided a free appropriate public education (FAPE) by the school district as required by the Individuals with Disabilities Act (IDEA), 20 U.S.C. 1400 et seq. The court affirmed the district court's holding that the school district had provided a FAPE for the child and allowed his parents meaningful participation in the development of his behavior and educational plans. View "M.M., et al v. Dist 0001 Lancaster Co. School" on Justia Law

After a jury trial, Defendant was convicted of burglary, grand larceny, conspiracy to commit kidnapping, first-degree kidnapping, conspiracy to commit murder, and first-degree murder with the use of a deadly weapon. At issue on appeal was whether the district court erred by dismissing a prospective juror before conducting a Batson hearing, and whether sufficient evidence supported the kidnapping conviction. The Supreme Court reversed and remanded, holding (1) because Defendant asserted a Batson violation, it was a structural error to dismiss the challenged juror prior to conducting the Batson hearing because it showed the district court predetermined the challenge before actually hearing it; and (2) the evidence was sufficient to support the kidnapping conviction. View "Brass v. State" on Justia Law

Plaintiff appealed the district court's grant of summary judgment to the school district, alleging that she was denied a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court held that plaintiff satisfied the court's liberal notice of appeal requirements and therefore considered the appeal on the merits. The court found that the district court complied with the IDEA's procedural requirements and, moreover, if any defects existed, they did not rise to the level of denying plaintiff a lost educational opportunity. In regards to plaintiff's substantive claim, the court analyzed the Michael F. factors and concluded that plaintiff received a FAPE. Accordingly, the court affirmed the judgment. View "R. P. v. Alamo Heights Indep Sch Dist" on Justia Law

Defendant's vehicle collided with Plaintiff's vehicle as Plaintiff was driving through an intersection. The collision damaged both vehicles and injured Plaintiff. Plaintiff filed an amended complaint against Plaintiff, alleging negligence. The district court granted Defendant's motion for summary judgment, concluding that Defendant was not negligent nor did she proximately cause the accident, as the collision would not have occurred without Plaintiff's violation of the right-of-way statute. The Supreme Court reversed, holding that Defendant was not entitled to judgment as a matter of law, as (1) the evidence established factual issues concerning the parties' comparative negligence; and (2) the district court erred by concluding that the issue of whether Defendant was maintaining a proper lookout was not a genuine issue of material fact. View "Tonner v. Cirian" on Justia Law

After a jury trial, Defendant was convicted of one count of incest. On appeal, the Supreme Court affirmed, holding (1) Defendant was not entitled to a new trial due to law enforcement's warrantless monitoring and recording of his telephone conversations with his daughter, the victim, where (i) the recordings of Defendant's conversations with his daughter violated his rights under the Montana Constitution as interpreted by the Court in State v. Allen, but (ii) the admission of the recordings at trial was harmless error; and (2) the district court did not abuse its discretion in admitting sexually oriented photographs that Defendant took of his daughter. View "State v. Stewart" on Justia Law

Defendant was charged with DUI, fourth or subsequent offense. The information provided that Defendant was previously convicted of qualifying DUI offenses in 2009, 1999, and 1992. Defendant filed a motion to dismiss due to invalidity of prior DUI convictions, challenging his 1992 DUI conviction on the basis of constitutional infirmity. The district court denied Defendant's motion, concluding that Defendant failed to meet his burden to come forward with affirmative evidence establishing that his 1992 conviction was obtained in violation of the Constitution. Defendant subsequently entered a no contest plea to the DUI charge, reserving his right to appeal the denial of his motion. On appeal, the Supreme Court affirmed the district court's order denying Defendant's motion to dismiss, holding that the court correctly concluded that Defendant failed to meet his burden to persuade the court that his 1992 conviction was constitutionally infirm. View "State v. Nixon" on Justia Law

Both the State and Defendant Wallace Nolan appealed a trial court's revocation of Defendant's probation, though for different reasons. Specifically, both defendant and the State disputed the trial court’s authority to summarily terminate probation without a hearing. Defendant equated an "unsatisfactory" discharge with findings of a probation violation, or as otherwise reflecting adversely on his conduct as a probationer. Defendant claimed he was denied an opportunity to contest the grounds for such an appellation. The State, on the other hand, argued that when, as in this case, a motion's predicate facts were in dispute, Vermont Rule of Criminal Procedure 47(b)(2) calls for a hearing. Upon review, the Supreme Court agreed that a probationer is entitled to a hearing on disputed material facts before the trial court can order a less-than-satisfactory discharge from probation. The trial court's order was reversed and remanded for further proceedings. View "Vermont v. Nolen" on Justia Law

Defendant pled guilty to one count of sexual abuse of children pursuant to a plea agreement. The district court sentenced Defendant to the Department of Corrections (DOC) for seven years, with two years suspended upon several terms and conditions. The district court later revoked Defendant's suspended sentence after an evidentiary hearing at which it found Defendant in violation of the conditions of his sentence. The court then imposed a two-year commitment to the DOC and ordered that Defendant be designated a Level 3 sexual offender. The Supreme Court affirmed, holding that the district court did not err by elevating Defendant's sexual offender level designation from Level 1 to Level 3 upon revocation. View "State v. Claassen" on Justia Law

This appeal was the third in the course of this litigation. Plaintiffs were a group of landowners with properties on the shores of Flathead Lake and a portion of the upper Flathead River. Plaintiffs commenced this action in 1999 against Montana Power Company (MPC) and MPC's successor, PPL Montana, LLC, asserting claims of trespass, nuisance, a taking of property, and breach of easements. In Mattson II, Plaintiffs filed motions to certify the lawsuit as a class action. The district court granted the motions as to both Defendants. The Supreme Court vacated the district court's orders concerning class certification. On remand, the district court denied Plaintiffs' renewed motion for class certification. The Supreme Court reversed, holding (1) the district court erred in its application of Mattson II to the class-certification question under Mont. R. Civ. P. 23; and (2) the six criteria for certification of a class action under Rule 23 were satisfied in this case. Remanded with instructions to certify the class. View "Mattson v. Mont. Power Co." on Justia Law