Justia Constitutional Law Opinion Summaries

The Supreme Court reversed the decision of the district court concluding that Plaintiffs - a climate advocacy group and three NorthWestern Energy ratepayers - had standing to challenge Mont. Code Ann. 69-8-421 as unconstitutional and then invalidating the statute, holding that Plaintiffs' challenge to the preapproval statute was not justiciable.At issue was section 69-8-421, which effectively permitted NorthWestern, but no other public utility, to apply to the Montana Public Service Commission for preapproval of an electricity supply resource. Plaintiffs filed a complaint requesting declaratory judgment that the preapproval statute violated both Mont. Const. art. II, 31 and Mont. Const. art. V, 12. NorthWestern filed a motion to dismiss for both lack of standing and ripeness. The district court denied the motion. The Supreme Court reversed, holding (1) Plaintiffs lacked standing to raise the rights of non-party utilities; and (2) Plaintiffs' alleged consumer injuries were not yet ripe for consideration. View "350 Montana v. State" on Justia Law

The Supreme Court affirmed the decision of the district court to deny Petitioner's petition to reinstate his driver's license, holding that the district court did not err in denying the petition because Petitioner did not meet his burden to prove that the suspension of his driver's license was improper.On appeal, Petitioner argued that his request to speak to an attorney prior to taking a preliminary breath test and a post-arrest blood test should not have been taken as an implied refusal to submit to either test and, therefore, he did not refuse to take the tests. The Supreme Court affirmed, holding (1) the record reflected that Petitioner explicitly refused to take the tests; and (2) the district court correctly denied Petitioner's petition. View "Turner v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that Mont. Code Ann. 50-20-109(1)(a), which restricts providers of abortion care to physicians and physician assistants (PAs), violates a woman's fundamental right of privacy, guaranteed by the Montana Constitution, to seek abortion care from a qualified health care provider of her choosing, holding that there was no error.In reaching its decision, the district court concluded that the State failed to "clearly and convincingly demonstrate a medically acknowledged, bona fide health risk which justifies interfering with a patient's fundamental right[....]to choose the health care provider who performs the [abortion] procedure[.]" The Supreme Court affirmed, holding (1) there is no medically acknowledged, bona fide health risk for the State to restrict the availability of abortion care by preventing Advanced Practice Registered Nurses (APRNs) from performing abortions; and (2) therefore, Montanans have the right to seek abortion care from certified APRNs. View "Weems v. State" on Justia Law

The Supreme Court reversed the conclusion of the district court that the more than three-year delay between Defendant's arrest and his subsequent criminal trial did not violate his constitutional right to a speedy trial, holding that Defendant did not receive his guaranteed right to a speedy trial.Defendant was charged with assault with a weapon. After facing a lengthy wait to be evaluated for his mental fitness to stand trial Defendant received a bed at the Montana State Hospital (MSH), where his fitness for trial improved. Defendant's fitness, however, decompensated after he was sent back to jail, leading to a second admission to MSH before the case finally went to trial. A jury found Defendant guilty, and the district court denied Defendant's motion to dismiss for lack of speedy trial. The Supreme Court reversed, holding that the 1,179-day delay between Defendant's arrest and trial, due to systemic institutional problems, violated Defendant's constitutional right to a speedy trial. View "State v. Allery" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant for robbery, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that he did not knowingly and voluntarily waive his right to counsel during his criminal trial. Defendant also argued, for the first time, that the district court compromised his right to a unanimous jury verdict by not giving a specific unanimity instruction requiring the jury to agree that either or both victims were in fear of immediate bodily injury. The Supreme Court affirmed, holding (1) Defendant knowingly and voluntarily waived his right to counsel; and (2) this Court declines to exercise plain error review to address Defendant's second argument on appeal. View "State v. Winzenburg" on Justia Law

The Supreme Court reversed the order of the district court granting Defendant's motion to dismiss Plaintiff's complaint making a claim for statutory damages against the Board of County Commissioners pursuant to Mont. Code Ann. 76-3-625(1) and equal protection, takings, and due process claims under 42 U.S.C. 1983, holding that the district court erred.In granting the Board's motion to dismiss, the district court determined that Plaintiff's section 76-3-625(1) claims were barred by a thirty-day statute of limitations and its section 1983 claims failed to state a claim. The Supreme Court reversed, holding that the district court erred in (1) determining that the section 76-3-625(1) claim was subject to a thirty-day statute of limitations and was therefore time-barred; and (2) erred in concluding that Plaintiff's 42 U.S.C. 1983 claims lacked a sufficient protected property interest and were insufficiently pled to survive a motion to dismiss for failure to state a claim. View "Tai Tam, LLC v. Missoula County" on Justia Law

The Supreme Court affirmed the order entered by the district court granting summary judgment to the Public Service Commission (PSC) and dismissing Appellants' claim that Mont. Code Ann. 69-2-102 was unconstitutional, holding that this matter lacked a justiciable controversy.Appellants filed a petition seeking a judgment declaring that the PSC's contested case procedures were unconstitutional. Specifically, Appellants alleged that the PSC's application of section 69-2-102 was unconstitutional as applied. The district court granted summary judgment to the PSC, dismissing Appellants' challenges against the statute on justiciability grounds. The Supreme Court affirmed, holding that the district court did not err in concluding that Appellants lacked standing to challenge, on due process grounds, the constitutionality of section 69-2-102. View "Broad Reach Power, LLC v. Mont. Dep't of Service Regulation" on Justia Law

The Supreme Court denied Defendant's motion to allow withdrawal of his guilty plea and dismiss the underlying matter on double jeopardy grounds, holding that the district court did not err in denying Defendant's motion to withdraw his guilty plea and dismiss and the criminal endangerment and criminal mischief charges in Jefferson County.Jefferson County charged Defendant with criminal endangerment, fleeing from or eluding a peace officer, and criminal mischief. The next month, Gallatin County charged with him criminal endangerment and fleeing from or eluding a peace officer. Defendant pled guilty to both charges. Defendant subsequently moved to withdraw his guilty plea and to dismiss the Jefferson County charges, arguing that they violated constitutional double jeopardy protections. The district court allowed the motion as to the fleeing from or eluding a peace officer charge and otherwise denied the motion. The Supreme Court affirmed, holding that the district court did not err by denying Defendant's motion to withdraw his guilty plea as to the criminal endangerment and criminal mischief charges. View "State v. Dunne" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of deliberate homicide and tampering with or fabricating physical evidence, holding that Defendant's assignments of error were without merit.On appeal, Defendant argued, among other things, that the State's 391-day delay in bringing his case to trial violated his constitutional right to a speedy trial under both the state and federal constitutions. The Supreme Court affirmed, holding (1) where the delay was primarily institutional under the conditions presented at the time by the unprecedented COVID-19 pandemic and where Defendant failed to demonstrate prejudice, Defendant failed to establish that he was denied his right to a speedy trial; and (2) the district court did not err when it denied Defendant's motion to strike the jury panel. View "State v. Hesse" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of incest, holding that Defendant was not entitled to reversal of his convictions based on any of his allegations of error.Specifically, the Supreme Court held (1) the district court did not err in finding that Defendant had not demonstrated that the victim's allegations against other male relatives were false and thus inadmissible under the Rape Shield statute; (2) Defendant's ineffective assistance of counsel claim was inappropriate for review on direct appeal; and (3) this Court declines to exercise plain error review to consider whether Defendant received a fundamentally fair trial when the district court did not sua sponte exclude testimony of false reporting statistics. View "State v. McCaulou" on Justia Law