Justia Constitutional Law Opinion Summaries

Articles Posted in Montana Supreme Court

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The Supreme Court affirmed Defendant's conviction of one count of deliberate homicide and two counts of attempted deliberate homicide, holding that Defendant's ineffective assistance of counsel claim was not appropriately considered on direct appeal. On appeal, Defendant argued that his counsel provided ineffective assistance by failing to object to irrelevant, highly prejudicial evidence concerning his criminal past in two video interviews admitted at trial. The Supreme Court affirmed the judgment without prejudice to Defendant raising his ineffective assistance of counsel claim in a postconviction relief proceeding, holding that the record was not sufficient to address Defendant's claim on direct appeal. View "State v. Sawyer" on Justia Law

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The Supreme Court affirmed the order of the district court denying Plaintiff's motion to suppress evidence that was obtained when a highway patrol trooper, after noticing Plaintiff's vehicle parked on the side of the road, stopped to see if Plaintiff needed assistance, holding that the district court did not err when it denied Plaintiff's motion to suppress. On appeal, Plaintiff argued that the test set forth in State v. Lovegren, 51 P.3d 471 (Mont. 2002), to ensure that application of the community caretaker doctrine comports with constitutional protections was not met in this case. The Supreme Court disagreed, holding that the contact began as a welfare check, which met the first prong of the Lovegren test. The contact then shifted to a criminal investigation supported by particularized suspicion only after additional information became available to the trooper. View "State v. Grmoljez" on Justia Law

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The Supreme Court affirmed the decision of the district court denying Appellant’s motion to suppress, holding that the denial of Appellant’s motion to suppress was not erroneous. Defendant was charged with criminal possession of dangerous drugs. Defendant filed a motion to suppress his statements on the basis that he was detained without reasonable suspicion and arrested without probable cause. The district court denied the motion to suppress. The Supreme Court affirmed, holding (1) the district court did not err in its determination that the officers’ initial investigation was supported by particularized suspicion; (2) the immediate use of handcuffs did not elevate the investigatory stop into an arrest; and (3) the district court did not err in its determination that the arrest was supported by probable cause. View "State v. Stevens" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the district court granting summary judgment in favor of Anaconda-Deer Lodge County in this dispute over the status of a road, holding that the district court did not err in concluding that the County’s use of the upper branch of the road did not amount to a taking but that Letica Land Company, LLC was not constitutionally entitled to litigation expenses and that both Letica and the County were responsible for their individual trial costs. At issue was the status of Modesty Creek Road, located near the boundary between Anaconda-Deer Lodge County (the County) and Powell County. Letica filed a complaint and sought a preliminary injunction barring public use of the road until a judgment established the existence of a right-of-way over either or both the upper and lower branches. The district court granted summary judgment in favor of the County and dismissed Letica’s takings claims. The Supreme Court held (1) the district court did not err in granting summary judgment in the County’s favor; (2) because a taking did not occur, Letica was not constitutionally entitled to compensation or litigation expenses; and (3) the district court erred in holding Letica accountable for the County’s trial costs. View "Letica Land Co., LLC v. Anaconda-Deer Lodge County" on Justia Law

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The Supreme Court reversed the order and decree of adoption issued by the district court terminating Father’s parental rights and ordering the adoption of his minor daughter, L.F.R., by her stepfather, K.J.D., holding that the district court’s failure to notify Father of his right to counsel violated his constitutional rights. During a hearing on the petition for termination of Father’s parental rights, Father appeared but was not represented by counsel. On appeal, Father argued that the district court’s failure to notify him of his right to counsel during the proceeding violated his constitutional rights. The Supreme Court agreed and reversed, holding that Father did not knowingly and voluntarily waive his right to counsel. The Court remanded the cause for a new hearing. View "In re Adoption of L.F.R." on Justia Law

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The Supreme Court affirmed the order of the district court denying Defendant’s motion to dismiss for lack of a speedy trial and admitting Defendant’s blood alcohol concentration into evidence, holding that the district court did not err. Defendant was convicted of driving under the influence of alcohol (DUI). Defendant appealed, arguing that the district court erred when it denied his motion to dismiss because his speedy trial rights had been violated and that the circumstances of his blood draw for the DUI investigation violated Montana law. The Supreme Court affirmed, holding (1) Defendant was not deprived of his right to a speedy trial; and (2) the blood draw comported with Montana law. View "State v. Heath" on Justia Law

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The Supreme Court reversed the judgment of the district court sentencing Defendant to five years in the Montana State Prison, holding that Defendant’s attorney provided ineffective assistance of counsel and that Defendant was prejudiced as a result. Defendant pleaded guilty to criminal possession of dangerous drugs, criminal possession of drug paraphernalia, and obstructing a peace officer. The district court sentenced Defendant to five years in the Montana State Prison for criminal possession of dangerous drugs. On appeal, Defendant argued that his defense counsel’s failure to cite Mont. Code Ann. 45-9-202 and its application in State v. Brendal, 213 P.3d 448 (Mont. 2009), amounted to ineffective assistance of counsel that prejudiced the result of his sentencing hearing. The Supreme Court agreed and reversed, holding that Defendant’s attorney provided ineffective assistance by filing to cite section 45-9-202 and Brendal, resulting in prejudice to Defendant. The Court remanded the cause for resentencing. View "State v. Walter" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting Defendant of speeding, holding that the State’s comment to the jury that Defendant had already been convicted of the charge in the justice court required reversal. After a jury trial, Defendant was found guilty of speeding, in violation of Mont. Code Ann. 61-8-303(1)(b). On appeal, the Supreme Court held (1) the district court did not err when it did not dismiss the case for lack of particularized suspicion and for lack of corroborating evidence; (2) Defendant was entitled to a new trial because the State’s comment that Defendant was previously convicted of speeding presented prejudicial facts not before the jury’s consideration and implicated the fundamental fairness of the proceedings; and (3) the district court did not abuse its discretion when it did not allow Defendant to argue his theory of law to the jury that multiple witnesses are required for a conviction. View "State v. French" on Justia Law

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The Supreme Court affirmed the judgment of the district court revoking a deferred sentence for failure to pay restitution, holding that the district court did not abuse its discretion. Specifically, the Court held (1) substantial evidence supported the district court’s finding that Defendant did not make good faith efforts to pay his restitution and supervision fees; (2) the district court did not abuse its discretion in revoking Defendant’s deferred sentence and imposing a new sentence; (3) revocation did not violate the due process requirements of the Fourteenth Amendment because Defendant did not make good faith effort to pay his restitution; and (4) Defendant’s obligation to pay restitution was not a fine within the purview of the Excessive Fines Clause of Mont. Const. art. II, 22 because it was remedial in nature. View "State v. Johnson" on Justia Law

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The Supreme Court reversed the order of the district court denying Defendant’s motion to suppress evidence gathered from a vehicle after a traffic stop, holding that sufficient evidence did not exist for an extended stop. Defendant was charged with drug-related offenses. Defendant filed motion to suppress evidence obtained after a traffic stop. The district court denied the motion, concluding that the police officer had sufficient facts to expand the traffic stop into a drug investigation and particularized suspicion to justify a canine search of the vehicle’s exterior. The Supreme Court reversed, holding (1) the officer lacked the particularized suspicion required to extend the traffic stop into a drug investigation, and the stop violated Mont. Code Ann. 46-5-403; and (2) the extension of the stop to request a search by a K-9 unit violated the constitutional prohibition against unreasonable searches. View "State v. Wilson" on Justia Law