Justia Constitutional Law Opinion Summaries

A rockfall damaged the residence of Jane Deschner and Jon Lodge (together, Plaintiffs) near the Billings Rimrocks (Rims). The City of Billings owned the property from which the slab fell, and the State maintained a highway that ran on top of the Rims north of Plaintiffs’ property. In 1963, the State improved the highway, rerouting it and installing culverts underneath the new roadway to facilitate water runoff. As relevant to this appeal, Plaintiffs sued the State, claiming inverse condemnation. At trial, Plaintiffs argued that the State’s construction and placement of the highway and a culvert caused an unnatural increase in the amount of water that ran off the highway onto the rockfall site, ultimately causing the slab to fall onto their home. The jury returned a special verdict finding that the State was not negligent, that Plaintiffs’ negligence was a substantial factor in bringing about their own damages, and that the State did not inversely condemn Plaintiffs’ property. The Supreme Court affirmed, holding that the district court’s instruction on inverse condemnation was not erroneous. View "Deschner v. State, Department of Highways" on Justia Law

Defendant was charged with deliberate homicide in the death of her infant daughter. Defendant moved to suppress the results of a police interrogation, asserting that her admissions that she had shaken her daughter were not voluntary. The district court denied the motion to suppress. A jury found Defendant not guilty of deliberate homicide but guilty of felony assault on a minor. The Supreme Court reversed, holding (1) based upon the totality of the circumstances, the district court erred by concluding that the interrogation was not unduly coercive or manipulative and by concluding that Defendant was “fully cognizant” of her situation; and (2) therefore, the State failed to meet its burden of proving that Defendant’s admissions were voluntary, and the district court erred in denying the motion to suppress. View "State v. Eskew" on Justia Law

After a jury trial, Defendant was convicted of securities fraud. Defendant appealed, arguing that he was denied his right to a speedy trial guaranteed by the Montana Constitution and that the district court erred when it refused his proposed jury instructions, which included language regarding exemptions to the statutes under which he was charged. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant’s motion to dismiss for lack of a speedy trial; and (2) did not err in denying Defendant a new trial on the basis that the jury was not properly instructed. View "State v. Reynolds" on Justia Law

After a jury trial, Defendant was convicted of felony theft. Defendant was sentenced to ten years in prison. Defendant appealed, arguing, among several other arguments, that the prosecutor committed plain error requiring reversal by stripping Defendant of the presumption of innocence. Specifically, Defendant challenged the prosecutor’s comment during closing arguments that the presumption of innocence had been removed from Defendant. The Supreme Court agreed with Defendant. The Court reversed the judgment and remanded the cause for a new trial, holding that the prosecutor’s comments during closing arguments constituted prosecutorial misconduct and required reversal of Defendant’s conviction. View "State v. Lawrence" on Justia Law

After the conclusion of a bench trial, Defendant was found guilty of aggravated driving under the influence with a breath alcohol concentration (BAC) of 0.239. Defendant appealed to the district court and filed a motion to suppress the evidence gathered after the vehicle he was driving was stopped by an officer of the Motor Carrier Services Division, Montana Department of Transportation (MDT). The district court denied the motion. The Supreme Court affirmed, holding that the MDT officer acted properly and within the requirements of law in stopping Defendant’s truck, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Beaver" on Justia Law

Defendant was charged with partner or family member assault (PFMA) for physically assaulting his girlfriend. Defendant filed a motion to dismiss the PFMA charge, arguing that the statute under which he was charged violated his right to equal protection because it did not apply to persons in same-sex intimate relationships. The justice court denied the motion, concluding that the statute did not violate Defendant’s right to equal protection because it does not treat similarly-situated individuals unequally. The court then found Defendant guilty. The district court affirmed, concluding that the justice court correctly analyzed Defendant’s equal protection claim. The Supreme Court affirmed, holding (1) the former version of the statute under which Defendant was charged violated equal protection; (2) the unconstitutional provision was unnecessary for the integrity of the law, and severing that provision leaves the remainder of the statute complete in itself; and (3) therefore, Defendant was not entitled to dismissal of his PFMA charge. View "State v. Theeler" on Justia Law

Defendant was charged with criminal possession of dangerous drugs with intent to distribute and criminal possession of dangerous drugs/opiates. Defendant moved to suppress the evidence found in his vehicle during a search pursuant to a search warrant, arguing that the police lacked particularized suspicion to initiate a traffic stop. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err in determining that the stop of Defendant was supported by a particularized suspicion that Defendant’s tail light covers violated Mont. Code Ann. 61-9-204(5). View "State v. Massey" on Justia Law

Citizens for a Better Flathead brought this lawsuit challenging Flathead County’s 2012 Revised Growth Policy, asserting that the Flathead County Planning Board and the County Commission violated Montana statutes, the Montana Constitution, and Flathead County’s own procedures when they developed the revised policy without adequate public participation. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in striking Citizens’ expert report; (2) did not err in determining that the Commission substantially complied with the growth policy’s mandatory procedures for adopting revisions; (3) did not err in determining that the Commission allowed for meaningful public participation in the revision process; (4) did not err in determining that the Commission adequately incorporated public comments into its decision-making process; and (5) properly concluded that Part 6 of the revised growth policy is not unconstitutional. View "Citizens for a Better Flathead v. Bd. of County Comm’rs of Flathead County" on Justia Law

After a jury trial, Defendant was convicted of threats and other improper influence in official matters, criminal trespass, and disorderly conduct. The Supreme Court affirmed the improper influence conviction and reversed the conviction for criminal trespass, holding (1) the Court declines to consider in this appeal Defendant’s argument that the improper influence statute is unconstitutionally overbroad; (2) the State presented sufficient evidence to convict Defendant of improper influence; (3) the State did not present sufficient evidence to convict Defendant of criminal trespass; (4) the district court did not abuse its discretion in allowing evidence of prior incident with the arresting officer; and (5) the Court declines to consider whether Defendant’s counsel provided deficient representation by failing to object to the jury instructions on mental state. View "State v. Spottedbear" on Justia Law

After a jury trial, Defendant was found guilty of sexual assault and sexual intercourse without consent. The Supreme Court affirmed, holding that the district court (1) did not violate Defendant’s constitutional right to a public trial when it closed to the public a hearing on the admissibility of the victim’s prior allegations of sexual abuse; (2) did not abuse its discretion in preventing Defendant from questioning the victim about prior allegations of sexual abuse; and (3) did not err by not disclosing information contained in sealed records after conducting an in camera review. View "State v. Hoff" on Justia Law