Justia Constitutional Law Opinion Summaries

Plaintiff sought disclosure of a settlement agreement entered into by a Cascade County detention officer, Cascade County, and the officer’s collective bargaining unit (the Union). The only barrier to disclosure of the settlement agreement was the resistance of the Union. The district court ultimately granted Plaintiff’s motion and ordered the County to disclose the settlement agreement. Plaintiff subsequently filed a motion for an award of costs and attorney fees under Mont. Code Ann. 2-3-221. The request was directed solely against the Union. The district court awarded Plaintiff his costs but denied his request for attorney fees. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Plaintiff’s motion for attorney fees because the sole entity from which the fees were sought - the Union - is not a public or governmental body subject to Mont. Const. art. II, 9. View "Shockley v. Cascade County" on Justia Law

After a jury trial, Defendant was found guilty of criminal possession of dangerous drugs. Defendant was sentenced to five years in prison. Defendant appealed, arguing that the district court erred in denying his motions to suppress evidence and to dismiss the case for lack of evidence, arguing that the arresting police officer did not have particularized suspicion to conduct a stop of Defendant. The Supreme Court affirmed, holding that the district court correctly denied Defendant’s motions to suppress and to dismiss, as, based on the totality of the facts and circumstances of this case, the police officer had particularized suspicion to conduct an investigatory stop of Defendant. View "State v. Ballinger" on Justia Law

After a jury trial at which Defendant represented himself, Defendant was found guilty of the felony offense of assault with a weapon. The district court sentenced Defendant to a twenty-year prison sentence with ten years suspended. The Supreme Court affirmed. Defendant later filed a petition for postconviction relief. The district court dismissed the petition, concluding that Defendant’s trial-related claims were procedurally barred because they could have been brought on direct appeal and that Defendant’s ineffective assistance of counsel claims were without merit. The Supreme Court affirmed in part and reversed in part, holding (1) the district court correctly determined that Defendant’s trial-related claims were procedurally barred; (2) the district court correctly dismissed most of Defendant’s ineffective assistance of counsel claims because they lacked merit; but (3) one of Defendant’s ineffective assistance of counsel claims could not be resolved, as neither the record nor the district court’s order is sufficient to review for correctness the district court’s general conclusions. Remanded. View "Chyatte v. State" on Justia Law

Defendant was a passenger in a van that was parked at a park. A police officer parked behind the van, approached the van, and asked the driver for her driver’s license and Defendant for identification. After learning that the driver did not have a license and that Defendant had an outstanding warrant, the officer placed Defendant under arrest. Defendant subsequently produced a baggie filled a methamphetamine. Defendant filed a motion to suppress her statements and the evidence, arguing that the officer lacked particularized suspicion to perform an investigatory stop when he asked her and the driver for identification. The district court denied Defendant’s motion, concluding that there had not been a seizure for which particularized suspicion was required. Thereafter, Defendant pled guilty to one count of criminal possession of dangerous drugs, a felony. The Supreme Court reversed, holding that there was not particularized suspicion to stop or seize the driver that could support or properly lead to the subsequent investigation of Defendant. Remanded. View "State v. Strom" on Justia Law

After a jury trial, Defendant was convicted of assault with a weapon, criminal endangerment, and tampering with or fabricating physical evidence. The district court sentenced Defendant to a total of thirty years in prison with five years suspended. The Supreme Court affirmed, holding (1) plain error review of Defendant’s contention that the failure to immediately assign him counsel violated his constitutional and statutory rights was not warranted here; (2) the district court did not err in refusing Defendant’s proposed jury instructions regarding factors affecting the reliability of eyewitness identification; (3) the district court erred by admitting evidence of condoms found in Defendant’s van, but the error was harmless; and (4) the district court did not abuse its discretion when it refused to declare a mistrial based on the court’s comments to a co-conspirator. View "State v. Zlahn" on Justia Law

After a jury trial, Defendant was convicted of the offenses of felony DUI and criminal endangerment. Defendant appealed, arguing that the district court erred by denying his motion to suppress the results of a blood alcohol test taken pursuant to a search warrant because once he refused to cooperate in sobriety tests, Montana law prohibited law enforcement officers from taking any action to obtain a blood sample for testing. The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress, holding that the law enforcement officers in this case acted in accordance with the principles of Montana law in obtaining a search warrant for Defendant’s blood. View "State v. Minett" on Justia Law

After a jury trial, Defendant was convicted of accountability for arson, a felony, and accountability for theft, a felony. The Supreme Court reversed, holding (1) defense counsel’s failure to offer a “mere presence” jury instruction constituted deficient performance under the first prong of Strickland v. Washington, counsel’s conduct fell below an “objective standard of reasonableness,” and Defendant was prejudiced by her counsel’s inadequate performance; and (2) the prosecutor committed misconduct by telling the jurors to base their decision on factors other than the law and evidence. Remanded for a new trial. View "State v. Chafee" on Justia Law

Pursuant to a plea agreement, Appellant pled no contest to the felony offense of mitigated deliberate homicide. Appellant subsequently filed a motion to withdraw his no contest plea, which the district court denied. Appellant appealed from the denial of his motion but later waived his appeal. Thereafter, Appellant filed a petition for postconviction relief, claiming ineffective assistance of counsel against his trial and appellate counsel. The district court denied Appellant’s petition. The Supreme Court affirmed the district court’s denial of Appellant’s petition for postconviction relief, holding (1) trial counsel was ineffective for failing to provide to Appellant a copy of a report by a forensic pathologist, but Appellant was not prejudiced by trial counsel’s error; and (2) Appellant failed to establish that appellate counsel was deficient by advising Appellant to withdraw his direct appeal in order to file a petition for postconviction relief. View "Haagenson v. State" on Justia Law

Plaintiffs filed claims against the Montana Fish, Wildlife & Parks Commission (FWP) for violating their rights to know and participate under Sections 8 and 9, Article II, of the Montana Constitution by, among other things, failing to provide prior public notice and opportunity to participate in FWP’s decision to close certain areas to wolf hunting during a meeting. The district court issued a preliminary injunction prohibiting FWP from further enforcing its decision. Thereafter, the Legislature acted to ban these types of closures in the future, and the FWP ultimately allowed the wolf season to expire on its own. Subsequently, the court granted FWP’s motion to dismiss Plaintiffs' claims as moot. The court then awarded attorney’s fees and costs to Plaintiffs after determining that it had prevailed on its constitutional claims by obtaining the preliminary injunction. The Supreme Court affirmed the award of attorney’s fees and costs to Plaintiffs, holding that because Plaintiffs obtained the relief they sought to procure through litigation, they must be considered a “prevailing party” under the relevant statute. View "Citizens for Balanced Use v. Fish, Wildlife & Parks Comm'n" on Justia Law

Defendant was charged with ninety-one counts of felony cruelty to animals after law enforcement officers applied for and obtained a warrant to search Defendant’s home and kennels, where Defendant bred Malamutes. The dogs were found to be ill and malnourished. One hundred and thirty-nine adult dogs and twenty-three puppies were seized. The district court denied Defendant’s motion to suppress, concluding, among other things, that probable cause was well established. Defendant was subsequently convicted as charged, and the district court ordered the forfeiture of every seized dog. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant’s motion to suppress; (2) did not abuse its discretion in limiting evidence to the time period of the charged offenses; and (3) did not abuse its discretion in requiring Defendant to forfeit all of his dogs. View "State v. Chilinski" on Justia Law