Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was found guilty of felony DUI and driving without a valid driver's license. Defendant subsequently filed a motion to vacate his convictions primarily on the grounds that he had not received a probable cause hearing within forty-eight hours of his arrest. The district court denied Defendant's motion. The Supreme Court affirmed, holding that Defendant waived his right to complain that nineteen days was an unreasonable time for the State to initiate filing charges in the district court by failing to object or file a motion to dismiss before his trial. View "State v. Haller" on Justia Law

After a jury trial, Defendant was convicted of felony sexual assault and sentenced to forty years imprisonment. The district court imposed a restitution obligation of $1,583 with an ongoing obligation to the extent the victim required additional or ongoing treatment. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the district court did not abuse its discretion in denying Defendant's for-cause challenge of a prospective juror; (2) the district court did not abuse its discretion in admitting a forensic interviewer's opinion testimony; (3) the district court properly admitted the victim's prior consistent statements; and (4) the district court erred in imposing a restitution obligation that was not for a "specified amount." Remanded to the district court to set a specified amount for restitution for future costs. View "State v. Champagne" on Justia Law

On July 25, the State charged Defendant with partner or family member assault (PFMA), alleging that the pending charge was a felony. Defendant pled not guilty on August 18. On October 26, the district court dismissed the felony charge. The State then filed a misdemeanor PFMA charge against Defendant. On November 15, Defendant pled not guilty to the misdemeanor charge. The case was set for trial on May 5. Defendant filed a motion to dismiss for failure to provide a speedy trial, alleging that the State failed to bring his case to trial within six months of his initial plea on the dismissed felony PFMA charge. Defendant's motion to dismiss was denied, and Defendant pled guilty to the reduced charge of disorderly conduct, a misdemeanor. The Supreme Court affirmed, holding that the district court (1) correctly concluded that Defendant's not guilty plea to the felony PFMA charge was irrelevant in determining whether Defendant's right to a speedy trial had been violated; and (2) correctly concluded that Defendant's right to a speedy trial had not been violated when he filed his motion to dismiss less than six months after pleading not guilty to the misdemeanor PFMA charge. View "State v. Case" on Justia Law

After Defendant stole numerous firearms and other merchandise from his employer, the United States charged him with theft of firearms from a federal licensee and possession of stolen firearms. Defendant pleaded guilty to the charges. Meanwhile, the State charged Defendant with theft by common scheme for his theft of the non-firearm merchandise. Defendant filed a motion to dismiss for violation of his statutory double jeopardy rights. The district court denied the motion. Defendant subsequently entered a conditional plea of guilty to the charge. The Supreme Court affirmed the district court's denial of Defendant's motion to dismiss, holding that double jeopardy did not bar the State's prosecution of Defendant for his theft of non-firearm items pursuant to the three part test set forth in State v. Fox. View "State v. Cline" on Justia Law

In 2007, Defendant received a suspended sentence for felony offense that was ordered to run consecutively to his revocation in another proceeding in which he was serving probation after being transferred from juvenile to adult supervision. In 2012, the State filed a petition to revoke Defendant's 2007 suspended sentence. Defendant filed a motion to dismiss the petition. The district court denied Defendant's petition and revoked Defendant's 2007 sentence. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to dismiss the petition where (1) Defendant was here challenging his 2007 as illegal, and his challenge was untimely; and (2) the consecutive designation of the 2007 was not properly raised here. View "State v. Adams" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to one count of negligent vehicular assault and driving while suspended. The district court sentenced Defendant to a six-year deferred sentence. Defendant, who lived in Oregon, expected to immediately return to Oregon but was informed by his probation officer that he must complete ninety days on supervision before he was permitted to leave Montana. Defendant moved to withdraw his plea. The district court denied the motion, concluding that Defendant's plea was entered voluntarily because defense counsel never promised that Defendant would be allowed to reside in Oregon. The Supreme Court affirmed, holding (1) the district court correctly concluded that Defendant failed to demonstrate defense counsel rendered ineffective assistance; and (2) the district court correctly concluded that Defendant's plea was not involuntarily entered where defense counsel's failure to accurately predict that Defendant would have to complete ninety days in Montana on good behavior before returning to Oregon did not rise to the level of gross mischaracterization. View "State v. Prindle" on Justia Law

After a jury trial, Defendants were convicted of aggravated cruelty to animals, a felony, for knowingly mistreating or neglecting several cats in the form of cruel confinement and/or inadequate nourishment. The Supreme Court affirmed, holding (1) the State presented sufficient evidence upon which a rational trier of fact could find beyond a reasonable doubt that Defendants, without justification, knowingly subjected their animals to mistreatment or neglect; and (2) the district court did not abuse its discretion in denying Defendants' motion for a mistrial, as the prosecutor's remarks during closing argument were not so egregious as to render the juror incapable of judging the evidence fairly. View "State v. Criswell" on Justia Law

Defendant, a sexual offender, was charged with failing to provide notice of his change of residence. Defendant pled guilty pursuant to a plea agreement. The district court imposed a four-year sentence and imposed several probation conditions recommended in Defendant's presentence investigation report. The district court also required Defendant to pay the costs of his court-ordered evaluations and treatment. The Supreme Court affirmed the sentence, holding (1) Defendant's failure to object to the district court's requirement that he pay the costs of his court-ordered evaluations and treatment in the district court precluded Defendant from raising the issue on appeal; and (2) the district court did not abuse its discretion in imposing certain conditions, which relate specifically to sexual offenders, as part of Defendant's probation. View "State v. Bullplume" on Justia Law

Defendant entered a plea of not guilty to disorderly conduct, a misdemeanor. Defendant was informed that his failure to appear at the final pre-trial hearing would constitute a waiver of his right to a jury trial. Defendant failed to appear at the final hearing, although his counsel made an appearance. The court set a date for a bench trial. Defendant filed a motion to vacate the bench trial and reset the matter for a jury trial, arguing that his absence was due to his development disabilities and medical conditions, which affected his memory. The municipal court summarily denied Defendant's motion and proceeded to a nonjury trial, after which the court found Defendant guilty of disorderly conduct. The district court affirmed the conviction. The Supreme Court reversed, holding that, in light of certain affidavits and Defendant's medical records, combined with defense counsel's appearance and affirmative representation at the final pre-trial hearing that Defendant was not waiving his right of trial by jury, the municipal court abused its discretion in deeming Defendant's failure to appear at the final pre-trial hearing as a waiver of Defendant's right to a jury trial. View "City of Missoula v. Girard" on Justia Law

Defendant was charged with driving under the influence of alcohol or drugs. Defendant filed a motion to suppress the evidence obtained during the stop of his vehicle, arguing that the officer lacked particularized suspicion for the stop. The justice court denied Defendant's motion. Defendant subsequently pleaded guilty, reserving his right to appeal the court's suppression ruling. On appeal, the district court denied Defendant's motion to suppress, finding that the officer had particularized suspicion to justify an investigative stop. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's motion to suppress, as there were sufficient facts for the officer to form a particularized suspicion that Defendant was committing an offense and, thus, to initiate an investigative stop. View "State v. Wagner" on Justia Law