Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of aggravated kidnapping, assault with a weapon, and assault on a peace officer. The Supreme Court upheld Defendant's convictions. Defendant subsequently filed a petition for postconviction relief, alleging that his trial and appellate counsel provided ineffective assistance. The district court dismissed Defendant's petition. The Supreme Court affirmed, holding that that the district court did not err by denying Defendant's postconviction relief claim alleging that (1) Defendant's trial counsel provided ineffective representation during plea negotiations, as Defendant could not show prejudice by asserting an incorrect or overruled legal principle as the basis for his claim of ineffective assistance; (2) Defendant was denied access to counsel during an overnight recess; and (3) Defendant's appellate counsel provided ineffective representation by failing to raise certain issues on appeal. View "Rose v. State" on Justia Law

Defendant was charged with felony DUI and two misdemeanors. Defendant filed a motion to dismiss the charges on speedy trial grounds. The district court denied the motion. Defendant subsequently pleaded guilty to DUI pursuant to a plea agreement with the State in which the State agreed to drop the misdemeanor charges. Thereafter, Defendant appealed the district court's denial of his motion to dismiss. The Supreme Court affirmed, holding that the district court correctly found the State did not violate Defendant's right to a speedy trial where (1) Defendant's delay exceeded the 200-day trigger for a speedy trial analysis; but (2) the State's institutional delay did not prejudice Defendant. View "State v. Steigelman" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to felony DUI. Defendant appealed, arguing that the district court erred in denying his motion to dismiss the charge based on an alleged violation of his speedy trial rights. The Supreme Court affirmed the conviction, holding (1) Defendant suffered substantial pretrial delay largely attributed to the State's institutional delay in bringing him to trial, but Defendant failed to demonstrate that the delay caused undue prolonged disruption of his life or aggravated his anxiety beyond the expected level; and (2) Defendant failed to demonstrate that this delay substantially prejudiced his ability to defend against the charges. View "State v. Steigelman" on Justia Law

After a jury trial, Defendant was found guilty of one count of deliberate homicide and one count of aggravated assault. The Supreme Court affirmed, holding (1) the district court did not err by excluding evidence of justifiable use of force as a defense to the charge of deliberate homicide; and (2) the Court declined to exercise plain error review of Defendant's claims that the district court erred by excluding evidence of the victim's prior mental health history, suicide attempts, and cutting behavior, and that this exclusion violated Defendant's Sixth Amendment right to compulsory process and confrontation and Fourteenth Amendment right to due process. View "State v. King" on Justia Law

Petitioner served two terms as a Public Service Commissioner (PSC). While serving his first term at the PSC, Respondent, campaign manager for Petitioner's opponent in the upcoming election, filed four complaints against Petitioner with the Commissioner of Political Practices (Commissioner), alleging that Petitioner had violated the statutory Code of Ethics by accepting gifts of substantial value from two corporations with which the PSC regularly dealt and by using state resources to aid his reelection campaign and for personal business. Following a three-day hearing on Respondent's complaints, a hearing examiner determined that Petitioner violated Mont. Code Ann. 2-2-104 two times by receiving "gifts of substantial value" and violated Mont. Code Ann. 2-2-121 five times by using state facilities and equipment for election purposes. The Commissioner affirmed, ordering Petitioner to pay $5,750 in fines and $14,945 for the costs of the hearing. The district court affirmed. The Supreme Court affirmed, holding that the district court did not err by concluding (1) Respondent had legal standing to file ethics complaints against Petitioner; (2) Petitioner received unlawful gifts; (3) Petitioner improperly used State facilities for political purposes; and (4) the penalty statute for ethics violations was not unconstitutionally vague. View "Molnar v. Fox" on Justia Law

Following a jury trial, Defendant was convicted of felony DUI. The trial was held after several delays. Defendant was sentenced as a persistent felony offender to twenty years imprisonment with ten years suspended and ordered to pay restitution. Defendant appealed the district court's denial of his motion to dismiss based on an alleged violation of his speedy trial rights. The Supreme Court affirmed, holding that the district court (1) provided sufficient findings of fact and conclusions of law to enable appellate review of Defendant's speedy trial arguments; and (2) did not err in concluding that Defendant's speedy trial rights had not been violated under the circumstances. View "State v. Stops" on Justia Law

After a jury trial in 1984, Defendant was convicted of deliberate homicide and sentenced to 100 years imprisonment without the possibility of parole. In 2008, Defendant filed a second petition for postconviction relief, alleging that newly discovered evidence proved his actual innocence. The district court held a three-day hearing and took testimony from witnesses that suggested a group of teenage girls had killed the victim. The district court subsequently concluded that Defendant had presented sufficient evidence of his "actual innocence" to warrant a new trial. The Supreme Court reversed and dismissed Defendant's petition for postconviction relief, holding that the district court erred by concluding that Defendant was entitled to a new trial, as, applying the proper standard of review to the new evidence offered by Defendant, Defendant failed to sustain his burden of demonstrating either a freestanding claim or a gateway claim of "actual innocence." View "State v. Beach" on Justia Law

Defendant pleaded guilty to unlawful possession of an open alcoholic beverage container in a motor vehicle, failure to drive on the right side of a roadway, and driving under the influence of alcohol. The district court subsequently granted Defendant's motion to suppress evidence. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) incorrectly concluded that, because the arresting officer did not follow Mont. Code Ann. 46-6-312, all evidence gathered after Defendant's arrest should be suppressed because the arrest was lawful; (2) incorrectly concluded that the arresting officer's failure to advise Defendant of her Miranda rights at the time of arrest required suppression of all evidence obtained after her arrest with the exception of two self-incriminating statements Defendant made in response to the officer's questions after he placed her in the patrol vehicle; and (3) incorrectly concluded that evidence seized from Defendant's vehicle must be suppressed, as the plain view doctrine permitted seizure of the evidence. View "State v. Kelm" on Justia Law

After a jury trial, Defendant was convicted and sentenced for sexual assault. The Supreme Court affirmed the conviction, holding (1) the district court did not err by admitting into evidence a recored interview with the victim in violation of Defendant's confrontation rights or in contravention of Mont. R. Evid. 613(b); (2) there was sufficient evidence to support the conviction under the criteria set forth in State v. Yuhas; (3) the district court did not err in denying Defendant's motion for a new trial; and (4) Defendant's argument that his attorney provided ineffective assistance at trial should be raised in a petition for postconviction relief. View "State v. Baker" on Justia Law

Defendant brought her seven-week-old son, John Doe, to a medical center for injuries. A jury later convicted Defendant of assault on a minor and aggravated assault. The district court ordered a change in parenting arrangements for John Doe as part of the criminal sentence despite pending dependency and neglect proceedings. As part of Defendant's sentence, the district court ordered Defendant to pay fees, costs, and surcharges without recording findings regarding Defendant's financial situation. The Supreme Court affirmed, holding (1) because Defendant had regained custody of John Doe through the civil proceeding, her claim regarding the imposition of a condition concerning the temporary custody of John Doe was moot; however, the statement in the court's written judgment that the father should be presumed to have custody of John Doe should not have been included in the criminal sentence; and (2) the district court acted within its discretion in imposing fees. View "State v. MacDonald" on Justia Law