Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of aggravated assault, burglary, criminal endangerment, and assault on a peace officer, all felonies. Defendant appealed, arguing, among other things, that the Supreme Court should exercise plain error review of his argument that the convictions for aggravated assault and criminal endangerment violated statutory and constitutional double jeopardy protections. The Supreme Court affirmed, holding (1) sufficient evidence supported the aggravated assault conviction; (2) sufficient evidence supported the burglary conviction; and (3) charging both crimes of criminal endangerment and aggravated assault was not plain error under the facts of this case since different victims were involved. View "State v. Torres" on Justia Law

After a jury trial, Defendant was convicted of assault on a peace officer, a felony, for biting a detention officer on the arm. Defendant appealed, arguing that the prosecutor's comments during closing argument constituted misconduct and warranted reversal of her conviction under plain error review. Defendant argued that the prosecutor repeatedly made direct comments about the reliability of the witnesses, and thus the prosecutor vouched for the witnesses and attempted to interject his personal opinion. The Supreme Court affirmed, holding that when viewed in the context of the entire argument, the challenged comments made in closing argument did not raise the specter of prosecutorial misconduct necessitating the exercise of plain error review to protect fundamental fairness of this proceeding. View "State v. McDonald" on Justia Law

After Employee failed to ask a shopper for a loyalty card per Employer's policy, Employee was fired. Employee brought a wrongful discharge claim against Employer under Montana's Wrongful Discharge From Employment Act (WDEA). Employee accepted Employer's offer to arbitrate the dispute because she said Mont. Code Ann. 39-915 would force her to pay Employer's attorney fees if she declined the offer and later lost at trial. Employee then successfully moved to amend her complaint to add destruction of evidence and declaratory judgment claims, alleging, inter alia, that section 39-2-915 was unconstitutional. The district court subsequently dismissed Employee's amended complaint, concluding that it had lost jurisdiction over Employee's claim once she accepted the offer to arbitrate. The court also ruled that 39-2-915 was constitutional. The Supreme Court (1) affirmed the dismissal of Employee's amended complaint, as the court lost its ability to consider Employee's claim once she agreed to arbitration; and (2) set aside the district court's determination of Employee's constitutional claim, as the court lost its authority to act further once Employee agreed to arbitrate. View "Ensey v. Mini Mart, Inc." on Justia Law

Defendant pleaded guilty to the aggravated assault of his wife (Wife). As part of his sentence, the district court ordered Defendant to pay $44,112 in restitution, including $19,866 for Wife's medical expenses arising from her suicide attempt two and a half months after Defendant's assault. Defendant appealed the portion of his sentence involving the restitution for Wife's suicide attempt. The Supreme Court affirmed the district court's order of restitution, holding (1) the district court did not err in determining that Wife's suicide attempt was "a result of" Defendant's criminal conduct; and (2) substantial evidence in the record supported the restitution obligation. View "State v. Jent" on Justia Law

After a jury trial, Defendant was convicted of negligent homicide and criminal endangerment. Prior to trial, Defendant filed a motion in limine requesting that five photos of the victim's body be excluded from evidence at trial. Defendant argued that the photos were highly prejudicial in that they depicted death, and the photos had no probative value. The district court granted Defendant's request as to one photo but allowed the State to use the remaining photos. The Supreme Court affirmed, holding that the district court did not err when it admitted the photos of the victim into evidence where the court correctly balanced the probative value of the photos against their prejudicial effect. View "State v. Buslayev" on Justia Law

After a jury trial, Defendant was convicted of the offense of partner of family member assault (PFMA), a felony. The Supreme Court affirmed the conviction and remanded for correction of the written judgment, holding (1) Defendant's attorney did not provide ineffective assistance of counsel by failing to object to the mental state instructions given at trial, as the district court properly instructed the jury in the applicable law on the mental state for the PFMA offense; and (2) an error in the district court's written judgment imposing terms and conditions of parole or conditional release required that the written judgment be amended. Remanded. View "State v. Birthmark" on Justia Law

Two police officers observed Defendant in a bar holding a beer can. Believing that Defendant was younger than twenty-one years old, the officers asked how old Defendant was then asked for identification to verify Defendant's age. The officers subsequently told Defendant to accompany the officers outside. After Defendant provided a false first name and birthdate, the officers placed Defendant under arrest. After confirming that Defendant was under twenty-one years old, the State charged Defendant with minor in possession and obstructing a police officer. The city court granted Defendant's motion to suppress. The district court affirmed, determining the officers had violated Defendant's right against self-incrimination by requesting Defendant's name, birthdate, and identification. The Supreme Court affirmed, holding that the officers had sufficient particularized suspicion to approach Defendant and ask his age, but the officers improperly expanded their investigation by taking Defendant outside without additional articulable facts. View "State v. Driscoll" on Justia Law

Appellant was a fifty-five-year-old male with a history of schizoaffective disorder. The State filed a petition to involuntarily commit Appellant, alleging that Appellant was unable to care for his basic needs and appeared to pose a danger to himself and others. After a hearing, the district court granted the State's petition and involuntarily committed Appellant to the Montana State Hospital (MSH), authorizing MSH to administer appropriate medication involuntarily. The Supreme Court affirmed, holding (1) the district court did not violate Appellant's statutory and due process rights when it failed to obtain a personal waiver of rights under Mont. Code Ann. 53-21-119(1), as Appellant effectively waived his rights by allowing his counsel to inform the judge of his desire to do so; and (2) the district court complied with the statutory requirements in ordering Appellant to take medications as prescribed by his doctors, and this directive was sufficient to authorize involuntary medication. View "In re R.W.K." on Justia Law

Defendant's vehicle hit Brian Beaver from behind, and Beaver died from severe blunt force trauma to his head. Defendant was assigned a public defender for his criminal case. Eight days before his trial, Defendant provided the district court with a pro se motion for appointment of different counsel, claiming that appointed counsel's representation was deficient. Defendant also filed a request for a continuance so that he could retain private counsel. The court denied Defendant's request for substitution of counsel, determining that counsel was providing adequate representation. The court also denied Defendant's motion to continue, determining that Defendant had lacked diligence in seeking private counsel. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by finding that Defendant's counsel was providing effective assistance of counsel; and (2) did not abuse its discretion in determining that Defendant had not made a good faith, diligent effort to retain substitute counsel. View "State v. Holm" on Justia Law

After a jury trial, Defendant was found guilty of felony aggravated assault and misdemeanor unlawful restraint. Defendant subsequently filed a petition for postconviction relief, raising twelve issues. The district court determined that Defendant's petition did not demonstrate any kind of error, cumulative or otherwise, and dismissed the petition. Defendant appealed pro se to the Supreme Court. The Supreme Court affirmed, holding that the district court did not err in finding that Defendant did not meet his burden of establishing that any error of his pre-trial and trial counsel prejudiced his right to a fair trial. View "Rukes v. State" on Justia Law