Justia Constitutional Law Opinion Summaries

After Respondent voluntarily admitted herself to the behavioral health unit of a hospital, Respondent requested to be discharged. However, the county attorney's office filed a petition requesting that Respondent be committed for further evaluation and treatment. The district court appointed a public defender to represent Respondent, and following a hearing on the petition for commitment, the court committed Respondent to the Montana State Hospital with a treatment order that included the involuntary administration of medication. The Supreme Court affirmed, holding (1) plaint error review of this issue was not warranted; and (2) Respondent was not denied the effective assistance of counsel during the hearing. View "In re J.S.W." on Justia Law

Defendant pled guilty to one count of felony negligent vehicular assault and one count of felony criminal endangerment. The district court sentenced Defendant to the Department of Corrections for six years with eighteen months suspended on each count, to run concurrently, ordered Defendant to complete 100 hours of community service, and imposed twenty-nine enumerated conditions of probation. The Supreme Court affirmed, holding (1) the district court imposed a legal sentence on Defendant; (2) the district court did not impose unreasonable and unconstitutional probation conditions on Defendant; and (3) Defendant's argument that the sentence review division process was unconstitutional was not ripe for judicial determination. View "State v. Whalen" on Justia Law

Defendants in this suit included the St. Labre Indian Education Association, Inc. and the St. Labre Home for Indian Children and Youth (collectively, St. Labre). After St. Labre experienced a decrease in government funding, St. Labor began a fundraising campaign that NCT asserted resulted in millions of dollars donated to St. Labre through efforts that marketed the plight and need of NCT. NCT filed suit against Defendants alleging (1) St. Labre's fundraising system created a constructive trust on behalf of NCT and St. Labre wrongfully converted those funds to its own use, thus unjustly enriching itself; (2) contract and fraud type issues; and (3) St. Labre unconstitutionally committed cultural genocide against NCT. The district court dismissed all of NCT's motions. The Supreme Court (1) reversed the district court's grant of summary judgment on NCT's claim for unjust enrichment and the imposition of a constructive trust that may arise from St. Labre's fundraising activities after 2002; (2) reversed the district court's grant of summary judgment regarding St. Labre's fundraising activities before 2002; and (3) affirmed the court's grant of summary judgment on all of NCT's remaining claims. View "N. Cheyenne Tribe v. Roman Catholic Church" on Justia Law

The State charged Defendant with felony driving under the influence of alcohol and careless driving. The State filed notice that it intended to seek persistent felony offender status for Defendant due to Defendant's previous conviction for felony DUI. Defendant's attorney objected to the proposed designation, and the district court denied the objection. Defendant subsequently pled guilty to the felony DUI charge. After a bench trial, Defendant was convicted on the careless driving charge. The district court sentenced Defendant to ten years in prison as a persistent felony offender based on the felony DUI and to thirty days in jail on the careless driving conviction. The Supreme Court (1) affirmed the sentence for felony DUI as a persistent felony offender, holding that the sentence was lawful; but (2) reversed the jail time sentence for the careless driving conviction and remanded with instructions to strike the jail time because the district court exceeded its authority when it imposed the sentence. View "State v. Kime" on Justia Law

Without entering a plea bargain agreement with the State, Defendant pled guilty to a felony DUI charge and admitted he violated the terms of the suspended sentence he was serving for a previous DUI conviction. The district court accepted Defendant's guilty plea and revoked Defendant's sentence. Defendant subsequently filed a petition for postconviction relief, asserting he received ineffective assistance of counsel in the proceedings because his court-appointed attorney allegedly told him "just prior to sentencing" that the State had made a more favorable plea offer before he changed his plea to guilty that would have resulted in a shorter sentence. The district court dismissed Defendant's petition for failing to provide factual support for his claim. The Supreme Court affirmed, holding that the district court did not err by dismissing Defendant's postconviction relief petition as insufficiently pled, as there was no record evidence of a formal plea offer or of Defendant's lawyer's failure to inform him of a plea offer, other than an insufficient affidavit submitted by Defendant. View "Kelly v. State" on Justia Law

After a justice court bench trial, Defendant was convicted and sentenced for partner or family member assault. The district court affirmed the conviction. The Supreme Court affirmed, holding (1) the justice court jury was properly called pursuant to Mont. Code Ann. 3-15-313; (2) the court's determination that the charging documents in this case were sufficient under the law was not an abuse of discretion; and (3) the district court correctly affirmed the decision of the justice court to reject Defendant's proposed jury instructions on disorderly conduct as a lesser-included offense, which would have allowed the jury to convict Defendant of disturbing the peace instead of partner or family member assault. View "State v. Fehringer" on Justia Law

Brandon Davis was killed when the vehicle that he was driving collided with a small bus, owned by Defendant, that was parked in the middle of the interstate. Defendant was convicted of felony criminal endangerment, failing to use a lamp on a parked vehicle, failure to display warning devices on a disabled vehicle, and failure to park as close as practicable to the edge of the shoulder, among other things. The Supreme Court affirmed in part and reversed in part, holding (1) sufficient evidence supported Defendant's criminal endangerment conviction; (2) Defendant was not denied her right to be personally present at all critical stages of the trial; (3) Defendant was given effective assistance of counsel during trial; (4) the district court did not impose a greater sentence based on Defendant's refusal to admit guilt; but (5) the district court exceeded its authority when it restricted Defendant's eligibility for parole because it did not sentence Defendant to incarceration in a state prison. View "State v. Bekemans" on Justia Law

Defendant was arrested and charged with violating a permanent order of protection. While incarcerated, Defendant was charged with tampering with a witness. Following a jury trial, Defendant was convicted on both counts. Defendant's written sentence contained terms and conditions that were not expressly stated during oral pronouncement of sentence. Defendant appealed, claiming his attorney was ineffective in offering erroneous jury instructions and in failing to file a motion to conform the written sentence to the orally-pronounced sentence. The Supreme Court held that Defendant's trial counsel did not provide ineffective assistance, as (1) Defendant was not prejudiced in the giving of the disputed instructions; and (2) the cause was remanded for another sentencing hearing in which Defendant would be presented with and allowed to respond to the additional terms and conditions contained in his written sentence that were not listed by the court during the sentencing hearing. View "State v. Andress" on Justia Law

MCR, LLC filed an action for condemnation of a compressor station site on property owned by Appellees. Appellees counterclaimed against MCR for damage to their property and claimed punitive damages. Appellees sought restoration costs as the measure of damages for their contract, trespass, and nuisance claims. The parties stipulated to the substitution of MCR Transmission, LLC (MCR-T) for MCR on the condemnation claim. The district court dismissed MCR-T's condemnation claim and granted Appellees' summary judgment motion allowing Appellees to seek restoration costs. The jury awarded restoration costs and punitive damages to Appellees. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) erred in dismissing MCR-T's motion to condemn Appellees' property for a compressor station, as genuine issues of material fact existed as to whether Appellees' property was necessary for the compressor station; (2) properly determined that Appellees were entitled to seek restoration costs as the measure of their damages; and (3) properly admitted evidence at trial that MCR had jumped Appellees' bid on state trust land leases. View "McEwen v. MCR, LLC" on Justia Law

Plaintiff The Big Sky Colony, Inc., a signatory to the Hutterian Brethren Church Constitution, organized itself as a religious corporation under Montana law. Plaintiff Daniel Wipf was the Colony's first minister and corporate president. Plaintiffs brought suit against the Montana Department of Labor and Industry, claiming that the requirement to provide workers' compensation coverage for the Colony's members engaged in certain commercial activities contained in HB 119 violated the Colony's rights under the Free Exercise Clause and the Establishment Clause and also violated the Colony's right to equal protection. The district court found in favor of the Colony. The Supreme Court reversed, holding that the provisions of HB 119 that incorporated the Colony into the definition of "employer" and the Colony's members into the definition of "employee" under the Workers' Compensation Act did not violate the Free Exercise Clause, the Establishment Clause, or the Colony's right to equal protection of the laws. View "Big Sky Colony, Inc. v. Dep't of Labor & Indus." on Justia Law