Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of attempted theft and sentenced to ten years imprisonment. Defendant appealed, arguing that the district court abused its discretion in finding a sufficient chain of custody for the admission of latent fingerprint evidence and forensic analysis. At issue was two fingerprint cards used to take the prints. In specific, in contention was discrepancies between dates written on the back of the cards and their storage in a law enforcement officer's patrol car and office. The Supreme Court affirmed, holding that because the State adequately established the chain of custody of the prints cards, the district court did not abuse its discretion by admitting the latent print evidence. View "State v. McCoy" on Justia Law

Plaintiffs in this case were individuals who were in committed same-sex relationships. Plaintiffs sued the State, contending that there was a statutory structure in Montana law that prohibited them from enjoying significant relationships and family protections and obligations provided to similarly-situated different-sex couples who marry. Plaintiffs expressly did not challenge Montana law's restriction of marriage to heterosexual couples and did not seek the opportunity to marry. Instead, Plaintiffs sought a declaration that the State's failure to provide them access to the statutory scheme available to different-sex couples denied them the rights guaranteed by Mont. Const. art II. The district court granted the State's motion to dismiss, noting that Plaintiffs did not seek the declaration of the unconstitutionality of a specific statute but rather a direction to the legislature to enact a statutory arrangement, which was unprecedented in Montana law. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the district court did not err in finding Plaintiffs' requested relief exceeded the bounds of a justiciable controversy; but (2) Plaintiffs should be afforded the opportunity to amend their complaint. View "Donaldson v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual intercourse without consent and one count of sexual assault. Defendant appealed. The Supreme Court affirmed, holding (1) under the circumstances presented here, the district court's application of Montana's rape shield statute did not violate Defendant's right to a fair trial under the Montana and United States Constitutions; and (2) the district court did not err in refusing to dismiss Counts I and IV on grounds that the State failed to prove venue, as the State showed that the only rational conclusion to be drawn from the facts and testimony was that the crime was committed in the county alleged. View "State v. Patterson" on Justia Law

Defendant pled guilty to the felony offense of criminal possession with intent to distribute. The district court sentenced him to a three-year deferred imposition of sentence. Defendant appealed his conviction and sentence, contending that the district court erred in denying his motion to suppress and dismiss because a drug task force agent did not have probable cause to believe a crime was occurring in his residence, and thus there was no basis for the agent to contact Defendant and request to search his residence. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to suppress and dismiss, as (1) the information Defendant's neighbor provided to law enforcement officers was reliable; and (2) the court's findings regarding Defendant's consent to the initial search of his home and the court's findings regarding the validity of the search warrant were supported by substantial credible evidence and were not clearly erroneous. View "State v. Deshaw" on Justia Law

After a youth violated the terms of his initial probation agreement, the judicial district youth court revoked that agreement and entered a dispositional order that extended the youth's probationary period for an additional three years. The youth appealed. The Supreme Court affirmed, holding (1) the youth court did not exceed its statutory authority and correctly and interpreted and applied the Youth Court Act by imposing on revocation an additional three-year probationary term that lasted until the youth's twenty-first birthday; and (2) the imposition of an additional three-year term of probation did not violate the youth's constitutional right to equal protection of the laws. View "In re S.M.K." on Justia Law

After a jury trial, Defendant was convicted of one count of incest. The district court sentenced Defendant to 100 years in the Montana State Prison with a possibility of parole after fifty years. The district court designated Defendant a Level 3 sexual offender. Defendant appealed. The Supreme Court affirmed, holding (1) Defendant's trial counsel did not render ineffective assistance of counsel by failing to conduct cross-examination of the State' witnesses at the sentencing hearing or failing to call any witnesses on Defendant's behalf; and (2) trial counsel did not render ineffective assistance by making no alternative sentencing recommendation. View "State v. Peart" on Justia Law

Helena Sand and Gravel, Inc. (HSG) challenged Lewis and Clark County's decision to adopt a citizen-initiated proposal to configure a zoning district that favored residential uses and prohibited mining. The district court entered summary judgment in favor of the County, concluding that the County had properly adopted the zoning pattern and regulations creating the district, and the County's zoning decision did not constitute a taking of HSG's property. The Supreme Court affirmed in part and remanded, holding (1) the County's decision to adopt the zoning pattern and regulations for the district was not clearly unreasonable or an abuse of discretion; (2) the County's adoption of zoning regulations prohibiting sand and gravel mining did not constitute illegal reverse spot zoning; and (3) because HSG had a constitutionally protected property interest in property within the district, the Court granted HSG's request for remand to the district court for the parties to brief the Penn Central takings test, narrowly limited to whether the County's adoption of the zoning pattern and regulations in the district constituted a taking of HSG's real property interest without just compensation. View "Helena Sand & Gravel, Inc. v. Planning & Zoning Comm'n" on Justia Law

Plaintiffs sought a declaratory ruling that Mont. Code Ann. 13-35-227(1) violated their constitutional rights to free speech by prohibiting political expenditures by corporations on behalf of or opposing candidates for public office. Plaintiffs argued that the U.S. Supreme Court's decision in Citizens United v. FEC barred Montana from prohibiting independent and indirect corporate expenditures on political speech, and that Montana's century-old ban on independent corporate expenditures therefore was invalid. The district court granted ATP's motion for summary judgment on the merits of its constitutional claim, declared section 13-35-227(1) unconstitutional, and denied ATP's request for attorneys' fees. The Supreme Court reversed, concluding (1) the statute was constitutional; and (2) Plaintiffs' cross-appeal on the attorneys' fee issue, therefore, was moot. The Court's decision thereafter was reversed by the U.S. Supreme Court. The Montana Supreme Court then returned to ATP's cross-appeal on the issue of attorneys' fees and affirmed the district court's order declining to award attorneys' fees to Plaintiffs, holding that equitable considerations did not require the district court to award fees against the State under either the Uniform Declaratory Judgments Act or the private attorney general doctrine. View "W. Tradition P'ship, Inc. v. Attorney Gen." on Justia Law

Russell Sherman obtained loans for over $1,594,282 from the Whitefish Credit Union (WCU). Russell defaulted in paying the loans. WCU subsequently gave notice of default in a ten-day demand letter. Receiving no response from Russell or his wife, Joan, WCU waited an additional thirty days and then requested that the sheriff serve the Shermans. As it turned out, only Russell was served; Joan was not personally served with process. Russell failed to enter a timely appearance or answer WCU's complaint, and accordingly, the district court entered default judgment against the Shermans. Thereafter, the Shermans filed a motion to vacate and set aside the default judgment. The court denied the motion insofar as it applied to Russell but granted the motion insofar as it applied to Joan. Russell appealed. The Supreme Court affirmed, holding that the district court did not slightly abuse its discretion in denying Russell's motion to vacate and set aside the default judgment entered against him. View "Whitefish Credit Union v. Sherman" on Justia Law

Defendant pled guilty to felony arson for setting fire to a car and two dumpsters. After a sentencing hearing, the district court sentenced Defendant to a four-year suspended DOC commitment and required him to pay $1600 in restitution. It further imposed recommended probationary conditions, including that Defendant register as a violent offender and complete anger management classes and chemical dependency and mental health evaluations. Defendant challenged the sentencing condition requiring him to register as a violent offender. The Supreme Court affirmed, holding that the district court's sentencing condition requiring that Defendant register as a violent offender did not violate his constitutional right to privacy, as whatever limited expectation of privacy Defendant had as a violent offender in his whereabouts and residential information, the State's compelling interest in requiring that he register justified the enactment of the statute requiring registration. View "State v. Brooks" on Justia Law