Justia Constitutional Law Opinion Summaries

Shortly after Defendant was charged with DUI, she notified the police department that she believed she had been given a "date rape" drug that caused her impairment. Before trial commenced, Defendant claimed she would assert the involuntary intoxication defense to show she did not commit a voluntary act by driving. The municipal court granted the City's motion to prevent Defendant from claiming involuntary intoxication as a defense and from calling witnesses about the use of "date rape" drugs in the City. The district court affirmed, concluding that involuntary intoxication can only be used where the mental state of the defendant is an element of the crime. Defendant appealed, contending that the lower court erred by failing to apply the voluntary act element of Montana's DUI statute. The Supreme Court reversed and remanded, holding (1) the lower court erred by precluding Defendant from raising automatism as an affirmative defense to the DUI charge; and (2) if Defendant was able to lay the proper foundation, she could elicit from certain law enforcement officers evidence regarding their personal knowledge, opinions, and statements regarding whether Defendant was unknowingly drugged, and voluntarily drove a vehicle. View "City of Missoula v. Paffhausen" on Justia Law

Defendant was convicted of attempted sexual intercourse without consent, a felony. The district court sentenced Defendant to Montana State Prison for a term of fifteen years, with five suspended. The Supreme Court affirmed, holding (1) the court did not violate Defendant's right to due process by excluding evidence of alleged sexual conversations between the complainant and Defendant and photos of third parties allegedly sent by the complainant to Defendant on the basis that they were irrelevant or more prejudicial than probative under the rules of evidence; and (2) Defendant's claim of ineffective assistance of counsel was better examined within a postconviction relief proceeding. View "State v. Bishop" on Justia Law

The district court involuntarily committed and authorized the involuntary medication of thirty-year-old C.R. after it determined that he suffered from a mental disorder and that his condition met the statutory criteria for involuntary commitment to the Montana State Hospital. The Supreme Court affirmed, holding (1) the district court properly disregarded C.R.'s hearing testimony, as substantial evidence supported the court's findings that the testimony was unreliable; (2) the district court's failure to offer C.R. a court-appointed friend did not violate C.R.'s statutory or constitutional rights, as the appointment of a friend was not statutorily mandated; and (3) C.R. received effective assistance of counsel. View "In re C.R." on Justia Law

Defendant was convicted of deliberate homicide stemming from the shooting death of his former roommate. On appeal, Defendant contended that the district court erred by instructing the jury it was prohibited from considering Defendant's intoxication when rendering its verdict in accordance with Mont. Code Ann. 45-2-203 because the statute violated a criminal defendant's due process right to present a defense. The Supreme Court affirmed, holding that the instructions given by the court fully and fairly instructed the jury on the applicable law and did not prejudice Defendant's right to present a defense, and therefore, the district court did not abuse its discretion by giving the instruction to the jury. View "State v. Myran" on Justia Law

The State charged Defendant with DUI and two drug counts. The DUI count was charged as a felony because the State maintained that Defendant had three prior DUI convictions. Defendant had been convicted of DUI twice in Idaho and once in Montana. Defendant filed a motion to dismiss the felony DUI charge arguing that his two Idaho DUI convictions should not be counted because the Idaho DUI statute was not similar to Montana's DUI statute. The district court denied Defendant's motion to dismiss, determining that while the statutes were not precisely identical, they were similar because they had characteristics in common and were alike in substance. Thereafter, pursuant to a plea agreement, Defendant pled guilty to felony DUI, and the State dismissed the drug charges. The Supreme Court affirmed Defendant's conviction, holding that the district court did not err in determining that Idaho's DUI statute was similar enough to Montana's DUI statute to allow the enhancement of a Montana DUI to a felony. View "State v. Young" on Justia Law

After a trial, Defendant was convicted for driving under the influence. The Supreme Court affirmed the conviction, holding (1) the district court erroneously allowed the results of a horizontal gaze nystagmus and preliminary breath test to be admitted at trial without expert testimony to establish the reliability of the tests, but the cumulative evidence of Defendant's intoxication presented at trial overcame any reasonable probability that the indirect admission of the test results contributed to Defendant's conviction; and (2) the district court properly exercised its discretion in excluding cross-examination regarding Defendant's blood alcohol content at the time that Defendant had been driving. View "State v. Chavez-Villa" on Justia Law

This was Defendant's second appeal to the Supreme Court. In the prior appeal, the Court affirmed Defendant's conviction of two counts of felony sexual assault and remanded the case for resentencing. The district court subsequently granted Defendant's petition for postconviction relief on the grounds of ineffective assistance of counsel and prosecutorial misconduct. In this interlocutory appeal, Defendant challenged the district court's order denying his motion to dismiss the criminal charges for which the State intended to re-prosecute him on double jeopardy grounds. The Supreme Court affirmed, holding that Defendant's constitutional right to be free from double jeopardy did not prohibit the State from re-prosecuting him after his conviction was overturned by the postconviction court's determination of prosecutorial misconduct and ineffective assistance of counsel. View "State v. Duncan" on Justia Law

A jury convicted Defendant of aggravated burglary and sexual intercourse without consent. Defendant argued on appeal that his convictions should be reversed because his standby counsel had a conflict of interest, the district court erred by modifying the jury instructions regarding aggravated burglary during jury deliberations, and his counsel was ineffective for failing to obtain an independent medical expert. The State conceded reversible error on the instruction issue and requested that Defendant's conviction for aggravated burglary be vacated on that basis. The Supreme Court reversed Defendant's conviction for aggravated burglary and affirmed Defendant's conviction for sexual intercourse without consent, holding (1) Defendant's standby counsel did not have an active conflict of interest that required reversal of Defendant's sexual intercourse without consent conviction; and (2) because the record did not fully explain why an independent medical examination or expert was not ultimately obtained by Defendant's counsel, Defendant's claim that his counsel rendered ineffective assistance by failing to obtain a medical expert could not be reviewed on appeal. View "Longjaw v. State" on Justia Law

Plaintiffs were employees of Defendant Kalispell Regional Medical Center (KRMC). Defendant Northwest Healthcare Corporation (NWHC) was the parent corporation of the remaining defendant entities. This case arose out of a dispute over the discontinuation of a sick leave buy-back program. Defendants appealed the order of the district court granting Plaintiffs' motion for class certification. The Supreme Court affirmed, holding (1) the district court properly determined that the named Plaintiffs had standing to bring claims against defendants they did not directly work for because the juridically linked Defendants were operating under a common scheme; and (2) the district court did not abuse its discretion in certifying the class under Mont. R. Civ. P. 23(a) and (b). View "Chipman v. Nw. Healthcare Corp." on Justia Law

After a bench trial in justice court, Defendant was convicted for DUI per se. At the close of the State's case-in-chief, Defendant moved the justice court to dismiss the charge on grounds of insufficient evidence, arguing that the margin of error in the Intoxilyzer breath test's result created reasonable doubt that Defendant's alcohol concentration had, in fact, reached the statutorily prohibited level. The district court affirmed the justice court's denial of Defendant's motion, concluding that Defendant had forfeited his right to challenge the veracity of his breath test. The Supreme Court affirmed, holding (1) Defendant had an evidentiary right to challenge the veracity of his Intoxilyzer breath test at trial, and the district court erred in concluding otherwise; but (2) the district court did not err in concluding that there was sufficient evidence to support Defendant's conviction, as a rational trier of fact could have found beyond a reasonable doubt that Defendant's alcohol concentration was over the statutorily proscribed limit. View "State v. Gai" on Justia Law