Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the orders entered by the Fourth and Eighteenth Judicial District Courts denying their requests for preliminary injunctions to enjoin the masking requirements of Defendants, school districts in Missoula and Gallatin Counties, that were adopted in response to the continuing COVID-19 pandemic, holding that the district courts did not err.Plaintiffs filed complaints and motions for preliminary injunctions shortly after Defendants' adoption of the masking policies for the 2021-2022 school year, seeking to enjoin the masking requirements based upon constitutional privacy, individual dignity, and parental rights. Both district courts denied the motions. The Supreme Court affirmed, holding that the district courts did not manifestly abuse their discretion by denying the preliminary injunctions. View "Stand Up Montana v. Missoula County Public Schools" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Petitioner's petition for postconviction relief, holding that the district court correctly denied the postconviction relief petition.After a jury trial, Petitioner was found guilty of theft by common scheme for embezzling a sizable amount of money from a youth softball organization. The Supreme Court affirmed. Petitioner later brought this postconviction petition alleging, among other claims, ineffective assistance of his trial counsel. The district court denied the petition. The Supreme Court affirmed, holding that the district court did not err in concluding that Petitioner failed to demonstrate deficiency in his appellate counsel's representation and that his remaining complaints were unsuitable grounds for postconviction relief. View "Crabtree v. State" on Justia Law

The Supreme Court affirmed the order of the district court denying Appellants' motion for partial summary judgment and dismissing their inverse condemnation claim against the City of Billings, holding that the district court did not err.Appellants, who owned and resided in a home within the City limits, brought this action seeking to recover damages when 1,000 gallons of raw sewage backed up into their basement. The district court dismissed Appellants' sole claim of inverse condemnation because they did not establish that their damage was caused by the deliberate actions of the City. The Supreme Court affirmed, holding that Appellants failed to establish that the sewer backup was a constitutional damages of their basement for public use, and thus, a condemnation. View "Wittman v. City of Billings" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to suppress and remanded this case to the district court to vacate Defendant's conviction of criminal possession of dangerous drugs and use or possession of property subject to criminal forfeiture, holding the district court erred in denying Defendant's motion to suppress.In his motion to suppress, Defendant claimed that law enforcement exceeded the scope of a lawful traffic stop by asking Defendant for his license and then questioning him behind the vehicle after learning that the license was valid. The district court denied the motion, concluding that the officer lawfully escalated his investigation from a traffic stop to an investigation of other criminal activity. The Supreme Court reversed, holding that the officer did not possess the requisite particularized suspicion to expand the scope of the traffic stop into a criminal investigation. View "State v. Carrywater" on Justia Law

In this case arising from House Bill 102 (HB 102), the Supreme Court held that the Montana Board of Regents of Higher Education (Board) has the sole authority under the Montana Constitution to set policy regarding the possession of firearms on the Montana University System property.In 2021, the legislature enacted HB 102, which generally revised gun laws with respect to open and concealed carry of firearms. HB 102 also nullified a Board policy that limited the use of and access to firearms on campuses of the Montana University System (MUS). The district court concluded that HB 102 was unconstitutional as applied to the Board because it violated the Board's constitutional authority to regulate MUS campuses. The Supreme Court affirmed, holding (1) campus safety and security is an integral responsibility of the Board's constitutional authority; (2) the regulation of firearms on MUS campuses falls squarely within this authority; and (3) as applied to the Board, certain sections of HB 102 unconstitutionally infringe upon the Board's constitutionally-derived authority. View "Board of Regents of Higher Education v. State" on Justia Law

The Supreme Court affirmed the judgment and sentence of the district court in this criminal case, holding that the district court adequately considered evidence of Defendant's post-offense rehabilitation under Miller v. Alabama, 567 U.S. 460 (2012), and imposed a constitutional sentence by striking a parole restriction.When he was seventeen years old, Defendant was charged with burglary and three counts of deliberate homicide. Defendant was convicted of all counts and sentenced to three consecutive life sentences without parole. Defendant later filed a successful postconviction petition seeking resentencing under Miller. After a resentencing hearing, the district court sentenced Defendant to three consecutive life terms at MSP without the possibility of parole. The Supreme Court remanded the case. On remand, the district court resentenced him to three life sentences and did not restrict Defendant's eligibility for parole. The Supreme Court affirmed, holding that the district court complied with the Court's instructions on remand in Keefe II and imposed a legal sentence. View "Keefe v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for partner or family members assault (PFMA), unauthorized use of a motor vehicle, and two counts of tampering with witnesses or informants but reversed the district court's imposition of various fees and costs on Defendant, holding that remand was required for an analysis of Defendant's ability to pay before imposing costs and fees.Specifically, the Supreme Court held (1) the admission of certain hearsay statements was not harmless error; (2) Defendant's right to a fair trial by an impartial jury was not violated; (3) Defendant was not entitled to relief on his argument that his right to confrontation was violated by the repeated emphasis on recorded jail phone calls; (4) the record was insufficient to review Defendant's claim of ineffective assistance of trial counsel; and (5) the district court erred in imposing jury and other costs on Defendant without first undertaking an ability to pay inquiry. View "State v. Oliver" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony driving a motor vehicle under the influence of alcohol or drugs (DUI), holding that there was no harmless error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not violate Defendant's right to equal protection by denying his Batson objection to the State's peremptory strike of the only racial minority member of the venire; (2) while one of the prosecutor's remarks during closing argument was erroneous, the prosecutor's remarks, considered cumulatively, did not violate Defendant's right to a fair trial; and (3) the district court did not err when it relied on one of Defendant's prior convictions to support enhancement of his DUI conviction to a felony offense and in determining that the prior conviction was constitutionally valid. View "State v. Wellknown" on Justia Law

The Supreme Court reversed Defendant's convictions for felony criminal possession of dangerous drugs and misdemeanor criminal possession of drug paraphernalia, holding that the district court erred in denying Defendant's motion to suppress.On appeal, Defendant argued that the district court abused its discretion in denying his motion to suppress evidence seized after a vehicle search that resulted from an unlawfully prolonged investigative driving under the influence (DUI) stop. The district court denied the motion to suppress on the ground that the initial stop of Defendant was lawful based on a reasonable particularized suspicion of DUI. The Supreme Court reversed, holding (1) while Defendant was lawfully stopped on a reasonable particularized suspicion of DUI, the officers unlawfully prolonged the duration of the stop before subjecting Defendant to the confirmatory DUI field sobriety testing; and (2) therefore, the district court erroneously denied Defendant's motion to suppress. View "State v. Zeimer" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of assault with a weapon, a felony, and misdemeanor possession of marijuana and drug paraphernalia and sentencing him to a nine-year prison term, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the State's peremptory strike of the only non-white member of the jury venire was not plain error under the three-prong equal protection analysis set forth by Batson v. Kentucky, 476 U.S. 79 (1986); (2) Defendant failed to establish plain error as to his arguments regarding various unpreserved assertions of error regarding the prosecutor’s closing argument and rebuttal comments; and (3) defense counsel's withdrawal of the Batson challenge and failure to object to certain statements by the prosecutor did not constitute ineffective assistance of counsel. View "State v. Miller" on Justia Law