City of Helena v. Parsons

The Supreme Court reversed Defendant’s conviction on the misdemeanor offenses of negligent endangerment and reckless driving in the municipal court, holding that the municipal court erred in refusing to instruct the jury and allow evidence and argument on the authority of private citizens to make a citizen’s arrest as a factual consideration in determining whether Defendant committed the charged offenses as alleged.Defendant was prosecuted after he pulled his pickup and towed boat across a main thoroughfare in the City of Helena to block the escape of a motorcyclist fleeing from pursuing police in a high-speed chase through the City. At Defendant’s ensuing jury trial, the municipal court precluded him from presenting evidence and argument that he acted reasonably under the circumstances to assist police in apprehending the fleeing motorcyclist as authorized by Mont. Code Ann. 46-6-501, which establishes citizen arrest authority. The Supreme Court reversed, holding that the municipal court erroneously precluded the evidence, jury instruction, and argument on Defendant’s asserted statutory authority and intent to make a citizen’s arrest because these were factual considerations materially relevant on the record to whether Defendant acted in negligent, willful, or wanton disregard for the safety of others beyond a reasonable doubt. View "City of Helena v. Parsons" on Justia Law