Justia Criminal Law Opinion Summaries

A police officer in Kalispell, Montana, conducted a traffic stop after observing traffic violations. While the officer was engaged with the driver, the defendant, Sean Doman, stopped on a nearby public sidewalk and began recording the police interaction with his phone. The officer, concerned for safety, called for backup. When the backup officer arrived, he repeatedly asked Doman to move further away from the scene, stating that filming was allowed but Doman’s proximity and engagement were distracting. Doman refused to comply with the officer’s orders to reposition, insisting on his right to film from his chosen spot. After several warnings, Doman was arrested for obstructing a peace officer.The case was first tried in the Kalispell Municipal Court, where a jury found Doman guilty of obstructing a peace officer under Montana law. At trial, the jury was instructed that citizens have a First Amendment right to film police, subject to reasonable time, place, and manner restrictions, but also that it is not a defense if the officer was acting illegally, as long as the officer acted under official authority. Doman did not raise constitutional objections to the statute during trial. On appeal to the Eleventh Judicial District Court, Doman challenged the constitutionality of the obstruction statute as applied to his conduct. The District Court affirmed the conviction, holding that Doman failed to preserve his constitutional arguments for appeal.The Supreme Court of the State of Montana reviewed the case de novo. It held that sufficient evidence supported the conviction because a rational juror could find that Doman knowingly impeded the officers’ duties by refusing to comply with reasonable orders during a traffic stop. The court declined to address Doman’s constitutional claims, finding them unpreserved and not warranting plain-error review. The Supreme Court affirmed Doman’s conviction. View "City of Kalispell v. Doman" on Justia Law

The case involves a dispute over a theft that occurred in Great Falls, Montana. The defendant, who had been living with her cousin at the cousin’s home and then at the home of another relative, was accused of stealing property from a storage unit rented in the name of the cousin’s daughter and paid for by the cousin’s husband. Surveillance footage and gate access records showed the defendant, along with a co-defendant, accessing the storage unit multiple times and removing property. The defendant acknowledged taking some items that did not belong to her but claimed she believed she had permission to retrieve her own belongings and returned most of the items.The Eighth Judicial District Court held a jury trial where the prosecution introduced text messages between the co-defendant and the complaining witness, which discussed details of the alleged theft and the property taken. Although the defense objected to these messages as hearsay, the court admitted them. The jury ultimately convicted the defendant of felony theft of property valued between $1,500 and $5,000 but acquitted her of burglary. The defendant appealed, arguing that the admission of the text messages constituted an abuse of discretion and that the error was not harmless.The Supreme Court of the State of Montana reviewed whether the District Court’s error in admitting the hearsay text messages was harmless. The Court held that the error was not harmless because the messages impermissibly bolstered the prosecution’s case and undermined the defendant’s credibility, contributing to the conviction. The Supreme Court reversed the conviction and remanded the case for a new trial, holding that the State failed to demonstrate there was no reasonable possibility that the inadmissible evidence contributed to the conviction. View "State v. Henderson" on Justia Law

Two individuals were found sleeping in a parked car outside a casino in Kalispell, Montana, prompting an employee to request law enforcement both conduct a welfare check and ask the occupants to leave the premises. Flathead County Sheriff’s Deputies approached the vehicle, spoke with the occupants—Christina Torres and Randy Joe Fish—and requested Fish’s identification. After Fish provided his name and date of birth, a warrant check revealed Fish had an outstanding arrest warrant. Fish was arrested, and a subsequent search uncovered less than 0.1 gram of methamphetamine in his pocket.Fish was charged with Felony Criminal Possession of Dangerous Drugs in the Eleventh Judicial District Court, Flathead County. He moved to suppress the methamphetamine evidence, arguing the officers conducted a Terry stop without sufficient justification since they requested his name absent reasonable suspicion of illegal activity, thus violating his constitutional rights. The State responded that the interaction did not amount to a seizure, or alternatively, that the officers had particularized suspicion to investigate a possible trespass. After an evidentiary hearing, the District Court denied Fish’s suppression motion, concluding there was no Terry violation because the deputies acted appropriately given the circumstances and the property owner’s request.The Supreme Court of the State of Montana reviewed the District Court’s denial of the suppression motion. It presumed Fish was seized for constitutional analysis but found the initial police contact was justified under the community caretaker doctrine. When the welfare check was complete, the deputies had particularized suspicion to investigate trespass due to the request to remove Fish from the property. The Court held the officers’ actions did not violate the Fourth Amendment or Article II, Section 11 of the Montana Constitution and affirmed the District Court’s denial of Fish’s motion to suppress. View "State v. Fish" on Justia Law

An armed and masked individual entered a pharmacy in Columbia Falls, Montana, and demanded Percocet 10 from three employees. The perpetrator directed the employees into a bathroom and fled after receiving the drugs. One employee, who knew Grant West personally, identified him as the robber based on his voice and limp, which matched surveillance footage. Police responded swiftly, arrested West at his residence, and found Percocet 10 in his pocket, along with shoes and a handgun resembling those seen in the surveillance video. West denied involvement, stating he had lent his vehicle to a friend and explaining his prescription history.The State charged West with robbery, aggravated kidnapping, and criminal possession of dangerous drugs in the District Court of the Eleventh Judicial District, Flathead County. Before trial, the State disclosed that its key identifying witness had a hearing impairment. West’s motion to exclude this testimony for delayed disclosure was denied by the District Court. During trial, the jury heard evidence from pharmacy employees, law enforcement, and others. West moved to dismiss for insufficient evidence after the State's case, but the motion was denied. The jury found West guilty on all counts and he was sentenced to prison.The Supreme Court of the State of Montana reviewed five issues raised on appeal: the Brady claim regarding witness hearing impairment, sufficiency of the robbery evidence, alleged prosecutorial misconduct, ineffective assistance of counsel, and cumulative error. The court held that the delayed disclosure of the witness’s impairment did not undermine the verdict, that sufficient evidence supported the robbery conviction, that the prosecutor’s conduct did not prejudice West’s substantial rights, and that the ineffective assistance claims were not record-based and thus not reviewable on direct appeal. No cumulative error was found. The Supreme Court of Montana affirmed the District Court’s judgment. View "State v. West" on Justia Law

The appellant was convicted in North Dakota for misdemeanor Sexual Assault after entering a guilty plea to having inappropriate contact with a person and having reasonable cause to believe the contact was offensive. He was originally charged with a more serious felony, but the plea agreement stipulated a lesser offense and specifically stated he was not required to register as a sex offender under North Dakota law. After relocating to Montana, the Department of Justice informed him that, based on Montana’s interpretation of his conviction and the age of the victim alleged in the charging documents, he was required to register as a sex offender under Montana law.The Nineteenth Judicial District Court of Montana reviewed his petition for a writ of prohibition seeking to prevent the Montana DOJ from requiring registration. The court denied his petition, reasoning that the proper remedy was to register and then later petition for removal under Montana Code Annotated § 46-23-506. The District Court also concluded that the facts alleged in the North Dakota charging document, though not proved beyond a reasonable doubt or admitted by the appellant, were sufficient to impose the registration duty.On appeal, the Supreme Court of the State of Montana reversed the District Court. The Supreme Court held that a writ of prohibition was an appropriate remedy because there was no statutory or administrative process for contesting the DOJ’s determination, and registration requirements under Montana law are punitive. The Court further held that Montana courts may not rely on facts not proved to a jury beyond a reasonable doubt or admitted by the defendant when determining registration duties. Finally, the Court concluded that the North Dakota misdemeanor Sexual Assault statute is not reasonably equivalent to the Montana sexual offense statute that triggers registration, due to the lack of an age element in the North Dakota statute. The case was remanded for further proceedings. View "Cooper v. Department of Justice" on Justia Law

A 16-year-old individual was criminally charged in Montana with several offenses, including aggravated burglary and assault on a peace officer. The prosecution filed an Information in the District Court, and a hearing was scheduled to decide whether the matter should be transferred to Youth Court, as permitted by Montana law for certain juvenile defendants. Before being arraigned, the defendant moved to substitute the presiding judge, arguing the motion was timely since arraignment had not yet occurred.The Montana Fourth Judicial District Court, Missoula County, denied the substitution motion without prejudice, reasoning that such motions are prohibited in Youth Court actions and would only be considered if the case remained in District Court following the transfer hearing. The court also issued an order for evaluation to assist in the transfer determination, but the order was initially filed under an incorrect cause number. The defendant then petitioned the Montana Supreme Court for a writ of supervisory control, claiming the denial of the substitution motion was erroneous because the case was pending in District Court as a criminal action, not a Youth Court matter.The Supreme Court of the State of Montana reviewed the case. It held that after the State files an Information in District Court, jurisdiction over the criminal matter rests with the District Court, and the action is not a Youth Court case at that stage. The court further clarified that under Montana law, a defendant’s right to substitute a judge in criminal cases may be exercised any time before arraignment, and that the 10-day window for substitution closes at arraignment rather than opening at that point. The Supreme Court granted the petition for supervisory control, set aside the District Court’s order denying substitution, and remanded for further proceedings consistent with its opinion. View "S.L. v. 4th Judicial District Court" on Justia Law

Francisco Padilla-Canales, a Spanish-speaking undocumented immigrant, was arrested after breaking into a residence where his estranged wife was staying with another man, Lesman Escobar Andara. Upon discovering them together, Padilla-Canales stabbed Andara, who died at the scene. Padilla-Canales attempted to have his wife report the incident as a suicide and performed CPR until emergency services arrived. He was advised soon after arrest, in Spanish, that a conviction could lead to deportation, and signed documentation acknowledging this warning. More than a year later, he pled guilty to mitigated deliberate homicide under a nonbinding plea agreement.The Eighteenth Judicial District Court in Gallatin County, Montana, accepted Padilla-Canales’s guilty plea after confirming he understood the charges and potential penalties, and that there were no communication barriers due to language. However, at the change-of-plea hearing, the court did not specifically advise Padilla-Canales of the immigration consequences of his plea or confirm his understanding of those consequences, as required by Montana law. Both the State and defense counsel referenced his immigration status during sentencing, discussing that deportation would likely follow his prison term. The District Court sentenced Padilla-Canales to forty years in prison without parole restrictions.On appeal to the Supreme Court of the State of Montana, Padilla-Canales argued for the first time that his guilty plea was involuntary due to the District Court’s failure to properly advise him about potential deportation. The Supreme Court recognized the advisement failure but concluded that, in this case, Padilla-Canales was aware of the immigration consequences through discussions in open court and with counsel. The Court declined to exercise plain error review, holding that the record did not reveal a manifest miscarriage of justice or compromise the fairness of the proceedings, and affirmed the District Court’s sentencing order. View "State v. Padilla-Canales" on Justia Law

In this case, a woman was accused of participating in a staged burglary intended to facilitate an insurance fraud scheme. The orchestrator of the scheme, seeking funds to pay her son's legal fees, enlisted several individuals to help remove and conceal items from her home, including a refrigerator and a boat, while her husband was away. Law enforcement initiated an investigation after the orchestrator’s husband discovered the apparent burglary and contacted police. The accused woman was alleged to have assisted in disassembling and moving the refrigerator and in storing the stolen items at her own residence, knowing that an official investigation was imminent.The Seventh Judicial District Court in Richland County presided over the case. Before trial, the defendant requested that a witness be allowed to testify by video due to travel difficulties, but the court required in-person testimony. The defendant also requested an “accomplice instruction” for the jury, arguing that a key witness’s testimony should be viewed with distrust as that witness was allegedly an accomplice. The court denied both requests, finding the accomplice instruction inapplicable because the relevant charges had been amended. After hearing testimony from the orchestrator, other involved parties, and law enforcement, the jury acquitted the defendant of conspiracy to commit insurance fraud but convicted her of tampering with evidence. The defendant then appealed, arguing errors in jury instructions, witness testimony procedures, and sufficiency of corroborating evidence.The Supreme Court of the State of Montana reviewed the case. It held that the district court did not commit reversible error in denying the accomplice instruction, as it would have been inconsistent with the defendant’s claim of innocence on the tampering charge. The court further determined there was no abuse of discretion in denying the video testimony request and that sufficient evidence supported the conviction. Accordingly, the Supreme Court affirmed the conviction for tampering with evidence. View "State v. Lord" on Justia Law

An individual was accused of sexually assaulting his fiancée’s seven-year-old niece while visiting the child’s home. The child reported the incident to her sibling, who then informed their mother. Law enforcement conducted interviews with the child, her family, and the accused, and collected physical evidence, including a blanket identified by the child. DNA analysis of the blanket matched the accused. The accused was charged with sexual assault and sexual intercourse without consent. At trial, the child, family members, law enforcement, and crime lab personnel testified. The defense focused on challenging the investigation rather than the child’s credibility. The accused was found guilty on both charges.After conviction, the accused appealed directly to the Supreme Court of Montana, raising several issues including claims of ineffective assistance of counsel. The Supreme Court of Montana affirmed the conviction. The accused then sought postconviction relief in the District Court of the Sixteenth Judicial District, Fallon County, arguing that his trial counsel was ineffective, particularly in the cross-examination of a law enforcement officer. The District Court denied the petition, finding the claims both procedurally barred and without merit. The defense attorney was later disbarred and did not participate in the postconviction proceedings.The Supreme Court of the State of Montana reviewed the denial of postconviction relief. The Court held that the accused did not establish ineffective assistance of counsel under the standard set by Strickland v. Washington. The Court found that the defense counsel’s cross-examination strategy fell within the wide range of reasonable professional assistance and did not prejudice the outcome, given the strong physical evidence and the content presented to the jury. The Supreme Court of Montana affirmed the District Court’s denial of postconviction relief. View "Kapps v. State" on Justia Law

In this case, a man was charged with multiple felony counts arising from sexual abuse allegations involving two victims: his adopted daughter, who disclosed in 2021 that she had been repeatedly molested by him from age 10 to 14, and his sister-in-law, who reported a 2009 incident in which he sexually assaulted her when she was 17. After investigations and forensic interviews, the defendant was charged with one count of felony sexual assault and three counts of felony sexual intercourse without consent. The charges related to both victims were tried together before a jury.Prior to trial in the Thirteenth Judicial District Court, Yellowstone County, neither party objected to the joinder of charges or moved to sever them. During voir dire, a Yellowstone County Undersheriff, whose office had investigated the case, was seated as a juror without objection or peremptory strike from either party. During trial, the State raised concerns about the Undersheriff’s impartiality, but the defendant’s counsel argued against removing him, and the District Court declined any implied motion to strike. The jury found the defendant guilty on all counts, and he was sentenced to 100 years in prison.On appeal to the Supreme Court of the State of Montana, the defendant raised three issues: whether the presence of the Undersheriff as a juror or the joinder of charges should be reviewed under the plain error doctrine, and whether he received ineffective assistance of counsel for failing to object to either issue. The Supreme Court held that neither issue merited plain error review because the defendant had affirmatively waived challenges below, and there was no manifest miscarriage of justice. The Court further determined that the record was insufficient to review the ineffective assistance of counsel claim on direct appeal, leaving that question for postconviction proceedings. The Court affirmed the conviction. View "State v. Soapes" on Justia Law