Justia Criminal Law Opinion Summaries

Articles Posted in Montana Supreme Court
by
In a split decision, the Supreme Court reversed Defendant's negligent homicide convictions but upheld his convictions on nine counts of criminal endangerment and eleven counts of criminal distribution of dangerous drugs, holding that there was insufficient evidence to establish that Defendant's actions in prescribing narcotics was the cause in fact of the deaths of two of his patients.After a jury trial, Defendant, a licensed medical doctor, was convicted of several crimes related to the repeated prescribing of copious amounts of opiates and other narcotics to eleven individuals. Two of Defendant's patients died from drug overdoses. The Supreme Court reversed in part and affirmed in part the convictions, holding (1) the State did not present sufficient evidence to establish that Defendant's actions were the direct cause of the two drug overdose deaths; and (2) Defendant was operating outside the bounds of a professional medical practice, and therefore, the exemption for medical practitioners acting within the course of a professional practice did not apply to the facts of this case. View "State v. Christensen" on Justia Law

by
The Supreme Court held that Mont. Code Ann. 46-5-105 prohibits detention center employees who are booking a person into the general population of a detention facility from conducting a visual body cavity search without reasonable suspicion to believe that person is concealing contraband, a weapon, or evidence of the commission of a crime.William Rogers, leading ninety-six named plaintiffs, brought this action challenging the Lewis and Clark County Detention Center policy to conduct an unclothed visual body cavity search of every detainee prior to placement in the general population of the facility as a violation of Mont. Const. art. II, 10 and 11 and Mont. Code Ann. 46-5-105. The district court granted summary judgment for Defendants as to ninety-two of the named plaintiffs and denied the motion as to four plaintiffs who were never placed in the general population of the facility after they were strip searched. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs' diminished privacy interests did not outweigh the legitimate penological interests of the Detention Center; and (2) the plain language of section 46-5-105 unequivocally prohibits suspicionless strip searches of those arrested for minor offenses in any situation. View "Rogers v. Lewis & Clark County" on Justia Law

by
The Supreme Court reversed the decision of the district court denying Defendant's motion to suppress evidence found during a probation search of the room Defendant rented from a person on probation, holding that Defendant had a legitimate expectation of privacy in his residence.Defendant rented a room from Parischere Hughes (Paris), who was on misdemeanor probation and subject to probation searches. During a probation search of Paris's residence, law enforcement officers searched Defendant's residence and found drugs and drug paraphernalia. Defendant was charged criminal possession of dangerous drugs, a felony. Defendant filed a motion to suppress, arguing that the search exceeded the scope of any lawful probation search of Paris's residence. The district court denied the motion. The Supreme Court reversed, holding that Defendant's rights to privacy in his person and residence were not diminished by Paris's probationary status. View "State v. Thomas" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of assault with a weapon, a felony, holding that the district court conducted an adequate inquiry into Defendant's request to substitute counsel.On appeal, Defendant argued that when she requested that her counsel be replaced, the trial court's inquiry into her complaints was inadequate. The Supreme Court disagreed, holding (1) the district court conducted an adequate inquiry into the nature and causes of the apparent conflicts and alleged breakdown in communication between Defendant and her counsel; and (2) because Defendant failed to present material facts demonstrating that there was an irreconcilable conflict or breakdown in communication such that she was unable to mount an adequate defense, the district court did not abuse its discretion in denying Defendant's request to substitute counsel. View "State v. Khongwiset" on Justia Law

by
The Supreme Court reversed Defendant's conviction of criminal distribution of dangerous drugs, methamphetamine, and criminal possession of dangerous drugs, methamphetamine, holding that the district court erred in denying Defendant's motion to disclose the identity of a confidential informant.After Defendant was charged, Defendant filed a motion asking the district court to compel the State to disclose the identity of the confidential informant that led to Defendant's arrest. The district court denied the motion. After a second trial, the jury convicted Defendant. On appeal, Defendant argued that she had the right to know the identity of the informant because the informant played a continuous, active, and primary role in the alleged crime. The Supreme Court agreed, holding that, considering the circumstances of the case balanced against the public's interest in withholding the confidential informant's identity, the district court erred in denying Defendant's motion to compel disclosure of the informant's identity. View "State v. Walston" on Justia Law

by
The Supreme Court reversed Defendant's conviction of sexual intercourse without consent, holding that the district court abused its discretion and compromised Defendant's right to a fair trial when it allowed expert witness testimony on statistics about false reports of sexual assault.On appeal, Defendant argued that the trial court's admission of the expert testimony regarding the statistics about false reports of rape prejudiced his right to a fair trial by turning the case into a "trial by statistic" rather than a case based on specific facts. The Supreme Court reversed, holding (1) the expert testimony regarding the rate of false reports of sexual assault was improper, and the district court abused its discretion in admitting the testimony; and (2) Defendant's right to a fair trial was violated by the improper admission of the false reporting statistics. View "State v. Grimshaw" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of felony strangulation of his girlfriend, holding the evidence was sufficient to support the conviction, and Defendant did not receive ineffective assistance of counsel.Specifically, the Supreme Court held (1) the evidence was sufficient to sustain Defendant's conviction of felony strangulation; (2) Defendant failed to meet the prejudice standard set forth in Strickland v. Washington, 466 U.S. on his claim that his counsel was ineffective by opening the door to evidence of Defendant's prior violence; and (3) this Court declines to review for plain error Defendant's argument challenging the district court's instruction on the mental state for strangulation. View "State v. Dineen" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of one count of sexual intercourse without consent, holding that the district court did not err in denying Defendant's motion to strike a prospective juror for cause.After the district court denied Defendant's motion to remove the prospective juror for cause Defendant used a peremptory challenge to strike her from the panel and exhausted all of his peremptory challenges. Defendant appealed, arguing (1) the prospective juror's voir dire statements demonstrated an inability to act fairly and impartially in his trial, and therefore, the district court abused its discretion in denying his for-cause challenge; and (2) because he had to exercise a peremptory strike to remove the juror and subsequently exhausted his peremptory challenges, the error was prejudicial. The Supreme Court disagreed, holding that the district court did not abuse its discretion in accepting the prospective juror's assurances that she could fairly and impartially weigh the evidence despite her initial statements of prejudice. View "State v. Morales" on Justia Law

by
The Supreme Court reversed the judgment of the district court designating Defendant as a persistent felony offender (PFO) and imposing an enhanced sentence under Mont. Code Ann. 46-18-502 , holding that the PFO designation failed.Defendant was convicted of distributing dangerous drugs. The State sought to designate Defendant as a PFO based on a 2014 Montana conviction for burglary and a 1994 federal conviction for bank robbery. The district court sentenced Defendant to the minimum PFO sentence enhancement. The Supreme Court reversed, holding that Defendant's federal bank robbery conviction was not reasonably equivalent to a Montana robbery conviction, and therefore, it may not be used as a predicate violent offense under Mont. Code Ann. 46-1-202(18) to impose a persistent felony offender sentence enhancement. View "State v. Scott" on Justia Law

by
The Supreme Court affirmed the decision of the district court denying Defendant's motion to suppress the evidence discovered during a police officer's chemical "field test" on the contents of a syringe found in Defendant's jacket pocket, holding that a rudimentary chemical field test of a lawfully seized substance is not a constitutionally protected search requiring a warrant.Defendant was placed under arrest after driving with a suspended driver's license and without vehicle insurance. While searching Defendant incident to his arrest, the arresting officer located a used syringe in Defendant's front jacket pocket. When booking Defendant into jail, the officer conducted a field test on the contents of the syringe. The field test came back positive for methamphetamine. Defendant filed a motion to suppress, arguing that the field test of the syringe's contents without a warrant constituted an unlawful search that violated his reasonable expectations of privacy. The district court denied the motion to suppress. The Supreme Court affirmed, holding that Defendant had no reasonable expectation of privacy violated by a test for the presence of methamphetamine in a syringe lawfully seized from his person, and therefore, Defendant could not assert the constitutional protections afforded to a search. View "State v. Funkhouser" on Justia Law