Justia Criminal Law Opinion Summaries

The case revolves around Kyle Severson, who was convicted for mitigated deliberate homicide after shooting Tyler Hayden. Severson, his girlfriend, her sister, and his daughter were at a convenience store when Hayden and Dalton Watson arrived. Hayden approached Severson's car, and Severson shot him, claiming he feared Hayden would harm him or his daughter. Severson was charged with deliberate homicide and later found guilty of mitigated deliberate homicide, resulting in a forty-year prison sentence.Severson appealed his conviction, arguing that the District Court erred in denying his motion to dismiss based on the State's failure to disclose favorable evidence and that the cumulative effect of errors in the District Court denied him a fair trial. The undisclosed evidence included law enforcement investigative reports of a burglary at Severson's home and the contents of Watson's cell phone.The Supreme Court of the State of Montana concluded that the cumulative effect of errors in the proceedings denied Severson his constitutional rights to a fair trial and due process. The court found that the prosecutor's misconduct and the State's failure to disclose certain evidence had a direct bearing on the credibility of the witnesses at trial. The court reversed Severson's conviction and remanded the case for a new trial. View "State v. Severson" on Justia Law

The case revolves around Eric Boudette, who was convicted of Driving Under the Influence of Alcohol, First Offense, following a jury trial on May 31, 2022. Boudette appealed the verdict, asserting that his motion to dismiss for prosecutorial misconduct was wrongly denied. He also contended that his plea for a new trial was wrongly denied on the grounds that his arrest was an unlawful seizure, the Justice Court lacked jurisdiction to try the case, and the statutory speedy trial deadline had expired by the time his trial was held.The Supreme Court of the State of Montana reviewed the case following Boudette's appeal against the District Court's affirmation of the Justice Court's decision. The Supreme Court analyzed several aspects of the case, including jurisdiction, the Community Caretaker Doctrine, allegations of prosecutorial misconduct, and the speedy trial issue.The Court ruled that Boudette could rightfully be charged in either county where he was found driving under the influence. They also determined that the arresting officer acted in her capacity as a community caretaker when she entered Boudette's vehicle to check on his wellbeing, thus making the arrest lawful. Regarding the allegations of prosecutorial misconduct, the Court found no evidence of perjury or the State unreasonably impeding Boudette from obtaining an independent blood test. Lastly, the Court declared that Boudette had waived his right to a speedy trial by requesting a continuance.Hence, the Supreme Court of the State of Montana affirmed the District Court’s decision. View "State v. Boudette" on Justia Law

In Montana, Robert Murray Gibbons was found guilty of driving under the influence, his fifth or subsequent offense. On appeal to the Montana Supreme Court, Gibbons raised three issues. First, he argued that the District Court incorrectly instructed the jury that he did not need to be conscious to be in actual physical control of his vehicle. The Supreme Court disagreed, finding that the instruction was consistent with the preventative purpose of the state's DUI statute.Second, Gibbons argued that the State’s rebuttal argument, which suggested that he could have introduced photographic evidence that was available to him during discovery, violated his constitutional rights. The Supreme Court rejected this argument, concluding that the State was entitled to respond to Gibbons’ accusation that it had improperly withheld evidence.Finally, Gibbons challenged the constitutionality of the statute that imposed a mandatory minimum $5,000 fine for his offense, arguing that it did not take into account a defendant’s ability to pay. The Supreme Court agreed with Gibbons on this point, finding that the statute was facially unconstitutional because it required the imposition of a mandatory fine in every case without considering constitutionally required proportionality factors, such as the financial burden on the defendant and the defendant’s ability to pay.Thus, the Supreme Court affirmed Gibbons’s DUI conviction, but reversed the $5,000 fine and remanded the case to the District Court for recalculation of the fine in line with its opinion. View "State v. R. Gibbons" on Justia Law

In November 2019, Vietnam veteran Bruce Schroder was charged with criminal mischief, a felony, after he removed an Uber sign from driver Jamie Hauge's car and pounded on the vehicle when several younger women offered Hauge cash for the ride and pushed Schroder out of the way. Schroder's charge was later reduced to a misdemeanor in exchange for his guilty plea and an agreement to pay restitution up to $4,930.07 as determined by the court. At the sentencing hearing, the court issued a 6-month deferred sentence and imposed a total of $2,039.20 in restitution and fees to be paid in monthly installments of $340.Schroder appealed the decision, arguing that the District Court erred in imposing restitution against him without fully considering his ability to pay. The Supreme Court of the State of Montana disagreed. The court found that there was a plea agreement in place where Schroder had agreed to pay restitution in any amount up to $4,930.07 as determined by the court. By signing this agreement, Schroder had affirmatively represented to the court that he had the ability to pay that amount. Moreover, at the sentencing hearing, Schroder made no claim of duress or undue pressure in entering the plea agreement.The Supreme Court of the State of Montana thus affirmed the lower court's decision, stating that while it is better practice for a district court to thoroughly analyze a defendant’s ability to pay restitution, fines, and fees at sentencing, under these circumstances, it could not fault the District Court for not making a more thorough inquiry into Schroder’s financial ability to pay. View "State v. Schroder" on Justia Law

In this case, the defendant, Malinda Crazymule, was found to have violated her probation. The Sixteenth Judicial District Court, Rosebud County revoked her suspended sentence and ordered a four-year commitment to the Department of Corrections (DOC). The court gave Crazymule 130 days of street time and 21 days of jail time credit but denied credit for jail time served while Crazymule was in Northern Cheyenne Tribal custody. Crazymule appealed this denial.The Supreme Court of the State of Montana reversed the lower court's decision. The key issue was whether Crazymule was entitled to credit for the time served during her arrest warrant's issuance while she was in custody for tribal offenses. The Supreme Court found that the District Court erred in its interpretation of the relevant statutes.According to Section 46-18-203(7)(b), MCA, if a suspended or deferred sentence is revoked, the judge must allow credit for time served in a detention center. The Supreme Court emphasized that the language of this statute is not discretionary regarding awarding credit for time served. The court held that the District Court had jurisdiction over Crazymule once the arrest warrant was issued following the filing of the State’s revocation petition with the court, regardless of Crazymule's incarceration for a different offense.The Supreme Court concluded that Crazymule was entitled to credit from the date the revocation warrant was issued and she remained incarcerated in a detention center. The case was reversed and remanded for further proceedings. View "State v. Crazymule" on Justia Law

In this case, Kaitlyn Holmes, a nurse, was convicted of theft and ordered to pay restitution for stealing credit cards from the personal belongings of several employees at a medical clinic in Bozeman, Montana. The Eighteenth Judicial District Court, Gallatin County, also held Holmes responsible for the disappearance of social security cards from the belongings of one of the victims, Brooke Templeton, and included in the restitution order the cost of LifeLock memberships for Templeton and her children.Holmes appealed the decision, arguing that she should not be held liable for the missing social security cards as she only admitted to stealing the credit cards. She also contested the inclusion of the cost of long-term LifeLock memberships in the restitution order.The Supreme Court of the State of Montana affirmed the lower court's decision holding Holmes responsible for the missing social security cards, noting that there was sufficient evidence to establish a causal connection between Holmes' crimes and the missing cards. However, the court partially reversed the lower court's decision regarding the restitution order. It held that the cost of the LifeLock memberships, intended to provide broad identity theft protection for the victims, was too attenuated to qualify for restitution under the statute as it was not incurred in the pursuit of the lost property.The case was remanded for entry of an amended judgment. The court's decision underscores the importance of establishing a clear causal relationship between a defendant's criminal conduct and the pecuniary loss suffered by the victim when determining restitution. This case also highlights the limitations of restitution orders, indicating that secondary expenses, not directly related to the pursuit of lost property, may not qualify for restitution under the statute. View "State. v. Holmes" on Justia Law

The case involves an appeal from a defendant, Christopher Michael Welch, who was convicted of attempted incest, incest, sexual abuse of children, and unlawful restraint. Welch began dating the mother of three daughters in 2018, and they eventually got married. The oldest daughter, J.P., testified about the inappropriate behavior and sexual advances made by Welch towards her. During the trial, Welch's defense suggested J.P. fabricated her claims.Welch's appeal raised two issues. First, he claimed prosecutorial misconduct, arguing that the prosecutor improperly vouched for J.P.'s credibility and made inappropriate emotional appeals to the jury. The Supreme Court of the State of Montana found no evidence of prosecutorial misconduct that would warrant plain error review, arguing that the prosecutor's comments were within the boundaries of discussing witness credibility and the lack of forensic evidence. The court also rejected Welch's argument that the cumulative effect of the state's comments prejudiced his right to a fair trial.Second, Welch objected to certain probation restrictions imposed by the District Court, arguing they had no reasonable nexus to the offense charged. These included prohibitions on using or possessing alcohol and illegal drugs, gambling, entering bars, and entering casinos. The court found these to be standard conditions authorized by statute and ruled that Welch failed to demonstrate that the lower court abused its discretion in imposing them. Therefore, the court affirmed the conviction and sentencing. View "State v. Welch" on Justia Law

The Supreme Court of Montana overturned the conviction of Daniel Christopher Rowe for sexual assault, a felony. Rowe was initially charged with the offense for multiple instances of abuse that allegedly took place over several years against H.B., who was under sixteen years of age at the time of the offenses. The case was remanded for a new trial due to two significant issues.First, the court found the lower court erred in admitting a subsequent uncharged act of sexual assault as proof of motive or plan to commit the earlier sexual assaults charged under a "common scheme." The court reasoned that the State had charged Rowe with a non-existent offense not recognized under Montana law, which led to the improper admission of other bad acts evidence.Second, the court found that the lower court erred in giving the jury both conduct-based and result-based definitions of "knowingly" for the sexual assault charge without specifying to the jury which definition applied to which elements of the offense. The court determined that this lowered the State's burden of proof, which violated Rowe's right to due process. The Supreme Court of Montana reversed Rowe's sexual assault conviction and remanded the case for further proceedings. View "State v. Rowe" on Justia Law

In this case, the defendant, June Wolverine, was charged with six misdemeanor traffic violations, including a third offense of Driving Under the Influence of Alcohol (DUI). Wolverine was unable to attend her trial due to being in federal custody. The State of Montana moved to continue the trial, but did not provide information on when Wolverine would be released from federal custody. Wolverine subsequently filed a motion to dismiss the charges due to a lack of a speedy trial, as required by Montana law. The Justice Court denied Wolverine's motion, and she pleaded guilty to the DUI charge while reserving her right to appeal the speedy trial issue. The District Court affirmed the Justice Court's denial of the motion to dismiss, ruling that Wolverine's federal incarceration had a clear causal impact on the trial delay.The Supreme Court of the State of Montana reversed the decision of the District Court. The Supreme Court held that the State had failed to demonstrate good cause for the delay in Wolverine's trial. The State knew Wolverine was in federal custody and had ample time to ask for Wolverine’s temporary release for trial or to notify the Justice Court about the looming deadline for a speedy trial. Yet, the State did nothing as the deadline passed. The Supreme Court concluded that the State did not fulfill its obligation to try the defendant in a timely manner, thus violating Wolverine's right to a speedy trial. The court reversed the District Court's decision and ruled in favor of Wolverine. View "State v. Wolverine" on Justia Law

In this case, defendant Bradley Alan Stokes appealed his convictions from the Fourteenth Judicial District Court, Musselshell County, for both burglary and assault with a weapon. Stokes was charged with these crimes following an altercation at the home of Michael Benson, in which he used a crowbar to break into the residence and assaulted Benson with the crowbar. He was convicted of burglary and assault with a weapon, both felonies. There was agreement that Stokes could not be convicted of both charges, as the assault with a weapon charge was the predicate offense for the burglary conviction. The dispute concerned which of the convictions should be vacated and whether the case should be remanded for resentencing.The Supreme Court of the State of Montana reversed Stokes's conviction for assault with a weapon, as it was determined to be the predicate offense that merged into the principal offense of burglary. The court held that the assault with a weapon conviction should be vacated, following the precedent that when a criminal defendant is improperly convicted of two offenses arising from the same transaction, the remedy is to reverse the conviction for the lesser-included offense only and remand for resentencing. Therefore, the court remanded the case to the District Court to vacate the assault with a weapon conviction and for resentencing on the remaining burglary conviction. View "State v. Stokes" on Justia Law