Justia Criminal Law Opinion Summaries

In the State of Montana v. Sky M. Little Coyote, the Supreme Court of Montana dealt with an appeal by Little Coyote, who had been incarcerated and was appealing the revocation of his suspended sentence. Little Coyote argued that his time served had been incorrectly calculated and that, when correctly accounted for, his sentence had already expired before the State filed its revocation petition. The State argued that Little Coyote was bound by an agreement he had entered into regarding the time served.The Supreme Court reversed the lower court's decision and remanded the case for dismissal of the State's Petition for Revocation. The court found that Little Coyote's time served had indeed been inaccurately calculated. It ruled that the parties involved had been operating under a mutual mistake regarding the time Little Coyote had served. The court held that, when correctly calculated and credited, Little Coyote's sentence had expired nearly three months before the State filed its revocation petition. Thus, the disposition imposed on Little Coyote was deemed illegal as the lower court had lacked the authority to revoke or impose a disposition after the expiration of his sentence. View "State v. Little Coyote" on Justia Law

The case involves Tylor Buttolph who appealed his conviction of stalking. Buttolph had been charged with eight counts of felony stalking, allegedly occurring between October 17, 2019, and April 6, 2020. For each count of stalking, the State listed only one act of misconduct. However, the stalking statute requires a "course of conduct" involving two or more acts. The State used evidence of prior, uncharged conduct to prove the "course of conduct" element.The Supreme Court of the State of Montana reversed the conviction. The court held that Buttolph's constitutional right to due process was violated when the State used an act not charged in the information to prove "course of conduct" for the offense of stalking. The court reasoned that the State cannot shift its theory of criminality on the day of trial without violating Buttolph's fundamental right to due process. The charging document was silent as to the second act constituting the course of conduct element of the offense, and thus, there was no "statement of facts constituting the offense charged". View "State v. Buttolph" on Justia Law

In this case from the Supreme Court of the State of Montana, the defendant, Joshua Richard Larson, appealed the revocation of his suspended sentence by the Fourth Judicial District Court. Larson argued that the revocation proceeding should have been dismissed with prejudice due to his first appearance in court occurring sixty-six days after his arrest, exceeding the statutory 60-day limit. The District Court acknowledged the delay but dismissed the revocation petition without prejudice, leading to the State refiling the petition, Larson admitting the allegations, and the court revoking his suspended sentence.The Supreme Court of Montana sided with the lower court, affirming its decision. It held that Larson’s initial appearance before the Justice Court on the same day he was served with the warrant fulfilled the requirements of the statute. Although this appearance was not before the District Court, the justices ruled that this didn't materially affect Larson's substantial rights. Therefore, the delay in his appearance before the District Court didn't violate his due process rights. The Supreme Court also concluded that Larson wasn't prejudiced by the delay, and so the District Court didn't err in refusing to dismiss the petition with prejudice. View "State v. Larson" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment entered by the district court following a jury trial in which Defendant was found guilty of criminal mischief and sentenced to six days in jail but with a deferred sentence conditioned upon successful completion of probation and payment of restitution over four years, holding that the district court erred in the determination of the amount of restitution to be imposed.A jury found Defendant guilty of criminal mischief for breaking and damaging parts of vehicles belonging to Douglas Nelsen and Keith Nelsen. After a sentencing hearing, the district court ordered restitution in the amount of $11420.13, including $1,222 for the Dakota and Sentra, $5,219.98 for the Ford Mustang, $1,850 for the Astro, $3,125 for the Grand Prix, and $105.15 in costs for a rental car. The Supreme Court reversed in part, holding that the district court (1) did not err by concluding that restitution could be imposed for all the damage that was alleged under the single count of criminal mischief; but (2) erred in the determination of the amount of restitution to be imposed for damage to the Mustang. View "State v. Arthun" on Justia Law

The Supreme Court reversed the judgment and order transferring jurisdiction of this matter involving H.R. from youth court to district court, imposing a Department of Corrections (DOC) commitment, auditing two years of supervision to the disposition, and requiring H.R. to register as a sex offender, holding that there was no error.The youth court revoked H.R.'s probation and committed him to the DOC for placement. Upon turning eighteen, H.R. was released, and the State sought to transfer jurisdiction from youth court to district court and to order the supervisory responsibility to transfer from juvenile probation services to adult probation services. The youth court transferred jurisdiction to the district court and supervisory responsibility to adult probation. The Supreme Court reversed, holding that the youth court exceeded the bounds of its authority under Mont. Code Ann. 41-5-208 because it imposed a new disposition on H.R. in addition to the transfer of jurisdiction and supervision agency because such a new disposition was not available under section 41-5-208. View "State v. H.R." on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant, holding that the district court did not err in determining that there was probable cause Defendant committed a crime that allowed the State to withdraw from the plea agreement and relieved the State's obligation to make a particular sentencing recommendation.Defendant pled guilty to assault with a weapon, criminal endangerment, and theft pursuant to a plea agreement. The State recommended a twenty-year sentence with no time suspended and treatment of Defendant as a persistent felony offender (PFO). Prior to sentencing, the State informed Defendant that it would withdraw from its plea agreement recommendation based on alleged crimes Defendant committed while in custody. The district court ultimately permitted the State to diverge from its sentencing recommendation in the plea agreement. The Supreme Court affirmed, holding that the district court (1) correctly determined that Defendant waived his right to challenge the timeliness of the PFO notice; and (2) did not err in determining that Defendant had breached the plea agreement and that the State was entitled to withdraw from the guilty plea and recommend a harsher sentence. View "State v. Claus" on Justia Law

The Supreme Court reversed Defendant's felony sentence imposed in connection with his conviction for felony driving under the influence (DUI) per se, holding that the presentence investigation report (PSI) in this case did not constitute competent proof if its accuracy is challenged.The district court found Defendant guilty of DUI per se and filed a PSI. The district court relied on the PSI and ordered a felony sentence of five years' incarceration with three years suspended. The Supreme Court reversed and remanded the case for resentencing, holding that Defendant's sentence was unlawful because the district court erred by taking the disputed PSI, without further of Defendant's prior convictions, as competent proof of Defendant's prior convictions. View "State v. Letherman" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to suppress evidence obtained during a probation home visit, holding that the district court did not err in denying the suppression motion.Defendant was convicted of bail jumping and received a deferred sentence of four years. After a probation home visit resulted in the discovery of a "significant amount of methamphetamine" by a probation officer the State petitioned to revoke Defendant's deferred sentence. Defendant filed a motion to suppress, arguing that the discovery of the drugs found in her home was the result of an unlawful search. The district court denied the motion, concluding that the officer did not violate the reasonable protocols for a probation home visit. The Supreme Court affirmed, holding that what began as a home visit turned into a search pursuant to the officer's plain view observation of drug paraphernalia, which provided probable cause for the search. View "State v. Thompson" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant to seventy years in Montana State Prison for deliberate homicide, a felony, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's claim that his trial attorney provided ineffective assistance when he advised Defendant and the court that mitigated deliberate homicide was not a lesser-included offense of deliberate homicide was more appropriate for postconviction relief; and (2) the district court did not err when it concluded that the State's offer of proof provided sufficient evidence to accept Defendant's Alford plea. View "State v. Bristow" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant based on the counts of strangulation of a partner, assault of a partner, and child endangerment, holding that the district court did not err or abuse its discretion.Specifically, the Supreme Court held that the district court (1) did not abuse its discretion when it permitted Dr. Tiffany Kuehl to testify about the legal and medical definitions of strangulation; (2) did not abuse its discretion by admitting Defendant's statements made in a separate legal proceeding; (3) did not err in assuring that no prejudicial juror misconduct occurred; and (4) erred in allowing a brief statement of the make-up of the population of the high-risk, violent crimes pod of the jail, but the error was harmless. View "State v. Sneed" on Justia Law