Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the district court imposing sentencing conditions limiting Defendant's ability to access the internet or possess certain electronic devices, holding that three conditions were overly broad.Defendant pled guilty to one count of sexual intercourse without consent for communicating with the victim through text messaging and Snapchat. The district court sentenced Defendant to a twelve year term of incarceration and imposed the conditions at issue on appeal regarding technology use. The Supreme Court reversed the district court's imposition of the three challenged conditions, holding that, in their current incarceration, the conditions failed to consider the multiple legitimate purposes for internet usage, but that, as modified by the Court, the conditions provided Defendant the change to rehabilitate outside of the prison setting and the community protection from future criminal activity. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to dismiss for lack of a speedy trial, holding that, while the State did not show a valid reason for the over 1,300-day delay in bringing Defendant's case to trial, Defendant was not prejudiced.On May 23, 2017, the State charged Defendant with felony criminal distribution of dangerous drugs and felony criminal possession of dangerous drugs with intent to distribute. On February 10, 2021, Defendant pleaded guilty to criminal distribution of dangerous drugs, and the remaining charge was dismissed. On appeal, Defendant argued that the district court erred in denying his motion to dismiss for lack of a speedy trial. The Supreme Court affirmed, holding that the district court did not err in its balance of the speedy trial factors and in concluding that Defendant was not denied his right to a speedy trial. View "State v. Daly" on Justia Law

The Supreme Court reversed Defendant's convictions and sentence for negligent vehicular assault, resisting arrest, and disorderly conduct, holding that the district court committed reversible error by responding to the jury's questions about the definition and timing of "arrest" without first consulting Defendant and counsel on record.On appeal, Defendant argued that his right to be present was violated during a point at trial "where the jury made a substantive inquiry about the law pertaining to the charge of resisting arrest" under the facts of this case. The Supreme Court agreed and reversed as to Defendant's conviction for resisting arrest, holding that when the district court responded to questions from the deliberating jury outside of Defendant's presence, it constituted reversible error because it was during a critical stage of the proceedings. View "State v. Zitnik" on Justia Law

The Supreme Court affirmed Defendant's conviction for threats and other improper influence in official and political matters but remanded for the district court to strike its imposition of pretrial supervision costs, holding that the court erred in imposing pretrial supervision costs without considering Defendant's ability to pay. Specifically, the Supreme Court held (1) considering the probative value of the evidence and the limited risk of unfair prejudice, the district court did not abuse its discretion Under Iowa R. Evid. 403 by admitting evidence of Defendant's prior sex offense; and (2) the district court erred by imposing pretrial supervision costs without considering whether Defendant had the ability to pay the costs. View "State v. Hardin" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Defendant's request to provide a jury instruction on th lesser-included offense of mitigated deliberate homicide and the ensuing sentencing order and judgment for felony deceptive practices, holding that there was insufficient evidence to support Defendant's conviction of deceptive practices.On appeal, Defendant argued that the district court erroneously refused his request to provide a jury instruction on the lesser-included offense of mitigated deliberate homicide and that insufficient evidence supported the jury's guilty verdict as to his felony deceptive practices conviction. The Supreme Court affirmed, holding (1) Defendant's first claim of error was unavailing; and (2) the evidence was legally insufficient to convict Defendant of felony deceptive practices, and therefore, acquittal on this count was proper. View "State v. Craft" on Justia Law

The Supreme Court reversed the judgment of the municipal court sentencing Appellant for operating a motor vehicle with a blood alcohol content of .08 percent or greater (DUI per se), first offense, holding that the municipal court lawfully ordered Appellant to satisfy a $600 fine using his COVID-19 stimulus payment but erred in concluding that it did not have discretion to suspend the fine or to enforce the fine through an alternative method of payment.Appellant pleaded guilty to an amended misdemeanor charge of first-offense DUI per se and agreed to the minimum $600 fine with the understanding that he would ask the court to consider his ability to pay the fine. The municipal court sentenced Appellant to ten days of incarceration and a $600 fine. Appellant appealed, arguing that the municipal court erred in imposing the fine despite his inability to pay. The district court affirmed. The Supreme Court reversed, holding that the municipal court abused its discretion by not recognizing that it possessed the discretion to order Appellant to satisfy the mandatory fine via alternative methods to a dollar-for-dollar repayment plan ordered by the municipal court. View "City of Whitefish v. Curran" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to dismiss the State's felony charge against him for failure to register as a sexual offender, holding that the Sexual or Violent Offender Registration Act (SVORA), as amended since 2007, was punitive in nature.Defendant was convicted of sexual assault in 1994 and served and discharged his sentence. At the time, SVORA, known then as Montana's Sexual offender Registration Act, required Defendant to maintain registration for ten years. When the legislature amended SVORA, it included more onerous steps and applied them retroactively to previously convicted registrants such as Defendant. In 2019, Defendant was charged with failure to register. Defendant appealed, arguing that the amended SVORA requirements rendered the statute an unconstitutional ex post facto punishment for his earlier crime. The Supreme Court reversed, holding (1) SVORA as amended is punitive in nature; and (2) therefore, the requirements brought on by those amendments could not retroactively be applied to defendants whose convictions predate the amendments. View "State v. Hinman" on Justia Law

The Supreme Court affirmed Defendant's convictions for two homicides and two attempts to solicit a third homicide, holding that Defendant was not entitled to relief on his allegations of error.After a jury trial, Defendant was convicted of two counts of deliberate homicide and two counts of solicitation to commit deliberate homicide and sentenced to serve four concurrent sentences of life imprisonment. The Supreme Court affirmed, holding (1) the State's use of jailhouse informants did not violate Defendant's right to counsel; (2) the jury was fully and fairly instructed as to the applicable law; (3) any error on the part of the trial court in limiting defense counsel's ability to comment on a missing prosecution witness during closing argument; and (4) this Court will not exercise plain error review to consider whether Defendant's allegations of prosecutorial misconduct and other trial errors deprived him of a fair trial. View "State v. Hardy" on Justia Law

The Supreme Court affirmed Defendant's conviction of assault with a weapon and his commitment to the Department of Public Health and Human Service (DPHHS) for the duration of his twenty-year sentence with ten years suspended, holding that Defendant was not entitled to relief on his allegations of error.Defendant pleaded guilty to assault with a weapon, and the parties agreed to recommend that Defendant be committed to the Department of Public Health and Human Services (DPHHS) for the duration of his sentence. Defendant was subsequently sentenced to twenty years in DPHHS's custody with ten years suspended. Defendant appealed, arguing that the district court unjustly resumed his criminal proceedings due to the lengthy period between his arrest and the date he regained fitness to stand trial. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's motion to dismiss because resuming Defendant's criminal proceedings was not unjust. View "State v. Gibson" on Justia Law

The Supreme Court affirmed the order of the district court requiring Broadwater County to provide to Helena Independent Record (IR) or other interested persons redacted videographer and documentation records pertaining to Jason Ellsworth's May 2021 stop by and encounter with a Montana Highway Patrol officer, holding that there was no error.Ellsworth pleaded guilty to an obstructing a peace officer. Thereafter, a reporter with the IR requested from Broadwater County a copy of Ellsworth's investigative file. Petitioner, a county attorney, determined that the file contained confidential criminal justice information and filed a petition seeking a declaratory ruling to clarify and enforce the rights of recovery to redacted confidential criminal justice information (CCJI) contained in the file. Petitioner also filed a separate motion for leave to deposit the investigative file under seal. The district court (1) concluded that Ellsworth's criminal case had been completed and that the declaratory action was ripe for decision; and (2) held that Ellsworth's privacy rights outweighed the public's right to know regarding certain information irrelevant to the charge. The Supreme Court affirmed, holding that Ellsworth was given a proper opportunity to participate, and his due process right was not infringed regarding the release of the CCJI. View "Broadwater Co. v. Release of Confidential Criminal Justice Information" on Justia Law