Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction and sentence for two counts of felony tampering with witnesses, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) the State presented sufficient evidence to support Defendant's convictions for witness tampering pursuant to Mont. Code Ann. 45-7-206; (2) this Court declines to exercise plain error review of Defendant's claims of prosecutorial misconduct; and (3) trial counsel's failure to object to a alleged misconduct by the prosecutor did not constitute ineffective assistance of counsel. View "State v. Palafox" on Justia Law

The Supreme Court reversed the conclusion of the district court that the more than three-year delay between Defendant's arrest and his subsequent criminal trial did not violate his constitutional right to a speedy trial, holding that Defendant did not receive his guaranteed right to a speedy trial.Defendant was charged with assault with a weapon. After facing a lengthy wait to be evaluated for his mental fitness to stand trial Defendant received a bed at the Montana State Hospital (MSH), where his fitness for trial improved. Defendant's fitness, however, decompensated after he was sent back to jail, leading to a second admission to MSH before the case finally went to trial. A jury found Defendant guilty, and the district court denied Defendant's motion to dismiss for lack of speedy trial. The Supreme Court reversed, holding that the 1,179-day delay between Defendant's arrest and trial, due to systemic institutional problems, violated Defendant's constitutional right to a speedy trial. View "State v. Allery" on Justia Law

The Supreme Court reversed the judgment of the district court revoking Defendant's deferred sentence and sentencing him to a five-year term with the Montana Department of Corrections (DOC) and giving him credit for 138 days of time served, holding that's the district court imposed an illegal sentence.After an adjudicatory hearing, the district court found that Defendant committed several violations of his probation, as alleged by the State. The district court imposed the sentence after holding a dispositional hearing. The Supreme Court reversed, holding that the district court lacked authority to revoke Defendant's previous deferred sentence and to resentence him to a five-year DOC commitment because the deferred sentence expired before the State filed a petition to revoke. View "State v. Ellsworth" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of bail-jumping and sentencing him to ten years in prison with no time suspended, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not violate Defendant's constitutional right to confrontation by admitting minute entries by the clerk of court stating that Defendant was present at his arraignment but absent from his omnibus hearing; and (2) the trial court did not commit reversible error when it denied Defendant's motion to continue the trial date because Defendant's substantial right were not prejudiced. View "State v. Staudenmayer" on Justia Law

The Supreme Court affirmed the judgment and commitment of the district court sentencing Appellant to fifty-five years in the Montana State Prison, including a consecutive ten-year commitment to the Department of Corrections, for his two criminal endangerment convictions, holding that there was no error.On appeal, Defendant argued that his two criminal endangerment convictions violated Mont. Code Ann. 46-11-410(2)(a), the multiple charges statute, because his convictions arose from the same transaction. The Supreme Court affirmed, holding that Defendant's convictions of criminal endangerment were based on two distinct criminal offenses and therefore did not violate the multiple charges statute. View "State v. McNamara" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant for robbery, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that he did not knowingly and voluntarily waive his right to counsel during his criminal trial. Defendant also argued, for the first time, that the district court compromised his right to a unanimous jury verdict by not giving a specific unanimity instruction requiring the jury to agree that either or both victims were in fear of immediate bodily injury. The Supreme Court affirmed, holding (1) Defendant knowingly and voluntarily waived his right to counsel; and (2) this Court declines to exercise plain error review to address Defendant's second argument on appeal. View "State v. Winzenburg" on Justia Law

The Supreme Court affirmed Defendant's conviction and judgment of guilty for the offense of escape, holding that Defendant was not entitled to relief on his claims of error.The State charged Defendant with felony escape after he failed to report to his probation offense. The jury returned a guilty verdict, and Defendant was sentenced to six years' imprisonment. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant's motion to dismiss for insufficient evidence; and (2) did not err in declining to provide Defendant's requested jury instruction for criminal contempt as a lesser-included offense. View "State v. Ohl" on Justia Law

The Supreme Court reversed the district court's sentence on Defendant's convictions for escape and assault on a peace officer, holding that the district court erred in calculating credit for time served and in imposing supervisory conditions on Defendant's future parole.On appeal, Defendant argued (1) the trial court failed properly to credit the time Defendant spent in jail prior to sentencing after he was committed on another offense to the Montana Department of Corrections (DOC), and (2) the court improperly imposed supervisory conditions on Defendant's unsuspended sentence to the DOC. The State conceded the second issue on appeal. The Supreme Court reversed, holding that the district court (1) erred by granting Defendant only 56 days of credit for time served and should have given for time served in the amount of 396 days; and (2) erred in imposing supervisory conditions on Defendant's sentence when it was ordered entirely unsuspended. View "State v. Spagnolo" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting and sentencing Defendant for assault with a weapon, holding that the district court erred in its calculation of Defendant's credit for time served.On appeal, Defendant challenged several evidentiary rulings and the calculation of credit toward his sentence for time served. The Supreme Court remanded the case, holding that the district court (1) did not err by admitting the victim's hospital statement at trial as a prior inconsistent statement; (2) did not err by admitting evidence of a conversation between Defendant and his girlfriend as an admission by party-opponent; and (3) should have awarded Defendant an additional 269 days of credit for time served. View "State v. Pitkanen" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence confiscated by a adult foster care group home's manager who subsequently turned the evidence over to the police, holding that the district court did not err when it failed to suppress the evidence.The manager of the group home contacted the police on several occasions stating that she had confiscated child pornography from Defendant, a resident of the group home, pursuant to the group home's rules. The manager gave the police the confiscated evidence, which led to the grant and execution of a search warrant. Defendant was subsequently charged with possession of child pornography. Defendant moved to suppress the evidence, which the district court denied. Defendant subsequently entered into a plea agreement with the State. The Supreme Court affirmed the denial of Defendant's motion to suppress, holding (1) the group home manager was acting as a private party when she confiscated Defendant's electronic devices containing pornography; and (2) Defendant consented to the manager confiscating his electronic devices by agreeing to the group home's rules. View "State v. Larson" on Justia Law