Justia Criminal Law Opinion Summaries

The defendant, Jacob Palmer, was found guilty of felony Partner or Family Member Assault (PFMA) by the Eleventh Judicial District Court, Flathead County, following an incident where he attacked his girlfriend, K.Y., with whom he had been in a relationship for over a decade. During his trial, evidence was presented regarding prior altercations between Palmer and K.Y. Palmer appealed to the Supreme Court of the State of Montana, challenging the District Court's decision to admit this evidence.The issue before the Supreme Court of Montana was whether the District Court had abused its discretion by admitting evidence of Palmer's prior altercations with K.Y. in his PFMA trial. The Supreme Court held that the District Court had not abused its discretion. The court reasoned that the evidence of Palmer's previous altercations with K.Y. was relevant and admissible under Montana Rule of Evidence 404(b). The court explained that such evidence can provide context about the complex dynamics of domestic violence, including the cycle of abuse and the reasons why victims such as K.Y. might not immediately report the abuse or might be reluctant to discuss the abuse with law enforcement. The court further determined that the probative value of this evidence was not significantly outweighed by its potential prejudicial effect against Palmer. As such, the court affirmed the District Court's decision to admit the evidence and upheld Palmer's conviction. View "State v. Palmer" on Justia Law

The case involves an appellant, M.T.H., who was arrested for criminal endangerment after he pulled the steering wheel in his mother's vehicle while she was driving. M.T.H. was diagnosed with major depressive disorder and paranoid schizophrenia. Following his arrest, the State filed a petition for M.T.H.'s involuntary commitment to the Montana State Hospital (MSH) for up to three months. The District Court of the Twenty-First Judicial District, Ravalli County, ordered his commitment and authorized MSH to involuntarily administer medications to M.T.H. This led to an appeal to the Supreme Court of the State of Montana.The Supreme Court of Montana had two main issues to consider. The first issue was whether the District Court erroneously determined that a signed waiver constituted a sufficient record to commit M.T.H. The Supreme Court found that M.T.H.'s waiver and the District Court’s order committing him were sufficient to constitute an intentional and knowing waiver under the relevant statute. The court emphasized that the record reflected that M.T.H. understood his procedural rights and had a clear presence of mind to consider his position logically.The second issue was whether the District Court erroneously authorized MSH to administer involuntary medications to M.T.H. The Supreme Court held that the District Court erred in this aspect. It emphasized the importance of due process protections and noted that the State must demonstrate a need for involuntary medication before a court may authorize it. In this case, the State did not make this necessary showing. Therefore, the Supreme Court affirmed the District Court’s decision in part but reversed its decision to authorize involuntary medication for M.T.H. View "In re M.T.H." on Justia Law

Duane Burchill was convicted of two counts of robbery, one count of conspiracy to commit deceptive practices, and one count of possession of dangerous drugs in 2017. Following his conviction, Burchill filed a petition for postconviction relief, asserting that his counsel provided ineffective assistance by failing to object to the prosecutor’s misconduct during his trial. The Supreme Court of the State of Montana affirmed the denial of Burchill's petition for postconviction relief.Burchill's claim of ineffective assistance centered on two main arguments. First, he argued that the prosecutor repeatedly asked him to comment on the credibility of other witnesses by asking "were they lying" questions. Second, he alleged that the prosecutor posed questions suggesting his personal opinion that Burchill's testimony was not truthful.The court, however, found that the "were they lying" questions were not improper because they had probative value in evaluating the credibility of a defendant who is claiming that everyone else is lying. The court also disagreed that the prosecutor had expressed personal opinions on Burchill's credibility. The court concluded that the prosecutor's questions were within the scope of permissible questions allowed on cross-examination. Therefore, the court found that Burchill's counsel's failure to object did not constitute ineffective assistance.The court did not find it necessary to address Burchill's claim of prejudice due to the failure of his counsel to object, as it had already determined that his counsel's performance was not deficient. Thus, Burchill's petition for postconviction relief was denied. View "Burchill v. State" on Justia Law

In the state of Montana, William James Rupnow Jr., a licensed bail bondsman, was accused of criminal offenses after he tried to apprehend a client, Victorianne Dahl, who had violated her bail conditions. Dahl had consistently been late with payments and had violated other conditions of her release. Rupnow resorted to using pepper spray in his attempt to detain Dahl, leading to the State charging him with felony assault with a weapon and aggravated assault. Rupnow was ultimately acquitted on the aggravated assault charge, but the jury could not reach a verdict on the assault with a weapon charge. In response, Rupnow filed a lawsuit against the Montana State Auditor and Commissioner of Insurance, Mike Winsor, Jennifer Hudson, and XYZ government subdivision, alleging malicious prosecution, abuse of process, and violation of his rights under the Montana Constitution. The defendants requested the case be dismissed based on prosecutorial immunity, a motion which the District Court granted. Rupnow appealed the decision, arguing that as a bail bondsman, he had the authority to arrest Dahl without a warrant.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision to dismiss Rupnow's case. The Court found that Montana's statutory scheme for pre-trial release, or bail, did not provide bail bondsmen with an unfettered right to remit a bail bond client to jail without an outstanding warrant. The Court reasoned that the legislature did not intend to grant bail bondsmen arrest authority that far exceeded that of law enforcement officers. Therefore, Rupnow did not have the authority to arrest Dahl without a warrant, meaning there was probable cause to charge Rupnow with the crimes he was accused of. The Court concluded that Rupnow's claims of malicious prosecution and abuse of process failed as a matter of law. View "Rupnow v. State Auditor" on Justia Law

In this case from the Supreme Court of the State of Montana, the defendant, Cody Ray Tunnell, appealed from his conviction and sentence for driving under the influence as a fourth offense and criminal endangerment. The central issue in the appeal was whether the trial court erred by not allowing Tunnell to cross-examine a witness, Sandra Hyer, about her prior conviction for false reporting, which Tunnell argued was relevant to her credibility for truthfulness.The Supreme Court affirmed the lower court's decision. The court held that Montana Rule of Evidence 609 prohibits the introduction of prior convictions to impeach a witness, and the trial court did not abuse its discretion by not allowing Tunnell to introduce Sandy's prior conviction for false reporting. The court noted that the trial court correctly advised Tunnell that while he could not introduce the conviction itself, he could inquire about the details and circumstances surrounding the conviction as permitted under Montana Rule of Evidence 608(b). The court also rejected Tunnell's argument that a prior case, State v. Martin, supported his position, concluding that the Martin case also held that the trial court did not abuse its discretion by limiting the cross-examination of a witness to the facts surrounding her prior conviction and prohibiting the introduction of her conviction itself. View "State v. Tunnell" on Justia Law

David Abraham Lorenz was convicted in 2003 for operating an illegal drug lab and possessing illegal drugs in the state of Montana. His initial sentence was partially suspended, but multiple violations led to the suspension being lifted and further sentencing in 2005 and 2014. In 2020, the State sought to revoke his suspended sentences again. Lorenz, who initially represented himself, requested counsel in July 2021. However, prior to the dispositional hearing in August 2021, his attorney, Michael Haase, filed a motion to withdraw. Lorenz consented to this but then indicated he did not want to proceed without a lawyer. Despite a perceived conflict, Haase continued to represent Lorenz in the hearing, and Lorenz was resentenced after his suspended sentences were revoked.Lorenz appealed, arguing that the District Court had not adequately investigated his complaint about his lawyer. The Supreme Court of the State of Montana disagreed, ruling that Lorenz had not directly raised any issues about Haase's effectiveness or requested a substitution of counsel. The court further noted that Lorenz had agreed to Haase's motion to withdraw, then reaffirmed his desire for Haase's representation during the dispositional hearing. The Supreme Court thus affirmed the District Court's decision. View "State v. Lorenz" on Justia Law

In the case before the Supreme Court of the State of Montana, the plaintiff, Billy Ann Merila, sought the expulsion of her business partner, Daniel Brian Burke, from their partnership, MBC. MBC is a business entity that owns a single piece of real property and rents it out for income. Merila alleged that Burke engaged in conduct that made it not reasonably practicable for her to carry on the business in partnership with him. Burke, a certified public accountant, was convicted on six charges of aiding and assisting tax fraud, unrelated to MBC, and sentenced to prison. He also unilaterally changed the partnership's depository without Merila's consent, limited her authority over MBC funds, refused to communicate with her directly, and appointed a third-party agent to act on his behalf. He also attempted to amend the partnership's tax returns and capital accounts without Merila's consent or knowledge.The District Court granted summary judgment in favor of Merila, finding that Burke's conduct made it not reasonably practicable for her to carry on the business in partnership with him. The court also ordered the parties to negotiate a purchase price for Burke's interest in MBC. Burke appealed the decision.Upon review, the Supreme Court of the State of Montana affirmed the District Court's decision. The Supreme Court noted that the relevant standard for expelling a partner is whether the partner's conduct has made it not reasonably practicable for the other to carry on the business in partnership, not whether the partnership suffered damages or harm. The Court found that Burke's refusal to interact with Merila, his unilateral decisions affecting the partnership, and his conviction of tax fraud constituted conduct that made it not reasonably practicable for Merila to carry on the business with him as a partner. It affirmed the lower court's decision to expel Burke from the partnership and order him to negotiate a purchase price for his interest in MBC. View "Merila v. Burke" on Justia Law

In the Supreme Court of the State of Montana, defendant Nels Jerry Peterson appealed his conviction on the offense of sexual assault against his eleven-year-old step-granddaughter (Q.H.). The main contention was the District Court’s decision to permit evidence of Peterson’s prior sexual conduct with other young girls under M. R. Evid. 404(b) and 403. The court concluded that some of the evidence may have been admissible for a permissible purpose under Rule 404(b), but the potential for unfair prejudice substantially outweighed its probative value as presented. The details of Peterson’s prior sexual misconduct were not more abhorrent than the current charge. However, the frequency and manner of the State’s references to them throughout the trial risked inducing the jury’s hostility toward Peterson, resulting in unfair prejudice. Further, the State did not meet its burden to show no reasonable possibility that its use of the tainted evidence might have contributed to Peterson’s conviction. Therefore, the court reversed the conviction and remanded the case for a new trial. View "State v. Peterson" on Justia Law

In Montana, Hannah Rose Kuntz was charged with Violation of a Protective Order and pleaded not guilty. The City of Great Falls requested multiple continuances due to witness unavailability, with the final one being due to a key witness being quarantined due to exposure to COVID-19. The trial was set for a date beyond the statutory six-month deadline for a speedy trial, prompting Kuntz to file a motion to dismiss for lack of speedy trial. The Municipal Court denied the motion, citing good cause due to public health concerns and uncertainty about the ability to convene the requisite number of jurors due to the COVID-19 pandemic. Kuntz changed her plea to guilty and later appealed the Municipal Court's order to the District Court. The District Court affirmed the Municipal Court's determination of good cause for delay.Upon Kuntz's appeal, the Supreme Court of the State of Montana affirmed the lower courts' decisions. The Supreme Court found that the Municipal Court's factual findings were not clearly erroneous and that its legal conclusions were correct. It was determined that the totality of the facts and circumstances surrounding trial scheduling and the COVID-19 pandemic provided good cause for the delay in Kuntz's trial. The Supreme Court also highlighted that the Municipal Court was in the best position to assess local trends and manage its docket in accordance with health risks. The court concluded that there was no prejudice to Kuntz and that the public health risks outweighed any potential prejudice, providing good cause to delay the trial two days beyond the deadline. View "Great Falls v. Kuntz" on Justia Law

In this case, the Supreme Court of the State of Montana upheld the decision of the Montana First Judicial District Court, Lewis and Clark County, committing the appellant, C.M., a youth, to the custody of the Department of Corrections for placement in a state youth correctional facility until the age of 18. The appellant was charged with sex offenses against three of his high school classmates and he appealed the decision on the grounds that he was denied the right to effective assistance of counsel when his attorney failed to make objections to the admission of various hearsay statements.The court concluded that the appellant's counsel's failure to object to the admission of hearsay statements did not result in substantial prejudice. The court noted that the state presented sufficient admissible evidence to the jury that proved the same facts as the prior consistent statements and bus records. Furthermore, the court found that the appellant's counsel vigorously challenged the complaining witnesses' testimony by highlighting inconsistencies and gaps in their testimony, as well as aspects of the investigation. As a result, the court found that the appellant failed to demonstrate that he was prejudiced by any alleged deficient performance by his counsel and affirmed the lower court's decision. View "Matter of C.M" on Justia Law