Justia Criminal Law Opinion Summaries

Cissy Deen Manyhides was placed on probation after pleading guilty to Endangering the Welfare of a Child. As a condition of her probation, she agreed to make her residence open and available to probation officers for home visits or searches upon reasonable suspicion, and to refrain from possessing illegal drugs. In February 2022, probation officers conducted a home visit at her apartment. During a walkthrough for safety and compliance, one officer observed drug paraphernalia in plain view in her bedroom. This led to a further search of her belongings, revealing additional contraband and suspected methamphetamine. Manyhides was subsequently charged with drug possession and possession of drug paraphernalia.The Eighth Judicial District Court of Montana reviewed Manyhides’s motion to suppress the evidence, arguing that the officers’ actions constituted an unlawful search. The District Court denied the motion, finding that the officers’ conduct during the home visit did not amount to a search under the law. Manyhides then pleaded guilty to felony drug possession while reserving her right to appeal the suppression ruling.The Supreme Court of the State of Montana reviewed the District Court’s decision. The Supreme Court held that a standard probation home visit, conducted pursuant to explicit probation conditions, does not constitute a search requiring reasonable cause. The Court found that Manyhides had no reasonable expectation of privacy precluding such visits, as she had agreed to the conditions of her probation. The officers’ actions remained within the permissible scope of a home visit until contraband was observed in plain view, at which point reasonable cause existed for a further search. The Supreme Court affirmed the District Court’s denial of the motion to suppress. View "State v. Manyhides" on Justia Law

The defendant was charged with multiple felony and misdemeanor violations for repeatedly contacting his estranged wife in violation of a temporary order of protection issued in May 2022. After the order was dismissed due to the protected party’s absence at a hearing, the defendant continued his prohibited communications, including sending over 100 text messages in a short period. He was arrested and later entered into a plea agreement, acknowledging the State’s intent to seek Persistent Felony Offender (PFO) status but securing a promise that the State would not pursue the PFO designation if he complied with certain conditions, including not committing further offenses or violating bail.The Eighth Judicial District Court, Cascade County, presided over the case. After the defendant pled guilty, he was released on his own recognizance. However, prior to sentencing, the State alleged that the defendant violated release conditions by continuing to contact the protected party. The State then sought to pursue the PFO designation, arguing that the defendant’s breach of the plea agreement allowed it to deviate from its original sentencing recommendation. The District Court continued the sentencing hearing to allow briefing and argument on whether the State’s PFO notice was timely and whether the defendant had breached the agreement. The District Court found that the State’s notice, although sent two minutes after the deadline, was sufficient and that the defendant suffered no prejudice from the timing.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in accepting the State’s PFO notice and imposing a PFO sentence, and whether plain error review should be conducted regarding the court’s omnibus hearing procedure. The Supreme Court held that the State’s PFO notice was compliant and timely for statutory purposes, and that the defendant was not prejudiced by the minor delay. The Court also declined to exercise plain error review over the omnibus hearing procedure. The judgment of the District Court was affirmed. View "State v. Anderson" on Justia Law

Erin Holcomb was convicted of deliberate homicide following an incident at a friend’s house near Fairfield, Montana. On the night in question, Holcomb and two friends arrived at the home after drinking and shooting guns earlier in the day. Holcomb brought a handgun into the house and was seen handling it repeatedly. After a dispute over driving due to intoxication, Holcomb refused to leave the driver’s seat of a truck, leading to a heated argument with the host, Trysten Fellers. Later, Fellers called his father for help, and after further attempts to get the guests home, Fellers drove his farm truck out to where Holcomb was in a field. Fellers stopped the truck, illuminating Holcomb, and a gunshot was heard. Fellers was found with a fatal gunshot wound, and Holcomb was arrested the next morning.The State of Montana charged Holcomb with deliberate homicide in the Ninth Judicial District Court. At trial, Holcomb’s defense requested a jury instruction on justifiable use of force, arguing that evidence showed Holcomb feared imminent harm from Fellers, who allegedly assaulted and pursued him. The District Court denied this request, finding insufficient evidence that Holcomb was in imminent danger of death or serious bodily injury. After a five-day trial, the jury found Holcomb guilty.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in refusing the justifiable use of force instruction. The Supreme Court held that the trial record did not support the instruction, as there was no evidence that Fellers physically assaulted Holcomb, drove threateningly, or fired a weapon at him. The Court concluded that Holcomb’s fear was not reasonable or supported by the evidence, and affirmed the conviction. View "State v. Holcomb" on Justia Law

The case concerns a defendant who was charged with felony distribution of dangerous drugs in Montana, based on alleged conduct between July 2017 and February 2018. During pretrial proceedings, the State redacted portions of discovery materials, including a police report and a witness interview transcript, to exclude information not related to the defendant or not considered impeachment evidence. The witness in question, Ferguson, was facing federal charges and ultimately testified at trial that she had supplied the defendant with methamphetamine but denied receiving any promises or benefits for her testimony, aside from immunity from state charges.At trial in the Eighth Judicial District Court, several witnesses testified to the defendant’s involvement in drug transactions. Ferguson’s testimony was corroborative but not the sole evidence against the defendant. After the defendant’s conviction, a federal prosecutor filed a motion to reduce Ferguson’s sentence, citing her assistance in the defendant’s case. The defendant’s counsel was unaware of this at the time of trial and sentencing. The defendant later filed a petition for postconviction relief, arguing that the State violated its obligations under Brady v. Maryland by failing to disclose potential benefits to Ferguson and under Napue v. Illinois by not correcting her allegedly false testimony regarding those benefits. The District Court denied the petition, finding no evidence of a pretrial agreement or expectation of benefit that could be imputed to the State, and concluded that any non-disclosure was not material to the outcome.The Supreme Court of the State of Montana affirmed the District Court’s denial of postconviction relief. The Court held that, while evidence of a witness’s expectation of a benefit may be subject to disclosure, the record did not establish that such an expectation existed or that it could be imputed to the State prosecutor. Furthermore, the Court found that any non-disclosure was not material, as other substantial evidence supported the conviction. The Court also rejected the Napue claim, finding no basis to conclude the State knowingly allowed false testimony. View "Temple v. State" on Justia Law

The defendant was charged with eight offenses, including sexual abuse of children under 12 and incest. He entered into a plea agreement with the State, pleading guilty to all counts in exchange for the State’s agreement to recommend specific terms of incarceration for each offense. The plea agreement was silent regarding any restrictions on parole eligibility and expressly allowed only the defendant, not the State, to argue for any legal sentence.After the plea agreement was executed, the Seventh Judicial District Court, Dawson County, held a sentencing hearing. At that hearing, the State recommended a 40-year parole restriction, even though the agreement did not mention parole restrictions. The defendant did not object at the hearing but requested no parole restriction. The District Court ultimately sentenced the defendant to 75 years in prison, with a 40-year parole restriction, explicitly referencing the State’s recommendation in its decision.The Supreme Court of the State of Montana reviewed the case. Applying plain error review due to the lack of objection at sentencing, the court held that the prosecutor breached the plea agreement by recommending a parole restriction not contemplated by the agreement. The court distinguished this case from State v. Lewis, 2012 MT 157, because, unlike in Lewis, the plea agreement here did not allow the State to argue for any lawful sentence. The court found that the breach affected the fairness of the proceedings, as the District Court’s decision was explicitly based on the prosecutor’s improper recommendation. The Supreme Court of Montana reversed the District Court’s sentence and remanded for a new sentencing hearing before a different judge, ordering specific performance of the plea agreement. View "State v. Walton" on Justia Law

The case concerns Lloyd Mortier Barrus, who, along with his son Marshall, was involved in a series of violent events in Montana in May 2017. After a period of escalating paranoia and antigovernment rhetoric, Barrus and Marshall engaged in a high-speed chase and shootout with law enforcement, resulting in the death of Deputy Sheriff Mason Moore and the disabling of two police vehicles. Barrus was arrested after a standoff in which both he and Marshall fired at officers; Marshall was killed, and Barrus surrendered. Barrus was charged with deliberate homicide by accountability and two counts of attempted deliberate homicide by accountability.The First Judicial District Court, Broadwater County, presided over Barrus’s trial. Prior to trial, Barrus was found unfit to proceed due to a mental disorder but was later restored to fitness through involuntary medication. After a jury convicted Barrus on all counts, the court held a bifurcated evidentiary hearing to determine whether Barrus’s mental disease or disorder rendered him unable to appreciate the criminality of his conduct or to conform his behavior to the law, as required by § 46-14-311, MCA. Expert testimony was presented by both parties, with conflicting opinions regarding Barrus’s mental state at the time of the offense.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by sentencing Barrus to the Department of Corrections (DOC) rather than the Department of Public Health and Human Services (DPHHS). The Supreme Court held that the District Court did not abuse its discretion, finding substantial evidence supported the conclusion that Barrus appreciated the criminality of his actions and could have conformed his conduct to the law. The judgment sentencing Barrus to DOC custody was affirmed. View "State v. Barrus" on Justia Law

The defendant, while on probation for prior convictions, was involved in a series of incidents that led to multiple criminal charges. After fleeing from law enforcement during a stop, he was apprehended and his backpack, which he initially denied owning, was searched. The search revealed illegal drugs, drug paraphernalia, and a mask matching the description of one worn by a gunman in a recent shooting. He was subsequently charged with attempted deliberate homicide, assault with a weapon, drug offenses, and obstructing a peace officer. Additionally, the State sought to revoke his previously suspended sentences.The First Judicial District Court of Montana denied the defendant’s motion to suppress evidence found in his backpack, finding that law enforcement had particularized suspicion to justify the stop and subsequent search. The court also denied his motion to substitute counsel after a hearing, concluding that the defendant’s complaints did not establish good cause for new representation. The defendant was convicted by juries on the drug charges and the attempted deliberate homicide and assault charges. The court revoked his suspended sentences and imposed new sentences, ordering all to run concurrently.On appeal, the Supreme Court of the State of Montana addressed three main issues. First, the Court held that the District Court erred by allowing a key witness to testify via video deposition at trial without a proper showing of the witness’s unavailability, violating the defendant’s confrontation rights. The State conceded this error, and the Supreme Court reversed the convictions for attempted deliberate homicide and assault with a weapon, remanding for a new trial on those charges. The Court affirmed the denial of the motion to suppress and the motion to substitute counsel, finding no abuse of discretion. The Court also ordered new sentencing for the drug convictions and the revocation of suspended sentences, as the original sentences were influenced by the now-reversed convictions. View "State v. Songer" on Justia Law

A sixteen-year-old youth admitted to sexually assaulting his two younger half-siblings, ages six and seven, over a period spanning late 2021 to early 2023. The abuse involved coercion through threats of withholding privileges and included both physical and digital penetration. The youth was charged with multiple counts of felony sexual assault and incest, and a more serious charge was dismissed as part of a plea agreement. A psychosexual evaluation found the youth to be at moderate risk of reoffending and recommended against requiring registration as a sexual offender, suggesting that avoiding registration would better support his rehabilitation. The victims’ family members and therapist, however, advocated for registration due to the trauma suffered.The Fourth Judicial District Court, Missoula County, reviewed the psychosexual evaluation, probation officer’s report, and victim impact statements. The court designated the youth as a Level 2 Sexual Offender, committed him to a youth correctional facility until age 18, and placed him on probation until age 21. Despite recommendations against registration from the evaluator and probation officer, the court ordered the youth to register as a sexual offender for life, citing the need to protect the public given the nature of the offenses and the youth’s position of trust.On appeal, the Supreme Court of the State of Montana considered whether the District Court abused its discretion in imposing the registration requirement. The Supreme Court held that the District Court acted within its discretion, finding substantial evidence supported the decision and that the court properly considered the statutory requirements and public interest. The Supreme Court affirmed the District Court’s order requiring the youth to register as a sexual offender. View "In re B.J.B." on Justia Law

Rodney Owen Skurdal, who is not a licensed attorney, attempted to represent Ronald Trow during Trow’s initial appearance in a criminal case in Yellowstone County Justice Court. Judge Jeanne Walker, presiding over the case, ordered Skurdal to vacate the defendant’s table and did not permit him to represent Trow, as Skurdal was not a member of the bar. Trow subsequently entered a plea of not guilty, and a public defender was appointed. Skurdal then filed a lawsuit in the Thirteenth Judicial District Court for Yellowstone County against Judge Walker, later joined by Yellowstone County as a defendant, alleging violations of his and Trow’s rights and advancing various arguments, including those associated with the “Sovereign Citizen” movement.The Thirteenth Judicial District Court dismissed Skurdal’s complaint with prejudice, holding that Judge Walker and Yellowstone County were protected by absolute judicial immunity for actions taken in the course of judicial duties. The court also found that Skurdal, as a non-lawyer, had no statutory or constitutional right to represent another individual in a criminal proceeding in Montana. The court denied leave to amend the complaint, finding that any amendment would be futile due to the immunity defense.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal. The Supreme Court held that Montana law does not permit non-lawyers to represent others in criminal cases, and that Judge Walker’s actions were judicial acts performed within her jurisdiction, entitling her and Yellowstone County to absolute immunity from suit. The Court also concluded that the District Court did not err in denying leave to amend, as further amendment could not overcome the immunity bar. View "Skurdal v. Walker" on Justia Law

The defendant was originally sentenced in 2003 in Lewis and Clark County, Montana, to 20 years with 16 years suspended. In 2008, after committing new offenses, he was sentenced in Yellowstone County to five years, to run concurrently with the Lewis and Clark sentence. In 2009, his suspended sentence in the Lewis and Clark case was revoked, and he was resentenced to 16 years with 11 years suspended. The Department of Corrections (DOC) treated the sentences as consecutive, not concurrent, based on statutory default. Over the years, the defendant repeatedly challenged the calculation of his sentences and the credit for time served, arguing that the sentences should have run concurrently and that he was entitled to additional credit for time served.The First Judicial District Court, Lewis and Clark County, most recently revoked the defendant’s suspended sentence in 2023, imposing an 11-year commitment with six years suspended, and granted him 62 days of credit for time served and 1,167 days of elapsed time credit. The defendant appealed, arguing that the court failed to award the proper amount of credit for time served, specifically for periods when he was incarcerated and for time when the sentences should have been running concurrently.The Supreme Court of the State of Montana held that the district court erred by not awarding the correct amount of credit for time served. The Court determined that, under Montana law and its own precedents, the revocation sentence could not be run consecutively to the earlier sentence, and the defendant was entitled to additional credit for time served. The Court reversed the district court’s order and remanded with instructions to amend the judgment to grant the defendant an additional 2,220 days of credit for time served, in addition to the credits already awarded. View "State v. Keech" on Justia Law