Justia Criminal Law Opinion Summaries

The Supreme Court reversed Defendant's conviction of criminal distribution of dangerous drugs, methamphetamine, and criminal possession of dangerous drugs, methamphetamine, holding that the district court erred in denying Defendant's motion to disclose the identity of a confidential informant.After Defendant was charged, Defendant filed a motion asking the district court to compel the State to disclose the identity of the confidential informant that led to Defendant's arrest. The district court denied the motion. After a second trial, the jury convicted Defendant. On appeal, Defendant argued that she had the right to know the identity of the informant because the informant played a continuous, active, and primary role in the alleged crime. The Supreme Court agreed, holding that, considering the circumstances of the case balanced against the public's interest in withholding the confidential informant's identity, the district court erred in denying Defendant's motion to compel disclosure of the informant's identity. View "State v. Walston" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual intercourse without consent, holding that the district court abused its discretion and compromised Defendant's right to a fair trial when it allowed expert witness testimony on statistics about false reports of sexual assault.On appeal, Defendant argued that the trial court's admission of the expert testimony regarding the statistics about false reports of rape prejudiced his right to a fair trial by turning the case into a "trial by statistic" rather than a case based on specific facts. The Supreme Court reversed, holding (1) the expert testimony regarding the rate of false reports of sexual assault was improper, and the district court abused its discretion in admitting the testimony; and (2) Defendant's right to a fair trial was violated by the improper admission of the false reporting statistics. View "State v. Grimshaw" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony strangulation of his girlfriend, holding the evidence was sufficient to support the conviction, and Defendant did not receive ineffective assistance of counsel.Specifically, the Supreme Court held (1) the evidence was sufficient to sustain Defendant's conviction of felony strangulation; (2) Defendant failed to meet the prejudice standard set forth in Strickland v. Washington, 466 U.S. on his claim that his counsel was ineffective by opening the door to evidence of Defendant's prior violence; and (3) this Court declines to review for plain error Defendant's argument challenging the district court's instruction on the mental state for strangulation. View "State v. Dineen" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of sexual intercourse without consent, holding that the district court did not err in denying Defendant's motion to strike a prospective juror for cause.After the district court denied Defendant's motion to remove the prospective juror for cause Defendant used a peremptory challenge to strike her from the panel and exhausted all of his peremptory challenges. Defendant appealed, arguing (1) the prospective juror's voir dire statements demonstrated an inability to act fairly and impartially in his trial, and therefore, the district court abused its discretion in denying his for-cause challenge; and (2) because he had to exercise a peremptory strike to remove the juror and subsequently exhausted his peremptory challenges, the error was prejudicial. The Supreme Court disagreed, holding that the district court did not abuse its discretion in accepting the prospective juror's assurances that she could fairly and impartially weigh the evidence despite her initial statements of prejudice. View "State v. Morales" on Justia Law

The Supreme Court reversed the judgment of the district court designating Defendant as a persistent felony offender (PFO) and imposing an enhanced sentence under Mont. Code Ann. 46-18-502 , holding that the PFO designation failed.Defendant was convicted of distributing dangerous drugs. The State sought to designate Defendant as a PFO based on a 2014 Montana conviction for burglary and a 1994 federal conviction for bank robbery. The district court sentenced Defendant to the minimum PFO sentence enhancement. The Supreme Court reversed, holding that Defendant's federal bank robbery conviction was not reasonably equivalent to a Montana robbery conviction, and therefore, it may not be used as a predicate violent offense under Mont. Code Ann. 46-1-202(18) to impose a persistent felony offender sentence enhancement. View "State v. Scott" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's motion to suppress the evidence discovered during a police officer's chemical "field test" on the contents of a syringe found in Defendant's jacket pocket, holding that a rudimentary chemical field test of a lawfully seized substance is not a constitutionally protected search requiring a warrant.Defendant was placed under arrest after driving with a suspended driver's license and without vehicle insurance. While searching Defendant incident to his arrest, the arresting officer located a used syringe in Defendant's front jacket pocket. When booking Defendant into jail, the officer conducted a field test on the contents of the syringe. The field test came back positive for methamphetamine. Defendant filed a motion to suppress, arguing that the field test of the syringe's contents without a warrant constituted an unlawful search that violated his reasonable expectations of privacy. The district court denied the motion to suppress. The Supreme Court affirmed, holding that Defendant had no reasonable expectation of privacy violated by a test for the presence of methamphetamine in a syringe lawfully seized from his person, and therefore, Defendant could not assert the constitutional protections afforded to a search. View "State v. Funkhouser" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted deliberate homicide, holding that a challenged jury instruction did not undermine the fundamental fairness of the proceeding.After a jury trial, Defendant was convicted of attempted deliberate homicide. On appeal, Defendant argued that the district court's "specific purpose" jury instruction warranted review under either the doctrine of plain error or ineffective assistance of counsel and that the prosecutor's comment warranted plain error review by the Supreme Court. The Supreme Court affirmed, holding (1) the trial court's instruction did not result in a manifest miscarriage of justice, and the claimed error by trial counsel in failing to object to the instruction did not prejudice Defendant; and (2) the prosecutor's conduct did not warrant plain error review. View "State v. St. Marks" on Justia Law

The Supreme Court affirmed the district court's denial of Appellant's petition for postconviction relief and the court's order granting partial summary judgment in favor of the State, holding that the district court did not err.Defendant was convicted of vehicular homicide while under the influence, failure to stop immediately at the scene of an accident involving an injured person, and driving without a valid driver's license. Defendant later filed a petition for postconviction relief, alleging ineffective assistance of counsel (IAC), Brady violations, and newly discovered evidence of her innocence. The district court granted summary judgment on Defendant's newly discovered evidence claims and Brady claim and then denied the remainder of the claims after a hearing. The Supreme Court affirmed, holding that the district court did not err by (1) denying Defendant's postconviction petition based on her claim of ineffective assistance of counsel; (2) concluding that the State did not violate Defendant's due process rights by failing to disclose certain non-exculpatory photographs; and (3) dismissing Defendant's newly discovered evidence claim. View "Garding v. State" on Justia Law

The Supreme Court reversed Defendant's conviction and sentence for burglary, holding that the district court erred by requiring Defendant to pay restitution for pecuniary losses resulting from offenses committed by others absent evidence of criminal accountability or a causal connection between Defendant's offense and those losses.Defendant was one of several persons involved in multiple burglaries of the main house, garage, and separate guest house owned by Elden and Betty White. Defendant pled guilty to burgling the guest house. The district court concluded that Defendant should be jointly and severally responsible with his associates for the entire amount of pecuniary loss of $43,294 sustained by the Whites as a result of the burglaries. The Supreme Court reversed the restitution order, holding that where there was no record evidence that Defendant's admitted commission of the guest house burglary directly caused any pecuniary loss resulting from any burglary of the main house or garage by others, the district court erred by ordering Defendant to pay restitution for pecuniary losses sustained by the Whites as a result of the burglaries of their main house. View "State v. Pierre" on Justia Law

The Supreme Court reversed the sentencing order and judgment issued by the district court following Defendant's conviction of assault on a peace officer, a felony, holding that Defendant did not use a "weapon" pursuant to Montana law and thus could not be convicted for a violation of Mont. Code Ann. 45-5-210(1)(b).The Supreme Court reversed Defendant's conviction of assault on a peace officer, a felony, in violation of Mont. Code Ann. 45-5-210(1)(b), holding that there was insufficient evidence to convicted Defendant of assault on a peace officer. On appeal, Defendant argued that the State did not present sufficient evidence to convict him because he did not use a weapon during the incident. Rather, Defendant used a "nonfunctioning CO2 pellet gun." The Supreme Court agreed with Defendant, holding that the non-operational BB gun did not qualify as a "weapon" under the facts of this case. View "State v. Stillsmoking" on Justia Law