Justia Criminal Law Opinion Summaries

In November 2006, Lloyd Kvelstad was murdered at a house party in Havre, Montana. Evidence showed that James Main was involved in a physical altercation with Kvelstad, during which Main choked Kvelstad multiple times. Kvelstad was later found severely beaten and unresponsive. Main was arrested and charged with deliberate homicide by felony murder. At trial, various testimonies and forensic evidence linked Main to the crime, leading to his conviction in February 2009.Main appealed his conviction, but the Montana Supreme Court upheld it in 2011, finding sufficient evidence to support the jury's verdict. Main later filed a petition for postconviction relief, alleging that the State violated his Brady rights by failing to disclose certain crime scene photos. He argued that these photos were crucial for determining the time and cause of Kvelstad's death. The District Court denied Main's petition without holding a hearing, taking judicial notice of findings from a co-defendant's postconviction case.The Montana Supreme Court reviewed the case and affirmed the District Court's decision. The Court found that even if the missing photos had been disclosed, they would not have changed the outcome of the trial. The evidence already presented was sufficient to establish Main's guilt for deliberate homicide by felony murder. The Court also found that Main's petition did not present newly discovered evidence but rather a new theory of the crime. Therefore, the District Court did not abuse its discretion in denying the petition without a hearing. View "Main v. State" on Justia Law

Jay Le Cleveland was approached by Polson police officers for a welfare check after a 911 caller reported him slumped over the steering wheel of his running car. Upon interaction, Cleveland explained he was fine but had burning eyes. When asked for his driver’s license, Cleveland stated he did not have it. The officer then verified Cleveland’s probation status and, with authorization from Cleveland’s probation officer, conducted a search of Cleveland’s car, finding drugs and a digital scale. Cleveland was charged with felony possession with intent to distribute.The Twentieth Judicial District Court denied Cleveland’s motion to suppress the evidence obtained from the search, ruling that the officer had particularized suspicion to expand the welfare check into a drug investigation. Cleveland entered a plea agreement, pleading no contest to one count and agreeing to pay a $300 prosecution fee, while reserving the right to appeal the suppression ruling.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court’s decision. The Court held that the officer had reasonable cause to continue the interaction beyond the initial welfare check based on Cleveland’s behavior and responses. The Court also found that the probation officer had reasonable suspicion to authorize the search of Cleveland’s car. Additionally, the Court upheld the $300 prosecution fee, noting that Cleveland had agreed to it in his plea deal and did not object at sentencing. View "State v. Cleveland" on Justia Law

Ariel Jonae Powers was charged with arson in September 2020. In August 2021, her attorney informed the court that an evaluator found her unfit to proceed. The court ordered the evaluation to be filed under seal and allowed the State to respond. The State agreed with the unfitness finding and requested Powers be committed to the Montana State Hospital (MSH) for evaluation and treatment. In December 2021, the court stayed the proceedings, committed Powers to the Department of Public Health and Human Services, and she was transferred to MSH.Powers moved to dismiss the charge in March 2022, arguing the court failed to review her fitness within 90 days as required by law. Six days later, she was released from MSH after being found fit to proceed. The evaluators' report was filed with the court in March 2022. The District Court denied her motion to dismiss in May 2022, stating her commitment duration was less than 90 days from her admission to MSH. Powers then pled no contest to misdemeanor negligent endangerment and was sentenced to one year in the Park County Detention Center, all suspended, with fines and fees totaling $175.The Supreme Court of the State of Montana reviewed the case. Powers argued that the failure to review her fitness within 90 days required dismissal of the charges. The court held that while the statute mandates a review within 90 days, it does not automatically compel dismissal if the review is delayed. The court emphasized that dismissal is required only if the defendant remains unfit and unlikely to become fit in the foreseeable future. The court found that Powers regained fitness within a reasonable time, and thus, the District Court did not err in denying her motion to dismiss. The Supreme Court affirmed Powers's conviction. View "State v. Powers" on Justia Law

Garrett Michael O’Howell was arrested following a traffic stop on May 4, 2020. Broadwater County Sheriff’s Deputy Tony Cordova observed a vehicle in a parking lot and found the behavior of its occupants suspicious. The vehicle was registered to Kaitlyn Smock, whose driver’s license was revoked. After Smock drove the vehicle away, Cordova stopped it for speeding and because of Smock’s revoked license. None of the passengers, including O’Howell, had a valid driver’s license. Cordova discovered that O’Howell had an outstanding warrant and arrested him. A subsequent search of the vehicle revealed methamphetamine and drug paraphernalia.The First Judicial District Court denied O’Howell’s motion to suppress the evidence, concluding that the stop was justified and that Cordova’s actions were lawful. The court found that Cordova had a particularized suspicion to stop the vehicle and that the questioning of the passengers was within the scope of the stop. O’Howell was convicted by a jury of criminal possession of dangerous drugs with intent to distribute and possession of drug paraphernalia.The Supreme Court of the State of Montana reviewed the case. The court held that Cordova’s questioning of the passengers did not exceed the scope of the traffic stop, as it was necessary to determine if any of them could legally drive the vehicle. The court also found that there was sufficient evidence to support the jury’s verdict, including testimony from Smock and Laird, corroborated by O’Howell’s own statements and the physical evidence found in the vehicle. The court affirmed the lower court’s decision, upholding O’Howell’s convictions. View "State v. O'Howell" on Justia Law

Joshua Allen Baldwin was arrested by Officer Daniel Beasley on July 22, 2021, at Lucky Lil’s Casino in Anaconda, Montana, for allegedly violating his pre-release conditions by being in a casino. Beasley confirmed with dispatch that Baldwin was under court conditions prohibiting him from being in such establishments. After Baldwin was arrested, officers observed suspicious items in his car, including a butane refill bottle, burnt pliers, and a Ziploc baggie with a white crystalline substance. A subsequent search of Baldwin’s car, conducted after obtaining a warrant, revealed methamphetamine and drug paraphernalia.The Third Judicial District Court, Anaconda-Deer Lodge County, denied Baldwin’s motion to suppress the evidence obtained from the search, ruling that the arrest was lawful. Baldwin then pleaded guilty to felony drug possession while reserving his right to appeal the suppression ruling. The misdemeanor charge for drug paraphernalia was dismissed.The Supreme Court of the State of Montana reviewed the case and reversed the lower court’s decision. The court held that Beasley did not have probable cause to arrest Baldwin for contempt of court based on the alleged violation of pre-release conditions. The court determined that pre-release conditions do not constitute an independent mandate of the court under Montana law, and thus, Baldwin’s arrest was unlawful. Consequently, the evidence obtained from the search of Baldwin’s car, which was conducted as a result of the unlawful arrest, should have been suppressed. The court found no applicable exceptions to the exclusionary rule, such as good faith or independent source exceptions, and concluded that the evidence was directly tied to the unlawful arrest. View "State v. Baldwin" on Justia Law

In May 2023, the State charged Samuel Wade Frydenlund with burglary, stalking, and partner or family member assault. Frydenlund intended to present a defense of mental disease or defect. Before trial, the court dismissed the stalking and assault charges, proceeding only with the burglary charge. Frydenlund requested that the jury be instructed on criminal trespass as a lesser included offense of burglary. The court agreed to include this instruction if the jury could not reach a verdict on the burglary charge.At trial, the jury found Frydenlund not guilty of burglary but guilty of criminal trespass. Frydenlund moved to set aside the verdict, arguing that the jury should not have considered the lesser offense after acquitting him of burglary. The Ninth Judicial District Court denied his motion, stating that it was not inconsistent to find him not guilty of burglary but guilty of criminal trespass, as the latter requires proof of fewer elements.The Supreme Court of the State of Montana reviewed the case. The court held that the verdict form and jury instructions were consistent with Montana law, specifically § 46-16-607(3), MCA, which allows the jury to consider a lesser included offense if it cannot reach a verdict on the greater offense. The court found no double jeopardy violation, as Frydenlund was convicted of only one crime—criminal trespass. The court affirmed the District Court's decision, concluding that the jury's consideration of the lesser included offense was appropriate and that Frydenlund's rights were not violated. View "State v. Frydenlund" on Justia Law

In April 2020, Christopher I. Toulouse was charged with multiple offenses, including misdemeanor partner or family member assault (PFMA), felony intimidation, felony stalking, and misdemeanor violation of a no-contact order, following a series of harassing incidents directed at his ex-girlfriend, L.J. Toulouse pled guilty to PFMA, intimidation, and stalking under a plea agreement, and the State dismissed the no-contact order violation. The District Court initially intended to impose a consecutive sentence for stalking but allowed Toulouse to withdraw his guilty pleas. Toulouse later re-entered his guilty pleas and was sentenced to a combination of suspended and active sentences.The Fourth Judicial District Court of Missoula County sentenced Toulouse to a total of 15 years, with 10 years suspended. In April 2021, the State filed a petition to revoke Toulouse’s suspended sentences due to new charges. Toulouse admitted to two violations, and the District Court revoked his suspended sentences, imposing a 15-year commitment to the Montana State Prison (MSP) with no time suspended.The Supreme Court of the State of Montana reviewed the case. Toulouse argued that the new sentence was illegal because it imposed a longer imprisonment term than his original sentence. The Court agreed, noting that under Montana law, a district court can only impose a sentence upon revocation that does not exceed the original sentence's imprisonment term. The Court found that the District Court's sentence of a 15-year MSP commitment exceeded the original suspended sentence's terms, making it illegal. The Supreme Court reversed the District Court's decision and remanded the case for further proceedings consistent with its opinion. View "State v. Toulouse" on Justia Law

Chris Landon Loberg was convicted of Criminal Possession of Dangerous Drugs after a guilty plea. He appealed a decision by the Tenth Judicial District Court, which denied his motion to suppress evidence found in his vehicle. Loberg argued that the law enforcement officers lacked sufficient particularized suspicion to conduct a canine sniff of his vehicle.The Tenth Judicial District Court found that Officer Connelly had particularized suspicion based on several factors: Loberg's pinpoint pupils, the smell of a masking agent, his presence at a casino, old reports associating him with drug users, and his delayed response to being pulled over. The court concluded that these factors collectively justified the canine sniff and denied Loberg's motion to suppress the evidence.The Supreme Court of the State of Montana reviewed the case and reversed the District Court's decision. The Supreme Court found that the totality of the circumstances did not amount to particularized suspicion. The court noted that pinpoint pupils alone were insufficient for a drug possession investigation, the smell of a single air freshener was not enough to suggest masking illegal drugs, and the old, uncorroborated reports in the police database were unreliable. Additionally, Loberg's brief stop at the casino and his delayed but safe pull-over did not provide specific indicia of criminal activity. The Supreme Court held that the evidence obtained from the canine sniff should be suppressed, as the officer's suspicion was no more than a generalized hunch. The decision of the lower court was reversed. View "State v. Loberg" on Justia Law

Andrew McCurdy entered a plea agreement in February 2022, pleading guilty to felony criminal mischief and agreeing to pay restitution. The District Court ordered a presentence investigation (PSI) report, which included McCurdy’s juvenile records without a Youth Court order. McCurdy filed motions to strike the juvenile records from the PSI and to determine his ability to pay certain fees. The District Court denied the motion to strike, stating the records were provided pursuant to a court order, and imposed a $50 PSI fee and probation supervision costs without inquiring into McCurdy’s ability to pay.The Eleventh Judicial District Court denied McCurdy’s motion to strike his juvenile records, reasoning that the records were provided under a court order and could be considered at sentencing. The court also imposed the PSI fee and probation supervision costs without determining McCurdy’s ability to pay, despite his motion requesting such an inquiry. McCurdy appealed these decisions.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court’s decision to include McCurdy’s juvenile records in the PSI, finding that any error in the procedure was harmless as McCurdy did not demonstrate prejudice. However, the Supreme Court reversed the imposition of the $50 PSI fee and probation supervision costs, noting that the District Court failed to inquire into McCurdy’s ability to pay, as required by law. The case was remanded for the District Court to conduct the necessary inquiry into McCurdy’s financial situation before imposing these costs. View "State v. McCurdy" on Justia Law

James Edward Meuret II was sentenced to two years with the Department of Corrections, all time suspended, for criminal possession of dangerous drugs. Meuret appealed, arguing that his attorney at the District Court rendered ineffective assistance of counsel (IAC) and requested the court to vacate the judgment and allow him to withdraw his plea of no contest. The case arose from a traffic stop on July 22, 2019, where police found methamphetamine and paraphernalia in Meuret's vehicle after arresting him on an outstanding warrant.Initially, Meuret was represented by Casey Moore from the Office of State Public Defender (OPD). Meuret pleaded not guilty to both charges but reserved the right to file a motion to suppress evidence, which was never filed. On the morning of his trial, Meuret decided to enter a plea of nolo contendere to the drug possession charge in exchange for the dismissal of the paraphernalia charge. He acknowledged waiving his constitutional rights and expressed no issues with his counsel. Later, Meuret considered withdrawing his plea, but no motion was filed by the deadline. A new attorney, Mark Epperson, was assigned and filed a motion to suppress evidence instead of a motion to withdraw the plea, which the District Court rejected as untimely.The Montana Supreme Court reviewed the case and applied the two-pronged test from Strickland v. Washington to assess IAC claims. The court found that the record did not sufficiently demonstrate the reasons behind Moore's and Epperson's actions. The court noted that IAC claims require a developed record, which was lacking in this case. Consequently, the court affirmed the District Court's judgment but allowed Meuret the option to pursue his IAC claims through a petition for postconviction relief. View "State v. Meuret" on Justia Law