Justia Criminal Law Opinion Summaries

Articles Posted in Montana Supreme Court
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The Supreme Court reversed the judgment of the district court convicting Defendant of deliberate homicide committed with a dangerous weapon, holding that the district court made numerous erroneous rulings amounting to cumulative error and requiring reversal. Specifically, the Court held (1) the district court erred by excluding statements the victim made to Defendant as hearsay; (2) the district court erred by prohibiting a limited inquiry into the State’s expert witness’s credibility; (3) the district court acted within its discretion in resolving the jury’s concern about media publicity; and (4) the cumulative effect of the first two errors denied Defendant of his right to a fair trial. View "State v. Cunningham" on Justia Law

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The Supreme Court reversed the judgment of the district court convicting Defendant of deliberate homicide committed with a dangerous weapon, holding that the district court made numerous erroneous rulings amounting to cumulative error and requiring reversal. Specifically, the Court held (1) the district court erred by excluding statements the victim made to Defendant as hearsay; (2) the district court erred by prohibiting a limited inquiry into the State’s expert witness’s credibility; (3) the district court acted within its discretion in resolving the jury’s concern about media publicity; and (4) the cumulative effect of the first two errors denied Defendant of his right to a fair trial. View "State v. Cunningham" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of aggravated assault and reversed his conviction for violating a no-contact order. The Court held (1) the State did not present sufficient evidence for the jury to find Defendant guilty of violating a no-contact order; and (2) the prosecutor’s comment during rebuttal closing argument that the jury’s “job” was to ensure the alleged victim’s safety was improper, and the nature of the remark implicated Defendant’s right to a fair trial, but this isolated incident of alleged misconduct did not result in a miscarriage of justice or compromise the integrity of Defendant’s trial. View "State v. Ritesman" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of aggravated assault and reversed his conviction for violating a no-contact order. The Court held (1) the State did not present sufficient evidence for the jury to find Defendant guilty of violating a no-contact order; and (2) the prosecutor’s comment during rebuttal closing argument that the jury’s “job” was to ensure the alleged victim’s safety was improper, and the nature of the remark implicated Defendant’s right to a fair trial, but this isolated incident of alleged misconduct did not result in a miscarriage of justice or compromise the integrity of Defendant’s trial. View "State v. Ritesman" on Justia Law

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The Supreme Court affirmed the judgment of the district court sentencing Defendant to the Department of Corrections (DOC) for five years and imposing financial obligations on Defendant, including public defender fees, supervision fees, presentence investigation report fees and surcharges.Defendant pled guilty to felony possession of dangerous drugs. The district court sentenced Defendant as a persistent felony offender and prescribed the minimum sentence thereunder. Defendant appealed his sentence. The Supreme Court affirmed, holding (1) the district court appropriately considered alternatives to imprisonment; and (2) Defendant’s claims of ineffective assistance of counsel were more appropriate for presentation through a petition for postconviction relief. View "State v. Hinshaw" on Justia Law

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The Supreme Court affirmed the judgment of the district court sentencing Defendant to the Department of Corrections (DOC) for five years and imposing financial obligations on Defendant, including public defender fees, supervision fees, presentence investigation report fees and surcharges.Defendant pled guilty to felony possession of dangerous drugs. The district court sentenced Defendant as a persistent felony offender and prescribed the minimum sentence thereunder. Defendant appealed his sentence. The Supreme Court affirmed, holding (1) the district court appropriately considered alternatives to imprisonment; and (2) Defendant’s claims of ineffective assistance of counsel were more appropriate for presentation through a petition for postconviction relief. View "State v. Hinshaw" on Justia Law

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The district court erred by imposing a restriction upon Defendant’s release from incarceration while committing him to the Department of Corrections (DOC).Defendant pleaded guilty to attempted prostitution. The district court committed Defendant to the DOC and ordered that he could not be released from incarceration until he had completed sexual offender treatment. The Supreme Court reversed and remanded for resentencing, holding that, under statute, a sentence cannot include both a placement to the DOC while also imposing incarceration by way of a restriction on release until the defendant completes sex offender treatment. View "State v. Day" on Justia Law

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The district court erred by imposing a restriction upon Defendant’s release from incarceration while committing him to the Department of Corrections (DOC).Defendant pleaded guilty to attempted prostitution. The district court committed Defendant to the DOC and ordered that he could not be released from incarceration until he had completed sexual offender treatment. The Supreme Court reversed and remanded for resentencing, holding that, under statute, a sentence cannot include both a placement to the DOC while also imposing incarceration by way of a restriction on release until the defendant completes sex offender treatment. View "State v. Day" on Justia Law

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The Supreme Court affirmed the district court order denying Defendant’s motion to dismiss for entrapment as a matter of law.Defendant was charged with felony attempted prostitution. Thereafter, Defendant filed a motion to dismiss, asserting the affirmative defense of entrapment. The district court denied the motion to dismiss as a matter of law, concluding that the record contained conflicting facts as to the origination of criminal intent and Defendant’s state of mind that made submitting the issue of entrapment to a jury proper. The Supreme Court affirmed, holding that the district court correctly denied Defendant’s motion to dismiss based on the affirmative defense of entrapment as a matter of law because conflicting facts existed as to whether Defendant had the requisite intent to commit the criminal act. View "State v. Lindquist" on Justia Law

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The Supreme Court affirmed the district court order denying Defendant’s motion to dismiss for entrapment as a matter of law.Defendant was charged with felony attempted prostitution. Thereafter, Defendant filed a motion to dismiss, asserting the affirmative defense of entrapment. The district court denied the motion to dismiss as a matter of law, concluding that the record contained conflicting facts as to the origination of criminal intent and Defendant’s state of mind that made submitting the issue of entrapment to a jury proper. The Supreme Court affirmed, holding that the district court correctly denied Defendant’s motion to dismiss based on the affirmative defense of entrapment as a matter of law because conflicting facts existed as to whether Defendant had the requisite intent to commit the criminal act. View "State v. Lindquist" on Justia Law