Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court wherein Defendant pled guilty to felony driving under the influence of alcohol, fourth or subsequent offense, and three misdemeanors. On appeal, Defendant argued that the district court violated his right to due process during sentencing and erred in sentencing him, and that he was denied the effective assistance of counsel during sentencing. The Supreme Court affirmed and remanded for entry of an amended judgment, holding (1) the district court did not deprive Defendant of his right to due process during sentencing; (2) the district court did not err in imposing a condition on Defendant’s suspended sentence; (3) Defendant was not deprived of effective assistance of counsel during sentencing; and (4) the sentencing conditions in the written judgment should be amended to conform to oral pronouncement of the conditions. View "State v. Lafield" on Justia Law

The Supreme Court denied Petitioner’s petition for a writ of habeas corpus, holding that Petitioner’s sentence of 110 years’ imprisonment, without the possibility of parole, for deliberate homicide with the use of a weapon did not violate his Eighth Amendment rights even where Petitioner committed the offense when he was seventeen years old. At issue was whether Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, __ U.S. __ (2016), apply to Montana’s discretionary sentencing scheme and whether Petitioner’s sentence qualifies as a de facto life sentence to which Miller and Montgomery apply. The Supreme Court held (1) Miller and Montgomery apply to discretionary sentences in Montana; and (2) Petitioner’s sentence, when viewed in light of Petitioner’s eligibility for day-for-day good time credit and the concurrent sentence he was serving in Washington, did not qualify as a de facto life sentence to which Miller’s substantive rule applied. View "Steilman v. Michael" on Justia Law

The State filed an amended information charging Defendant of thirteen counts. Thereafter, federal prosecutors obtained an indictment against Defendant for four federal charges. The State then filed a second amended in information to remove from the first amended information transactions that were the subject of the federal indictment. Defendant filed a motion to dismiss, which the district court denied. A jury subsequently found Defendant guilty of aggravated kidnapping and sexual intercourse without consent. Defendant then pled guilty to federal count two and the other federal charges were dismissed. Upon Defendant’s second trial on the remaining State charges, the jury found Defendant guilty of all counts except for burglary and an alternative theft charge. Defendant moved to dismiss the state felony charges on statutory multiple prosecution grounds. The district court denied the motion. Before Defendant was sentenced on the state charges, he filed this appeal. The Supreme Court held (1) a defendant can appeal the denial of a motion for dismissal under Mont. Code Ann. 46-11-504(1) prior to the entry of a final judgment; and; (2) the district court did not err by denying Defendant’s motion under section 46-11-504(1) to dismiss the charges of deceptive practices, burglary, and felony theft, given his federal conviction for possession of stolen firearms. View "State v. Burton" on Justia Law

The Supreme Court affirmed the order of the district court granting Defendant’s motion to withdraw his plea of guilty to one count of felony sexual assault.After entering his guilty plea, Defendant moved to withdraw his guilty plea and rescind the plea agreement. The district court granted the motion, concluding that Defendant had established good cause to withdraw his plea. The court based its decision primarily on its conclusion that defense counsel had rendered ineffective assistance of counsel and on the threatening atmosphere surrounding the proceedings. The Supreme Court affirmed, holding (1) the State was authorized to appeal the district court’s order granting Defendant’s motion to withdraw his guilty plea; and (2) the district court did not err by determining that good cause existed to permit Defendant to withdraw his guilty plea. View "State v. Terronez" on Justia Law

The Supreme Court affirmed the judgment of the district court rejecting a reoffered plea agreement between the State and Appellant and leaving Appellant’s conviction undisturbed, despite a federal district court’s direction that the State reoffer Appellant an originally un-communicated and favorable plea proposal.Appellant was convicted of aggravated kidnapping and other crimes. Appellant later applied for a writ of habeas corpus in federal district court, arguing that he received ineffective assistance of counsel (IAC) because his counsel failed to communicate a plea offer to him. The federal district court granted Appellant’s petition relating to his IAC claim and remanded the case. In accordance with the court’s directions, the State reoffered Appellant an equivalent plea. The district court rejected the reoffered plea agreement because Appellant was unwilling to accept responsibility for his actions at the time the plea offer was made. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in rejecting the reoffered plea agreement; and (2) did not err by not allowing Appellant to withdraw his guilty plea after it rejected the reoffered plea agreement. View "State v. Rose" on Justia Law

Defendant pleaded no contest to felony criminal endangerment under Mont. Code Ann. 45-5-207. The district court imposed a ten-year sentence to the Department of Corrections, with five years suspended. Defendant appealed, asserting claims of judicial bias and ineffective assistance of counsel. At no time during the proceedings did Defendant state a claim of judicial bias against the district court. The Supreme Court affirmed, holding (1) this court declines to undertake consideration of the merits of Defendant’s bias allegation pursuant to the plain error doctrine; and (2) Defendant’s claim of ineffective assistance of counsel was not reviewable on direct appeal. View "State v. Howard" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of criminal endangerment. On appeal, Defendant asserted judicial bias and argued that his appointed counsel violated their duty of loyalty. The Supreme Court held (1) this court declines to undertake consideration of the merits of Defendant’s bias allegation pursuant to the plain error doctrine because Defendant’s assertion of bias did not implicate a fundamental right or convince the court that failure to review the claim would result in a manifest miscarriage of justice, leave unsettled the question of the fundamental fairness of the trial proceedings, or compromise the integrity of the judicial process; and (2) Defendant’s ineffective assistance of counsel claims were not reviewable on direct appeal because they were not factually established in the record. View "State v. Howard" on Justia Law

The Supreme Court held that the district court did not err in dismissing Defendant’s motion to dismiss the State’s petition to revoke her suspended sentence on the ground that there had been a four-year delay in executing the arrest warrant.In 2009, the district court issued a “Montana only” warrant for the arrest of Defendant, who was on probation. Thereafter, Defendant was convicted of another offense in Colorado, where, several times, Defendant was paroled and then her sentence was revoked. Defendant discharged her Colorado sentences in 2013. That same year, Defendant was arrested on the 2009 warrant. Defendant moved to dismiss the petition to revoke her suspended sentence, arguing that the State violated her right to due process by failing to bring her to court without unnecessary delay. The district court concluded that Defendant had not suffered a deprivation of due process and then determined that Defendant had violated the terms of her original sentence. The Supreme Court affirmed, holding that the district court did not err in denying Defendant’s motion to dismiss the revocation petition. View "State v. Koon" on Justia Law

The Supreme Court affirmed the order of the district court affirming the municipal court’s denial of Defendant’s motion to suppress blood evidence in a driving under the influence of alcohol (DUI) proceeding against him, holding (1) the district court did not err in denying Defendant’s motion to suppress a telephonic search warrant issued pursuant to Mont. Code Ann. 61-8-402(5) to draw Defendant’s blood; and (2) this court declines to address Defendant’s argument that the warrant was invalid because Defendant did not receive the implied consent advisory prior to his blood draw. View "City of Missoula v. Williams" on Justia Law

The Supreme Court vacated the sentence imposed upon Defendant following his plea of no contest to sexual assault, holding that the district court erred in accepting Defendant’s no contest plea, and therefore, the district court could not have imposed a valid sentence upon Defendant. The district court erred in accepting Defendant’s no contest plea because generally, a court may not accept a plea of nolo contendere in a case involving a sexual offense, and the term sexual offense is statutorily defined to include sexual assault. The Supreme Court voided the plea agreement and remanded the matter to the district court to allow Defendant to enter a legal plea to the original charges, enter a new plea agreement, or to proceed to trial. View "State v. Hansen" on Justia Law