Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the district court’s denial of Defendant’s two motions to dismiss the charges against him for sexual abuse of children.Pursuant to a plea agreement, Defendant pleaded guilty to one count of sexual abuse of children. Defendant reserved the right to appeal the district court’s denial of his two motions to dismiss. The Supreme Court affirmed, holding (1) the district court properly found that there was sufficient evidence that a rational jury could have found Defendant guilty of sexual abuse of children because he knowingly possessed child pornography; and (2) Montana’s statutory definition of possession under Mont. Code Ann. 45-2-101(59) is not unconstitutionally vague as applied to Defendant’s conduct. View "State v. Harrington" on Justia Law

The Supreme Court affirmed the district court’s determination that Defendant, who pled guilty to deliberate homicide, was competent to stand trial and that, at the time of the offense, Defendant was able to appreciate his behavior and conform to the requirements of the law. The court held (1) the district court did not err when it found that Defendant was competent to stand trial and was competent when he entered his guilty plea; (2) the district court did not err when it found that, at the time of the offense, Defendant was able to appreciate his behavior and conform his conduct to the requirements of the law; and (3) sentencing Defendant to prison did not violate his constitutional rights to be free from cruel and unusual punishments and to human dignity. View "State v. Spell" on Justia Law

The Supreme Court reversed the municipal court’s order denying Petitioner’s motion to dismiss the charge against him, holding that the municipal court abused its discretion in declaring a mistrial and in concluding that double jeopardy did not bar Petitioner’s retrial.Petitioner was charged with partner or family member assault (PFMA). The City of Billings moved for a mistrial, and the trial judge declared a mistrial based on the purportedly inconsistent testimony of a City’s witness. The judge then rescheduled Petitioner’s trial. Petitioner filed a motion to dismiss the PFMA on double jeopardy grounds. The municipal court denied the motion. The Supreme Court reversed, holding (1) there was no manifest necessity to discontinue the trial, and Petitioner’s conduct did not demonstrate a waiver of his right to object to termination of the proceedings and to a retrial; and (2) therefore, retrying Petitioner for the PFMA charge would violate his federal and state fundamental constitutional rights to be free from double jeopardy. View "Billings ex rel. Huertas v. Billing" on Justia Law

The Supreme Court affirmed Defendant’s conviction for felony driving under the influence (DUI), concluding that the district court did not err in denying Defendant’s motion to dismiss on the grounds that two of his prior convictions upon which the State based its felony enhancement were obtained in violation of his constitutional right to counsel. The district court denied the motion to dismiss on the ground that Defendant had not met his burden of rebutting the presumption of regularity that attached to the prior convictions. The Supreme Court affirmed, holding (1) the district court did not clearly err in finding that Defendant failed to satisfy his burden to rebutting the presumption of regularity in his two prior convictions; and (2) therefore, the district court’s determination that those convictions could be used for felony enhancement purposes was correct. View "State v. Rasmussen" on Justia Law

The Supreme Court affirmed the district court’s imposition of a seven and one-half year parole restriction on Defendant’s sentence for obstructing justice but remanded for the purpose of striking the condition that Defendant register as a violent offender.Defendant was convicted of criminal endangerment and obstructing justice. Defendant was sentenced to ten years imprisonment, parole restricted for the entire term, on her criminal endangerment conviction and ten years imprisonment, parole restricted for seven and one-half years, on her conviction for obstructing justice, to be served consecutively to her criminal endangerment sentence. The Supreme Court held that the district court (1) did not err by imposing a parole eligibility restriction on Defendant’s sentence for obstructing justice; but (2) erred in requiring Defendant to register as a violent offender where neither of the crimes of which Defendant was convicted are included among the crimes requiring violent offender registration. View "State v. Old Bull" on Justia Law

The district court erred by concluding that particularized suspicion did not exist for the investigatory stop of Defendant.The Supreme Court reversed the order of the district court reversing the municipal court’s order denying Defendant’s motion to suppress evidence related to his arrest for driving under the influence of alcohol (DUI). The district court concluded that the trial court’s finding that Defendant was apprehended for a technical violation was clearly erroneous. The Supreme Court disagreed, holding (1) the district court erred in finding from the evidence that Defendant was stopped for “alleged behavior,” which required its own assessment and speculation about the record; and (2) there was substantial evidence in the record to support the municipal court’s findings of fact about the reasons that Defendant’s vehicle was stopped. View "City of Helena v. Brown" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence of a traffic stop based on the law enforcement officer’s lack of particularized suspicion. After an evidentiary hearing, the district court concluded that that particularized suspicion existed and denied the motion. Defendant then entered a nolo contendere plea to driving under the influence. Defendant appealed, challenging the denial of his motion to suppress. The Supreme Court affirmed, holding that, based on the totality of the circumstances, the district court’s determination that particularized suspicion existed was not clearly erroneous. View "State v. Nelson" on Justia Law

The Supreme Court reversed the order of the district court affirming the justice court’s denial of Defendant’s motion to suppress evidence obtained subsequent to an investigative law enforcement stop. On appeal, the district court concluded that sufficient particularized suspicion of criminal activity existed to temporarily detain Defendant for questioning prior to arrest. The Supreme Court reversed, holding that the justice court erred in concluding that the officers had an objectively reasonable particularized suspicion that Defendant had committed, was committing, or was about to commit a criminal offense. Therefore, the justice court erred in denying Defendant’s motion to suppress evidence obtained subsequent to his seizure. View "State v. Hoover" on Justia Law

The Supreme Court affirmed the city court’s denial of Defendant’s motion to dismiss the charges of reckless driving, criminal mischief, DUI-second offense, and negligent endangerment. In his motion, Defendant argued that the arresting officer failed to read the Montana implied consent advisory and that the failure violated Defendant’s due process rights. After the city court denied the motion, Defendant pleaded guilty to reckless driving, criminal mischief, and DUI-first offense. The district court upheld the denial of Defendant’s motion to suppress, ruling that the appropriate remedy for the failure of an officer to advise an accused of the right to an independent test is the suppression of any blood or breath tests the State may have undertaken. The Supreme Court affirmed, holding (1) because there was no test result in this case, there was nothing to suppress; and (2) the officer’s failure to notify Defendant of his right to obtain an independent blood test did not impede Defendant’s right to obtain such a test, nor did it not violate Defendant’s due process rights. View "State v. Berger" on Justia Law

The district court correctly denied Defendant’s motion to suppress evidence based on an alleged lack of particularized suspicion to seize his vehicle.A trooper stopped Defendant for expired North Dakota vehicle registration. The trooper informed Defendant that he had a particularized suspicion of criminal activity within the vehicle and therefore would deploy a drug canine. After the dog alerted near the driver’s side door, the trooper applied for and received a warrant to search the vehicle. The State later charged Defendant with multiple drug counts. The district court denied Defendant’s motion to suppress, and Defendant pleaded guilty to possession of dangerous drugs. The Supreme Court affirmed, holding (1) the district court did not err in concluding that the canine search of Defendant’s vehicle was lawfully conducted pursuant to a particularized suspicion of narcotics activity; and (2) the search of Defendant’s vehicle was lawfully carried out pursuant to a valid search warrant. View "State v. Estes" on Justia Law