Justia Criminal Law Opinion Summaries

Defendant was convicted of disorderly conduct in the Bozeman Municipal Court. Defendant was sentenced to pay a $100 fine and $135 in surcharges and fees. Defendant appealed his sentence to the district court, asserting eight grounds for appeal. The district court declined appellate jurisdiction and remanded the matter to the municipal court for enforcement of Defendant’s sentence, determining that Defendant’s $100 fine did not satisfy the threshold amounts for appellate jurisdiction set forth in the applicable rules or statutes and that it was unlikely that Defendant would prevail on any of the issues raised. The Supreme Court affirmed, holding that the district court’s denial of Defendant’s motion to appeal did not constitute an abuse of discretion or error. View "City of Bozeman v. King" on Justia Law

Defendant was convicted of criminal possession of dangerous drugs after police officer discovered Oxycodone residue on a spoon in Defendant’s possession. During trial, the court instructed the jury that Defendant could assert as a defense that he had obtained the Oxycodone pursuant to a valid prescription. When, during deliberations, the jury asked the court whether crushing prescription Oxycodone violated the law, the court responded that the jury was to rely “on the instructions previously given.” Defendant appealed, contending that the court abused its discretion in refusing to further instruct the jury on the legality of crushing prescription Oxycodone. The Supreme Court affirmed, holding that the district court did not abuse its discretion in deciding to refer the jury back to its original instructions. View "State v. Temple" on Justia Law

Defendant was convicted of five felony charges stemming from his illegal baiting, killing, and transportation or assistance in illegal baiting, killing, and transportation of nine black bears. The district court imposed a ten-year suspended prison sentence and twenty-six conditions. Thereafter, the State filed a motion to conform the district court’s written judgment to its oral pronouncement of Defendant’s sentence. The district court denied the motion. The Supreme Court affirmed in part and reversed in part, holding (1) the district court incorrectly applied the law when it denied the State’s petition to conform its written judgment to its oral pronouncement by striking the provision in Condition 23 that allows Defendant to petition for early termination of his lifetime hunting, fishing, and trapping prohibition; and (2) the district court correctly determined that Defendant may petition for early termination of his lifetime prohibition on accompanying any hunter, angler, or trapper. View "State v. Harrison" on Justia Law

After a jury trial, Defendant was convicted of reckless driving and failing to yield to an emergency vehicle. Defendant appealed, arguing that the victim’s in-court identification was impermissibly suggestive and unreliable and that a police officer’s testimony regarding vehicle registration information received from dispatch was inadmissible hearsay. The district court denied the appeal. The Supreme Court affirmed, holding that the trial court (1) did not err in allowing the victim’s in-court identification of Defendant at trial; and (2) did not abuse its discretion in admitting testimony concerning vehicle registration information received from police dispatch. View "City of Billings v. Nolan" on Justia Law

After a jury trial, Defendant was convicted of criminal endangerment. Defendant appealed, arguing that the district court erred in refusing to instruct the jury on negligent endangerment as a lesser included offense of criminal endangerment and that she was entitled to a new trial on that basis. The Supreme Court affirmed, holding that the evidence demonstrates that Defendant acted knowingly in engaging in conduct that created a substantial risk of death or serious bodily injury to another, and therefore, the district court did not abuse its discretion in concluding that the evidence was insufficient to support an instruction on negligent endangerment as a lesser included offense of criminal endangerment. View "State v. Russell" on Justia Law

After a jury trial, Defendant was convicted of criminal production or manufacture of dangerous drugs. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in instructing the jury on the theory of accountability when the State did not charge Defendant with accountability in the information; (2) the district court did not abuse its discretion when it allowed the State to admit Defendant’s medical marijuana provider application during rebuttal; (3) the prosecutor’s statements during closing argument were not improper; and (4) the district court acted within the proper bounds of its discretion when it denied Defendant’s request for a surrebuttal closing argument. View "State v. Dobrowski" on Justia Law

After a jury trial, Defendant was found guilty of sexual assault and sexual intercourse without consent. The Supreme Court affirmed, holding that the district court (1) did not violate Defendant’s constitutional right to a public trial in closing to the public a hearing on the admissibility of the victim’s prior allegations of sexual abuse; (2) did not err in preventing Defendant from questioning the victim about prior allegations of sexual abuse; and (3) did not err by not disclosing information contained in sealed records after conducting an in camera review. View "State v. Hoff" on Justia Law

After a jury trial, Defendant was convicted of threats and other improper influence in official matters, criminal trespass, and disorderly conduct. The Supreme Court affirmed the improper influence conviction and reversed the conviction for criminal trespass, holding (1) the Court declines to consider in this appeal Defendant’s argument that the improper influence statute is unconstitutionally overbroad; (2) the State presented sufficient evidence to convict Defendant of improper influence; (3) the State did not present sufficient evidence to convict Defendant of criminal trespass; (4) the district court did not abuse its discretion in allowing evidence of prior incident with the arresting officer; and (5) the Court declines to consider whether Defendant’s counsel provided deficient representation by failing to object to the jury instructions on mental state. View "State v. Spottedbear" on Justia Law

After a jury trial, Defendant was found guilty of sexual assault and sexual intercourse without consent. The Supreme Court affirmed, holding that the district court (1) did not violate Defendant’s constitutional right to a public trial when it closed to the public a hearing on the admissibility of the victim’s prior allegations of sexual abuse; (2) did not abuse its discretion in preventing Defendant from questioning the victim about prior allegations of sexual abuse; and (3) did not err by not disclosing information contained in sealed records after conducting an in camera review. View "State v. Hoff" on Justia Law

After a jury trial, Defendant was convicted of two counts of attempted sexual abuse of children (referred to as “attempted possession of child pornography”). Defendant appealed, arguing that there was insufficient evidence to support his convictions. The Supreme Court affirmed, holding that the State met its evidentiary burden at trial to prove beyond a reasonable doubt that an appreciable fragment of the crime was in such progress that Defendant would have knowingly possessed child pornography unless interrupted by circumstances independent of his own will, as required by the relevant statute. View "State v. Colburn" on Justia Law