Justia Criminal Law Opinion Summaries

In Montana, Robert Murray Gibbons was found guilty of driving under the influence, his fifth or subsequent offense. On appeal to the Montana Supreme Court, Gibbons raised three issues. First, he argued that the District Court incorrectly instructed the jury that he did not need to be conscious to be in actual physical control of his vehicle. The Supreme Court disagreed, finding that the instruction was consistent with the preventative purpose of the state's DUI statute.Second, Gibbons argued that the State’s rebuttal argument, which suggested that he could have introduced photographic evidence that was available to him during discovery, violated his constitutional rights. The Supreme Court rejected this argument, concluding that the State was entitled to respond to Gibbons’ accusation that it had improperly withheld evidence.Finally, Gibbons challenged the constitutionality of the statute that imposed a mandatory minimum $5,000 fine for his offense, arguing that it did not take into account a defendant’s ability to pay. The Supreme Court agreed with Gibbons on this point, finding that the statute was facially unconstitutional because it required the imposition of a mandatory fine in every case without considering constitutionally required proportionality factors, such as the financial burden on the defendant and the defendant’s ability to pay.Thus, the Supreme Court affirmed Gibbons’s DUI conviction, but reversed the $5,000 fine and remanded the case to the District Court for recalculation of the fine in line with its opinion. View "State v. R. Gibbons" on Justia Law

In November 2019, Vietnam veteran Bruce Schroder was charged with criminal mischief, a felony, after he removed an Uber sign from driver Jamie Hauge's car and pounded on the vehicle when several younger women offered Hauge cash for the ride and pushed Schroder out of the way. Schroder's charge was later reduced to a misdemeanor in exchange for his guilty plea and an agreement to pay restitution up to $4,930.07 as determined by the court. At the sentencing hearing, the court issued a 6-month deferred sentence and imposed a total of $2,039.20 in restitution and fees to be paid in monthly installments of $340.Schroder appealed the decision, arguing that the District Court erred in imposing restitution against him without fully considering his ability to pay. The Supreme Court of the State of Montana disagreed. The court found that there was a plea agreement in place where Schroder had agreed to pay restitution in any amount up to $4,930.07 as determined by the court. By signing this agreement, Schroder had affirmatively represented to the court that he had the ability to pay that amount. Moreover, at the sentencing hearing, Schroder made no claim of duress or undue pressure in entering the plea agreement.The Supreme Court of the State of Montana thus affirmed the lower court's decision, stating that while it is better practice for a district court to thoroughly analyze a defendant’s ability to pay restitution, fines, and fees at sentencing, under these circumstances, it could not fault the District Court for not making a more thorough inquiry into Schroder’s financial ability to pay. View "State v. Schroder" on Justia Law

In this case, the defendant, Malinda Crazymule, was found to have violated her probation. The Sixteenth Judicial District Court, Rosebud County revoked her suspended sentence and ordered a four-year commitment to the Department of Corrections (DOC). The court gave Crazymule 130 days of street time and 21 days of jail time credit but denied credit for jail time served while Crazymule was in Northern Cheyenne Tribal custody. Crazymule appealed this denial.The Supreme Court of the State of Montana reversed the lower court's decision. The key issue was whether Crazymule was entitled to credit for the time served during her arrest warrant's issuance while she was in custody for tribal offenses. The Supreme Court found that the District Court erred in its interpretation of the relevant statutes.According to Section 46-18-203(7)(b), MCA, if a suspended or deferred sentence is revoked, the judge must allow credit for time served in a detention center. The Supreme Court emphasized that the language of this statute is not discretionary regarding awarding credit for time served. The court held that the District Court had jurisdiction over Crazymule once the arrest warrant was issued following the filing of the State’s revocation petition with the court, regardless of Crazymule's incarceration for a different offense.The Supreme Court concluded that Crazymule was entitled to credit from the date the revocation warrant was issued and she remained incarcerated in a detention center. The case was reversed and remanded for further proceedings. View "State v. Crazymule" on Justia Law

In this case, Kaitlyn Holmes, a nurse, was convicted of theft and ordered to pay restitution for stealing credit cards from the personal belongings of several employees at a medical clinic in Bozeman, Montana. The Eighteenth Judicial District Court, Gallatin County, also held Holmes responsible for the disappearance of social security cards from the belongings of one of the victims, Brooke Templeton, and included in the restitution order the cost of LifeLock memberships for Templeton and her children.Holmes appealed the decision, arguing that she should not be held liable for the missing social security cards as she only admitted to stealing the credit cards. She also contested the inclusion of the cost of long-term LifeLock memberships in the restitution order.The Supreme Court of the State of Montana affirmed the lower court's decision holding Holmes responsible for the missing social security cards, noting that there was sufficient evidence to establish a causal connection between Holmes' crimes and the missing cards. However, the court partially reversed the lower court's decision regarding the restitution order. It held that the cost of the LifeLock memberships, intended to provide broad identity theft protection for the victims, was too attenuated to qualify for restitution under the statute as it was not incurred in the pursuit of the lost property.The case was remanded for entry of an amended judgment. The court's decision underscores the importance of establishing a clear causal relationship between a defendant's criminal conduct and the pecuniary loss suffered by the victim when determining restitution. This case also highlights the limitations of restitution orders, indicating that secondary expenses, not directly related to the pursuit of lost property, may not qualify for restitution under the statute. View "State. v. Holmes" on Justia Law

The case involves an appeal from a defendant, Christopher Michael Welch, who was convicted of attempted incest, incest, sexual abuse of children, and unlawful restraint. Welch began dating the mother of three daughters in 2018, and they eventually got married. The oldest daughter, J.P., testified about the inappropriate behavior and sexual advances made by Welch towards her. During the trial, Welch's defense suggested J.P. fabricated her claims.Welch's appeal raised two issues. First, he claimed prosecutorial misconduct, arguing that the prosecutor improperly vouched for J.P.'s credibility and made inappropriate emotional appeals to the jury. The Supreme Court of the State of Montana found no evidence of prosecutorial misconduct that would warrant plain error review, arguing that the prosecutor's comments were within the boundaries of discussing witness credibility and the lack of forensic evidence. The court also rejected Welch's argument that the cumulative effect of the state's comments prejudiced his right to a fair trial.Second, Welch objected to certain probation restrictions imposed by the District Court, arguing they had no reasonable nexus to the offense charged. These included prohibitions on using or possessing alcohol and illegal drugs, gambling, entering bars, and entering casinos. The court found these to be standard conditions authorized by statute and ruled that Welch failed to demonstrate that the lower court abused its discretion in imposing them. Therefore, the court affirmed the conviction and sentencing. View "State v. Welch" on Justia Law

The Supreme Court of Montana overturned the conviction of Daniel Christopher Rowe for sexual assault, a felony. Rowe was initially charged with the offense for multiple instances of abuse that allegedly took place over several years against H.B., who was under sixteen years of age at the time of the offenses. The case was remanded for a new trial due to two significant issues.First, the court found the lower court erred in admitting a subsequent uncharged act of sexual assault as proof of motive or plan to commit the earlier sexual assaults charged under a "common scheme." The court reasoned that the State had charged Rowe with a non-existent offense not recognized under Montana law, which led to the improper admission of other bad acts evidence.Second, the court found that the lower court erred in giving the jury both conduct-based and result-based definitions of "knowingly" for the sexual assault charge without specifying to the jury which definition applied to which elements of the offense. The court determined that this lowered the State's burden of proof, which violated Rowe's right to due process. The Supreme Court of Montana reversed Rowe's sexual assault conviction and remanded the case for further proceedings. View "State v. Rowe" on Justia Law

In this case, the defendant, June Wolverine, was charged with six misdemeanor traffic violations, including a third offense of Driving Under the Influence of Alcohol (DUI). Wolverine was unable to attend her trial due to being in federal custody. The State of Montana moved to continue the trial, but did not provide information on when Wolverine would be released from federal custody. Wolverine subsequently filed a motion to dismiss the charges due to a lack of a speedy trial, as required by Montana law. The Justice Court denied Wolverine's motion, and she pleaded guilty to the DUI charge while reserving her right to appeal the speedy trial issue. The District Court affirmed the Justice Court's denial of the motion to dismiss, ruling that Wolverine's federal incarceration had a clear causal impact on the trial delay.The Supreme Court of the State of Montana reversed the decision of the District Court. The Supreme Court held that the State had failed to demonstrate good cause for the delay in Wolverine's trial. The State knew Wolverine was in federal custody and had ample time to ask for Wolverine’s temporary release for trial or to notify the Justice Court about the looming deadline for a speedy trial. Yet, the State did nothing as the deadline passed. The Supreme Court concluded that the State did not fulfill its obligation to try the defendant in a timely manner, thus violating Wolverine's right to a speedy trial. The court reversed the District Court's decision and ruled in favor of Wolverine. View "State v. Wolverine" on Justia Law

In this case, defendant Bradley Alan Stokes appealed his convictions from the Fourteenth Judicial District Court, Musselshell County, for both burglary and assault with a weapon. Stokes was charged with these crimes following an altercation at the home of Michael Benson, in which he used a crowbar to break into the residence and assaulted Benson with the crowbar. He was convicted of burglary and assault with a weapon, both felonies. There was agreement that Stokes could not be convicted of both charges, as the assault with a weapon charge was the predicate offense for the burglary conviction. The dispute concerned which of the convictions should be vacated and whether the case should be remanded for resentencing.The Supreme Court of the State of Montana reversed Stokes's conviction for assault with a weapon, as it was determined to be the predicate offense that merged into the principal offense of burglary. The court held that the assault with a weapon conviction should be vacated, following the precedent that when a criminal defendant is improperly convicted of two offenses arising from the same transaction, the remedy is to reverse the conviction for the lesser-included offense only and remand for resentencing. Therefore, the court remanded the case to the District Court to vacate the assault with a weapon conviction and for resentencing on the remaining burglary conviction. View "State v. Stokes" on Justia Law

The defendant, Jacob Palmer, was found guilty of felony Partner or Family Member Assault (PFMA) by the Eleventh Judicial District Court, Flathead County, following an incident where he attacked his girlfriend, K.Y., with whom he had been in a relationship for over a decade. During his trial, evidence was presented regarding prior altercations between Palmer and K.Y. Palmer appealed to the Supreme Court of the State of Montana, challenging the District Court's decision to admit this evidence.The issue before the Supreme Court of Montana was whether the District Court had abused its discretion by admitting evidence of Palmer's prior altercations with K.Y. in his PFMA trial. The Supreme Court held that the District Court had not abused its discretion. The court reasoned that the evidence of Palmer's previous altercations with K.Y. was relevant and admissible under Montana Rule of Evidence 404(b). The court explained that such evidence can provide context about the complex dynamics of domestic violence, including the cycle of abuse and the reasons why victims such as K.Y. might not immediately report the abuse or might be reluctant to discuss the abuse with law enforcement. The court further determined that the probative value of this evidence was not significantly outweighed by its potential prejudicial effect against Palmer. As such, the court affirmed the District Court's decision to admit the evidence and upheld Palmer's conviction. View "State v. Palmer" on Justia Law

The case involves an appellant, M.T.H., who was arrested for criminal endangerment after he pulled the steering wheel in his mother's vehicle while she was driving. M.T.H. was diagnosed with major depressive disorder and paranoid schizophrenia. Following his arrest, the State filed a petition for M.T.H.'s involuntary commitment to the Montana State Hospital (MSH) for up to three months. The District Court of the Twenty-First Judicial District, Ravalli County, ordered his commitment and authorized MSH to involuntarily administer medications to M.T.H. This led to an appeal to the Supreme Court of the State of Montana.The Supreme Court of Montana had two main issues to consider. The first issue was whether the District Court erroneously determined that a signed waiver constituted a sufficient record to commit M.T.H. The Supreme Court found that M.T.H.'s waiver and the District Court’s order committing him were sufficient to constitute an intentional and knowing waiver under the relevant statute. The court emphasized that the record reflected that M.T.H. understood his procedural rights and had a clear presence of mind to consider his position logically.The second issue was whether the District Court erroneously authorized MSH to administer involuntary medications to M.T.H. The Supreme Court held that the District Court erred in this aspect. It emphasized the importance of due process protections and noted that the State must demonstrate a need for involuntary medication before a court may authorize it. In this case, the State did not make this necessary showing. Therefore, the Supreme Court affirmed the District Court’s decision in part but reversed its decision to authorize involuntary medication for M.T.H. View "In re M.T.H." on Justia Law