Justia Civil Rights Opinion Summaries

Articles Posted in Montana Supreme Court
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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

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In the state of Montana, William James Rupnow Jr., a licensed bail bondsman, was accused of criminal offenses after he tried to apprehend a client, Victorianne Dahl, who had violated her bail conditions. Dahl had consistently been late with payments and had violated other conditions of her release. Rupnow resorted to using pepper spray in his attempt to detain Dahl, leading to the State charging him with felony assault with a weapon and aggravated assault. Rupnow was ultimately acquitted on the aggravated assault charge, but the jury could not reach a verdict on the assault with a weapon charge. In response, Rupnow filed a lawsuit against the Montana State Auditor and Commissioner of Insurance, Mike Winsor, Jennifer Hudson, and XYZ government subdivision, alleging malicious prosecution, abuse of process, and violation of his rights under the Montana Constitution. The defendants requested the case be dismissed based on prosecutorial immunity, a motion which the District Court granted. Rupnow appealed the decision, arguing that as a bail bondsman, he had the authority to arrest Dahl without a warrant.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision to dismiss Rupnow's case. The Court found that Montana's statutory scheme for pre-trial release, or bail, did not provide bail bondsmen with an unfettered right to remit a bail bond client to jail without an outstanding warrant. The Court reasoned that the legislature did not intend to grant bail bondsmen arrest authority that far exceeded that of law enforcement officers. Therefore, Rupnow did not have the authority to arrest Dahl without a warrant, meaning there was probable cause to charge Rupnow with the crimes he was accused of. The Court concluded that Rupnow's claims of malicious prosecution and abuse of process failed as a matter of law. View "Rupnow v. State Auditor" on Justia Law

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In the State of Montana, a group of parents and the non-profit organization Stand Up Montana sued several school districts in Missoula County over the implementation of mask mandates in schools during the COVID-19 pandemic. The plaintiffs argued that the mask mandates violated their substantive due process rights. The Fourth Judicial District Court granted summary judgment in favor of the school districts, finding the mask mandates did not violate the plaintiffs' substantive due process rights. The Supreme Court of the State of Montana affirmed the lower court's decision. The Supreme Court reiterated that the mask mandates did not implicate any fundamental rights under Article II of the Montana Constitution, and therefore, the rational basis test was the appropriate standard of review. Under the rational basis test, the court found that the mask mandates were rationally related to the legitimate government interest of stemming the spread of COVID-19, as the school districts had considered information and recommendations from reputable public and private health care providers and agencies, including the CDC, which all recommended universal masking. The court also affirmed the lower court's decision to grant a motion in limine to exclude testimony from the plaintiffs' hybrid witnesses, as the proffered testimony was not relevant to whether the mask policies were rationally related to stemming the spread of COVID-19. View "Stand Up Montana v. Msla Co. Schools" on Justia Law

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The Supreme Court affirmed the order of the district court denying Defendant's motion to suppress evidence obtained during a probation home visit, holding that the district court did not err in denying the suppression motion.Defendant was convicted of bail jumping and received a deferred sentence of four years. After a probation home visit resulted in the discovery of a "significant amount of methamphetamine" by a probation officer the State petitioned to revoke Defendant's deferred sentence. Defendant filed a motion to suppress, arguing that the discovery of the drugs found in her home was the result of an unlawful search. The district court denied the motion, concluding that the officer did not violate the reasonable protocols for a probation home visit. The Supreme Court affirmed, holding that what began as a home visit turned into a search pursuant to the officer's plain view observation of drug paraphernalia, which provided probable cause for the search. View "State v. Thompson" on Justia Law

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The Supreme Court affirmed the judgment of the district court sentencing Defendant to seventy years in Montana State Prison for deliberate homicide, a felony, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's claim that his trial attorney provided ineffective assistance when he advised Defendant and the court that mitigated deliberate homicide was not a lesser-included offense of deliberate homicide was more appropriate for postconviction relief; and (2) the district court did not err when it concluded that the State's offer of proof provided sufficient evidence to accept Defendant's Alford plea. View "State v. Bristow" on Justia Law

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The Supreme Court affirmed Defendant's conviction of aggravated kidnapping, sexual intercourse without consent, and partner or family member assault, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) Mont. Code Ann. 45-5-303(2) is not facially unconstitutional because it permits a judge, rather than a jury, to apply factors that reduce the maximum penalty; (2) Defendant's level three offender designation was objectionable, not illegal, and Defendant did not properly reserve his objection to the designation during sentencing; and (3) Defendant's counsel was not ineffective for failing to argue that the maximum sentence for kidnapping was ten years based on mitigating factors and failing to object to Defendant's level-three sex offender designation. View "State v. Pine" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress and dismiss, holding that Defendant's warrantless arrest was unlawful, and therefore, it was error for the district court not to suppress and exclude the evidence discovered as a result of the unlawful search.Defendant pled guilty to criminal possession of dangerous drugs, reserving his right to appeal the denial of his motion to suppress and dismiss. On appeal, Defendant argued that the underlying arrest was illegal and led directly to the discovery of the incriminating evidence. The Supreme Court agreed and reversed, holding that the district court erred by not suppressing and excluding the evidence at issue. View "State v. Price" on Justia Law

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The Supreme Court affirmed the order of the district court determining that there was no genuine dispute of material fact that a routine clothed body search did not violate Appellant's Eighth Amendment rights, holding that there was no error.Appellant, an inmate, filed an amended complaint alleging that Sergeant Larry Pasha's performance of a routine clothed body search of Appellant violated his Eighth Amendment rights. The district court granted summary judgment to Appellees on all claims. The Supreme Court affirmed, holding that there was no genuine dispute of material fact that Sergeant Pasha's search of Appellant was routine and did not violate Appellant's Eighth Amendment rights. View "Lawrence v. Pasha" on Justia Law

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The Supreme Court affirmed the order of the district court requiring Broadwater County to provide to Helena Independent Record (IR) or other interested persons redacted videographer and documentation records pertaining to Jason Ellsworth's May 2021 stop by and encounter with a Montana Highway Patrol officer, holding that there was no error.Ellsworth pleaded guilty to an obstructing a peace officer. Thereafter, a reporter with the IR requested from Broadwater County a copy of Ellsworth's investigative file. Petitioner, a county attorney, determined that the file contained confidential criminal justice information and filed a petition seeking a declaratory ruling to clarify and enforce the rights of recovery to redacted confidential criminal justice information (CCJI) contained in the file. Petitioner also filed a separate motion for leave to deposit the investigative file under seal. The district court (1) concluded that Ellsworth's criminal case had been completed and that the declaratory action was ripe for decision; and (2) held that Ellsworth's privacy rights outweighed the public's right to know regarding certain information irrelevant to the charge. The Supreme Court affirmed, holding that Ellsworth was given a proper opportunity to participate, and his due process right was not infringed regarding the release of the CCJI. View "Broadwater Co. v. Release of Confidential Criminal Justice Information" on Justia Law

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The Supreme Court affirmed in part and reversed the judgment of the district court convicting Defendant of aggravated burglary and obstructing a police officer and sentencing him to forty years for aggravated burglary and six months for obstructing a peace officer, holding that the case must be remanded for resentencing.Specifically, the Supreme Court held (1) Defendant's constitutional right to a speedy trial was not violated; (2) Defendant's claim of instructional error not warrant plain error review because he failed to show how he was prejudiced; (3) Defendant's ineffective assistance of counsel claim must fail because Defendant he to show any prejudice; and (4) Defendant was entitled to resentencing because the district court relied on incorrect information when it imposed the sentence. View "State v. Kirn" on Justia Law