Justia Civil Rights Opinion Summaries

Articles Posted in Montana Supreme Court
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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained from a blood draw conducted pursuant to a search warrant, holding that there was no error.Defendant moved to suppress evidence obtained from a blood draw, arguing that Wheatland County Justice of the Peace Richard Egabakken lacked jurisdiction to issue the warrant because the crimes occurred in Golden Valley County. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err when it concluded that Justice of the Peace Egebakken had jurisdiction to issue a search warrant for Defendant's blood draw in Wheatland County. View "State v. Grussing" on Justia Law

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The Supreme Court reversed the order of the district court affirming the justice court's denial of Defendant's motion to suppress, holding that particularized suspicion did not exist to support extending Defendant's traffic stop into a drug investigation.Defendant pleaded guilty to criminal possession of drug paraphernalia and criminal possession of marijuana. On appeal, Defendant challenged the denial of his motion to suppress the State's evidence as the product of an illegal extension of the stop, arguing that the police officer lacked particularized suspicion to justify extending the traffic stop and ordering a canine sniff search. The Supreme Court agreed and reversed, holding that the justice court erred in denying Defendant's motion to suppress. View "State v. Harning" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained as a result of warrantless search of his apartment, holding that the district court did not err in denying Defendant's motion to suppress.In this case, three probation officers and a deputy federal marshal made a warrantless entry into Defendant's apartment without his consent to investigate his reported methamphetamine use and possible drug overdose in violation of the law and Defendant's probation. The district court concluded that the warrantless entry into Defendant's apartment was a constitutional search. The Supreme Court affirmed, holding that the district court (1) correctly concluded that the warrantless entry and probation search of Defendant's apartment was lawful on reasonable suspicion under the probation search exception to the warrant requirement of Mont. Const. art. II, 10-11; and (2) did not err in denying Defendant's motion to suppress based on the manner in which the officers entered the apartment or treated Defendant thereafter. View "State v. Peoples" on Justia Law

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The Supreme Court reversed the order of the district court affirming the denial of Defendant's motion to suppress evidence, holding that law enforcement officers lacked particularized suspicion to justify their investigatory stop of Defendant.Defendant was stopped by law enforcement officers based solely on his "flicking" his high beams on and off once. Defendant entered a conditional guilty plea to aggravated driving under the influence, third offense, reserving the right to appeal the justice court's denial of his motion to suppress. The district court affirmed. The Supreme Court reversed, holding that the totality of the circumstances did not give rise to particularized suspicion, and therefore, the seizure violated Defendant's constitutional right to be free from unreasonable searches and seizures. View "State v. Gardner" on Justia Law

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The Supreme Court reversed the order of the district court denying Defendant's motion to suppress evidence obtained when law enforcement officers entered Defendant's private property without a warrant, holding that that the State did not prove exigent circumstances permitting a warrantless search.At issue was whether Defendant had a reasonable expectation of privacy in his residence's driveway when he told a sheriff's deputy, who was attempting to effectuate a traffic stop, that he was trespassing and needed a warrant and whether exigent circumstances existed to allow the sheriff's deputy to conduct a warrantless investigation on the property. The Supreme Court held (1) the deputy sheriff properly entered the driveway when he already had initiated a traffic stop but exceeded his authority after Defendant asked him to leave; and (2) Defendant's failure to stop for a minor traffic violation did not create an exigency allowing the deputy sheriff to conduct a warrantless investigation after Defendant invoked his right to privacy. View "State v. Smith" on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of deliberate homicide with a weapons enhancement, holding that there were no grounds upon which to reverse Defendant's conviction.On appeal, Defendant argued that the State engaged in prosecutorial misconduct in its opening and closing statement, resulting in plain error, and that his trial counsel provided ineffective assistance in several respects. The Supreme Court disagreed, holding (1) the prosecutor's challenged statements were proper; and (2) Defendant failed to establish that trial counsel provided record-based ineffective assistance of counsel, in violation of Defendant's constitutional rights. View "State v. Polak" on Justia Law

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The Supreme Court affirmed the orders of the district court (1) resolving the parties' summary judgment motions, ruling in favor of Defendant, Plaintiff's former employer, in Plaintiff's wrongful discharge lawsuit; and (2) denying Plaintiff leave to amend his complaint in that case to add an age discrimination claim, holding that there was no error.Specifically, the Supreme Court held that the district court (1) did not err in holding that Defendant's failure to exhaust internal grievance procedures precluded his wrongful discharge case as a matter of law; and (2) did not abuse its discretion in finding Defendant's age discrimination claim futile and therefore denying his motion for leave to amend the complaint. View "Hathaway v. Zoot Enterprises, Inc." on Justia Law

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The Supreme Court affirmed the judgment of the district court convicting Defendant of felony sexual intercourse without consent, holding that Defendant received constitutionally effective assistance of counsel.At issue was whether Defendant's trial counsel rendered ineffective assistance when counsel allowed prior consistent statements from a forensic interview into evidence without challenge. The Supreme Court affirmed, holding (1) the record before the Court implied at least a plausible justification for counsel's actions; and (2) without more evidence, it cannot be determined whether defense counsel did not perform effectively for Defendant. View "State v. Mikesell" on Justia Law

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The Supreme Court reversed the judgment of the district court convicting Defendant of indecent exposure to a minor, sexual abuse of children in violation of Mont. Code Ann. 45-5-625(1)(c) and (4), and sexual abuse of children, in violation of Mont. Code Ann. 45-5-625(1)(c) and (2)(b), holding that Defendant's counsel provided record-based ineffective assistance of counsel that required reversal and remand for a new trial.Specifically, the Supreme Court held (1) Defendant's trial counsel provided ineffective assistance by failing to challenge the statutory basis for Count I when the statute upon which the charge was based did not go into effect until after one of the alleged incidents occurred; and (2) the ex post facto application of Mont. Code Ann. 45-5-625(1)(c) for Count II and Count III required remand for a new trial. View "State v. Tipton" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Defendant's motion to suppress illegal drug evidence seized as a result of a protective pat-down search for weapons and in a subsequent search of his vehicle, holding that the district court erred in concluding that the protective pat-down search of Defendant was justified.Specifically, the Supreme Court held (1) the district court erroneously held that the pat-down search of Defendant was justified under Terry v. Ohio, 392 U.S. 1 (1968) and Mont. Code Ann. 46-5-401(2)(b), whether incident to a valid Terry investigative stop or analogous community caretaker doctrine stop, but did not err in concluding that the exclusionary rule did not apply to the illegal drug evidence seized in the warrantless pat-down and vehicle searches at issue; and (2) therefore, the district court erred in denying Defendant's motion to suppress evidence found in his coat pocket as a result of the initial pat-down search but correctly denied Defendant's motion to suppress evidence found in the subsequent consent search of his vehicle. View "State v. Laster" on Justia Law