Justia Civil Rights Opinion Summaries

Articles Posted in Montana Supreme Court
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The Supreme Court dismissed the charges against Defendant, holding that Defendant was denied his constitutional right to a speedy trial and was presumptively prejudiced by the delay.The State filed an information charging Defendant with burglary and theft of more than $800. Nearly five years after his arrest Defendant had still not been brought to trial. Defendant filed a pro se motion to dismiss the charges, arguing that the five-year delay violated his right to a speedy trial. The district court denied the motion. Defendant pleaded guilty, reserving the right to appeal the denial of his speedy trial motion. The Supreme Court dismissed the charges against Defendant, holding that Defendant was denied his constitutional right to a speedy trial. View "State v. Chambers" on Justia Law

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The Supreme Court affirmed the order of the district court denying Defendant's motion to exclude evidence obtained during a traffic stop and to dismiss the charges against him, holding that an officer has a lawful right of access to reach into a vehicle and seize plainly visible contraband observed by the officer during a lawful traffic stop.Defendant was charged with criminal possession of dangerous drugs and criminal possession of drug paraphernalia. Defendant moved to exclude the evidence obtained during the traffic stop and to dismiss the charges, arguing that the deputy sheriff's warrantless seizure of a plastic bag found on Defendant's lap was unlawful. The district court denied the motion. Defendant then pled guilty, preserving his right to appeal the denial. The Supreme Court affirmed, holding that because the officer's warrantless seizure of the bag was not unlawful because the officer was lawfully present next to Defendant's truck during the traffic stop, could plainly see readily apparent contraband fall onto Defendant's lap, and had a lawful right of access to that contraband. View "State v. Tenold" on Justia Law

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The Supreme Court affirmed Defendant's felony conviction of criminal possession with intent to distribute, holding that the district court did not err in determining that the State was not required to disclose the identity of its confidential informant.After Defendant was charged, he moved to dismiss the case on the basis that the State had failed to disclose the confidential informant's identity within the discovery timeframe. The district court summarily denied Defendant's motion to dismiss, declining to require disclosure of the confidential informant's identity. Defendant pled guilty, reserving his right to appeal the denial of his motion to dismiss. The Supreme Court affirmed, holding that the district court did not err as a matter of law in denying Defendant's motion to dismiss and did not abuse its discretion in denying disclosure of the confidential informant's identity. View "State v. Soto" on Justia Law

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The Supreme Court affirmed the order of the district court revoking Defendant's deferred sentence for criminal possession of dangerous drugs, holding that the district court did not violate Defendant's Sixth Amendment right to confront witnesses during his revocation and did not abuse its discretion in determining that Defendant absconded.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confront witnesses against him by relying on statements made in a report of violation by Defendant's previous probation officer; and (2) the State presented sufficient evidence at Defendant's revocation hearing to establish that Defendant failed to report for the purpose of avoiding supervision and that the probation office made reasonable efforts to contact him. View "State v. Fetveit" on Justia Law

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The Supreme Court affirmed the order of the district court denying Defendant's motion to suppress testimony regarding statements he made during a phone conversation with the victim, holding that the testimony was not subject to exclusion.A.O. and her friend Tricia alleged that Defendant had committed sexual offenses against A.O. While A.O. was at the police department, Defendant called A.O. Police officers listened in on the conversation, during which Defendant admitted to raping A.O. Defendant moved to suppress the evidence. The district court ruled that the officer testimony regarding the conversation would be excluded but that A.O. and Tricia, as private actors, could testify as to the conversation. Defendant appealed, arguing that the testimony of A.O. and Tricia as to the contents of the conversation must be excluded as attributable to an unconstitutional privacy intrusion by a government actor. The Supreme Court affirmed, holding that the district court correctly denied the motion to suppress because A.O. and Tricia's testimony resulted from their own private actions, not from unconstitutional monitoring and recording by police. View "State v. Wolfe" on Justia Law

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The Supreme Court held that Mont. Code Ann. 46-5-105 prohibits detention center employees who are booking a person into the general population of a detention facility from conducting a visual body cavity search without reasonable suspicion to believe that person is concealing contraband, a weapon, or evidence of the commission of a crime.William Rogers, leading ninety-six named plaintiffs, brought this action challenging the Lewis and Clark County Detention Center policy to conduct an unclothed visual body cavity search of every detainee prior to placement in the general population of the facility as a violation of Mont. Const. art. II, 10 and 11 and Mont. Code Ann. 46-5-105. The district court granted summary judgment for Defendants as to ninety-two of the named plaintiffs and denied the motion as to four plaintiffs who were never placed in the general population of the facility after they were strip searched. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs' diminished privacy interests did not outweigh the legitimate penological interests of the Detention Center; and (2) the plain language of section 46-5-105 unequivocally prohibits suspicionless strip searches of those arrested for minor offenses in any situation. View "Rogers v. Lewis & Clark County" on Justia Law

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The Supreme Court reversed the decision of the district court denying Defendant's motion to suppress evidence found during a probation search of the room Defendant rented from a person on probation, holding that Defendant had a legitimate expectation of privacy in his residence.Defendant rented a room from Parischere Hughes (Paris), who was on misdemeanor probation and subject to probation searches. During a probation search of Paris's residence, law enforcement officers searched Defendant's residence and found drugs and drug paraphernalia. Defendant was charged criminal possession of dangerous drugs, a felony. Defendant filed a motion to suppress, arguing that the search exceeded the scope of any lawful probation search of Paris's residence. The district court denied the motion. The Supreme Court reversed, holding that Defendant's rights to privacy in his person and residence were not diminished by Paris's probationary status. View "State v. Thomas" on Justia Law

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The Supreme Court affirmed Defendant's conviction of felony strangulation of his girlfriend, holding the evidence was sufficient to support the conviction, and Defendant did not receive ineffective assistance of counsel.Specifically, the Supreme Court held (1) the evidence was sufficient to sustain Defendant's conviction of felony strangulation; (2) Defendant failed to meet the prejudice standard set forth in Strickland v. Washington, 466 U.S. on his claim that his counsel was ineffective by opening the door to evidence of Defendant's prior violence; and (3) this Court declines to review for plain error Defendant's argument challenging the district court's instruction on the mental state for strangulation. View "State v. Dineen" on Justia Law

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The Supreme Court affirmed Defendant's conviction of one count of sexual intercourse without consent, holding that the district court did not err in denying Defendant's motion to strike a prospective juror for cause.After the district court denied Defendant's motion to remove the prospective juror for cause Defendant used a peremptory challenge to strike her from the panel and exhausted all of his peremptory challenges. Defendant appealed, arguing (1) the prospective juror's voir dire statements demonstrated an inability to act fairly and impartially in his trial, and therefore, the district court abused its discretion in denying his for-cause challenge; and (2) because he had to exercise a peremptory strike to remove the juror and subsequently exhausted his peremptory challenges, the error was prejudicial. The Supreme Court disagreed, holding that the district court did not abuse its discretion in accepting the prospective juror's assurances that she could fairly and impartially weigh the evidence despite her initial statements of prejudice. View "State v. Morales" on Justia Law

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The Supreme Court affirmed the decision of the district court denying Defendant's motion to suppress the evidence discovered during a police officer's chemical "field test" on the contents of a syringe found in Defendant's jacket pocket, holding that a rudimentary chemical field test of a lawfully seized substance is not a constitutionally protected search requiring a warrant.Defendant was placed under arrest after driving with a suspended driver's license and without vehicle insurance. While searching Defendant incident to his arrest, the arresting officer located a used syringe in Defendant's front jacket pocket. When booking Defendant into jail, the officer conducted a field test on the contents of the syringe. The field test came back positive for methamphetamine. Defendant filed a motion to suppress, arguing that the field test of the syringe's contents without a warrant constituted an unlawful search that violated his reasonable expectations of privacy. The district court denied the motion to suppress. The Supreme Court affirmed, holding that Defendant had no reasonable expectation of privacy violated by a test for the presence of methamphetamine in a syringe lawfully seized from his person, and therefore, Defendant could not assert the constitutional protections afforded to a search. View "State v. Funkhouser" on Justia Law