Justia Civil Rights Opinion Summaries

Under the particular facts and circumstances of this case, the municipal court erred in denying Defendant’s motion to suppress evidence.Defendant was found guilty of being a minor in possession of alcohol. Before her non-jury trial, Defendant moved for suppression of the State’s evidence of her age and date of birth on the asserted ground that the police unreasonably prolonged its initial investigative stop of her and that the police subjected her to a custodial interrogation without a rights advisory. The municipal court denied the motion. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the police had sufficient particularized suspicion of criminal activity to initially stop Defendant and question her about her name, age, and conduct regarding the offense of minor in possession of alcohol; (2) the police had sufficient particularized suspicion of criminal activity to continue to detain Defendant for further investigation; but (3) the continuing temporary investigative stop and related non-custodial interrogation ripened into a custodial interrogation without a Miranda advisory and waiver, in violation of the Fifth Amendment of the United States Constitution and Mont. Const. art. II, 25, and therefore, the motion to suppress should have been granted. View "City of Missoula v. Kroschel" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of criminal possession of methamphetamine and other drug offenses after law enforcement found drugs and paraphernalia in Defendant’s pickup truck during a traffic stop, holding that the district court committed reversible error when it curtailed Defendant’s cross-examination of Leslie Hill, the lone passenger in the vehicle at the time of the traffic stop.Specifically, the Court held that the district court abused its discretion when it excluded evidence of Hill’s plea agreement with the State and prevented Defendant from fully cross-examining Hill about her plea agreement, and the error prejudiced Defendant and required a new trial. View "State v. Flowers" on Justia Law

In this case governed by the Indian Child Welfare Act (ICWA), the Supreme Court affirmed the decision of the district court to terminate Father’s rights to his minor child (Child), holding that Father’s contentions on appeal were unavailing.Specifically, the Court held (1) Montana’s Department of Public Health and Human Services provided the active efforts required under 25 U.S.C. 1912(d) to prevent the breakup of an Indian family; (2) Father did not establish that the Child was placed in a foster home in violation of the placement preferences set forth in 25 U.S.C. 1915; and (3) Father’s attorney did not provide ineffective assistance of counsel. View "In re A.L.D." on Justia Law

The Supreme Court affirmed Defendant’s conviction for driving under the influence (DUI), holding that the district court did not err by denying Defendant’s motion to suppress blood test results obtained by a search warrant because Defendant’s due process were not violated.Defendant moved to suppress blood tests obtained pursuant to a telephone search warrant, asserting a violation of due process by the officer’s failure to advise Defendant of his right to an independent blood draw. The district court denied the motion. The Supreme Court affirmed, holding that, under the circumstances of this case, including that the advisory’s reading was impeded by Defendant, there was no fundamental unfairness, and the circumstances fell short of a denial of due process. View "State v. Moore" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that the weighted average discount ratio (WADR), codified in Mont. Code Ann. 16-2-101(2)(b)(ii)(B), violated liquor store owners’ (collectively, Storeowners) rights to substantive due process and equal protection.The WADR was effective from 1995 to 2016. The State, Department of Revenue (DOR) sold liquor to certified liquor stores (agency liquor stores) and provided those stores with three discounts, one of which was the WADR. The agency liquor stores sold the liquor to individual retail customers and licensed taverns and bars (licensees). When the agency liquor stores sold to licensees whole or unbroken cars of liquor, known as case lots, section 16-2-201(1) required them to provide a separate discount (case discount). Four liquor store owners certified as a class representing similarly situated liquor store owners filed suit challenging the constitutionality of the WADR. Specifically, Storeowners claimed that the WADR should have fully reimbursed them for the cost of providing the case discount to Licensees. The district court concluded that the WADR was unconstitutional. The Supreme Court reversed, holding that the WADR did not violate Storeowners’ rights to substantive due process and equal protection and was, rather, a constitutional part of a statutory scheme designed to privatize liquor stores in Montana. View "Kohoutek v. State, Department of Revenue" on Justia Law

The justice court did not err in concluding that Defendant waived his right to a jury trial when he failed to appear at his jury confirmation hearing.Defendant was found guilty by the justice court of driving while under the influence of alcohol and obstructing a peace officer. On appeal, Defendant argued that the justice court erred in determining that Defendant waived his right to a jury trial when he failed to appear at the jury confirmation hearing. The Supreme Court affirmed, holding that, under the circumstances, the justice court did not err in determining that Defendant waived his right to a jury trial by failing to attend his jury confirmation hearing. View "State v. Sherlock" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence discovered in the course of a probationary search of the vehicle in which Defendant was a passenger, holding that, under the facts of this case, Defendant had no reasonable expectation of privacy in the vehicle or its contents. Therefore, there was no search.Defendant’s counsel moved to suppress the evidence seized as a result of the vehicle search on the grounds that there was no inquiry to determine if Defendant was the owner of or if he had control over the vehicle. The district court denied the motion, concluding that a probationer need not be a driver or owner of a vehicle in order for officers to initiate a probationary search of the vehicle, so long as the probationer was a passenger immediately prior to the search. The Supreme Court affirmed, holding (1) Defendant failed to show he had an actual expectation of privacy as a passenger in the vehicle; and (2) even though the vehicle was not Defendant’s, the probation officer had the authority to search it. View "State v. Conley" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence discovered in the course of a probationary search of the vehicle in which Defendant was a passenger, holding that, under the facts of this case, Defendant had no reasonable expectation of privacy in the vehicle or its contents. Therefore, there was no search.Defendant’s counsel moved to suppress the evidence seized as a result of the vehicle search on the grounds that there was no inquiry to determine if Defendant was the owner of or if he had control over the vehicle. The district court denied the motion, concluding that a probationer need not be a driver or owner of a vehicle in order for officers to initiate a probationary search of the vehicle, so long as the probationer was a passenger immediately prior to the search. The Supreme Court affirmed, holding (1) Defendant failed to show he had an actual expectation of privacy as a passenger in the vehicle; and (2) even though the vehicle was not Defendant’s, the probation officer had the authority to search it. View "State v. Conley" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court’s decision upholding the decision of the hearing officer with the Montana Human Rights Bureau (HRB) in favor of All Star Painting on Plaintiff’s complaint alleging that the company’s owner had sexually harassed her at work. The Court held (1) the district court erred in dismissing Plaintiff’s petition for judicial review because the hearing officer’s decision either ignored the testimony of four individuals, all of whom corroborated Plaintiff’s testimony, or misapprehended the effect of that evidence; and (2) the district court properly dismissed All Star Painting’s owner as a party to the action because he was never properly added as a party under Mont. R. Civ. P. 20. View "Jones v. All Star Painting Inc." on Justia Law

The Supreme Court affirmed Defendant’s sentence for three separate cases involving partner or family member assault against three different women to a combined twenty years, with eight suspended. The district court included conditions in all three cases that restricted contact between Defendant and his victims. On appeal, Defendant argued that the condition prohibiting contact between him and his second victim was an unreasonable sentencing condition and an unconstitutional restriction on his common-law marriage. The Supreme Court held (1) the contested condition was not an unreasonable sentencing condition; and (2) Defendant’s general objection to the restricted contact conditions was insufficient to preserve his argument that the conditions unconstitutionally infringe upon his marriage, privacy, and due process rights. View "State v. Parkhill" on Justia Law