Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of aggravated assault and reversed his conviction for violating a no-contact order. The Court held (1) the State did not present sufficient evidence for the jury to find Defendant guilty of violating a no-contact order; and (2) the prosecutor’s comment during rebuttal closing argument that the jury’s “job” was to ensure the alleged victim’s safety was improper, and the nature of the remark implicated Defendant’s right to a fair trial, but this isolated incident of alleged misconduct did not result in a miscarriage of justice or compromise the integrity of Defendant’s trial. View "State v. Ritesman" on Justia Law

The Supreme Court affirmed Defendant’s conviction for operating a noncommercial vehicle with alcohol concentration of 0.08 or more (DUI per se) but reversed the district court’s order imposing the cost of legal counsel on Defendant. The court held (1) Defendant’s right to due process was not violated by a jury instruction that instructed the jurors, when choosing between two competing interpretations of circumstances evidence, to choose whichever interpretation was the “most reasonable”; but (2) the district court erred in imposing costs of legal counsel on Defendant given Defendant’s limited fixed income and disability status. View "State v. Iverson" on Justia Law

The Supreme Court affirmed the order of the district court awarding summary judgment to the Missoula County Detention Facility and the Missoula County Sheriff’s Office (collectively, the County) on Plaintiff’s claim that the County had illegally discriminated against him based on his disability. Plaintiff initially filed a complaint with the Human Rights Bureau (HRB), which found no reasonable cause to believe that the County had discriminated against Plaintiff. The district court agreed. The Supreme Court Supreme Court affirmed, holding (1) the district court did not err in declining to consider evidence arising after Plaintiff filed his HRB complaint; and (2) the district court correctly granted summary judgment for the County. View "Borges v. Missoula County Sheriff’s Office" on Justia Law

The Supreme Court affirmed the order of the district court denying Appellant’s request for substitution of counsel in this criminal proceeding.Appellant pleaded guilty to deliberate homicide. Thereafter, Appellant made a request for substitution of counsel. After a hearing, the district court deemed the representation matter resolved because the Office of the State Public Defender denied Appellant’s request for new counsel and Appellant had not appealed that decision. On appeal, the Supreme Court held that the district court failed adequately to inquire into Defendant’s complaints regarding his counsel, which necessitated a remand. On remand, the district court issued an order again denying Appellant’s request for substitution of counsel. The Supreme Court affirmed, holding that the district court did not err when it inquired into Appellant’s complaints of ineffective assistance of counsel and in denying his request for substitution of counsel. View "State v. Schowengerdt" on Justia Law

The Supreme Court affirmed the judgment of the district court wherein Defendant pled guilty to felony driving under the influence of alcohol, fourth or subsequent offense, and three misdemeanors. On appeal, Defendant argued that the district court violated his right to due process during sentencing and erred in sentencing him, and that he was denied the effective assistance of counsel during sentencing. The Supreme Court affirmed and remanded for entry of an amended judgment, holding (1) the district court did not deprive Defendant of his right to due process during sentencing; (2) the district court did not err in imposing a condition on Defendant’s suspended sentence; (3) Defendant was not deprived of effective assistance of counsel during sentencing; and (4) the sentencing conditions in the written judgment should be amended to conform to oral pronouncement of the conditions. View "State v. Lafield" on Justia Law

The Supreme Court denied Petitioner’s petition for a writ of habeas corpus, holding that Petitioner’s sentence of 110 years’ imprisonment, without the possibility of parole, for deliberate homicide with the use of a weapon did not violate his Eighth Amendment rights even where Petitioner committed the offense when he was seventeen years old. At issue was whether Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, __ U.S. __ (2016), apply to Montana’s discretionary sentencing scheme and whether Petitioner’s sentence qualifies as a de facto life sentence to which Miller and Montgomery apply. The Supreme Court held (1) Miller and Montgomery apply to discretionary sentences in Montana; and (2) Petitioner’s sentence, when viewed in light of Petitioner’s eligibility for day-for-day good time credit and the concurrent sentence he was serving in Washington, did not qualify as a de facto life sentence to which Miller’s substantive rule applied. View "Steilman v. Michael" on Justia Law

The Supreme Court held that the district court did not err in dismissing Defendant’s motion to dismiss the State’s petition to revoke her suspended sentence on the ground that there had been a four-year delay in executing the arrest warrant.In 2009, the district court issued a “Montana only” warrant for the arrest of Defendant, who was on probation. Thereafter, Defendant was convicted of another offense in Colorado, where, several times, Defendant was paroled and then her sentence was revoked. Defendant discharged her Colorado sentences in 2013. That same year, Defendant was arrested on the 2009 warrant. Defendant moved to dismiss the petition to revoke her suspended sentence, arguing that the State violated her right to due process by failing to bring her to court without unnecessary delay. The district court concluded that Defendant had not suffered a deprivation of due process and then determined that Defendant had violated the terms of her original sentence. The Supreme Court affirmed, holding that the district court did not err in denying Defendant’s motion to dismiss the revocation petition. View "State v. Koon" on Justia Law

The Supreme Court reversed the municipal court’s order denying Petitioner’s motion to dismiss the charge against him, holding that the municipal court abused its discretion in declaring a mistrial and in concluding that double jeopardy did not bar Petitioner’s retrial.Petitioner was charged with partner or family member assault (PFMA). The City of Billings moved for a mistrial, and the trial judge declared a mistrial based on the purportedly inconsistent testimony of a City’s witness. The judge then rescheduled Petitioner’s trial. Petitioner filed a motion to dismiss the PFMA on double jeopardy grounds. The municipal court denied the motion. The Supreme Court reversed, holding (1) there was no manifest necessity to discontinue the trial, and Petitioner’s conduct did not demonstrate a waiver of his right to object to termination of the proceedings and to a retrial; and (2) therefore, retrying Petitioner for the PFMA charge would violate his federal and state fundamental constitutional rights to be free from double jeopardy. View "Billings ex rel. Huertas v. Billing" on Justia Law

The district court erred by concluding that particularized suspicion did not exist for the investigatory stop of Defendant.The Supreme Court reversed the order of the district court reversing the municipal court’s order denying Defendant’s motion to suppress evidence related to his arrest for driving under the influence of alcohol (DUI). The district court concluded that the trial court’s finding that Defendant was apprehended for a technical violation was clearly erroneous. The Supreme Court disagreed, holding (1) the district court erred in finding from the evidence that Defendant was stopped for “alleged behavior,” which required its own assessment and speculation about the record; and (2) there was substantial evidence in the record to support the municipal court’s findings of fact about the reasons that Defendant’s vehicle was stopped. View "City of Helena v. Brown" on Justia Law

Mont. Code Ann. 53-21-119(1), which prohibits a person from waiving the right to counsel in civil commitment proceedings, does not violate the Sixth or the Fourteenth Amendments to the United States Constitution.After the State filed a petition to involuntarily commit Respondent, Respondent advised the district court that he wished to waive counsel and represent himself. The district court denied Respondent’s request. The district court later approved a stipulation entered into by Respondent, together with his appointed counsel, for commitment to community-based treatment, and ordered Respondent’s commitment. On appeal, Respondent argued that section 53-21-119(1) violates his constitutional rights. The Supreme Court affirmed, holding (1) the Due Process clause does not establish as fundamental the right to represent oneself in civil commitment proceedings; and (2) the prohibition against waiver in civil commitment proceedings is reasonably related to a permissible legislative objective. View "In re S.M." on Justia Law