Justia Civil Rights Opinion Summaries

Pursuant to a plea agreement, Defendant pleaded guilty to the possession of dangerous drugs and drug paraphernalia. Defendant preserved his right to appeal the denial of his motion to suppress evidence seized during the warrantless search of the vehicle he was driving. The Supreme Court affirmed, holding (1) the district court made sufficient findings of fact and conclusions of law in its order denying Defendant’s motion to suppress to allow informed appellate review; and (2) the district court did not err in denying Defendant’s motion to suppress, as the police did not need to obtain Defendant’s consent to search the vehicle and its internal compartments. View "State v. Baty" on Justia Law

Allen Longsoldier, Jr., an eighteen-year-old Native American, died as a result of alcohol withdrawal while in custody at the Hill County Detention Center after he was arrested by Blaine County authorities. Longsoldier’s estate filed a claim against Blaine and Hill Counties with the Montana Human Rights Bureau alleging that the Counties discriminated against Longsoldier because of his race and his disability - alcoholism. A hearing officer concluded that the Counties had not illegally discriminated against Longsoldier. The Human Rights Commission found clear error in the hearing officer’s findings of fact and concluded that the Counties had discriminated against Longsoldier. Presiding Judge Jeffrey Sherlock with the district court reversed the Commission’s decision and reinstated the hearing officer’s order as the final agency decision. On the Estate’s motion to alter or amend, Judge James Reynolds, who had assumed jurisdiction of the case, found that Judge Sherlock had committed a “manifest error of law” by fashioning an improper remedy. The Supreme Court affirmed Judge Sherlock’s order and reversed Judge Reynold’s order, holding (1) Judge Sherlock correctly concluded that the Commission improperly modified the Hearing Officer’s findings; and (2) Judge Reynolds incorrectly concluded that Judge Sherlock erred as a matter of law by reinstating the hearing officer’s decision as the final agency decision. View "Blaine County v. Stricker" on Justia Law

Pursuant to a plea agreement, Defendant entered a plea of guilty to the charge of criminal distribution of dangerous drugs with intent to distribute. After a sentencing hearing, the district court imposed a six-year deferred sentence, with a $1,500 fine to be paid to the Eastern Montana Drug Task Force, and a $15,000 fine pursuant to Mont. Code Ann. 45-9-130. Defendant appealed, challenging the imposition of the $15,000 fine. The Supreme Court affirmed, holding (1) the $15,000 fine was not a sentence enhancement that violated the requirements of Apprendi v. New Jersey and Mont. Code Ann. 46-1-401; (2) the $15,000 fine did not violate Montana’s constitutional prohibition of “excessive fines”; and (3) Defendant’s double jeopardy argument, which he did not raise below, did not warrant plain error review, and Defendant was not entitled to relief pursuant to the Lenihan Rule. View "State v. Le" on Justia Law

Donnie Dorrell Nolan was incarcerated at the Yellowstone County Detention Facility at the time that RiverStone Health Care contracted with Yellowstone County to prove medical services for its inmates. Nolan filed a pro se complaint against RiverStone alleging that it violated the Eighth and Fourteenth Amendments by denying him access to a prescribed pain medication while incarcerated. The district court dismissed Nolan’s complaint for lack of timely service of process. The Supreme Court affirmed, holding that the district court correctly dismissed Nolan’s complaint due to his failure to comply with the mandatory rules for proper service of process on RiverStone. View "Nolan v. Riverstone Health Care" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to DUI per se. Defendant appealed the municipal court’s denial of her motion to suppress blood test results on the ground that, by remaining silent, she did not voluntarily consent to the blood test. The district court affirmed, ruling that Defendant consented to the blood draw pursuant to Montana’s implied consent law, Mont. Code Ann. 61-8-402(1), and that the municipal court did not err by finding that she did not withdraw that consent. The Supreme Court affirmed, holding (1) Defendant’s passive compliance to the blood test was insufficient to constitute a withdrawal of her implied consent; and (2) therefore, the municipal court correctly denied Defendant’s motion to suppress her blood test results. View "City of Great Falls v. Allderdice" on Justia Law

A rockfall damaged the residence of Jane Deschner and Jon Lodge (together, Plaintiffs) near the Billings Rimrocks (Rims). The City of Billings owned the property from which the slab fell, and the State maintained a highway that ran on top of the Rims north of Plaintiffs’ property. In 1963, the State improved the highway, rerouting it and installing culverts underneath the new roadway to facilitate water runoff. As relevant to this appeal, Plaintiffs sued the State, claiming inverse condemnation. At trial, Plaintiffs argued that the State’s construction and placement of the highway and a culvert caused an unnatural increase in the amount of water that ran off the highway onto the rockfall site, ultimately causing the slab to fall onto their home. The jury returned a special verdict finding that the State was not negligent, that Plaintiffs’ negligence was a substantial factor in bringing about their own damages, and that the State did not inversely condemn Plaintiffs’ property. The Supreme Court affirmed, holding that the district court’s instruction on inverse condemnation was not erroneous. View "Deschner v. State, Department of Highways" on Justia Law

Defendant was charged with deliberate homicide in the death of her infant daughter. Defendant moved to suppress the results of a police interrogation, asserting that her admissions that she had shaken her daughter were not voluntary. The district court denied the motion to suppress. A jury found Defendant not guilty of deliberate homicide but guilty of felony assault on a minor. The Supreme Court reversed, holding (1) based upon the totality of the circumstances, the district court erred by concluding that the interrogation was not unduly coercive or manipulative and by concluding that Defendant was “fully cognizant” of her situation; and (2) therefore, the State failed to meet its burden of proving that Defendant’s admissions were voluntary, and the district court erred in denying the motion to suppress. View "State v. Eskew" on Justia Law

On February 13, 2009, Defendant was charged with motor vehicle offenses. On May 21, 2009, the justice court issued a warrant for Defendant’s arrest for failing to appear. On April 13, 2012, Defendant was arrested on the warrant. Defendant pled not guilty, and trial was set for August 23, 2012. Defendant moved to dismiss the charges against him for lack of a speedy trial. The justice court concluded that while there was a lengthy delay of 1288 days between the initial charges and the trial date, Defendant’s constitutional right to a speedy trial had not been violated. Defendant then pled guilty to driving with a suspended license. The district court upheld the justice court’s determination that Defendant was not denied his right to a speedy trial. The Supreme Court affirmed, holding that, under the facts of this case, Defendant was not denied his right to a speedy trial. View "State v. Eystad" on Justia Law

Charlene Berdahl, a court reporter, filed a sexual harassment complaint against Judge George Huss, a district judge, with the Montana Human Rights Bureau (HRB). Huss’s attorney requested that the State agree to defend and indemnify Huss regarding Berdahl's HRB claims. Berdahl and Huss subsequently entered into a stipulated judgment resulting from the State’s refusal to defend and indemnify. The State filed this action seeking declarations that the State had no duty to defend or indemnify Huss against the claims and that Huss had entered a settlement without the consent of the State, which was unenforceable against the State. Berdahl counterclaimed seeking declarations that the State was responsible for the stipulated judgment entered by Berdahl and Huss and that the State was liable under the principle of respondent superior. The district court rejected Berdahl’s request for a declaration and held that the State owed no duty to defend or indemnify Huss. The court further reasoned that Berdahl’s exclusive remedy regarding her respondent superior claim was under the Montana Human Rights Act. The Supreme Court affirmed, holding that the district court did not err in concluding that the State bore no obligation to pay the stipulated settlement between Huss and Berdahl. View "State v. Berdahl" on Justia Law

After a jury trial, Defendant was convicted of felony theft. Defendant was sentenced to ten years in prison. Defendant appealed, arguing, among several other arguments, that the prosecutor committed plain error requiring reversal by stripping Defendant of the presumption of innocence. Specifically, Defendant challenged the prosecutor’s comment during closing arguments that the presumption of innocence had been removed from Defendant. The Supreme Court agreed with Defendant. The Court reversed the judgment and remanded the cause for a new trial, holding that the prosecutor’s comments during closing arguments constituted prosecutorial misconduct and required reversal of Defendant’s conviction. View "State v. Lawrence" on Justia Law