Justia Civil Rights Opinion Summaries

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

After the conclusion of a bench trial, Defendant was found guilty of aggravated driving under the influence with a breath alcohol concentration (BAC) of 0.239. Defendant appealed to the district court and filed a motion to suppress the evidence gathered after the vehicle he was driving was stopped by an officer of the Motor Carrier Services Division, Montana Department of Transportation (MDT). The district court denied the motion. The Supreme Court affirmed, holding that the MDT officer acted properly and within the requirements of law in stopping Defendant’s truck, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Beaver" on Justia Law

Defendant was charged with partner or family member assault (PFMA) for physically assaulting his girlfriend. Defendant filed a motion to dismiss the PFMA charge, arguing that the statute under which he was charged violated his right to equal protection because it did not apply to persons in same-sex intimate relationships. The justice court denied the motion, concluding that the statute did not violate Defendant’s right to equal protection because it does not treat similarly-situated individuals unequally. The court then found Defendant guilty. The district court affirmed, concluding that the justice court correctly analyzed Defendant’s equal protection claim. The Supreme Court affirmed, holding (1) the former version of the statute under which Defendant was charged violated equal protection; (2) the unconstitutional provision was unnecessary for the integrity of the law, and severing that provision leaves the remainder of the statute complete in itself; and (3) therefore, Defendant was not entitled to dismissal of his PFMA charge. View "State v. Theeler" on Justia Law

Defendant was charged with criminal possession of dangerous drugs with intent to distribute and criminal possession of dangerous drugs/opiates. Defendant moved to suppress the evidence found in his vehicle during a search pursuant to a search warrant, arguing that the police lacked particularized suspicion to initiate a traffic stop. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err in determining that the stop of Defendant was supported by a particularized suspicion that Defendant’s tail light covers violated Mont. Code Ann. 61-9-204(5). View "State v. Massey" on Justia Law

Defendant was arrested and charged with felony criminal possession. The district court granted the State’s motion for a continuance and reset Defendant’s trial for a day 285 days after his arrest. Defendant filed a motion to dismiss for speedy trial violations. The district court denied the motion. Defendant pleaded guilty but reserved the right to appeal the denial of his speedy trial motion. The Supreme Court reversed, holding that Defendant was denied his right to a speedy trial, considering the State’s reason for the delay, the simplicity and nature of the charges, and the prejudice to Defendant by his inability to participate in drug rehabilitation programs and community placement because of his unduly lengthy incarceration in county jail, in conjunction with Defendant’s need for treatment. Remanded for dismissal of the charges. View "State v. Mayes" on Justia Law

After a jury trial, Defendant was convicted of threats and other improper influence in official matters, criminal trespass, and disorderly conduct. The Supreme Court affirmed the improper influence conviction and reversed the conviction for criminal trespass, holding (1) the Court declines to consider in this appeal Defendant’s argument that the improper influence statute is unconstitutionally overbroad; (2) the State presented sufficient evidence to convict Defendant of improper influence; (3) the State did not present sufficient evidence to convict Defendant of criminal trespass; (4) the district court did not abuse its discretion in allowing evidence of prior incident with the arresting officer; and (5) the Court declines to consider whether Defendant’s counsel provided deficient representation by failing to object to the jury instructions on mental state. View "State v. Spottedbear" on Justia Law

After a jury trial, Defendant was found guilty of sexual assault and sexual intercourse without consent. The Supreme Court affirmed, holding that the district court (1) did not violate Defendant’s constitutional right to a public trial when it closed to the public a hearing on the admissibility of the victim’s prior allegations of sexual abuse; (2) did not abuse its discretion in preventing Defendant from questioning the victim about prior allegations of sexual abuse; and (3) did not err by not disclosing information contained in sealed records after conducting an in camera review. View "State v. Hoff" on Justia Law

This case concerned three retirement plans established by the Montana Legislature under the Montana Public Employee Retirement System (PERS). Plaintiffs, who elected to participate in the Defined Contribution Retirement Plan (DC Plan) and Montana University System Retirement Plan (University Plan), filed suit against the State and PERS, alleging that they were treated unequally from similarly-situated participants in the Defined Benefit Retirement Plan (DB Plan) and that requiring State employers of DC and University Plan participants to contribute to the trust that funds the retirement benefits of all DB Plan participants (DB Trust) violates Plaintiffs’ substantive due process rights. The district court granted summary judgment to Defendants, concluding (1) participants in the DB Plan, DC Plan, and University Plan are not members of similarly situated classes under an equal protection analysis, and (2) employer contributions to the DB Trust that are calculated based on the salaries of DC and University Plan participants do not violate substantive due process. The Supreme Court affirmed, holding that the district court did not err in its judgment. View "Wrzesien v. Mont. Pub. Employee Ret. Admin." on Justia Law

Defendant pleaded guilty to aggravated burglary, elder abuse, and failure to comply with licensing requirements. Defendant was sentenced to twenty-five years in prison for aggravated burglary, ten years in prison for elder abuse, and six months in jail for the licensing violation. All sentences were to run concurrently. Defendant appealed, arguing that receiving multiple convictions for elder abuse and aggravated burglary violated Mont. Code Ann. 46-11-410(2)(d) and that her counsel’s failure to object constituted ineffective assistance of counsel. The Supreme Court affirmed, holding that elder abuse and aggravated burglary do not constitute multiple convictions for the same offense and do not violate section 46-11-410(2)(d), and therefore, Defendant’s claim of ineffective assistance of counsel must fail. View "State v. Hooper" on Justia Law