Justia Civil Rights Opinion Summaries

The Supreme Court affirmed in part and reversed the judgment of the district court convicting Defendant of aggravated burglary and obstructing a police officer and sentencing him to forty years for aggravated burglary and six months for obstructing a peace officer, holding that the case must be remanded for resentencing.Specifically, the Supreme Court held (1) Defendant's constitutional right to a speedy trial was not violated; (2) Defendant's claim of instructional error not warrant plain error review because he failed to show how he was prejudiced; (3) Defendant's ineffective assistance of counsel claim must fail because Defendant he to show any prejudice; and (4) Defendant was entitled to resentencing because the district court relied on incorrect information when it imposed the sentence. View "State v. Kirn" on Justia Law

The Supreme Court affirmed the decision of the district court to deny Petitioner's petition to reinstate his driver's license, holding that the district court did not err in denying the petition because Petitioner did not meet his burden to prove that the suspension of his driver's license was improper.On appeal, Petitioner argued that his request to speak to an attorney prior to taking a preliminary breath test and a post-arrest blood test should not have been taken as an implied refusal to submit to either test and, therefore, he did not refuse to take the tests. The Supreme Court affirmed, holding (1) the record reflected that Petitioner explicitly refused to take the tests; and (2) the district court correctly denied Petitioner's petition. View "Turner v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that Mont. Code Ann. 50-20-109(1)(a), which restricts providers of abortion care to physicians and physician assistants (PAs), violates a woman's fundamental right of privacy, guaranteed by the Montana Constitution, to seek abortion care from a qualified health care provider of her choosing, holding that there was no error.In reaching its decision, the district court concluded that the State failed to "clearly and convincingly demonstrate a medically acknowledged, bona fide health risk which justifies interfering with a patient's fundamental right[....]to choose the health care provider who performs the [abortion] procedure[.]" The Supreme Court affirmed, holding (1) there is no medically acknowledged, bona fide health risk for the State to restrict the availability of abortion care by preventing Advanced Practice Registered Nurses (APRNs) from performing abortions; and (2) therefore, Montanans have the right to seek abortion care from certified APRNs. View "Weems v. State" on Justia Law

The Supreme Court affirmed the decision of the district court upholding the ruling of the Montana Human Rights Commission dismissing Appellant's discrimination claim against the National Board of Medical Examiners (NBME), holding that the Commission correctly found that Appellant's complaint was not timely filed.Appellant, a medical student, filed a complaint against the NBME alleging that NMBE discriminated against her for having a mental disability when it denied her request for test-taking accommodations. The Human Rights Bureau dismissed the complaint on the basis that Appellant filed it outside of the 180-day statutory time limit. The Commission affirmed, and the district court dismissed Appellant's petition for review. The Supreme Court affirmed, holding that Appellant's complaint was not timely filed within 180 days of the date when the alleged discriminatory act occurred and Appellant discovered it. View "Zolnikov v. Nat'l Bd. of Medical Examiners" on Justia Law

The Supreme Court reversed the conclusion of the district court that the more than three-year delay between Defendant's arrest and his subsequent criminal trial did not violate his constitutional right to a speedy trial, holding that Defendant did not receive his guaranteed right to a speedy trial.Defendant was charged with assault with a weapon. After facing a lengthy wait to be evaluated for his mental fitness to stand trial Defendant received a bed at the Montana State Hospital (MSH), where his fitness for trial improved. Defendant's fitness, however, decompensated after he was sent back to jail, leading to a second admission to MSH before the case finally went to trial. A jury found Defendant guilty, and the district court denied Defendant's motion to dismiss for lack of speedy trial. The Supreme Court reversed, holding that the 1,179-day delay between Defendant's arrest and trial, due to systemic institutional problems, violated Defendant's constitutional right to a speedy trial. View "State v. Allery" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting and sentencing Defendant for robbery, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that he did not knowingly and voluntarily waive his right to counsel during his criminal trial. Defendant also argued, for the first time, that the district court compromised his right to a unanimous jury verdict by not giving a specific unanimity instruction requiring the jury to agree that either or both victims were in fear of immediate bodily injury. The Supreme Court affirmed, holding (1) Defendant knowingly and voluntarily waived his right to counsel; and (2) this Court declines to exercise plain error review to address Defendant's second argument on appeal. View "State v. Winzenburg" on Justia Law

The Supreme Court reversed the order of the district court granting Defendant's motion to dismiss Plaintiff's complaint making a claim for statutory damages against the Board of County Commissioners pursuant to Mont. Code Ann. 76-3-625(1) and equal protection, takings, and due process claims under 42 U.S.C. 1983, holding that the district court erred.In granting the Board's motion to dismiss, the district court determined that Plaintiff's section 76-3-625(1) claims were barred by a thirty-day statute of limitations and its section 1983 claims failed to state a claim. The Supreme Court reversed, holding that the district court erred in (1) determining that the section 76-3-625(1) claim was subject to a thirty-day statute of limitations and was therefore time-barred; and (2) erred in concluding that Plaintiff's 42 U.S.C. 1983 claims lacked a sufficient protected property interest and were insufficiently pled to survive a motion to dismiss for failure to state a claim. View "Tai Tam, LLC v. Missoula County" on Justia Law

The Supreme Court denied Defendant's motion to allow withdrawal of his guilty plea and dismiss the underlying matter on double jeopardy grounds, holding that the district court did not err in denying Defendant's motion to withdraw his guilty plea and dismiss and the criminal endangerment and criminal mischief charges in Jefferson County.Jefferson County charged Defendant with criminal endangerment, fleeing from or eluding a peace officer, and criminal mischief. The next month, Gallatin County charged with him criminal endangerment and fleeing from or eluding a peace officer. Defendant pled guilty to both charges. Defendant subsequently moved to withdraw his guilty plea and to dismiss the Jefferson County charges, arguing that they violated constitutional double jeopardy protections. The district court allowed the motion as to the fleeing from or eluding a peace officer charge and otherwise denied the motion. The Supreme Court affirmed, holding that the district court did not err by denying Defendant's motion to withdraw his guilty plea as to the criminal endangerment and criminal mischief charges. View "State v. Dunne" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of deliberate homicide and tampering with or fabricating physical evidence, holding that Defendant's assignments of error were without merit.On appeal, Defendant argued, among other things, that the State's 391-day delay in bringing his case to trial violated his constitutional right to a speedy trial under both the state and federal constitutions. The Supreme Court affirmed, holding (1) where the delay was primarily institutional under the conditions presented at the time by the unprecedented COVID-19 pandemic and where Defendant failed to demonstrate prejudice, Defendant failed to establish that he was denied his right to a speedy trial; and (2) the district court did not err when it denied Defendant's motion to strike the jury panel. View "State v. Hesse" on Justia Law

The Supreme Court reversed the order of the district court committing Appellant to the Montana State Hospital at Warm Springs for a period of up to ninety days, holding that the district court committed reversible error when it allowed a professional person to testify by telephone over Appellant's objection.The State filed a petition for Appellant's involuntary commitment due to her disorganized thinking and confusion. At a hearing on the petition, the State called Amanda Torres, a licensed clinical professional counselor, to testify by telephone due to technical difficulties with courtroom video capabilities. The district court overruled Appellant's rejection and allowed Torres to testify by telephone. Relying on Torres's testimony, the district court concluded that Appellant suffered from a mental disorder and required commitment. The Supreme Court reversed, holding that the district court erroneously overruled Appellant's objection and that the court was statutorily mandated to prohibit Torres's testimony by telephone because it did not satisfy the requirement for two-way audio-video communication and because Appellant objected. View "In re S.E." on Justia Law