Justia Civil Rights Opinion Summaries

Pursuant to a plea agreement, Appellant pled no contest to the felony offense of mitigated deliberate homicide. Appellant subsequently filed a motion to withdraw his no contest plea, which the district court denied. Appellant appealed from the denial of his motion but later waived his appeal. Thereafter, Appellant filed a petition for postconviction relief, claiming ineffective assistance of counsel against his trial and appellate counsel. The district court denied Appellant’s petition. The Supreme Court affirmed the district court’s denial of Appellant’s petition for postconviction relief, holding (1) trial counsel was ineffective for failing to provide to Appellant a copy of a report by a forensic pathologist, but Appellant was not prejudiced by trial counsel’s error; and (2) Appellant failed to establish that appellate counsel was deficient by advising Appellant to withdraw his direct appeal in order to file a petition for postconviction relief. View "Haagenson v. State" on Justia Law

Defendant was charged with ninety-one counts of felony cruelty to animals after law enforcement officers applied for and obtained a warrant to search Defendant’s home and kennels, where Defendant bred Malamutes. The dogs were found to be ill and malnourished. One hundred and thirty-nine adult dogs and twenty-three puppies were seized. The district court denied Defendant’s motion to suppress, concluding, among other things, that probable cause was well established. Defendant was subsequently convicted as charged, and the district court ordered the forfeiture of every seized dog. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant’s motion to suppress; (2) did not abuse its discretion in limiting evidence to the time period of the charged offenses; and (3) did not abuse its discretion in requiring Defendant to forfeit all of his dogs. View "State v. Chilinski" on Justia Law

Defendant was charged with, among other offenses, aggravated DUI. Defendant filed a motion to suppress, arguing that Mark Fiorentino, an off-duty officer who arrested Defendant, lacked probable cause to effectuate a citizen’s arrest. The municipal court denied the motion, holding that the off-duty officer had probable cause to arrest Defendant under the circumstances. Defendant subsequently pleaded guilty to driving under the influence of alcohol, reserving the right to appeal the suppression order. The district court affirmed the municipal court’s denial of Defendant’s motion to suppress, holding that Fiorentino had probable cause to arrest Defendant and that the existing circumstances required Defendant’s immediate arrest. View "City of Missoula v. Iosefo" on Justia Law

In 2002, Elizabeth “Betsy” Baumgart was appointed to be the administrator of the Montana Tourism and Promotion Division of the Department of Commerce (DOC). In 2010, after Dore Schwinden was appointed as DOC director, Schwinden terminated Baumgart’s employment, citing a lack of management competencies and sufficient understanding of the Division’s budgeting process. Baumgart sued the DOC and Schwinden, individually and as DOC’s agent, alleging that DOC wrongfully discharged her and discriminated against her on political grounds because she was a Republican and Schwinden was a Democrat. The district court granted DOC’s motion for summary judgment as it pertained to Baumgart’s political affiliation discrimination claims and all claims against Schwinden. The Supreme Court affirmed, holding (1) because Baumgart failed to establish a prima facie case for political discrimination, the district court did not err in granting DOC’s motion for summary judgment on this issue; (2) the district court correctly dismissed the individual claims against Schwinden, as Schwinden was entitled to statutory immunity under the circumstances of this case; and (3) the district court correctly concluded that the DOC had good cause to terminate Baumgart. View "Baumgart v. Dep't of Commerce" on Justia Law

Defendant was charged with trespass to property and possession of dangerous drugs, both misdemeanor offenses. Defendant subsequently decided to enroll in the Mineral County Treatment Court. Defendant was aware that he could be sanctioned with incarceration if he was dishonest during his participation in the Treatment Court. During his participation in the Treatment Court Defendant tested positive for drug use and was interviewed by the Treatment Team regarding the results. Subsequently, a member of the Treatment Team sent a report to law enforcement detailing the information he learned from the interviews with Defendant. Defendant was subsequently charged with distribution of dangerous drugs and two counts of possession of dangerous drugs. Defendant filed motions to suppress and dismiss, arguing that the State violated the confidentiality provision of Mont. Code Ann. 46-1-1111(4) and his Fifth Amendment right against compelled self-incrimination by disclosing the confidential Treatment Court material to law enforcement. The district court denied the motions. The Supreme Court reversed the district court’s denial of Defendant’s motions to suppress and dismiss, holding that the State violated section 46-1-1111(4) by disclosing confidential drug testing information to law enforcement in order to investigate a new criminal offense. View "State v. Plouffe" on Justia Law

Martin Vincent Lau was charged with deliberate homicide. Lau claimed that the fatal shooting was an act of self-defense. Lau sought to offer his own out-of-court statement to prove that at the time of the shooting, he knew of specific instances of violence by the victim. The State moved in limine to prohibit Lau from introducing the statement on hearsay grounds. Lau, in turn, argued that the exclusion of his statement would limit his ability to put forth a defense and that he would be required to testify in order to establish his knowledge of specific instances of conduct by the victim. The district court ruled that Lau would be permitted to cross-examine witnesses about the victim's specific acts of violence and Lau’s knowledge of those acts, as contained in his statement. The Supreme Court granted the State’s petition for writ of supervisory control, holding that the Montana Rules of Evidence did not permit Lau to offer his own out-of-court statement in support of his claim of justifiable use of force. View "State v. District Court" on Justia Law

After a jury trial, Defendant was convicted of two counts of deliberate homicide. The Supreme Court affirmed the conviction on appeal. Defendant subsequently filed a petition for postconviction relief alleging that the State had failed to disclose exculpatory and impeachment evidence relevant to the case in violation of Brady v. Maryland and that his trial attorneys failed to provide effective assistance of counsel. The district court denied the petition. The Supreme Court affirmed, holding (1) the district court properly denied Defendant’s postconviction petition because the petition did not fulfill the elements of a Brady violation; and (2) any alleged error on the part of trial counsel did not prejudice Defendant, and therefore, the trial court did not err in concluding that Defendant had not received ineffective assistance of counsel. View "McGarvey v. State" on Justia Law

In 2011, Defendant was charged with driving under the influence of alcohol (DUI) and disorderly conduct. Defendant pleaded not guilty and requested a jury trial. The trial court later informed Defendant that his scheduled trial was rescheduled because an older case had been set for trial on the same day. Before his rescheduled trial, Defendant moved to have his case dismissed for lack of a speedy trial. The municipal court granted the motion. The district court reversed. On remand, Defendant was convicted of DUI and acquitted of disorder conduct. The Supreme Court reversed the district court ruling reversing the municipal court’s dismissal of the charges, holding that the City failed to meet its burden of showing “good cause” for the delay in bringing Defendant to trial. View "City of Helena v. Broadwater" on Justia Law

Defendant was charged with felony driving under the influence (DUI) and misdemeanor driving without valid liability insurance. Defendant entered pleas of not guilty and then filed a motion to dismiss for denial of his right to a speedy trial. After an evidentiary hearing, the district court denied Defendant’s motion to dismiss. Defendant then changed his plea to guilty on both charges, reserving the right to appeal the denial of his speedy trial motion. The Supreme Court reversed and remanded for dismissal of the charges, holding that the delay in bringing Defendant to trial violated his constitutional right to a speedy trial. View "State v. Zimmerman" on Justia Law

After a jury trial, Defendant was convicted of deliberate homicide. Defendant appealed, arguing that the district court erred by denying his motion to suppress statements he made to the police. The Supreme Court remanded with instructions to hold an evidentiary hearing. After a hearing on remand, the district court suppressed Defendant’s statements to the police on the grounds that the statements were made involuntarily and granted Defendant a new trial. The Supreme Court affirmed, holding that the district court did not err in concluding that Defendant’s statements were made involuntarily and in ordering a new trial. View "State v. OldHorn" on Justia Law