Justia Civil Rights Opinion Summaries

After a trial, Appellant was convicted of sexual intercourse without consent and sexual assault. The Supreme Court affirmed. Thereafter, Appellant filed a petition for postconviction relief raising numerous claims of ineffective assistance of counsel. The district court denied relief. The Supreme Court affirmed the district court’s denial of Appellant’s petition for postconviction relief, holding (1) counsel was not ineffective for failing to request dismissal of the charges against Defendant for the State’s alleged destruction of evidence or a jury instruction regarding the State’s failure to collect and preserve the subject evidence; and (2) counsel did not act unreasonably when he withdrew a proposed jury instruction on sexual assault as a lesser included offense. View "Taylor v. State" on Justia Law

After a jury trial, Defendant was convicted of felony sexual assault. Defendant later filed a petition for postconviction relief seeking DNA testing and alleging that he had received ineffective assistance of counsel (IAC). The district court denied the petition, but the Supreme Court reversed and remanded. Defendant subsequently filed a second petition requesting that he be allowed to conduct discovery. The district court denied both Defendant’s petition for DNA testing and his request to conduct discovery but granted relief as it pertained to his IAC claim. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in denying Defendant’s petition for DNA testing; and (2) erred in granting Defendant’s petition as it pertained to IAC of appellate counsel, as any error on appellate counsel’s part was harmless. View "Golden v. State" on Justia Law

Defendant pleaded guilty to tampering with witnesses and informants. Defendant subsequently filed a motion to withdraw his guilty plea, which the district court denied. Defendant appealed, arguing that he should be allowed to withdraw his guilty plea because his counsel misinformed him about his eligibility for a persistent felony offender designation. The Supreme Court affirmed the district court’s order denying Defendant’s motion to withdraw his guilty plea, holding (1) the district court correctly determined that Defendant was fully aware of the direct consequences of his plea and that the plea was not induced by misrepresentation; and (2) therefore, Defendant failed to show that, but for counsel’s deficient performance, he would not have entered a guilty plea. View "State v. Hendrickson" on Justia Law

In 1988, Appellant was convicted of misdemeanor assault and felony sexual intercourse without consent and was also designated a persistent felony offender (PFO). In 2013, Appellant filed a petition for writ of habeas corpus, claiming that he was wrongly sentenced for both the underlying felony and his PFO status. The Supreme Court granted the petition and remanded for correction of the illegal sentence. On remand, the district court resentenced Appellant during a status conference docketed under a newly-created civil cause number when neither Defendant nor his attorney were present. The Supreme Court reversed, holding that Appellant was sentenced with a complete lack of statutory or constitutional process. Remanded for a sentencing hearing. View "State v. McEvoy" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to two counts of criminal distribution of dangerous drugs. The State subsequently filed a petition to revoke Defendant’s deferred sentence based on her possession of oxycodone in violation of the conditions of her probation. Defendant filed a motion to suppress evidence seized by her probation officer after a search of Defendant’s purse. The district court denied the motion and later revoked Defendant’s deferred sentences. The Supreme Court affirmed, holding that the district court properly concluded that the probation officer conducted a legitimate probation search based on reasonable suspicion and in thereby denying Defendant’s motion to suppress. View "State v. Fischer" on Justia Law

The municipal court found Defendant guilty of disorderly conduct after Defendant and her daughter directed profane ad abusive language toward a thirteen-year-old boy from their vehicle on a public street. The district court affirmed Defendant’s conviction. The Supreme Court affirmed, holding, among other things, that (1) the disorderly conduct statute does not require proof that the peace of more than one person was disturbed; (2) Defendant’s speech constituted “fighting words” and was not constitutionally protected; (3) Defendant’s constitutional rights were not violated by the responding officer’s initial report of his investigation; and (4) the municipal court did not err by considering the victim’s age during sentencing. View "City of Billings v. Nelson" on Justia Law

Defendant was charged with felony burglary in 2007. The Flathead County District Court issued a warrant for Defendant’s arrest, but shortly afterward, Defendant was arrested and sentenced on unrelated federal charges. Defendant was subsequently committed to a federal correctional institution. In 2013, Defendant filed a pro se motion to dismiss the Flathead County arrest warrant, arguing that the county attorney’s failure to take action on his pending burglary charge violated his Sixth Amendment right to a speedy trial. The county attorney argued in response that Defendant’s motion must be denied because an inmate may invoke the provisions of the Interstate Agreement on Detainers Act (IAD) only after a detainer is filed. The District Court denied Defendant’s motion. The Supreme Court reversed, holding (1) Defendant’s motion was premised on an alleged denial of his constitutional right to a speedy trial, not the IAD; and (2) the district court improperly denied Defendant’s motion without addressing his speedy trial rights. Remanded. View "State v. Nickerson" on Justia Law

Plaintiff, registered voters seeking to invalidate the Montana Districting and Apportionment Commission’s (Commission) assignment of two “holdover senators” in its final 2013 redistricting plan, filed a complaint against the State and Secretary of State (collectively, "State") seeking injunctive and declaratory relief. The district court granted the State’s motion for summary judgment and denied Plaintiff’s motion for summary judgment. The Supreme Court affirmed, holding that the district court did not err in concluding that (1) the Commission did not violate the public’s “right to know”; (2) the Commission is part of the legislative branch and is not an agency, and that it is therefore exempt from statutes promulgating the right of participation; and (3) Plaintiffs’ argument that the Commission violated Plaintiffs’ right of suffrage was without merit. View "Willems v. State" on Justia Law

Defendant was arrested after law enforcement officers responded to a report that Defendant had stolen a purse and, after conducting a warrant check, learned that Defendant had an outstanding city warrant. At the detention center, officers conducted an inventory search of Defendant’s purse and found drugs and drug paraphernalia. The State charged Defendant with criminal possession of dangerous drugs with intent to distribute and criminal possession of drug paraphernalia. Defendant filed a motion to suppress or dismiss, which the district court denied. Defendant pleaded guilty to both counts. Defendant subsequently appealed the denial of her motion to suppress and dismiss, asking the Supreme Court to overturn State v. Pastos, in which the Court held that a compelling state interest justifies a routine, administrative inventory search of the personal property in the possession of the arrestee at the station house following a lawful arrest. The Supreme Court affirmed the denial of Defendant’s motion and, in so doing, reaffirmed its decision in Pastos, holding (1) safety concerns and procedural safeguards justify the inventory searches at issue; and (2) the search of Defendant’s purse was a valid inventory search under Pastos. View "State v. Demontiney" on Justia Law

After a jury trial, Defendant was found guilty of accountability for criminal distribution of dangerous drugs and committed to the custody of the Department of Corrections for fifteen years, with ten years suspended. Defendant appealed, arguing that his attorney provided ineffective assistance by moving to preclude evidence of accountability or conspiracy, which Defendant alleged alerted the State to its “charging error," thus prompting the State to amend the charges and thereby assuring his conviction. The Supreme Court affirmed, holding that Defendant’s argument was entirely without merit and that the efforts of Defendant’s attorney were well within the wide range of reasonable professional conduct. View "State v. Carter" on Justia Law