Justia Civil Rights Opinion Summaries

In 2004, Petitioner was hired as a production supervisor for Holcim Inc.’s cement manufacturing plant. In 2008, Petitioner was diagnosed with angina. After Petitioner left Holcim, Petitioner filed a claim under the Montana Human Rights Acts for discrimination. The Montana Department of Labor and Industry dismissed Petitioner’s complaint, concluding that Holcim did not discriminate against Petitioner on the basis of disability. The Montana Human Rights Commission upheld the dismissal, and the district court affirmed. The Supreme Court affirmed, holding that the district court did not err in affirming the hearing officer’s determination that Petitioner did not prove that he belonged to a protected class, as Petitioner failed to establish that he was disabled within the meaning of the Human Rights Act. View "Estate of Welch v. Holcim, Inc." on Justia Law

Appellant pleaded no contest to arson, a felony. Appellant later moved to withdraw his no contest plea. The district court denied the petition, concluding that Appellant entered a knowing and voluntary plea and could not demonstrate that the offer of proof was insufficient or that his representation was ineffective. The district court's judgment was affirmed on appeal. Appellant subsequently petitioned for postconviction relief, alleging ineffective assistance of counsel and that the district court misinterpreted the arson statute. The district court denied the petition. The Supreme Court affirmed, holding (1) the district court did not err in its interpretation of the arson statute; and (2) Appellant was unable to prove that he was afforded ineffective assistance of counsel. View "Ellison v. State" on Justia Law

After a jury trial, Defendant was convicted of vehicular homicide while under the influence, failure to stop immediately at the scene of an accident involving an injured person, and driving without a valid driver's license. The Supreme Court affirmed, holding (1) the district court did not err by limiting Defendant's cross-examination of the State's informant; (2) the district court erred when it prevented Defendant's expert forensic pathologist from testifying about matters not disclosed through discovery, but the error was harmless; and (3) the district court's decision to permit an undisclosed expert witness to testify for the State did not constitute reversible error. View "State v. Garding" on Justia Law

After a jury trial, Defendant was convicted of two counts of attempted deliberate homicide. The Supreme Court affirmed, holding that the district court (1) correctly denied Defendant's motion for a new trial based on juror misconduct; (2) made an adequate inquiry into Defendant's ineffective assistance of counsel claim and took adequate precautions to ensure that Defendant knowingly and voluntarily waived counsel; (3) correctly employed a balancing test to conclude that Defendant was not deprived of his right to a speedy trial; (4) did not err by admitting evidence of Defendant's prior assault of his wife to rebut Defendant's character evidence; (5) did not plainly err in instructing the jury on mitigated deliberate homicide; and (5) did not improperly impose parole conditions. View "State v. MacGregor" on Justia Law

Defendant was convicted of felony burglary and misdemeanor criminal mischief. Defendant was sentenced to five years incarceration, all suspended. One of the conditions of Defendant's probation was that he not use or possess illegal drugs. The State later filed a petition to revoke Defendant's suspended sentence for, inter alia, driving under the influence of drugs and crushing up his medications and snorting them, rather than taking them as directed by a physician. Defendant moved for a continuance of his revocation hearing, explaining that a "substantial amount of discovery" had not yet been produced. The district court denied the motion. After a hearing, the district court ordered Defendant's sentence revoked. The Supreme Court affirmed, holding that the district court did not abuse its discretion or violate Defendant's right to due process when it revoked Defendant's probation without requiring full disclosure of all evidence against him. View "State v. Sebastian" on Justia Law

After a jury trial, Appellant was convicted of theft and accountability to burglary. The Supreme Court reversed Appellant's conviction for theft and affirmed Appellant's conviction for accountability to burglary, holding (1) the district court did not err by instructing the jury on the theory of accountability when the State had not directly charged an accountability based offense; (2) Appellant's counsel's failure to object to an instruction on accountability that defined "purposely" as a conduct-based mental state rather than a result-based mental state caused no prejudice to Appellant; but (3) Appellant's counsel rendered ineffective assistance by failing to object to her theft conviction on the grounds that it violated Montana's statutory restriction on multiple charges. Remanded. View "State v. Tellegen" on Justia Law

After a jury trial, Appellant was convicted of the attempted deliberate homicide of her husband, Mike. The Supreme Court affirmed, holding that the district court did not err when it (1) excluded Appellant's proposed expert witness testimony from two expert witnesses about the behaviors of individuals in abusive relationships and the experts' diagnoses of Appellant with post-traumatic stress disorder; and (2) admitted Mike's alleged prior inconsistent statement to a volunteer firefighter responding to a medical emergency when Mike could not remember making the statement, as the statement was admissible under Mont. R. Evid. 801(d)(a)(A). View "State v. Lotter" on Justia Law

Five City employees were disciplined by the City for accessing pornography on their government computers. The local newspaper requested access to documents detailing the investigation of the misconduct and the employees' punishment. The City disclosed some documents, refused to release the disciplinary corrective action forms, and redacted all information that could be used to identify the disciplined employees or uninvolved third parties. The newspaper filed a petition for declaratory relief and writ of mandamus. The district court ordered that the City release copies of the investigative documents and disciplinary forms without redactions. The Supreme Court reversed, holding that the district court erred by ordering that identifying information for the five City employees be released to the newspaper, as the employees' reasonable expectation of privacy in their identities with regards to internal disciplinary proceedings clearly outweighed the limited merits of public disclosure. View "Billings Gazette v. City of Billings" on Justia Law

Appellant was convicted of criminal distribution of dangerous drugs and sentenced to a ten-year term of incarceration. On appeal, Appellant argued that insufficient evidence supported his conviction because the State did not produce sufficient evidence at trial that the substance given to a third party was marijuana, a dangerous drug. The State responded that although the substance was not tested, the third party's testimony and the fact that Appellant had a medical marijuana card were sufficient to prove that the substance was marijuana. The Supreme Court reversed Appellant's conviction, holding that the evidence presented at trial was insufficient to allow a rational trier of fact to conclude beyond a reasonable doubt that the substance in question was a dangerous drug. View "State v. Burwell" on Justia Law

Plaintiffs were covered by the State's employee healthcare benefit program established under Title 2, chapter 18, MCA ("the Plan"). Both Plaintiffs were injured in separate automobile accidents. All of the medical bills of both plaintiffs were paid by either the Plan or by third-party insurers. In both cases, medical care providers returned a claim payment to the Plan because the claim had been paid by other insurers. Plaintiffs asserted that the Plan should not have retained the payments returned by the medical providers but should have paid those amounts to Plaintiffs unless they had been made whole or fully compensated for all losses they incurred as a result of the automobile accidents. The district court concluded that the State's operation of the Plan was subject to the "made-whole" provisions Title 2, and thus, no insurer had a right to subrogation unless the insured was made whole for all losses. The Supreme Court affirmed, holding that the made-whole requirement of Mont. Code Ann. 2-18-902(4) applied to the Plan insofar as it had withheld payments or had retained payments returned by a healthcare provider because the medical expenses had been paid by a third party. View "Diaz v. State" on Justia Law