Justia Civil Rights Opinion Summaries

Appellant entered Alford pleas to the felony offenses of aggravated kidnapping, aggravated assault, assault with a weapon, intimidation, and aggravated burglary. Appellant later moved to withdraw his Alford pleas, contending that his mental state at the time of the pleas precluded him from knowingly and voluntarily making a plea decision, he was innocent to the changes against him, and the district court's colloquy was insufficient to determine whether the pleas were knowingly and voluntarily made. The district court denied Appellant's motion. The Supreme Court affirmed, holding (1) Appellant failed to establish that there was good cause to allow him to withdraw his prior Alford pleas to the charges against him; and (2) the matter should be remanded to the district court for a determination of the total amount of restitution for the victim's future counseling costs. Remanded. View "State v. Peterson" on Justia Law

After police officers knocked on the door to Defendant's residence to ask for directions they confiscated forty plants of marijuana. Defendant pled guilty to criminal production or manufacture of dangerous drugs, a felony. Defendant appealed the denial of his motion to suppress the results of the search of his residence, arguing that because officers had no reason to enter his property, they were not lawfully in a place where they could see the marijuana in plain view. The Supreme Court (1) affirmed the district court's denial of Defendant's motion to suppress, as the officers were lawfully on Defendant's property, and thus their observations of the marijuana in plain view were an appropriate basis for the charges; but (2) reversed the district court's imposition of the cost of court-appointed counsel, as the amount of that cost exceeded the statutorily allowed amount. View "State v. Phillips" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual assault and sentenced to concurrent 100 year sentences, with fifty years of each sentence suspended. The Supreme Court affirmed, holding that Defendant's trial counsel did not render ineffective assistance in (1) failing to object to the admission of certain incidences of hearsay testimony by various witnesses, as the testimony either fell among the hearsay exceptions provided for in the Montana Rules of Evidence or defense counsel may have had strategic reasons for not objecting; and (2) stipulating to the admission of multiple items of evidence that Defendant alleged contained otherwise inadmissible hearsay evidence, as Defendant's allegations implicated questions of trial strategy that exceeded the scope of the record. View "State v. Mederos" on Justia Law

Defendant pleaded no contest to one count of felony criminal endangerment pursuant to a plea agreement. Prior to sentencing, Defendant filed a motion to withdraw his plea, which the district court denied. The district court then imposed a ten-year suspended sentence. Defendant filed a motion to withdraw his plea, arguing that the district court failed to establish a sufficient factual basis for his no contest plea, and therefore, there was doubt as to whether Defendant entered his plea voluntarily. The Supreme Court affirmed, holding that the district court did not err by denying Defendant's motion to withdraw plea, as the district court established a sufficient factual basis for the offense, Defendant was made aware of the consequences of the plea, and the plea was made voluntarily. View "State v. Jackson" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony sexual abuse of children for having engaged in sexually-related conduct online with a deputy sheriff who represented himself as a fourteen-year-old female. Defendant was arrested based on his potential plans to travel to Montana to meet the supposed fourteen-year-old in person. The Supreme Court affirmed Defendant's convictions, holding (1) Montana's sexual abuse of children statute does not violate the First Amendment and the Commerce Clause by sweeping too broadly; and (2) the district court properly authenticated extensive internet chat logs and properly admitted them into evidence, and the court's ruling did not unfairly prejudice Defendant. View "State v. Hantz" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault. The Supreme Court affirmed, holding (1) the district court did not err in refusing to dismiss the charges against Defendant when, after Defendant disclosed information and defense strategies to the State Medical Examiner, communication occurred between the Medical Examiner and the County Attorney; (2) the district court properly determined that the State's witnesses were not unnecessarily cumulative or unfairly prejudicial to Defendant; (3) the district court did not abuse its discretion when it determined that the State's evidence was not so prejudicial as to render the trial fundamentally unfair; (4) the district court did not abuse its discretion in denying Defendant's motion for a new trial on the grounds of prosecutorial misconduct; and (5) Defendant's counsel did not provide ineffective assistance. View "State v. Ugalde" on Justia Law

After a jury trial, Defendant was convicted of two counts of attempted deliberate homicide. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) the district court correctly denied Defendant's motion for a new trial based on juror misconduct; (2) the district court id not err by failing to inquire into Defendant's ineffective assistance of counsel claim and the voluntariness of his decision to represent himself; (3) the district court correctly concluded that Defendant was not deprived of his right to speedy trial; (4) the district court did not err by admitting evidence of Defendant's prior assault of his wife; (5) a jury instruction on mitigated deliberate homicide did not rise to the level of plain error; and (6) the district court properly imposed parole conditions. View "State v. MacGregor" on Justia Law

Thomas Madsen, a sheriff's deputy, was charged with mistreating prisoners pursuant to Mont. Code Ann. 45-5-204 for his behavior toward K.J., a female juvenile who was brought to the county law and justice center at the request of her parents for assistance in getting her transported to residential treatment. Madsen moved to dismiss the charge, contending that K.J. was not a prisoner under section 45-5-204. The district court agreed and dismissed the charge against Madsen because K.J. was a juvenile, had not been convicted of an offense, and was not being held in a State facility. The Supreme Court reversed and remanded, holding that, under the circumstances, K.J. was a prisoner under section 45-5-204(1), and the charging information filed in this case was adequate to state an offense. View "State v. Madsen" on Justia Law

After a jury trial, Defendant was convicted of three counts of omitting material facts relating to his offer and sale of a security. Defendant appealed, arguing that the multiple charges statute, Mont. Code Ann. 46-11-410, precluded his convictions on two of the three counts with which he was charged. The Supreme Court reversed the district court's judgment as to two of Defendant's convictions, holding (1) the State's assertion that "each count had a different element" was incorrect, as each count had the same statutory element, and the offenses arose from the same transaction; and (2) therefore, the district court erred in denying Defendant's motion under section 46-11-410. Remanded. View "State v. Parks" on Justia Law

After a jury trial, Defendant was convicted of sexual intercourse without consent. The Supreme Court affirmed, holding (1) the district court correctly concluded that Defendant was not denied his right to a speedy trial; (2) Defendant failed to establish that he received ineffective assistance of counsel when his attorney failed to object to evidence at trial; (3) the State did not violate Defendant's right to due process by using Defendant's silence after receiving Miranda warnings against him at trial, as the issue was raised during cross-examination of Defendant and focused on Defendant's alibi; and (4) Defendant failed to establish that his conviction should be reversed based upon cumulative error, as there was no error in his conviction. View "State v. Morsette" on Justia Law