Justia Civil Rights Opinion Summaries

Mont. Code Ann. 15-7-211 requires the Department of Revenue (Department) to reappraise all residential property in the state every six years. The Department assessed the value of Plaintiff's property in 2008 and used the 2008 appraisal to establish Plaintiff's tax liability for the six-year tax cycle ending in 2014. Plaintiff argued that section 15-7-111, as applied, violated its right to equal protection. The State Tax Appeal Board rejected the claim. The district court, however, concluded that section 15-7-111 violated Plaintiff's right to equal protection because the six-year tax cycle caused some taxpayers to pay a disproportionate share of taxes due to their over-assessed property value and other taxpayers to pay less than their fair share of taxes due to their under-assessed property value. The Supreme Court reversed, holding that similarly situated taxpayers, for a short time, may pay divergent taxes, and such a divergence in taxes does not violate equal protection privileges. View "Covenant Invs., Inc. v. Dep't of Revenue" on Justia Law

Defendant pled guilty to felony DUI offenses and associated offenses, including two misdemeanor offenses. After Defendant began serving his period of probation, the State filed a petition to revoke Defendant's probation based upon his violation of certain conditions of probation. The district court issued a bench warrant for Defendant's arrest, but Defendant had absconded from supervision. Eight years later, the State petitioned the district court to quash the original arrest warrant and to issue a new warrant for Defendant's arrest. Defendant was subsequently arrested and sentenced. Defendant appealed, arguing that the eight-year delay between the initial arrest warrant and his actual arrest violated his right to due process. The Supreme Court remanded for resentencing, as the district court may have imposed a longer period of imprisonment than allowed. View "State v. Sullivant" on Justia Law

Defendant was charged with criminal possession of dangerous drugs with intent to distribute and was appointed counsel. A jury subsequently found Defendant guilty of criminal possession with intent to distribute. The Supreme Court affirmed, holding (1) the district court's pre-trial inquiry into Defendant's complaint about his counsel was adequate, and the court did not abuse its discretion by declining to further consider Defendant's complaints in a hearing; (2) the district court did not err in denying Defendant's motion for a new trial; and (3) the case was remanded so that the district court may conform the written judgment to the oral pronouncement of sentence, which conditioned any assessment of fees upon Defendant's future ability to obtain work if released on parole. View "State v. Hammer" on Justia Law

After a jury trial, Defendant was found guilty of felony DUI and driving without a valid driver's license. Defendant subsequently filed a motion to vacate his convictions primarily on the grounds that he had not received a probable cause hearing within forty-eight hours of his arrest. The district court denied Defendant's motion. The Supreme Court affirmed, holding that Defendant waived his right to complain that nineteen days was an unreasonable time for the State to initiate filing charges in the district court by failing to object or file a motion to dismiss before his trial. View "State v. Haller" on Justia Law

After a jury trial, Defendant was convicted of felony sexual assault and sentenced to forty years imprisonment. The district court imposed a restitution obligation of $1,583 with an ongoing obligation to the extent the victim required additional or ongoing treatment. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the district court did not abuse its discretion in denying Defendant's for-cause challenge of a prospective juror; (2) the district court did not abuse its discretion in admitting a forensic interviewer's opinion testimony; (3) the district court properly admitted the victim's prior consistent statements; and (4) the district court erred in imposing a restitution obligation that was not for a "specified amount." Remanded to the district court to set a specified amount for restitution for future costs. View "State v. Champagne" on Justia Law

On July 25, the State charged Defendant with partner or family member assault (PFMA), alleging that the pending charge was a felony. Defendant pled not guilty on August 18. On October 26, the district court dismissed the felony charge. The State then filed a misdemeanor PFMA charge against Defendant. On November 15, Defendant pled not guilty to the misdemeanor charge. The case was set for trial on May 5. Defendant filed a motion to dismiss for failure to provide a speedy trial, alleging that the State failed to bring his case to trial within six months of his initial plea on the dismissed felony PFMA charge. Defendant's motion to dismiss was denied, and Defendant pled guilty to the reduced charge of disorderly conduct, a misdemeanor. The Supreme Court affirmed, holding that the district court (1) correctly concluded that Defendant's not guilty plea to the felony PFMA charge was irrelevant in determining whether Defendant's right to a speedy trial had been violated; and (2) correctly concluded that Defendant's right to a speedy trial had not been violated when he filed his motion to dismiss less than six months after pleading not guilty to the misdemeanor PFMA charge. View "State v. Case" on Justia Law

After Defendant stole numerous firearms and other merchandise from his employer, the United States charged him with theft of firearms from a federal licensee and possession of stolen firearms. Defendant pleaded guilty to the charges. Meanwhile, the State charged Defendant with theft by common scheme for his theft of the non-firearm merchandise. Defendant filed a motion to dismiss for violation of his statutory double jeopardy rights. The district court denied the motion. Defendant subsequently entered a conditional plea of guilty to the charge. The Supreme Court affirmed the district court's denial of Defendant's motion to dismiss, holding that double jeopardy did not bar the State's prosecution of Defendant for his theft of non-firearm items pursuant to the three part test set forth in State v. Fox. View "State v. Cline" on Justia Law

In 2007, Defendant received a suspended sentence for felony offense that was ordered to run consecutively to his revocation in another proceeding in which he was serving probation after being transferred from juvenile to adult supervision. In 2012, the State filed a petition to revoke Defendant's 2007 suspended sentence. Defendant filed a motion to dismiss the petition. The district court denied Defendant's petition and revoked Defendant's 2007 sentence. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to dismiss the petition where (1) Defendant was here challenging his 2007 as illegal, and his challenge was untimely; and (2) the consecutive designation of the 2007 was not properly raised here. View "State v. Adams" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to one count of negligent vehicular assault and driving while suspended. The district court sentenced Defendant to a six-year deferred sentence. Defendant, who lived in Oregon, expected to immediately return to Oregon but was informed by his probation officer that he must complete ninety days on supervision before he was permitted to leave Montana. Defendant moved to withdraw his plea. The district court denied the motion, concluding that Defendant's plea was entered voluntarily because defense counsel never promised that Defendant would be allowed to reside in Oregon. The Supreme Court affirmed, holding (1) the district court correctly concluded that Defendant failed to demonstrate defense counsel rendered ineffective assistance; and (2) the district court correctly concluded that Defendant's plea was not involuntarily entered where defense counsel's failure to accurately predict that Defendant would have to complete ninety days in Montana on good behavior before returning to Oregon did not rise to the level of gross mischaracterization. View "State v. Prindle" on Justia Law

After a jury trial, Defendants were convicted of aggravated cruelty to animals, a felony, for knowingly mistreating or neglecting several cats in the form of cruel confinement and/or inadequate nourishment. The Supreme Court affirmed, holding (1) the State presented sufficient evidence upon which a rational trier of fact could find beyond a reasonable doubt that Defendants, without justification, knowingly subjected their animals to mistreatment or neglect; and (2) the district court did not abuse its discretion in denying Defendants' motion for a mistrial, as the prosecutor's remarks during closing argument were not so egregious as to render the juror incapable of judging the evidence fairly. View "State v. Criswell" on Justia Law