Justia Civil Rights Opinion Summaries

Defendant, a sexual offender, was charged with failing to provide notice of his change of residence. Defendant pled guilty pursuant to a plea agreement. The district court imposed a four-year sentence and imposed several probation conditions recommended in Defendant's presentence investigation report. The district court also required Defendant to pay the costs of his court-ordered evaluations and treatment. The Supreme Court affirmed the sentence, holding (1) Defendant's failure to object to the district court's requirement that he pay the costs of his court-ordered evaluations and treatment in the district court precluded Defendant from raising the issue on appeal; and (2) the district court did not abuse its discretion in imposing certain conditions, which relate specifically to sexual offenders, as part of Defendant's probation. View "State v. Bullplume" on Justia Law

Defendant entered a plea of not guilty to disorderly conduct, a misdemeanor. Defendant was informed that his failure to appear at the final pre-trial hearing would constitute a waiver of his right to a jury trial. Defendant failed to appear at the final hearing, although his counsel made an appearance. The court set a date for a bench trial. Defendant filed a motion to vacate the bench trial and reset the matter for a jury trial, arguing that his absence was due to his development disabilities and medical conditions, which affected his memory. The municipal court summarily denied Defendant's motion and proceeded to a nonjury trial, after which the court found Defendant guilty of disorderly conduct. The district court affirmed the conviction. The Supreme Court reversed, holding that, in light of certain affidavits and Defendant's medical records, combined with defense counsel's appearance and affirmative representation at the final pre-trial hearing that Defendant was not waiving his right of trial by jury, the municipal court abused its discretion in deeming Defendant's failure to appear at the final pre-trial hearing as a waiver of Defendant's right to a jury trial. View "City of Missoula v. Girard" on Justia Law

Defendant was charged with driving under the influence of alcohol or drugs. Defendant filed a motion to suppress the evidence obtained during the stop of his vehicle, arguing that the officer lacked particularized suspicion for the stop. The justice court denied Defendant's motion. Defendant subsequently pleaded guilty, reserving his right to appeal the court's suppression ruling. On appeal, the district court denied Defendant's motion to suppress, finding that the officer had particularized suspicion to justify an investigative stop. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's motion to suppress, as there were sufficient facts for the officer to form a particularized suspicion that Defendant was committing an offense and, thus, to initiate an investigative stop. View "State v. Wagner" on Justia Law

After a jury trial, Defendant was convicted of aggravated kidnapping, assault with a weapon, and assault on a peace officer. The Supreme Court upheld Defendant's convictions. Defendant subsequently filed a petition for postconviction relief, alleging that his trial and appellate counsel provided ineffective assistance. The district court dismissed Defendant's petition. The Supreme Court affirmed, holding that that the district court did not err by denying Defendant's postconviction relief claim alleging that (1) Defendant's trial counsel provided ineffective representation during plea negotiations, as Defendant could not show prejudice by asserting an incorrect or overruled legal principle as the basis for his claim of ineffective assistance; (2) Defendant was denied access to counsel during an overnight recess; and (3) Defendant's appellate counsel provided ineffective representation by failing to raise certain issues on appeal. View "Rose v. State" on Justia Law

Defendant was charged with felony DUI and two misdemeanors. Defendant filed a motion to dismiss the charges on speedy trial grounds. The district court denied the motion. Defendant subsequently pleaded guilty to DUI pursuant to a plea agreement with the State in which the State agreed to drop the misdemeanor charges. Thereafter, Defendant appealed the district court's denial of his motion to dismiss. The Supreme Court affirmed, holding that the district court correctly found the State did not violate Defendant's right to a speedy trial where (1) Defendant's delay exceeded the 200-day trigger for a speedy trial analysis; but (2) the State's institutional delay did not prejudice Defendant. View "State v. Steigelman" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to felony DUI. Defendant appealed, arguing that the district court erred in denying his motion to dismiss the charge based on an alleged violation of his speedy trial rights. The Supreme Court affirmed the conviction, holding (1) Defendant suffered substantial pretrial delay largely attributed to the State's institutional delay in bringing him to trial, but Defendant failed to demonstrate that the delay caused undue prolonged disruption of his life or aggravated his anxiety beyond the expected level; and (2) Defendant failed to demonstrate that this delay substantially prejudiced his ability to defend against the charges. View "State v. Steigelman" on Justia Law

After a jury trial, Defendant was found guilty of one count of deliberate homicide and one count of aggravated assault. The Supreme Court affirmed, holding (1) the district court did not err by excluding evidence of justifiable use of force as a defense to the charge of deliberate homicide; and (2) the Court declined to exercise plain error review of Defendant's claims that the district court erred by excluding evidence of the victim's prior mental health history, suicide attempts, and cutting behavior, and that this exclusion violated Defendant's Sixth Amendment right to compulsory process and confrontation and Fourteenth Amendment right to due process. View "State v. King" on Justia Law

Following a jury trial, Defendant was convicted of felony DUI. The trial was held after several delays. Defendant was sentenced as a persistent felony offender to twenty years imprisonment with ten years suspended and ordered to pay restitution. Defendant appealed the district court's denial of his motion to dismiss based on an alleged violation of his speedy trial rights. The Supreme Court affirmed, holding that the district court (1) provided sufficient findings of fact and conclusions of law to enable appellate review of Defendant's speedy trial arguments; and (2) did not err in concluding that Defendant's speedy trial rights had not been violated under the circumstances. View "State v. Stops" on Justia Law

After a jury trial in 1984, Defendant was convicted of deliberate homicide and sentenced to 100 years imprisonment without the possibility of parole. In 2008, Defendant filed a second petition for postconviction relief, alleging that newly discovered evidence proved his actual innocence. The district court held a three-day hearing and took testimony from witnesses that suggested a group of teenage girls had killed the victim. The district court subsequently concluded that Defendant had presented sufficient evidence of his "actual innocence" to warrant a new trial. The Supreme Court reversed and dismissed Defendant's petition for postconviction relief, holding that the district court erred by concluding that Defendant was entitled to a new trial, as, applying the proper standard of review to the new evidence offered by Defendant, Defendant failed to sustain his burden of demonstrating either a freestanding claim or a gateway claim of "actual innocence." View "State v. Beach" on Justia Law

Defendant pleaded guilty to unlawful possession of an open alcoholic beverage container in a motor vehicle, failure to drive on the right side of a roadway, and driving under the influence of alcohol. The district court subsequently granted Defendant's motion to suppress evidence. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) incorrectly concluded that, because the arresting officer did not follow Mont. Code Ann. 46-6-312, all evidence gathered after Defendant's arrest should be suppressed because the arrest was lawful; (2) incorrectly concluded that the arresting officer's failure to advise Defendant of her Miranda rights at the time of arrest required suppression of all evidence obtained after her arrest with the exception of two self-incriminating statements Defendant made in response to the officer's questions after he placed her in the patrol vehicle; and (3) incorrectly concluded that evidence seized from Defendant's vehicle must be suppressed, as the plain view doctrine permitted seizure of the evidence. View "State v. Kelm" on Justia Law