Justia Civil Rights Opinion Summaries

Defendant pled guilty to the felony offense of criminal possession with intent to distribute. The district court sentenced him to a three-year deferred imposition of sentence. Defendant appealed his conviction and sentence, contending that the district court erred in denying his motion to suppress and dismiss because a drug task force agent did not have probable cause to believe a crime was occurring in his residence, and thus there was no basis for the agent to contact Defendant and request to search his residence. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to suppress and dismiss, as (1) the information Defendant's neighbor provided to law enforcement officers was reliable; and (2) the court's findings regarding Defendant's consent to the initial search of his home and the court's findings regarding the validity of the search warrant were supported by substantial credible evidence and were not clearly erroneous. View "State v. Deshaw" on Justia Law

After a youth violated the terms of his initial probation agreement, the judicial district youth court revoked that agreement and entered a dispositional order that extended the youth's probationary period for an additional three years. The youth appealed. The Supreme Court affirmed, holding (1) the youth court did not exceed its statutory authority and correctly and interpreted and applied the Youth Court Act by imposing on revocation an additional three-year probationary term that lasted until the youth's twenty-first birthday; and (2) the imposition of an additional three-year term of probation did not violate the youth's constitutional right to equal protection of the laws. View "In re S.M.K." on Justia Law

After a jury trial, Defendant was convicted of one count of incest. The district court sentenced Defendant to 100 years in the Montana State Prison with a possibility of parole after fifty years. The district court designated Defendant a Level 3 sexual offender. Defendant appealed. The Supreme Court affirmed, holding (1) Defendant's trial counsel did not render ineffective assistance of counsel by failing to conduct cross-examination of the State' witnesses at the sentencing hearing or failing to call any witnesses on Defendant's behalf; and (2) trial counsel did not render ineffective assistance by making no alternative sentencing recommendation. View "State v. Peart" on Justia Law

Helena Sand and Gravel, Inc. (HSG) challenged Lewis and Clark County's decision to adopt a citizen-initiated proposal to configure a zoning district that favored residential uses and prohibited mining. The district court entered summary judgment in favor of the County, concluding that the County had properly adopted the zoning pattern and regulations creating the district, and the County's zoning decision did not constitute a taking of HSG's property. The Supreme Court affirmed in part and remanded, holding (1) the County's decision to adopt the zoning pattern and regulations for the district was not clearly unreasonable or an abuse of discretion; (2) the County's adoption of zoning regulations prohibiting sand and gravel mining did not constitute illegal reverse spot zoning; and (3) because HSG had a constitutionally protected property interest in property within the district, the Court granted HSG's request for remand to the district court for the parties to brief the Penn Central takings test, narrowly limited to whether the County's adoption of the zoning pattern and regulations in the district constituted a taking of HSG's real property interest without just compensation. View "Helena Sand & Gravel, Inc. v. Planning & Zoning Comm'n" on Justia Law

Plaintiffs sought a declaratory ruling that Mont. Code Ann. 13-35-227(1) violated their constitutional rights to free speech by prohibiting political expenditures by corporations on behalf of or opposing candidates for public office. Plaintiffs argued that the U.S. Supreme Court's decision in Citizens United v. FEC barred Montana from prohibiting independent and indirect corporate expenditures on political speech, and that Montana's century-old ban on independent corporate expenditures therefore was invalid. The district court granted ATP's motion for summary judgment on the merits of its constitutional claim, declared section 13-35-227(1) unconstitutional, and denied ATP's request for attorneys' fees. The Supreme Court reversed, concluding (1) the statute was constitutional; and (2) Plaintiffs' cross-appeal on the attorneys' fee issue, therefore, was moot. The Court's decision thereafter was reversed by the U.S. Supreme Court. The Montana Supreme Court then returned to ATP's cross-appeal on the issue of attorneys' fees and affirmed the district court's order declining to award attorneys' fees to Plaintiffs, holding that equitable considerations did not require the district court to award fees against the State under either the Uniform Declaratory Judgments Act or the private attorney general doctrine. View "W. Tradition P'ship, Inc. v. Attorney Gen." on Justia Law

Defendant pled guilty to felony arson for setting fire to a car and two dumpsters. After a sentencing hearing, the district court sentenced Defendant to a four-year suspended DOC commitment and required him to pay $1600 in restitution. It further imposed recommended probationary conditions, including that Defendant register as a violent offender and complete anger management classes and chemical dependency and mental health evaluations. Defendant challenged the sentencing condition requiring him to register as a violent offender. The Supreme Court affirmed, holding that the district court's sentencing condition requiring that Defendant register as a violent offender did not violate his constitutional right to privacy, as whatever limited expectation of privacy Defendant had as a violent offender in his whereabouts and residential information, the State's compelling interest in requiring that he register justified the enactment of the statute requiring registration. View "State v. Brooks" on Justia Law

Shortly after Defendant was charged with DUI, she notified the police department that she believed she had been given a "date rape" drug that caused her impairment. Before trial commenced, Defendant claimed she would assert the involuntary intoxication defense to show she did not commit a voluntary act by driving. The municipal court granted the City's motion to prevent Defendant from claiming involuntary intoxication as a defense and from calling witnesses about the use of "date rape" drugs in the City. The district court affirmed, concluding that involuntary intoxication can only be used where the mental state of the defendant is an element of the crime. Defendant appealed, contending that the lower court erred by failing to apply the voluntary act element of Montana's DUI statute. The Supreme Court reversed and remanded, holding (1) the lower court erred by precluding Defendant from raising automatism as an affirmative defense to the DUI charge; and (2) if Defendant was able to lay the proper foundation, she could elicit from certain law enforcement officers evidence regarding their personal knowledge, opinions, and statements regarding whether Defendant was unknowingly drugged, and voluntarily drove a vehicle. View "City of Missoula v. Paffhausen" on Justia Law

Defendant was convicted of attempted sexual intercourse without consent, a felony. The district court sentenced Defendant to Montana State Prison for a term of fifteen years, with five suspended. The Supreme Court affirmed, holding (1) the court did not violate Defendant's right to due process by excluding evidence of alleged sexual conversations between the complainant and Defendant and photos of third parties allegedly sent by the complainant to Defendant on the basis that they were irrelevant or more prejudicial than probative under the rules of evidence; and (2) Defendant's claim of ineffective assistance of counsel was better examined within a postconviction relief proceeding. View "State v. Bishop" on Justia Law

The district court involuntarily committed and authorized the involuntary medication of thirty-year-old C.R. after it determined that he suffered from a mental disorder and that his condition met the statutory criteria for involuntary commitment to the Montana State Hospital. The Supreme Court affirmed, holding (1) the district court properly disregarded C.R.'s hearing testimony, as substantial evidence supported the court's findings that the testimony was unreliable; (2) the district court's failure to offer C.R. a court-appointed friend did not violate C.R.'s statutory or constitutional rights, as the appointment of a friend was not statutorily mandated; and (3) C.R. received effective assistance of counsel. View "In re C.R." on Justia Law

Defendant was convicted of deliberate homicide stemming from the shooting death of his former roommate. On appeal, Defendant contended that the district court erred by instructing the jury it was prohibited from considering Defendant's intoxication when rendering its verdict in accordance with Mont. Code Ann. 45-2-203 because the statute violated a criminal defendant's due process right to present a defense. The Supreme Court affirmed, holding that the instructions given by the court fully and fairly instructed the jury on the applicable law and did not prejudice Defendant's right to present a defense, and therefore, the district court did not abuse its discretion by giving the instruction to the jury. View "State v. Myran" on Justia Law