Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was found guilty of incest and attempted incest involving his daughter, incest and sexual intercourse without consent involving his step-daughter, and sexual intercourse without consent involving his sister-in-law. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the district court did not abuse its discretion when it did not conduct a hearing on Defendant's posttrial allegation that some jurors slept through critical portions of the trial testimony; (2) Defendant was not subjected to double jeopardy when he was convicted of both incest and attempted incest, as the State charged and proved two separate and distinct transactions between Defendant and his daughter; and (3) the district court did not commit structural error when it failed to arraign Defendant on the amended charge of attempted sexual intercourse without consent. View "State v. Geren" on Justia Law

After a jury trial, Defendant was convicted of driving under the influence. Defendant appealed, arguing that the district court abused its discretion by partially denying his motion in limine to exclude video footage depicting administration of the Preliminary Alcohol Screening Test (PAST) administration without sound over Defendant's objection. The Supreme Court reversed, holding that the admission of the PAST evidence by video was prejudicial error, as (1) the video was impermissibly used as substantive evidence of Defendant's intoxication without the State satisfying the requirement of State v. Damon and Mont. R. Evid. 702 to call an expert to testify regarding the reliability and accuracy of the PAST; (2) the potential of unfair prejudice in admitting the evidence outweighed its probative value, as it prompted the inference that Defendant failed the PAST; and (3) the error was not harmless. View "State v. Lozon" on Justia Law

After an agent with the Tri-Agency Safe Trails Task Force purchased quantities of marijuana from Defendants in excess of what was legal under the Medical Marijuana Act, law enforcement arrested Defendants. Officers executed search warrants for Defendants' vehicles, their residence, and the garage Defendants frequented, retrieving four times the amount of marijuana Defendants were allowed to possess as caregivers and patients under the Act. Defendants were charged with several drug-related counts. Defendants filed a joint motion to suppress and dismiss, arguing that the state engaged in "outrageous government conduct" by obtaining evidence against them in violation of their federal due process rights. The district court granted the motion because the agent broke numerous laws under the banner of law enforcement. The Supreme Court reversed, holding that because the agent's conduct stopped short of violating the fundamental fairness shocking to the universal sense of justice mandated by the due process clause, the district court erred in dismissing Defendants' charges based on the outrageous government conduct defense. View "State v. Fitzpatrick" on Justia Law

Mike Alexander was one of two former employees of Bozeman Motors who filed suit against Bozeman Motors and its president and managers, alleging negligence, battery, and negligent or intentional infliction of emotional distress. Plaintiffs claimed long-term physical and emotional injuries resulting from exposure to carbon monoxide and propane. Alexander died after filing suit. Bozeman Motors moved for summary judgment on the basis that the claims against it were barred by the exclusive remedy provision of Montana's Workers' Compensation Act. The district court granted Bozeman Motors' motion, holding that the conduct of Defendants did not rise to the level of deliberate intent to cause specific harm, and that Mont. Code Ann. 39-71-413, which provides an exception to the exclusive remedy provision of the Act, was constitutional. The Supreme Court reversed and remanded with respect to Alexander's claims. On remand, the jury returned a verdict for Defendants on all claims. The Supreme Court affirmed, holding (1) section 39-71-413(2) does not create an impermissible class of employees in violation of equal protection; (2) the district court did not err in instructing the jury; and (3) the court did not err in denying Plaintiffs' motion to exclude Alexander's cause of death. View "Alexander v. Bozeman Motors, Inc." on Justia Law

After a jury trial, Defendant was convicted of attempted theft and sentenced to ten years imprisonment. Defendant appealed, arguing that the district court abused its discretion in finding a sufficient chain of custody for the admission of latent fingerprint evidence and forensic analysis. At issue was two fingerprint cards used to take the prints. In specific, in contention was discrepancies between dates written on the back of the cards and their storage in a law enforcement officer's patrol car and office. The Supreme Court affirmed, holding that because the State adequately established the chain of custody of the prints cards, the district court did not abuse its discretion by admitting the latent print evidence. View "State v. McCoy" on Justia Law

Plaintiffs in this case were individuals who were in committed same-sex relationships. Plaintiffs sued the State, contending that there was a statutory structure in Montana law that prohibited them from enjoying significant relationships and family protections and obligations provided to similarly-situated different-sex couples who marry. Plaintiffs expressly did not challenge Montana law's restriction of marriage to heterosexual couples and did not seek the opportunity to marry. Instead, Plaintiffs sought a declaration that the State's failure to provide them access to the statutory scheme available to different-sex couples denied them the rights guaranteed by Mont. Const. art II. The district court granted the State's motion to dismiss, noting that Plaintiffs did not seek the declaration of the unconstitutionality of a specific statute but rather a direction to the legislature to enact a statutory arrangement, which was unprecedented in Montana law. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the district court did not err in finding Plaintiffs' requested relief exceeded the bounds of a justiciable controversy; but (2) Plaintiffs should be afforded the opportunity to amend their complaint. View "Donaldson v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual intercourse without consent and one count of sexual assault. Defendant appealed. The Supreme Court affirmed, holding (1) under the circumstances presented here, the district court's application of Montana's rape shield statute did not violate Defendant's right to a fair trial under the Montana and United States Constitutions; and (2) the district court did not err in refusing to dismiss Counts I and IV on grounds that the State failed to prove venue, as the State showed that the only rational conclusion to be drawn from the facts and testimony was that the crime was committed in the county alleged. View "State v. Patterson" on Justia Law

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