Justia Civil Rights Opinion Summaries

Jeffrey Hardman was found guilty by a jury of deliberate homicide and tampering with the evidence. The district court sentenced Hardman to 110 years in prison with no parole eligibility for thirty years. Hardman appealed his conviction and sought a new trial, arguing (1) the district court made numerous erroneous evidentiary rulings amounting to cumulative error and requiring reversal, and (2) under the due process clause, the court's one-sided evidentiary rulings prevented him from effectively rebutting the State's case and presenting a defense, violating his right to a fair trial. The Supreme Court affirmed, holding (1) the district court properly exercised its discretion in all but one of its evidentiary rulings, and therefore, cumulative error did not warrant reversal of Hardman's conviction; and (2) since the holding on the first issue controlled, the constitutional argument was not considered.

Appellant Marla Ward filed suit seeking damages for personal injuries she sustained as she was sorting horses on Appellee Paul Johnson's property. Johnson resided in Pondera County. Johnson filed a motion to change venue, arguing that Pondera County was the appropriate place for trial because it was the only county where a defendant resided. Ward opposed the motion, asserting that case law permitted Ward to file her claim in Yellowstone County, her place of residence. The district court ruled in favor of Johnson. The Supreme Court reversed, holding (1) Ward's decision to file her complaint in Yellowstone County was legally correct under Mont. Code Ann. 25-2-122(2)(b); and (2) the statute permitting Ward to file her action in the county of her residence did not deprive Johnson of the equal protection of the laws.

After Brandon Burns was charged with felony DUI, Burns entered into a non-binding plea agreement with the State requiring the State to recommend a fifteen year prison sentence with five years suspended. The plea agreement was silent as to any possible fine. During the sentencing hearing, the State abided by its promise to recommend a fifteen year sentence and further recommended a $5,000 fine. The district court issued the State's recommended sentence, including the fine. Burns subsequently filed a motion to withdraw his guilty plea on the basis that the $5,000 fine violated the plea agreement. The district court denied the motion, concluding that the fine did not violate the plea agreement. The Supreme Court affirmed, holding that the evidence established that Burns failed to object to the fine at every step of the process, and accordingly, the district court properly denied Burns's motion to withdraw his guilty plea.

David Green pled guilty to felony aggravated assault and was sentenced to twenty years, with fifteen years suspended upon conditions. The conditions included the requirement that Green not use or possess illegal drugs. Defense counsel objected to the conditions on the basis that Green had no history of alcohol use and that the incident resulting in Green's charges did not involve alcohol. The district court overruled defense counsel's objection, finding that Green's refraining from alcohol use, considering his violent history, was necessary for his total rehabilitation. The Supreme Court affirmed the district court's imposition of green's alcohol-related sentencing conditions, holding that a sufficient nexus existed between the alcohol-related conditions and Green as an offender, and therefore, the district court did not err in imposing the conditions.

Pursuant to a plea agreement, Richard Melton pleaded guilty of failing to comply with the Sexual or Violent Offender Registration Act. The district court committed Melton to the Department of Corrections for two years, all suspended. As a condition of his suspended sentence, the district court prohibited Melton from frequenting places where children congregate or are reasonably expected to be present unless accompanied by an approved adult and granted permission from his probation officer beforehand. Melton objected to the condition, contending that the condition was indiscriminately imposed and unnecessarily burdened his constitutionally protected relationship with his children and his right to freedom of travel. The Supreme Court affirmed, holding that the condition was reasonably related to the objectives to rehabilitation and the protection of society and was not overbroad or unduly punitive.

A jury unanimously found Defendant Joel St. Germain guilty of four counts of incest and four counts of sexual intercourse without consent for sexually abusing his stepdaughter. The Supreme Court affirmed Defendant's conviction. Defendant then filed a petition for postconviction relief, setting forth nine claims of ineffective assistance of counsel against his defense counsel at trial and one claim against his original appellate counsel. The district court dismissed Defendant's petition, finding that Defendant received effective assistance of counsel. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Defendant's petition based on his claims of ineffective assistance of trial counsel; and (2) denied Defendant postconviction relief based on his claim of ineffective assistance of appellate counsel.

After a jury trial, Roger Labbe was convicted of partner or family partner assault. Labbe appealed, contending that the district court erred by (1) denying his motion to suppress statements he made to police outside his house, and (2) overruling his objection to a statement made by the prosecutor during closing argument. The Supreme Court affirmed, holding (1) the district court correctly denied Labbe's motion to suppress the statements he made to the officers, as Labbe was not in custody at the time and a Miranda warning was not necessary at any earlier point; and (2) to the extent that the prosecutor's statement would be considered improper, Labbe was not prejudiced by the prosecutor's statement.

Jeffrey Hardman was found guilty by a jury of deliberate homicide and tampering with evidence. The district court sentenced Hardman to 110 years in prison with no parole eligibility for thirty years. Hardman appealed his conviction and sought a new trial, contending that the district court made numerous erroneous evidentiary rulings amounting to cumulative error and requiring reversal. The Supreme Court affirmed, holding that the district court did not abuse its discretion in any of the evidentiary rulings save one, which was the court's admission into evidence of an irrelevant photograph of Hardmann holding a gun at a shooting range, but there was no reasonable probability that the photograph contributed to Hardman's conviction, and cumulative error did not require reversal of Hardman's conviction.

Douglas Kirn was charged with two felony counts of assault on a police officer by causing reasonable apprehension of serious bodily injury by use of a weapon. The matter proceeded to a jury trial, and Kirn was convicted. Kirn appealed the denial of his motion to dismiss for lack of sufficient evidence. The Supreme Court affirmed, holding that the district court did not err in denying Kirn's motion to dismiss for insufficient evidence because, under these circumstances, the State presented sufficient evidence upon which a rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.

Kevin Kichnet was babysitting his young nieces when he met three-year-old Eternity after the Head Start bus dropped her off after school. Kichnet was allegedly holding her hand as they crossed the street when Eternity collapsed. Kitchnet called 9-1-1. After Eternity reached the hospital she was pronounced dead. Kichnet was subsequently arrested for deliberate homicide and jailed. More than six months later, charges against Kichnet were dropped when it was determined that the Head Start school bus had run over Eternity. Kichnet sued (1) Butte-Silver Bow County, claiming County law enforcement officers performed their investigation negligently, resulting in Kichnet's arrest and incarceration; and (2) the State, claiming that the State Medical Examiner performed his duties negligently when he reported Eternity's death as a homicide. The district court granted the County's and State's motions for summary judgment. The Supreme Court affirmed, holding that the district court did not err in its judgment, as (1) the State was immune under the cited statutes from Kichnet's negligence claim; and (2) the court did not err in determining that there was probable cause for the arrest and incarceration of Kichnet, and that the investigation by the County was not negligent.