Justia Civil Rights Opinion Summaries

Following a jury trial, Rhonda Hall was sentenced on her conviction of charges of obstructing a peace officer, disorderly conduct, and assault with a bodily fluid. At the conclusion of the City's case, the district court judge expressed her concern that the City had not presented sufficient evidence to meet its burden of proof. Defense counsel subsequently filed a motion that the case be dismissed for insufficient evidence, which the trial court granted. The Supreme Court affirmed the district court's judgment, finding that inasmuch as the court dismissed the City's case against Hall for insufficient evidence, Hall stood acquitted and could not be retried, and the City had no appeal from the district court's decision.

After a jury trial, Defendant Blaine Fadness was convicted of three counts of attempted deliberate homicide. One of the conditions of Defendant's suspended sentence was that he not own, possess, or be in control of any firearms of deadly weapons. The county attorney subsequently filed a petition for order of disposing of evidence, seeking an order giving him authority to sell Defendant's firearms, dangerous weapons, ammunition, and other equipment that the government had seized for use in the investigation and trial. The Supreme Court reversed the district court's order in part, holding that the district court (1) erred in permitting the State to sell items that were not firearms, ammunition, or deadly weapons, as Defendant was entitled to have those items returned; (2) did not err in denying Defendant possession of the firearms, ammunition, and deadly weapons; and (3) did not abuse its discretion in allowing the State to sell Defendant's firearms, ammunition, with the proceeds to go to Defendant's father as an agent for Defendant, rather than releasing the items to Defendant's parents, who had no plan for selling them and little or no knowledge about how to do so. Remanded.

T.M.L. was seventeen when he pled guilty to felony burglary and misdemeanor criminal trespass to vehicles. The youth court entered a dispositional order providing that T.M.L. be placed on probation until he reached age eighteen, after which supervision was to be transferred to the district court and adult probation and parole department. After T.M.L. turned eighteen, the youth court transferred T.M.L.'s matter to district court and transferred T.M.L.'s supervision to adult supervision under the department of corrections. The Supreme Court (1) affirmed the youth court's denial of T.M.L.'s motion to dismiss where the youth court had jurisdiction over T.M.L.; and (2) remanded the matter for the limited purpose of striking the condition that T.M.L. register as a sexual offender as a condition of T.M.L.'s sentence, as the youth court did not have the power to require T.M.L. to register as a sexual offender.

Plaintiffs, Western Tradition Partnership (WTP), Champion Painting, and Montana Shooting Sports Foundation (MSSF), sued the Montana Attorney General and the Commissioner of Political Practices, seeking a declaration that Mont. Code Ann. 13-35-227(1) violated their freedom of speech protected by the state and federal Constitutions by prohibiting political expenditures by corporations on behalf of or opposing candidates for public office. The district court declared the statute unconstitutional, granted summary judgment for Plaintiffs, enjoined enforcement of the statute, and denied the motion of Champion and MSSF for an award of attorney fees. The Supreme Court reversed and entered summary judgment in favor of Defendants after applying the principles enunciated in Citizens United v. F.E.C., holding that Montana has a compelling interest to impose the challenged rationally-tailored statutory restrictions.

Bryan LeMay was convicted of numerous offenses ranging from disorderly conduct to assault with a weapon, in three separate causes of action. The Supreme Court consolidated the causes of action into this opinion and affirmed, holding (1) the district court did not err when it denied LeMay's motion to dismiss on the grounds of outrageous government conduct; (2) the assistance of LeMay's counsel was reasonable considering all the circumstances; (3) the district court properly denied LeMay's motion to withdraw his nolo contendere pleas, as they were voluntarily entered; (4) the district court did not err when it denied LeMay's motion to suppress because the officer had sufficient facts to form a particularized suspicion of wrongdoing to initiate an investigative stop; and (5) the district court did not abuse its discretion when it denied LeMay's motion to dismiss for lack of state criminal jurisdiction.

Late one night, a Jefferson County reserve deputy came upon a car parked in a posted "day use only" fishing access site in Madison County. The deputy made contact with the car's driver, Floyd Updegraff, and ascertained that Updegraff was intoxicated. A second deputy Jefferson County deputy responded to the scene and placed Updegraff under arrest for DUI. A jury ultimately convicted Updegraff of felony DUI and other offenses. Updegraff appealed, arguing that the district court erred in denying his motion to suppress the evidence because (1) if the deputies were acting under color of law, they had no authority to make an arrest in Madison County, or (2) the deputies were acting as private citizens, in which case they failed to comply with the private person arrest statute. The Supreme Court affirmed, holding (1) in order to make a warrantless arrest, an out-of-jurisdiction officer must meet the arrest standard that would apply to a private person in the same circumstances, but if this standard is met, the officer may then follow the procedures applicable to peace officers in processing the arrest; and (2) applying this approach to the circumstances in this case, Updegraff's arrest was legal.

Jesse Kirk was convicted by a jury of burglary and criminal possession of dangerous drugs. The district court issued a pre-trial order denying Kirk's motion to sever the counts, concluding that the counts in the amended information were properly joined and that severance was not required to avoid an unfair trial. The Supreme Court affirmed, holding (1) because the burglary and drug charges were linked by a common motive and because the burglary occasioned the second charge of criminal possession of dangerous drugs, the counts in the amended information were properly joined; and (2) the district court did not abuse its discretion in finding that severance was not required to avoid an unfair trial where Kirk did not prove that, while he may have faced some prejudice as a result of the joint trial, the prejudice was so great that it prevented a fair trial.

Defendant crashed into a car driven by a seventeen-year-old. The victim suffered several injuries, including a shattered ankle. Defendant subsequently entered a guilty plea to felony criminal endangerment and was sentenced to ten years' incarceration with all but 180 days suspended. The district court also ordered Defendant to pay restitution for the victim's summer wages, the victim's father's lost wages, and unpaid medical expenses. The Supreme Court affirmed, holding (1) the district court properly imposed restitution for lost wages, and (2) the district court did not exceed the bounds of reason or act arbitrarily under the circumstances in imposing the maximum length sentence allowed under statute.

Riley Styren's vehicle was struck by Sherry Roos's vehicle. Styren and the owner of her vehicle (collectively, Styren) filed a complaint against Roos, Roos's mother, Julia, and Curtis Stordahl, who together owned the car Roos was driving. The complaint alleged claims of negligence against Roos and negligent entrustment and liability under the family purpose doctrine against Julia and Stordahl. The district court granted summary judgment for Julia and Stordahl. A jury then found Roos was not negligent. The Supreme Court affirmed, holding that the district court properly (1) granted summary judgment to Julia on the negligent entrustment claim as there was no evidence that Julia knew that Roos was an incompetent driver or that Roos would drive in a manner that created an unreasonable risk to others; (2) granted summary judgment to Julia on the family purpose doctrine claim where Styren did not meet her burden to raise genuine issues of material fact in opposition to Julia's motion; and (3) denied Styren's motion for a new trial where Styren did not meet her burden on appeal to demonstrate that the district court erred and the jury's verdict was legal and supported by substantial evidence.

The State charged Michael Hass with three offenses, one of which was a DUI. The Stated alleged that Hass had three prior DUI convictions, making the DUI a felony. Hass filed a motion challenging the validity of one of his prior DUI convictions, arguing that his constitutional rights to counsel and to due process were violated when the trial judge in that case allowed Hass's counsel to withdraw on the day of trial and then proceeded to try and convict Hass in absentia. In the instant case, pursuant to a plea agreement, Hass pleaded guilty to fourth-offense DUI, and the remaining counts were dismissed. The Supreme Court reversed the district court's decision denying Hass's motion challenging the validity of his earlier DUI conviction and vacated the felony DUI sentence imposed by the district court, holding that the prior DUI conviction was constitutionally infirm and could not be used for sentence enhancement purposes. Remanded with instructions to resentence Hass for misdemeanor DUI.