Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the order of the district court revoking Defendant's deferred sentence for criminal possession of dangerous drugs, holding that the district court did not violate Defendant's Sixth Amendment right to confront witnesses during his revocation and did not abuse its discretion in determining that Defendant absconded.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confront witnesses against him by relying on statements made in a report of violation by Defendant's previous probation officer; and (2) the State presented sufficient evidence at Defendant's revocation hearing to establish that Defendant failed to report for the purpose of avoiding supervision and that the probation office made reasonable efforts to contact him. View "State v. Fetveit" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to suppress testimony regarding statements he made during a phone conversation with the victim, holding that the testimony was not subject to exclusion.A.O. and her friend Tricia alleged that Defendant had committed sexual offenses against A.O. While A.O. was at the police department, Defendant called A.O. Police officers listened in on the conversation, during which Defendant admitted to raping A.O. Defendant moved to suppress the evidence. The district court ruled that the officer testimony regarding the conversation would be excluded but that A.O. and Tricia, as private actors, could testify as to the conversation. Defendant appealed, arguing that the testimony of A.O. and Tricia as to the contents of the conversation must be excluded as attributable to an unconstitutional privacy intrusion by a government actor. The Supreme Court affirmed, holding that the district court correctly denied the motion to suppress because A.O. and Tricia's testimony resulted from their own private actions, not from unconstitutional monitoring and recording by police. View "State v. Wolfe" on Justia Law

The Supreme Court held that Mont. Code Ann. 46-5-105 prohibits detention center employees who are booking a person into the general population of a detention facility from conducting a visual body cavity search without reasonable suspicion to believe that person is concealing contraband, a weapon, or evidence of the commission of a crime.William Rogers, leading ninety-six named plaintiffs, brought this action challenging the Lewis and Clark County Detention Center policy to conduct an unclothed visual body cavity search of every detainee prior to placement in the general population of the facility as a violation of Mont. Const. art. II, 10 and 11 and Mont. Code Ann. 46-5-105. The district court granted summary judgment for Defendants as to ninety-two of the named plaintiffs and denied the motion as to four plaintiffs who were never placed in the general population of the facility after they were strip searched. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs' diminished privacy interests did not outweigh the legitimate penological interests of the Detention Center; and (2) the plain language of section 46-5-105 unequivocally prohibits suspicionless strip searches of those arrested for minor offenses in any situation. View "Rogers v. Lewis & Clark County" on Justia Law

The Supreme Court reversed the decision of the district court denying Defendant's motion to suppress evidence found during a probation search of the room Defendant rented from a person on probation, holding that Defendant had a legitimate expectation of privacy in his residence.Defendant rented a room from Parischere Hughes (Paris), who was on misdemeanor probation and subject to probation searches. During a probation search of Paris's residence, law enforcement officers searched Defendant's residence and found drugs and drug paraphernalia. Defendant was charged criminal possession of dangerous drugs, a felony. Defendant filed a motion to suppress, arguing that the search exceeded the scope of any lawful probation search of Paris's residence. The district court denied the motion. The Supreme Court reversed, holding that Defendant's rights to privacy in his person and residence were not diminished by Paris's probationary status. View "State v. Thomas" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony strangulation of his girlfriend, holding the evidence was sufficient to support the conviction, and Defendant did not receive ineffective assistance of counsel.Specifically, the Supreme Court held (1) the evidence was sufficient to sustain Defendant's conviction of felony strangulation; (2) Defendant failed to meet the prejudice standard set forth in Strickland v. Washington, 466 U.S. on his claim that his counsel was ineffective by opening the door to evidence of Defendant's prior violence; and (3) this Court declines to review for plain error Defendant's argument challenging the district court's instruction on the mental state for strangulation. View "State v. Dineen" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of sexual intercourse without consent, holding that the district court did not err in denying Defendant's motion to strike a prospective juror for cause.After the district court denied Defendant's motion to remove the prospective juror for cause Defendant used a peremptory challenge to strike her from the panel and exhausted all of his peremptory challenges. Defendant appealed, arguing (1) the prospective juror's voir dire statements demonstrated an inability to act fairly and impartially in his trial, and therefore, the district court abused its discretion in denying his for-cause challenge; and (2) because he had to exercise a peremptory strike to remove the juror and subsequently exhausted his peremptory challenges, the error was prejudicial. The Supreme Court disagreed, holding that the district court did not abuse its discretion in accepting the prospective juror's assurances that she could fairly and impartially weigh the evidence despite her initial statements of prejudice. View "State v. Morales" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's motion to suppress the evidence discovered during a police officer's chemical "field test" on the contents of a syringe found in Defendant's jacket pocket, holding that a rudimentary chemical field test of a lawfully seized substance is not a constitutionally protected search requiring a warrant.Defendant was placed under arrest after driving with a suspended driver's license and without vehicle insurance. While searching Defendant incident to his arrest, the arresting officer located a used syringe in Defendant's front jacket pocket. When booking Defendant into jail, the officer conducted a field test on the contents of the syringe. The field test came back positive for methamphetamine. Defendant filed a motion to suppress, arguing that the field test of the syringe's contents without a warrant constituted an unlawful search that violated his reasonable expectations of privacy. The district court denied the motion to suppress. The Supreme Court affirmed, holding that Defendant had no reasonable expectation of privacy violated by a test for the presence of methamphetamine in a syringe lawfully seized from his person, and therefore, Defendant could not assert the constitutional protections afforded to a search. View "State v. Funkhouser" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted deliberate homicide, holding that a challenged jury instruction did not undermine the fundamental fairness of the proceeding.After a jury trial, Defendant was convicted of attempted deliberate homicide. On appeal, Defendant argued that the district court's "specific purpose" jury instruction warranted review under either the doctrine of plain error or ineffective assistance of counsel and that the prosecutor's comment warranted plain error review by the Supreme Court. The Supreme Court affirmed, holding (1) the trial court's instruction did not result in a manifest miscarriage of justice, and the claimed error by trial counsel in failing to object to the instruction did not prejudice Defendant; and (2) the prosecutor's conduct did not warrant plain error review. View "State v. St. Marks" on Justia Law

The Supreme Court affirmed the district court's denial of Appellant's petition for postconviction relief and the court's order granting partial summary judgment in favor of the State, holding that the district court did not err.Defendant was convicted of vehicular homicide while under the influence, failure to stop immediately at the scene of an accident involving an injured person, and driving without a valid driver's license. Defendant later filed a petition for postconviction relief, alleging ineffective assistance of counsel (IAC), Brady violations, and newly discovered evidence of her innocence. The district court granted summary judgment on Defendant's newly discovered evidence claims and Brady claim and then denied the remainder of the claims after a hearing. The Supreme Court affirmed, holding that the district court did not err by (1) denying Defendant's postconviction petition based on her claim of ineffective assistance of counsel; (2) concluding that the State did not violate Defendant's due process rights by failing to disclose certain non-exculpatory photographs; and (3) dismissing Defendant's newly discovered evidence claim. View "Garding v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for attempted deliberate homicide and evidence tampering, both felonies, holding that the district court did not commit plain error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not commit plain error by not intervening sua sponte to limit or cure the State's closing argument that Defendant's failure to retreat or summon police prior to using deadly force was unreasonable; (2) the district court did not commit plain error by not intervening sua sponte to limit or cure the State's closing and rebuttal argument references to Defendant's post-Miranda silence; and (3) the State's closing argument regarding an alternative factual basis for the evidence tampering charge did not effect an improper de facto amendment of the substance of the charging information. View "State v. Trujillo" on Justia Law