City of Billings v. Staebler
2011 MT 254
| Mont. | 2011Background
- Staebler was convicted by Billings Municipal Court of misdemeanor driving while intoxicated and seatbelt violation after a jury trial.
- Officer Idhe observed Staebler weaving, speeding 15 mph under the limit, failing to stop, and failing to signal; Staebler smelled of alcohol and admitted drinking.
- Staebler failed field sobriety tests and refused breath samples at the scene and at the DUI Center; he was arrested and taken to the DUI Center.
- Municipal Court trial occurred April 5, 2010; during voir dire the City attorney made remarks about alcohol-related crashes and later discussed a juror's personal story about a DUI death; those jurors were excused for cause.
- Staebler appealed to the District Court arguing trial error (plain error) and ineffective assistance of counsel; the District Court found the comments prejudicial but not prejudicially to Staebler due to overwhelming evidence of guilt.
- The Montana Supreme Court affirmed, concluding no reversible error occurred and that the ultimate result was correct, though the reasoning differed from the trial court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the District Court err in affirming the Municipal Court judgment? | Staebler argues City comments violated fair trial rights. | Staebler contends trial error affected impartiality and requested plain error review. | No reversible error; Court affirms. |
| Were voir dire comments by City attorney reversible error? | Staebler asserts prejudicial remarks tainted jury pool. | City argues comments were permissible exploration of bias. | Not reversible error; voir dire proper. |
| Did rebuttal closing comment improperly influence jurors? | Staebler claims comment introduced horrific imagery unfairly. | City argues counsel latitude in closing; jurors can distinguish evidence. | Not reversible error. |
| Was there ineffective assistance of counsel to preserve error? | Courts found no need to address due to lack of error. |
Key Cases Cited
- State v. Finley, 276 Mont. 126, 915 P.2d 208 (1996) (plain error review for fundamental constitutional rights when no objection)
- State v. Gallagher, 304 Mont. 215, 19 P.3d 817 (2001 MT 39) (limits on plain error review; preservation principles)
- State v. Lamere, 327 Mont. 115, 112 P.3d 1005 (2005 MT 118) (voir dire duty to reveal bias; defense burden to develop record)
- State v. Pol, 346 Mont. 322, 195 P.3d 807 (2008 MT 352) (preservation requirement; standard for first-time appellate claims)
- Cooper v. Hanson, 356 Mont. 309, 234 P.3d 59 (2010 MT 113) (closing argument latitude; jurors capable of distinguishing evidence)
- State v. Shepard, 355 Mont. 114, 225 P.3d 1217 (2010 MT 20) (affirming result even when possibly wrong reasoning)
- Stanley v. Lemire, 334 Mont. 489, 148 P.3d 643 (2006 MT 304) (standard of appellate review for lower court judgments)