City of Helena v. Broadwater
2014 MT 185
| Mont. | 2014Background
- In July 2011 Broadwater was charged in Helena Municipal Court with misdemeanor DUI and disorderly conduct and pleaded not guilty.
- He requested a jury trial; the court set trial for January 10, 2012 but informed him on December 28 that the trial might not occur that day due to older cases being tried first.
- The trial was rescheduled in early January to February 14, 2012 — 12 days past the six-month deadline under § 46-13-401(2), MCA.
- Broadwater moved to dismiss for lack of a speedy trial; the municipal court granted dismissal, finding institutional delay from a crowded docket not excuse for missing the deadline.
- The City appealed to the District Court, which reversed, finding the crowded docket constituted good cause; Broadwater was later tried, convicted of DUI, and acquitted of disorderly conduct.
- The Supreme Court reviewed whether the State met its burden to show “good cause” for failing to bring Broadwater to trial within six months.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the City showed "good cause" under §46-13-401(2), MCA for trying Broadwater after six months | Broadwater: the State failed to show good cause; a crowded docket alone is insufficient and the City made no effort to secure an earlier date within the remaining 23 days | City: consider totality of circumstances; crowded docket and scheduling practices made a timely trial impossible | Court held the City did not meet its burden: a crowded docket, without evidence the State attempted to secure a timely trial, is not good cause; dismissal must be reinstated |
Key Cases Cited
- City of Helena v. Roan, 355 Mont. 172, 226 P.3d 601 (Mont. 2010) (defined "good cause" and upheld witness unavailability as good cause when properly demonstrated)
- State v. Case, 371 Mont. 58, 305 P.3d 812 (Mont. 2013) (Montana misdemeanor speedy-trial statute provides stricter protections than constitutional analysis)
- State v. Martz, 347 Mont. 47, 196 P.3d 1239 (Mont. 2008) (the statute is the sole standard for evaluating "good cause" in misdemeanor speedy-trial contexts)
- State v. Ronningen, 213 Mont. 358, 691 P.2d 1348 (Mont. 1984) (State failed to show good cause where no action was taken to prosecute after a judge retired and docket rescheduling occurred)
- State v. Bertolino, 317 Mont. 453, 77 P.3d 543 (Mont. 2003) (State failed to show good cause where it blamed defendant for delay without seeking sanctions or otherwise acting to advance the case)