City of Helena v. Heppner
2015 MT 15
| Mont. | 2015Background
- Heppner was arrested for DUI on April 29, 2012, and charged with DUI and felony tampering with evidence stemming from a blood-warrant dispute.
- Heppner initially appeared in Justice Court, was ordered to the 24/7 Sobriety Program, and elected to wear a SCRAM bracelet at his own cost.
- The case progressed to District Court and then was transferred to Helena Municipal Court after a key Green order related to the tampering charge.
- Heppner was arraigned in Municipal Court on October 1, 2012, and trial was set for March 7, 2013; he later moved to vacate the District Court trial date for a change of plea.
- Heppner's motion to dismiss for lack of speedy-trial relief was denied by Municipal Court; he renewed the claim in 2013, ultimately pleading guilty May 9, 2013 while preserving the speed-trial appeal.
- The Montana Supreme Court distinguished statutory and constitutional speedy-trial analyses, reversing on the statutory issue and remanding for factual findings on the constitutional claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Heppner's statutory speedy-trial rights apply despite his motions? | Heppner argues the six-month rule applies unless good cause or postponement by the State. | The district/municipal delays were caused by Heppner’s own motions to vacate and continuances. | Statutory protections unavailable after movant-induced delay. |
| Did Heppner's constitutional speedy-trial rights violate the Fourth/ Sixth Amendment and Montana Constitution? | Heppner contends the delay violated constitutional speedy-trial rights. | State argues no constitutional analysis is needed for a misdemeanor under the statute’s protections. | Constitutional analysis requires remand for findings of fact and law. |
Key Cases Cited
- State v. Ariegwe, 2007 MT 204 (Mont. 2007) (establishes the four-factor constitutional balancing test)
- State v. Luke, 2014 MT 22 (Mont. 2014) (misdemeanor speedy-trial statute analysis; timing after arraignment)
- State v. Hodge, 2014 MT 308 (Mont. 2014) (distinguishes statutory and constitutional speedy-trial analyses)
- State v. Case, 2013 MT 192 (Mont. 2013) (statutory speedy-trial considerations in misdemeanors)
- State v. Larson, 191 Mont. 257 (Mont. 1981) (accusation triggers speedy-trial rights; timing relevance)