State v. Branham, 2012 MT 1

Branham fatally stabbed Kinross-Wright during a nighttime fight arising from Kinross-Wright’s relationship with Branham’s child's mother.
Kinross-Wright allegedly attacked Branham; Branham claimed he grabbed a knife in fear and stabbed Kinross-Wright.
The stabbing occurred after Kinross-Wright allegedly punched Branham and Branham encountered a knife on the floor.
Branham testified that Kinross-Wright was aggressive and that Branham feared death or serious harm.
The State argued the stomach wound was the fatal early wound and that Branham’s statements at the time supported this theory.
The District Court admitted some evidence of Kinross-Wright’s prior violence but excluded other evidence unknown to Branham, and Branham was convicted of mitigated deliberate homicide and sentenced to 40 years with no parole.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Kinross-Wright’s violent-character evidence was admissible	Branham	Branham sought to show aggressor’s character	Evidence limited to facts Branham knew; excluded unknown facts; no abuse of discretion
Whether prosecutor's closing arguments violated Branham’s fair-trial rights	Branham	State misstatement challenged; comments improper	No reversible misconduct; arguments reasonably based on evidence
Whether the sentencing parole-restriction rationale complied with § 46-18-202	Branham	Reasoning allegedly incomplete or erroneous	Parole restriction supported by written reasons; within statutory authority

State v. Damon, 328 Mont. 276 (2005 MT) (evidentiary abuse of discretion standard for admissibility)
State v. Montgomery, 327 Mont. 138 (2005 MT) (reasonableness standard for self-defense knowledge)
State v. Henson, 235 P.3d 1274 (2010 MT) (limits on evidence for reasonable belief in self-defense)
State v. Sattler, 288 Mont. 79 (1998 MT) (Victim’s character evidence and essential elements)
State v. Deschon, 347 Mont. 30 (2008 MT) (evidence of victim’s prior acts; admissibility limits)
State v. Harville, 334 Mont. 380 (2006 MT) (identity of aggressor not an essential element of 45-3-102 defense)
State v. Russell, 307 Mont. 322 (2001 MT) (precedent on aggressor identity in self-defense)
State v. Green, 350 Mont. 141 (2009 MT) (limits on prosecutor’s personal opinions; credibility arguments)
State v. Kratz, 788 P.2d 298 (1990 MT) (brief written reasons for parole limitations upheld)
State v. Hill, 207 P.3d 307 (2009 MT) (legality review of sentences within statutory parameters)
State v. Phillips, 150 P.3d 1078 (2007 MT) (misinformation in sentencing must be materially inaccurate)