State v. Crider
328 P.3d 612
Mont.2014Background
- Crider was convicted in Montana for felony Sexual Intercourse Without Consent, PFMA (second offense), and felony Tampering With Witnesses and Informants.
- Crider’s July 2011 incident with M.W. involved violent physical and sexual abuse culminating in nonconsensual sex, with extensive injuries to M.W.
- Prior acts evidence was admitted at trial to show motive or absence of mistake, with other prior acts involving Crider and M.W. excluded.
- The district court issued a motion in limine ruling limiting prior acts to those involving M.W., excluding other victims.
- During trial, the State referenced the prior acts to influence credibility of M.W. and to support its theory of motive and control.
- Crider raised challenges post-trial regarding the admission and use of prior bad acts and the jury instruction, and he claimed ineffective assistance of counsel for not objecting.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Abuse of discretion in admitting prior acts | Crider argues the court erred admitting prior acts to prove motive/absence of mistake. | Crider contends the court should have excluded the acts or limited their use further. | No abuse; prior acts admissible to show motive/absence of mistake when properly narrowed. |
| Plain error review of jury instruction | Crider seeks plain error review of the instruction permitting use of prior acts for multiple purposes. | State contends no plain error as instruction was adequate and Crider acquiesced. | Plain error review declined; instruction adequate under the circumstances. |
| Ineffective assistance of counsel for failing to object | Crider claims counsel's failure to object prejudiced defense by allowing improper use of evidence. | State argues defense strategy and trial tactics justified not objecting at every turn. | IAC claim fails; actions were within reasonable professional judgment and tactical discretion. |
Key Cases Cited
- State v. Green, 350 Mont. 141 (Mont. 2009) (abuse of discretion standard for evidentiary rulings)
- Puccinelli v. Puccinelli, 272 P.3d 117 (Mont. 2012) (evidentiary rule interpretations on appeal)
- State v. Ring, 321 P.3d 800 (Mont. 2014) (jury instruction review; overall fairness standard)
- State v. Dist. Court of the Eighteenth Judicial Dist., 246 P.3d 415 (Mont. 2010) (framework for admitting Rule 404(b) evidence; procedures)
- State v. Vukasin, 317 Mont. 204 (Mont. 2003) (preservation requirements for Rule 404(b) objections)