State v. District Court of the Eighteenth Judicial District of Montana, 2010 MT 263

State v. Anderson involves a State petition for supervisory control to review a district court pretrial suppression ruling in a Deliberate Homicide case in Gallatin County.
The State sought to introduce evidence under theories of transaction rule and Rule 404(b) but the district court suppressed much of the evidence.
The Supreme Court overruled Just and Matt, finding their notice framework unworkable, and adopted a new approach to admissibility under 404(b).
The Just notices initially proposed by the State were challenged as procedurally defective and later amended; the district court struck the amended notice for lack of good cause.
The court ultimately addressed admissibility under a revised framework focusing on Rule 402 and 404(b) and allowed certain non-propensity evidentiary purposes while excluding others.
The decision remands for further proceedings consistent with the new approach and clarifies the procedural posture for future notice and admission of extrinsic evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether this Court may resolve the issue via a writ of supervisory control	State argues supervisory control is appropriate due to a legal question and potential gross injustice	Anderson contends issues are not purely legal or urgent for supervisory control	Yes; the Court grants supervisory control for misapplication of law
Was the State's evidence correctly deemed inadmissible	State contends evidence is admissible under revised 404(b) framework	Anderson asserts evidence is inadmissible as improper propensity or lacks proper support	No; Just and Matt overruled; adopt 404(b) analysis under Rules 402/404

State v. Just, 184 Mont. 262 (Mont. 1979) (adopted notice requirement for extrinsic evidence under 404(b))
State v. Matt, 249 Mont. 136 (Mont. 1999) (refined notice requirements for extrinsic evidence under 404(b))
State v. Lozon, 320 Mont. 26 (Mont. 2004) (transaction rule discussed; not required for all extrinsic evidence)
State v. Lacey, 355 Mont. 31 (Mont. 2010) (limited use of 404(b) after Lacey; non-transactional analysis)
State v. Stout, 356 Mont. 468 (Mont. 2010) (clarified scope of 404(b) and related rules)
State v. Sage, 357 Mont. 99 (Mont. 2010) (continued refinement of 404(b) admissibility framework)