State v. Edmundson, 2014 MT 12

Edmundson was charged in 2005 with four counts of felony assault with a weapon, one misdemeanor sexual assault, and one misdemeanor privacy in communications; he pled guilty to a single felony assault with a weapon and received a 10-year DOC commitment with 5 years suspended.
PSI disputed by Edmundson at sentencing; the court annotated objections but did not amend the PSI due to lack of evidence.
Edmundson was released on parole in 2009, transferred supervision to Indiana, discharged parole in 2010, and began serving the suspended sentence in Montana; supervision later moved to Montana in 2012.
An Indiana probation officer reported in 2011 that Edmundson was unemployed and behind on restitution, leading to a petition for revocation in Flathead County; he returned to Montana for the revocation proceedings.
Edmundson admitted violations at a 2012 revocation hearing and the court re-suspended his sentence, allowing continued supervision in Montana; later, additional violations led to a five-year DOC commitment with prerelease placement, which the court imposed after considering the PSI and evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by denying dismissal for delay	Edmundson argues delay between arrest and hearing violated §46-18-203 and due process	Edmundson contends delay was unjustified and prejudicial	No; delay was not due process violation; proceedings were fundamentally fair
Whether the district court erred in considering allegedly unreliable criminal-history information	Edmundson argues PSI inaccuracies were ignored; due process requires accuracy	Edmundson had opportunity to contest PSI; information was not materially inaccurate	No; court allowed contest of PSI and relied on accurate, lengthy history; revocation affirmed

State v. Finley, 2003 MT 239 (Mont. 2003) (due process in revocation proceedings; right to notice and evidence)
State v. Triplett, 2008 MT 360 (Mont. 2008) (de novo standard for statutory interpretation; due process in revocation)
Morrissey v. Brewer, 408 U.S. 471 (U.S. 1972) (due process protections in probation revocation)
Gagnon v. Scarpelli, 411 U.S. 778 (U.S. 1973) (due process in hearings; confrontation and evidence)
State v. West, 2008 MT 338 (Mont. 2008) (totality of circumstances in due process; delay analysis)
State v. Bar-Jonah, 2004 MT 344 (Mont. 2004) (accuracy standard for sentencing information)
State v. Harper, 2006 MT 259 (Mont. 2006) (rigorous accuracy standards; information used in sentencing)
State v. Knapp, 174 Mont. 373 (Mont. 1977) (due process in revocation; accuracy of information)
State v. Ferguson, 2005 MT 343 (Mont. 2005) (opportunity to explain or rebut PSI in sentencing)
State v. Oppelt, 184 Mont. 48 (Mont. 1979) (speedy-trial rights do not apply to revocation)