State v. Hardman, 2012 MT 70

Hardman shot and killed Michael Blattie on Blattie's front porch on Oct. 15, 2009 after a dispute over a $35 loan.
Hardman armed himself with a handgun during the confrontation, claiming an accidental or defensive context.
Blattie died from gunshot wounds; Hardman buried the murder weapon in a nearby field.
Hardman initially lied to investigators and attempted suicide, later confessing to a pastor before turning himself in.
Hardman was charged with deliberate homicide and evidence tampering for burying the gun, which was never recovered.
The jury convicted Hardman of deliberate homicide and tampering with the evidence; sentence was 110 years with no parole for thirty years.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court’s evidentiary rulings constituted reversible cumulative error	Hardman argues numerous rulings cumulatively denied his defense	State contends rulings were proper and not cumulatively prejudicial	No reversible cumulative error; one ruling lacks abuse; conviction affirmed

State v. Derbyshire, 349 Mont. 114 (2009 MT 27) (evidentiary rulings reviewed for abuse of discretion; need for substantial injustice)
State v. Bingman, 313 Mont. 376 (2002 MT 350) (abuse of discretion standard for evidentiary determinations; de novo review when rule interpretation involved)
State v. Detonancour, 306 Mont. 389 (2001 MT 213) (Rule 403 balancing in exclusion of probative evidence)
State v. Passmore, 355 Mont. 187 (2010 MT 34) (limited admissibility and risk of unfair prejudice under Rule 403)
State v. Daniels, 362 Mont. 426 (2011 MT 278) (When character evidence is admissible, Rule 405 governs proof; foundation required)
City of Red Lodge v. Nelson, 296 Mont. 190 (1999 MT 246) (transcends hearsay; transaction-rule considerations for relevance)