State v. Holland, 443 P.3d 519

On Aug. 14, 2016, a McDonald's employee reported a suspected drunk driver; police located Kena Holland and stopped her after observed lane crossings.
Deputy Bragg administered several field sobriety tests; Holland’s BAC from a blood draw was 0.079 and she tested positive for a non‑impairing THC metabolite.
Holland was charged with Aggravated DUI under § 61‑8‑465(1)(e), which alleged two prior DUI convictions as the aggravating element.
Holland moved to bifurcate trial (or to stipulate to priors) so the jury would first decide the underlying DUI element before hearing about prior DUIs; the Justice Court denied the motion and the State introduced prior DUI convictions at trial.
A jury convicted Holland of Aggravated DUI (third offense); the District Court (on de novo review) affirmed the Justice Court; the Supreme Court reversed and remanded for a new trial, holding bifurcation is required when prior DUIs are the aggravating element.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Holland)	Held
Admissibility of prior DUI convictions in an Aggravated DUI trial under § 61‑8‑465(1)(e)	Prior convictions are an element of Aggravated DUI and therefore must be proved to the jury; admissible.	Prior DUI convictions are highly prejudicial; court should bifurcate trial or accept a stipulation and admit priors only after the jury finds underlying DUI.	Reversed: Justice Court erred; bifurcation is required—priors inadmissible in first phase and may be introduced only if jury first finds underlying DUI.
Harmless‑error as to admission of priors	Any error was harmless because evidence of impairment was overwhelming.	Admission of priors could have tipped the scales given BAC was 0.079 (below inferable impairment).	Rejected State’s harmless‑error claim; there is a reasonable possibility the priors contributed to conviction.

State v. Meyer, 396 P.3d 1265 (Mont. 2017) (held aggravating prior DUIs are elements of aggravated DUI that the State must prove beyond a reasonable doubt)
State v. Zimmerman, 417 P.3d 289 (Mont. 2018) (addressed admission of prior DUIs; Court here adopts and follows aspects of Zimmerman regarding bifurcation)
State v. Van Kirk, 32 P.3d 735 (Mont. 2001) (harmless‑error standard: State must show no reasonable possibility that inadmissible evidence contributed to conviction)
State v. Franks, 335 P.3d 725 (Mont. 2014) (other‑acts evidence admissibility limits and Rule 403 balancing)