State v. J. Lafield, 2017 MT 312

DUI stop on MT Highway 93; LaField gave alias Fowler, no license or proof of insurance.
LaField showed intoxication signs; arrested for DUI fourth or subsequent offense and resisting arrest of Deputy Jessop.
Charges filed December 1, 2014 included felony DUI, assault on a peace officer, obstructing a peace officer, driving while privileges suspended, and proof of insurance in vehicle; State designated LaField as persistent felony offender.
LaField had multiple defense counsel changes; public defender appointed, various motions and a suppression hearing, and substitution of counsel before trial.
PSI report prepared; October 20, 2015 sentencing with 32 conditions; court struck/modified several; conditions 7 (permission to engage in business/debt/property/vehicle) and 17 (mental health evaluation) are central; LaField pled guilty to four charges and the remaining felony assault on a peace officer was dismissed; net sentence: 20 years to run consecutively.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Due process at sentencing.	LaField argues denied opportunity to finish letter and to admit seven photos; alleges bias.	LaField asserts violation of right to be heard and bias taints proceedings.	LaField given reasonable opportunity to be heard; photos not admitted but allowed in file; no reversible bias shown.
Nexus of a suspended-sentence condition (7).	Condition 7 has no nexus to offense or offender.	Condition authorized by statute and rule; no requirement of nexus under this context.	Condition 7 authorized under 46-23-1002(3) and Admin. R. M. 20.7.1101(6); no abuse of discretion.
Effective assistance of counsel at sentencing.	Counsel failed to object to judge’s demeanor and presence of officers; ineffective assistance.	Record shows strategic choices; claims lack merit.	Record supports that IAC claim lacks merit; no Strickland prejudice shown.
Written judgment vs. oral pronouncement on mental health evaluation.	Oral pronouncement limited evaluation if occurred; written judgment imposes cost.	Oral sentence controls; written judgment must conform to oral pronouncement.	Oral pronouncement controls; written judgment must be amended to reflect conditional requirement and cost.

State v. Sherman, 386 Mont. 363 (2017 MT 39) (due process/sentencing standards; de novo review for constitutional claims)
State v. Otto, 388 Mont. 391 (2017 MT 212) (consideration of relevant evidence in sentencing)
State v. Collier, 919 P.2d 376 (1996 MT) (considerations of character and history in sentencing)