State v. Lamarr, 332 P.3d 258

Lamarr was charged with one count of misdemeanor assault in Flathead County (2012).
Trial in Justice Court occurred November 8, 2012, resulting in Lamarr’s conviction.
The charged incident involved Lamarr, Huckins, Jelly, and Hill at the Garden Bar in Bigfork, with prior threats by Lamarr toward Huckins.
Huckins testified to threats and a prior parking-lot assault by Lamarr; Hill testified to the subsequent confrontation.
The State moved in limine to admit Huckins’s prior-threat and pre-incident conduct; the court admitted it over Lamarr’s objection with a curative instruction.
Lamarr appealed to the District Court, which affirmed the Justice Court’s evidentiary ruling; the Supreme Court reviews de novo and for abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admission of prior threats and conduct violated Rule 404(b) or was proper under the transaction rule.	State argues the evidence is admissible under the transaction rule to explain the charged acts.	Lamarr contends the evidence is not inextricably linked and overly prejudicial.	Affirmed; evidence admitted under the transaction rule was proper and not an abuse of discretion.

State v. Guill, 355 Mont. 490 (2010 MT) (transaction rule; acts linked with charged conduct; balancing under 403)
State v. Mackrill, 345 Mont. 469 (2008 MT) (contemporaneous, continuing series of events; admissible under transaction rule)
State v. Berosik, 352 Mont. 16 (2009 MT) (context for prior conduct to understand the charged act)
State v. Stout, 356 Mont. 468 (2010 MT) (application of transaction rule; not merely immediate prior acts)
State v. Hardman, 364 Mont. 361 (2012 MT) (Rule 403 balancing; probative value vs. prejudice)