State v. Luke, 2014 MT 22

Jared Mulloy Luke was charged with five misdemeanors (including DUI-related counts) on Nov. 26, 2011, and pleaded not guilty on Dec. 5, 2011.
Justice Court set a jury trial for May 3, 2012, and a mandatory, personal pretrial conference for April 27; Luke (but not his counsel) failed to appear timely at that conference.
The Omnibus Hearing Order warned that failure to appear at the pretrial conference and to file required jury materials would waive the right to a jury trial and result in resetting the case for a bench trial at the court’s next available date.
After Luke’s absence, the court vacated the May 3 jury trial and, on April 30, reset a bench trial for June 13, 2012 — eight days after the six-month statutory deadline under § 46-13-401(2), MCA.
Luke moved to dismiss under § 46-13-401(2) (trial not held within six months), the Justice Court denied the motion, the District Court affirmed, and the Montana Supreme Court reviewed whether "good cause" justified the delay.

Issue	Plaintiff's Argument (Luke)	Defendant's Argument (State/Justice Court)	Held
Whether “good cause” justified trial held eight days after the six-month statutory deadline under § 46-13-401(2), MCA	Luke: No good cause — his tardy/late appearance merely forfeited jury trial, did not cause an affirmative procedural delay; court could have converted May 3 jury date to a bench trial and complied with statute	State: Luke’s failure to appear triggered the Omnibus Order’s waiver and the court’s notification that the case would be reset to the next available bench trial date; that connection and court scheduling needs constitute good cause	Court: Affirmed — good cause existed because Luke was warned, failed to appear, and the court promptly reset the case to next available date, creating a sufficient connection to the delay

Stanley v. Lemire, 148 P.3d 643 (Mont. 2006) (describing district court’s appellate scope reviewing justice court record)
State v. Bertolino, 77 P.3d 543 (Mont. 2003) (passive disregard for deadlines did not constitute good cause when no connection to trial delay)
State v. Fitzgerald, 940 P.2d 108 (Mont. 1997) (justice courts must retain scheduling flexibility; defendant-caused continuances can relieve court of obligation to meet six-month deadline)
City of Helena v. Roan, 226 P.3d 601 (Mont. 2010) (definition and application of good cause in speedy-trial contexts)
State v. Martz, 196 P.3d 1239 (Mont. 2008) (interpretation of § 46-13-401(2) and related speedy-trial principles)