State v. P. Rossbach, 553 P.3d 402

Preston Csoo Rossbach was convicted by a Missoula County jury of two counts of deliberate homicide (felony murder), assault with a weapon, tampering with evidence, and two counts of intimidation related to an October 2018 shooting in a Missoula motel.
The convictions stemmed from an incident where Rossbach, Whitworth, and Charlo intended to confront a dealer about "bad" drugs, resulting in the shooting deaths of two victims and injuries to a third.
Evidence included testimony from accomplices and jailhouse informants, forensic experts, and surviving witnesses, linking Rossbach to the attempted robbery and violence.
Rossbach moved for acquittal or new trial on several grounds, all denied by the District Court.
On appeal, Rossbach challenged juror impartiality, limits on cross-examination of informants, sufficiency of evidence for felony murder, and an alleged Brady violation regarding untimely disclosure of an informant letter.

Issue	Rossbach's Argument	State's Argument	Held
Denial of challenge for cause of Prospective Juror C.S.	C.S. was biased toward State witnesses; forced to use peremptory	C.S.'s voir dire established impartiality	District court did not abuse discretion
Limits on cross-exam of jailhouse informants	Restrictions violated confrontation rights	Cross allowed wide latitude; limits proper	No abuse of discretion; rights protected
Sufficiency of evidence for felony murder	No overt act for robbery; no jury basis for accountability	Evidence showed planned robbery, overt acts, and accountability	Sufficient evidence supported conviction
Brady violation (late informant letter)	Letter was impeaching; late disclosure warranted new trial	Letter immaterial; no prejudice; not suppressed	No reasonable probability of different outcome

State v. Ghostbear, 399 Mont. 208 (Mont. 2020) (abuse of discretion standard for juror challenges)
State v. Garding, 373 Mont. 16 (Mont. 2013) (trial courts have broad discretion to limit cross-examination)
State v. Boyd, 407 Mont. 1 (Mont. 2021) (sufficiency of the evidence review)
State v. Burkhart, 325 Mont. 27 (Mont. 2004) (purpose and application of the felony-murder rule)
State v. Reinert, 391 Mont. 263 (Mont. 2018) (elements of a Brady violation)