State v. R. Staudenmayer, 523 P.3d 29

In Nov 2018 Staudenmayer was arraigned on felony charges; deputy clerk Krisstyn Leiter’s minute entry recorded: “Defendant present with Counsel Ashley Morigeau” and set an omnibus hearing for March 13, 2019.
Staudenmayer missed the March 13 omnibus; a minute entry recorded: “Defendant not present, represented by Counsel Ashley Morigeau” and that Morigeau had “no information on the non-appearance of her client.”
Prosecutors charged him with bail-jumping shortly after the missed hearing; that charge was later dismissed and refiled in March 2020 after a plea withdrawal.
Multiple counsel substitutions followed; newly assigned public defenders requested a one-month continuance in June 2020; the district court denied the continuance and permitted trial to proceed July 13, 2020.
At trial the State introduced the clerk’s minute entries (District Court Clerk Fricker laid foundation; the author Leiter did not testify). Defense objected under the Confrontation Clause. The jury convicted Staudenmayer of bail-jumping and he appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Staudenmayer)	Held
Whether admission of clerk minute entries violated the Sixth Amendment Confrontation Clause	Minute entries are public/business records made for routine court administration and are nontestimonial; admissible without the minute-author’s testimony	The minute entries (attendance and the attorney’s statement) are testimonial hearsay; admitting them without the author’s cross-examination violated confrontation rights	Affirmed. Court held entries were nontestimonial (primary purpose administrative); any error as to the attorney’s remark was harmless
Whether the court abused its discretion by denying a one-month continuance after new counsel was appointed	Denial was reasonable given lengthy pendency, multiple prior trial settings, and prejudice to the State; defense had basic discovery and could contact client by phone	Newly appointed counsel had inadequate time to prepare and were prejudiced; denial impaired effective assistance of counsel	Affirmed. Court found no abuse of discretion and no demonstrated prejudice to substantial rights

Crawford v. Washington, 541 U.S. 36 (testimonial hearsay requires opportunity for cross-examination)
Ohio v. Clark, 576 U.S. 237 (2015) (apply primary-purpose test to determine whether out-of-court statements are testimonial)
Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009) (certificates produced for evidentiary purpose are testimonial)
Bullcoming v. New Mexico, 564 U.S. 647 (2011) (forensic reports produced for trial are testimonial)
Michigan v. Bryant, 562 U.S. 344 (2011) (primary-purpose framework and context factors)
City of Kalispell v. Omyer, 383 Mont. 19 (2016) (Mont.) (administrative public records not testimonial when primary purpose is agency administration)
State v. Laird, 397 Mont. 29 (2019) (Mont.) (Confrontation Clause considerations guide admissibility despite hearsay exceptions)
State v. Clark, 290 Mont. 479 (1998) (Mont.) (Montana precedent on confrontation and use of laboratory/public records)