State v. Reinert, 419 P.3d 662

On Dec. 21, 2013, Richard Reinert shot and killed Jessica Stephenson in his home; surveillance and a 911 call recorded events and immediate aftermath. Reinert admitted shooting but claimed self‑defense.
Reinert testified he feared serious bodily injury and presented character evidence of peacefulness and truthfulness. Danielle (his wife) and others testified to a violent domestic dispute earlier that night. Physical and forensic evidence placed Jessica about three feet from Reinert when shot.
The State presented Dr. Thomas Bennett, forensic pathologist, who testified about wound paths, number of bullets, and Jessica’s position; Dr. Bennett modified his opinion on the number of bullets during cross‑examination.
The State cross‑examined Reinert with a 2011 Florida police report (an alleged false report) to impeach Reinert’s asserted truthfulness after Reinert opened the door by offering good‑character evidence.
Reinert moved for a new trial claiming Brady violations (the State withheld a letter from Dr. Gary Dale criticizing Dr. Bennett and withheld recorded jail calls); the district court denied the motion. Reinert appealed denial and the admission of the prior bad‑act evidence.

Issue	Plaintiff's Argument (Reinert)	Defendant's Argument (State)	Held
Whether nondisclosure of exculpatory/impeachment evidence (letter from Dr. Gary Dale re: Dr. Bennett) required a new trial under Brady	The State possessed and suppressed a letter undermining Dr. Bennett’s credibility/forensic opinions; disclosure would create a reasonable probability of a different outcome	The withheld material would not have changed the overwhelming evidence that Reinert shot and killed Jessica; trial transcript shows ample impeachment opportunity	Affirmed: No Brady violation; suppressed material not shown to create reasonable probability of different result
Whether cross‑examination about a prior false police report was an abuse of discretion	Admission was improper and unduly prejudicial; not relevant to self‑defense	Reinert opened the door by testifying to peaceful, truthful character; Rule 405/608 permitted limited inquiry to attack credibility	Affirmed: District court acted within discretion to permit narrow cross‑examination to rebut character evidence

Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose evidence favorable to defendant where material to guilt or punishment)
Smith v. Cain, 565 U.S. 73 (2012) (Brady materiality defined by reasonable probability that result would differ)
State v. Jackson, 354 Mont. 63 (Mont. 2009) (Brady framework applied in Montana; standard for reviewing new‑trial motion)
Amado v. Gonzalez, 758 F.3d 1119 (9th Cir. 2014) (rejecting a due‑diligence barrier to Brady claims)
State v. Carter, 285 Mont. 449 (1997) (defendant who introduces character evidence opens door to rebuttal cross‑examination on specific instances)
State v. Kaarma, 386 Mont. 243 (Mont. 2017) (limits on raising new issues on appeal; character evidence doctrines)