State v. Reynolds, 389 P.3d 243

Reynolds ran a nationwide securities fraud scheme through multiple sham entities, collecting over $5.3 million and using approximately $4.3 million for personal use. 141 witnesses were identified by the State.
Montana securities investigator Lynne Egan compiled a 120-page report, found Reynolds had never registered offerings, and testified he would not qualify for statutory exemptions (and had a prior Missouri Cease and Desist for fraud).
State filed an Information on Feb 22, 2012; Reynolds avoided arrest and was not taken into custody until July 5, 2012. Trial ultimately began Dec 3, 2013 — 650 days after filing.
Reynolds moved to dismiss for violation of his speedy-trial right; the District Court denied the motion after an Ariegwe balancing analysis.
At trial, the court refused Reynolds’ proposed jury instructions that would have referenced statutory exemptions to Montana securities registration provisions; the court used the State’s instructions instead.
Reynolds appeals two rulings: denial of his speedy-trial dismissal and the refusal to give his exemption-based jury instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Reynolds was denied a speedy trial under Mont. Const. Art. II, § 24	State: delays largely justified by case complexity and many delays attributable to defendant (flight, continuances); no prejudice shown	Reynolds: 650-day delay violated his speedy-trial right; State’s discovery/processing caused delay and impaired defense	Affirmed. Court applied Ariegwe four-factor test: much delay attributed to Reynolds (including flight and defense continuances), remaining delay was institutional/complexity-related, and defendant failed to show prejudice.
Whether District Court erred by refusing jury instructions referencing exemptions to §§ 30-10-201 and -202, MCA	State: exemption language inapplicable because Reynolds never registered and was disqualified by prior Missouri enforcement action; instructions given adequately stated law	Reynolds: exemption language should have been presented to jury as part of his defense theory	Affirmed. Court held the exemption language had no application (Reynolds never registered and was barred by prior enforcement), so refusal was not an abuse of discretion and instructions were sufficient.

State v. Ariegwe, 167 P.3d 815 (Mont. 2007) (sets out four-factor speedy trial balancing test)
State v. Cybulski, 204 P.3d 7 (Mont. 2009) (jury instruction standard: instructions must, taken as a whole, fairly instruct the jury)
State v. Archambault, 152 P.3d 698 (Mont. 2007) (instruction error standard and review)
State v. Bieber, 170 P.3d 444 (Mont. 2007) (abuse of discretion standard for jury instruction rulings)
State v. Carnes, 346 P.3d 1120 (Mont. 2015) (appellant bears burden to show jury instruction error)