State v. Ring, 2014 MT 49

Ring appeals his incest conviction from a Lewis and Clark County district court following a jury trial; S.H. testified Ring gave her multiple drinks, she became blackout drunk, and he engaged in intercourse with her while she slept; Ring claimed he was heavily medicated for pain and that she initiated the contact while he was largely unaware; the trial court admitted a single social services report about a prior unverified accusation and denied further questioning outside the jury; the court instructed the jury that intoxication proved under Montana law could not negate the mental-state element; the court sentenced Ring to 20 years with numerous conditions later found partly illegal on remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion under Anderson in denying outside-questioning of the victim about false prior accusations	Ring argues Anderson requires a separate hearing and outside questioning	State argues no admissible basis exists to question; evidence insufficient	No abuse; hearing properly denied; prior accusations not proven false under Mazurek.
Whether the intoxication jury instruction violated due process when Ring testified to prescription drug use	Ring contends instruction negated his defense on mental state	Instruction consistent with Egelhoff and governing statutes	Instruction proper; did not violate due process.
Whether the district court abused its discretion in denying a new trial for juror bias	Ring claims juror concealment of incest history biased the verdict	No intentional concealment and no demonstrated bias	No abuse; denial affirmed; juror bias not proven.
Whether illegal sentence conditions (restitution, costs) were properly handled and remand needed	Conditions exceed statutory authority or lack specificity	Some conditions valid, others must be struck or clarified	Remand to strike/modify illegal or unspecified conditions; restitution and cost orders remanded for specificity.

State v. Anderson, 211 Mont. 272, 686 P.2d 193 (Mont. 1984) (admissibility framework for prior false accusations; outside hearing required)
Mazurek v. District Court, 277 Mont. 349, 922 P.2d 474 (Mont. 1996) (three-part test for admissibility of prior accusations; preponderance standard)
Montana v. Egelhoff, 518 U.S. 37, 116 S. Ct. 2013 (U.S. 1996) (due process not violated by reduced mens rea under intoxication statute)
State v. McCaslin, 2004 MT 212, 322 Mont. 350, 96 P.3d 722 (Mont. 2004) (jury instruction under § 45-2-203 did not shift burden or violate due process)
State v. Myran, 2012 MT 252, 366 Mont. 532, 289 P.3d 118 (Mont. 2012) (substantial rights not prejudiced by standard intoxication instruction)
State v. Woods, 221 Mont. 17, 716 P.2d 624 (Mont. 1986) (non-disclosure of past victimization not automatic bias; discretionary denial upheld)
State v. Dunfee, 2005 MT 147, 327 Mont. 335, 114 P.3d 217 (Mont. 2005) (juror misconduct; no reversible error where no bias shown)
State v. Gunderson, 2010 MT 166, 357 Mont. 142, 237 P.3d 74 (Mont. 2010) (parole conditions generally governed by statute; district court may not exceed authority)