State v. St. Dennis
2010 MT 229
| Mont. | 2010Background
- St. Dennis was convicted of felony deliberate homicide in Missoula County and appeals to the Montana Supreme Court.
- St. Dennis and his co-defendant Strahan were represented by the Montana Office of Public Defender (OPD) in overlapping cases.
- The district court initially ruled that OPD could represent both defendants without an impermissible conflict of interest given safeguards.
- A proposed witness, Baldwin (Witness X), sought immunity, but the court denied immunity and Baldwin was not called.
- After trial, undisclosed witness statements surfaced; St. Dennis sought immunity for Baldwin and a new trial under Brady; the district court denied.
- The Montana Supreme Court adopts a case-by-case approach to conflicts within OPD and held no actual conflict existed given safeguards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did OPD's dual representation violate rights? | St. Dennis argues OPD is a single firm; conflict should require reversal. | State contends case-by-case safeguards prevent conflicts and avoid per se rule. | No actual conflict; case-by-case approach adopted. |
| Was denial of immunity for a proposed witness an abuse of discretion? | St. Dennis argues immunity was necessary to present a meaningful defense. | State argues lack of proof of relevance or witness availability; § 46-20-701(1) governs prejudice. | No reversal; record lacking showing prejudice; immunity ruling affirmed. |
| Did the failure to disclose witness statements amount to Brady prejudice requiring a new trial? | St. Dennis asserts Brady violation and prejudice to trial outcome. | State contends statements were not suppressed, not favorable, and not material given post-resting cases. | No reversal; statements not material; no reasonable probability of different verdict. |
Key Cases Cited
- Cuyler v. Sullivan, 446 U.S. 335 (1980) (conflict of interest requires case-by-case analysis unless per se rule)
- Holloway v. Arkansas, 435 U.S. 475 (1978) (joint representation prejudices must be considered for waiver of conflicts)
- Strickland v. Washington, 466 U.S. 668 (1984) (presumed prejudice when conflict of interest affects counsel's performance)
- United States v. Bagley, 473 U.S. 667 (1985) (materiality for Brady includes evidence that could change outcome)
- Cone v. Bell, 129 S. Ct. 1769 (2009) (Brady materiality and suppression standards reaffirmed; materiality requires reasonable probability of different outcome)
- Glick, 2009 MT 44, 349 Mont. 277, 203 P.3d 796 (2009) (case-by-case analysis for OPD conflicts; not per se rule)