State v. W. Grussing, 507 P.3d 1152

While driving in Golden Valley County, Grussing rolled his truck; trooper observed open alcohol containers and signs of intoxication.
Trooper Boots conducted field sobriety tests and a preliminary breath test (BAC 0.056%); Grussing was arrested and taken to Wheatland Memorial Hospital in Wheatland County.
At the hospital Grussing refused a requested blood draw; Trooper Boots phoned Wheatland County Justice of the Peace Egebakken, who issued a search warrant for the blood draw.
Blood test: THC 15 ng/ml (+/- 3 ng/ml) (above statutory limit); BAC 0.0025%.
State charged Grussing with multiple counts including felony operation under the influence of delta-9-THC and felony criminal endangerment; Grussing moved to suppress the blood evidence.
Grussing argued the Wheatland JP lacked jurisdiction because the crash and alleged offenses occurred in Golden Valley County; District Court denied suppression, Grussing pleaded guilty, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a Wheatland County justice of the peace had authority to issue a search warrant for a blood draw performed in Wheatland County where the underlying offense occurred in Golden Valley County	The State: jurisdiction depends on location of the search (Wheatland); JP may issue warrant within the judge’s geographic jurisdiction	Grussing: JP lacked authority because criminal jurisdiction is limited to offenses committed in the county where the court is established (Golden Valley)	The court held §46-5-220(2)(a) limits warrant issuance by limited-jurisdiction courts to their geographic jurisdiction (location of the search), not the location of the offense; JP had authority and suppression denial affirmed

State v. Smith, 407 Mont. 18 (standard of review for suppression rulings)
State v. Staker, 404 Mont. 307 (standard of review precedent)
Holms v. Bretz, 405 Mont. 186 (statutory interpretation: plain language controls)