State v. Williams, 423 P.3d 596

In February 2014, K.T. testified Williams broke into her home, strangled and sexually assaulted her, and she feared she would die; Williams claimed the encounter was consensual after prior drug use.
A jury convicted Williams of Sexual Intercourse Without Consent, Aggravated Burglary, and Aggravated Assault; district court entered final judgment (Sept. 9, 2016).
Post-trial Williams moved to dismiss, arguing the State failed to disclose that an evidence technician (Steven Brester), later fired for suspected evidence tampering, worked at the Montana State Crime Lab during the relevant period.
Defense had requested all internal/external lab audits and the court ordered production; the State provided some audit material but did not specifically disclose the lab personnel issues at first; lab witnesses testified Brester had no access to the DNA vault or the tested blood/DNA evidence in Williams’s case.
Williams objected to aggravated-assault jury instructions that included "death" (arguing only "serious bodily injury" was supported) and objected to restitution ($1,700) imposed on K.T.’s unsupplemented testimony.
The district court denied dismissal, gave aggravated-assault instructions including "death," and imposed $1,700 restitution based on victim testimony; the Montana Supreme Court affirmed.

Issue	Williams' Argument	State's Argument	Held
1. Post-trial dismissal for Brady/discovery violation	State suppressed impeachment evidence about Brester; dismissal or reversal required	State produced relevant audits and Brester had no access to tested DNA; no Brady prejudice	Denial affirmed: suppression found not prejudicial because Brester lacked access to the challenged evidence and no reasonable probability of a different outcome
2. Jury instruction on Aggravated Assault ("death" vs. "serious bodily injury")	Instruction improperly allowed conviction based on apprehension of death; evidence showed only fear of serious bodily injury	Evidence showed strangulation, loss of consciousness, and victim’s belief she would die; issue was properly for jury	Affirmed: sufficient evidence supported instruction including "death"
3. Restitution without written documentation	Court erred imposing $1,700 restitution absent documentary proof	Victim testified under oath and defendant had opportunity to rebut; victim testimony may support restitution	Affirmed: restitution not clearly erroneous; victim testimony was admissible and defendant had chance to challenge

Brady v. Maryland, 373 U.S. 83 (landmark holding that suppression of exculpatory evidence violates due process)
Betterman v. Montana, 136 S. Ct. 1609 (addresses review standard for certain post-trial motions and Brady analysis context)
Kills on Top v. State, 901 P.2d 1368 (impeachment evidence and State disclosure obligations)
State v. Weisbarth, 378 P.3d 1195 (Montana case discussing State's disclosure duties and impeachment evidence)
State v. Simpson, 328 P.3d 1144 (permitting restitution based on victim testimony where defendant had chance to rebut)