Sanchez v. State

Summary

The Supreme Court of Montana affirmed the denial of Gregory Sanchez's petition for postconviction relief. The court held that the petition was untimely under Montana's one-year statutory limitation period and that no exception for newly discovered evidence or miscarriage of justice applied.

Holdings

1. The timeliness of a petition for postconviction relief is governed by the statute of limitations in effect when the petition is filed, rather than the statute in effect when the offense was charged or the conviction occurred.
2. A conviction becomes final when the time for appealing to the Montana Supreme Court expires.
3. Sanchez's postconviction-relief petition was untimely because it was filed more than one year after his conviction became final.
4. No exception to the statutory time bar applied because Sanchez did not allege newly discovered evidence establishing actual innocence or demonstrate a clear miscarriage of justice.

Questions Presented

1. Whether the District Court correctly denied Sanchez's petition for postconviction relief as untimely under section 46-21-102(1), MCA.
2. Whether any statutory or miscarriage-of-justice exception to the postconviction-relief time bar applied.
3. Whether Sanchez established grounds warranting postconviction relief based on ineffective assistance of counsel, denial of access to the courts, denial of due process, or an involuntary or unknowing guilty plea.

Disposition

affirmed