State v. Shields

Summary

The Supreme Court of Montana affirmed Benjamin Timothy Shields's conviction for sexual intercourse without consent. The court held that sufficient evidence supported the jury's finding that the victim was sleeping during the intercourse and therefore physically helpless and incapable of consent under Montana law. The court deferred to the jury's credibility determinations and rejected Shields's sufficiency-of-the-evidence arguments.

Holdings

1. Viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could find beyond a reasonable doubt that the victim was asleep during the intercourse, was therefore physically helpless, and was incapable of consent. The evidence was sufficient to support the conviction.

Questions Presented

1. Whether the evidence was sufficient to support Shields's conviction for sexual intercourse without consent by proving that the victim was physically helpless and therefore incapable of consent because she was asleep.
2. Whether conflicting testimony concerning the victim's awareness and participation rendered the evidence insufficient as a matter of law.

Disposition

affirmed