State v. Trujillo, 342 Mont. 319

Summary

The Supreme Court of Montana affirmed Joe Trujillo's misdemeanor conviction for criminal trespass to property. The court held that sufficient evidence established that Trujillo knowingly drove a four-wheeler onto Plum Creek property without permission and that the property was effectively posted against such vehicle use. The court also held that ignorance of the law and reliance on another person's instructions did not negate the required knowing mental state.

Holdings

1. A defendant acts knowingly when aware of the defendant's own conduct; the State need not prove that the defendant knew the conduct constituted trespass or intended to violate the law.
2. The evidence was sufficient to establish that Plum Creek property was effectively posted against the use of four-wheelers, either because the principal access points were posted and gated or because Trujillo's off-road use violated the property's posted open-lands policy.
3. Sufficient evidence supported Trujillo's conviction for criminal trespass to property.

Questions Presented

1. Whether sufficient evidence supported Trujillo's conviction for misdemeanor criminal trespass to property.
2. Whether the evidence established that Trujillo knowingly entered Plum Creek property unlawfully despite his lack of knowledge that the property was posted against four-wheeler use.
3. Whether Plum Creek's property was effectively posted against the use of four-wheelers under Montana's criminal-trespass statutes.

Disposition

affirmed