State v. Campa

Summary

The Montana Supreme Court addressed whether defense counsel was ineffective for failing to attach an affidavit concerning the justification for a probationary vehicle stop and whether the trial court improperly admitted evidence of prior probation violations and sanctions. The court held that the search was supported by reasonable cause, so counsel's omission did not prejudice the defendant. It nevertheless reversed and remanded for a new trial because the State failed to provide the required notice before introducing evidence of the intervention hearing and resulting sanctions.

Holdings

1. Campa failed to establish prejudice because the probation officer had reasonable cause to stop and search the vehicle based on the totality of the circumstances, even without considering whether Rodriguez was a felon.
2. The District Court erred by admitting the evidence because it constituted evidence of prior wrongs subject to Montana Rule of Evidence 404(b) and section 46-13-109, MCA, and the State failed to provide the required timely written notice.

Questions Presented

1. Whether counsel provided ineffective assistance by failing to attach an affidavit stating that the person associated with the house was not a felon, thereby allegedly undermining the justification for the stop and search.
2. Whether the District Court erred by admitting evidence of Campa's prior probation violations, intervention hearing, and resulting sanctions without the notice required for other-acts evidence.

Disposition

reversed_and_remanded