State of Montana v. Beth Mount Joy Williams

Summary

The Montana Supreme Court affirmed the denial of Beth Williams’s motion to exclude Intoxilyzer 8000 breath-test evidence in a DUI proceeding. The court held that civil spoliation remedies do not apply in criminal cases and that the State’s failure to maintain accessible COBRA data did not constitute a due-process violation because Williams did not show bad faith. The memorandum opinion is noncitable and does not establish precedent.

Holdings

1. Spoliation is not applicable in this criminal proceeding because the Montana Rules of Criminal Procedure, rather than the Montana Rules of Civil Procedure, govern criminal cases.
2. The State's failure to maintain software making potentially useful COBRA data accessible did not deny Williams due process because the failure was not undertaken in bad faith.

Questions Presented

1. Whether spoliation remedies apply in a criminal proceeding when the State allegedly fails to preserve COBRA data underlying an Intoxilyzer 8000 breath-test result.
2. Whether the State's failure to maintain software making potentially useful COBRA data accessible denied Williams due process under Arizona v. Youngblood.

Disposition

affirmed