Gratzer v. State

Summary

The Montana Supreme Court affirmed the denial of Steven Kurt Gratzer’s petition for postconviction relief following his felony DUI conviction. The Court held that an officer’s allegedly misleading testimony concerning whether a Chevrolet Caprice could be operated without an ignition key was not material to the verdict because the officer independently testified that he saw Gratzer driving and exiting the vehicle.

Holdings

1. To prevail on a due process claim based on allegedly false testimony, a postconviction petitioner must establish that the testimony was actually false, material to the verdict, and known or believed by the prosecutor to be false.
2. The allegedly misleading testimony was not material to the verdict and therefore did not violate Gratzer's due process rights.
3. The District Court did not err in denying Gratzer's petition for postconviction relief.

Questions Presented

1. Whether the District Court erred in denying Gratzer's petition for postconviction relief based on his claim that Officer Eggett provided false or misleading testimony concerning operation of the vehicle without an ignition key.
2. Whether the challenged testimony was sufficiently false and material to the verdict to establish a Fourteenth Amendment due process violation.

Disposition

affirmed