State v. Slavin

Summary

The Montana Supreme Court affirmed Lenorse Slavin’s convictions for felony kidnapping and misdemeanor assault. The court held that any error in quashing subpoenas for a newspaper reporter and editor under Montana’s reporter shield statute was harmless, and that the district court did not abuse its discretion by limiting the testimony of Slavin’s expert regarding the victim’s medical history and prior conduct.

Holdings

1. Any error in excluding the reporters' testimony was harmless because there was no reasonable possibility that the exclusion contributed to Slavin's conviction.
2. The District Court did not abuse its discretion by allowing general testimony about Merryfield's disorder, medication, alcohol effects, and the expert's review of records while permitting specific testimony about only two prior incidents involving untruthful statements.

Questions Presented

1. Whether the District Court properly quashed subpoenas requiring a newspaper reporter and editor to testify at trial under Montana's reporter shield statute.
2. Whether the District Court abused its discretion by limiting the testimony of Slavin's expert witness regarding Merryfield's prior conduct and the materials reviewed by the expert.

Disposition

affirmed