State v. Lacey

Summary

The Montana Supreme Court affirmed Daniel Lacey’s convictions for felony sexual intercourse without consent and felony sexual assault. The court held that the defendant’s former girlfriend had sufficient authority to consent to searches and seizure of a laptop and items in a shared garage, and that the defendant’s statements to investigators were admissible because he knowingly waived his rights and made the statements voluntarily. The court also rejected the claim of judicial bias arising from the district court’s adoption of the State’s proposed findings and conclusions.

Holdings

1. Dozier had sufficient common authority to consent to the search of Lacey's belongings in the garage because the items were commingled, unmarked, unlocked, and kept in a common area to which she had access.
2. The evidence obtained from the laptop was admissible because it would inevitably have been discovered pursuant to a valid search warrant, even assuming Officer Spaulding lacked probable cause or Dozier lacked authority to consent to the laptop's seizure.
3. Although Lacey was subjected to custodial interrogation at the police station, his statements were admissible because he received Miranda warnings, knowingly, intelligently, and voluntarily waived his rights, did not unequivocally invoke his right to counsel, and confessed voluntarily.
4. The district judge's questioning during the suppression hearing and adoption of the State's proposed findings did not establish judicial bias or deny Lacey a fair hearing, and the court declined to review the unpreserved claim under the plain-error doctrine.

Questions Presented

1. Whether Dozier had sufficient common authority to consent to the search of items located in the shared garage.
2. Whether the laptop was lawfully seized and whether evidence obtained from it was admissible under the inevitable-discovery exception.
3. Whether Lacey was subjected to custodial interrogation, knowingly and voluntarily waived his Miranda rights, and voluntarily confessed.
4. Whether the district judge's questioning and adoption of the State's proposed findings demonstrated judicial bias or deprived Lacey of due process.

Disposition

affirmed