State of Montana v. Anthel Lavan Brown

Summary

The Montana Supreme Court affirmed the denial of Anthel Lavan Brown’s motion to compel discovery in connection with a potential postconviction-relief petition. The court held that Brown’s claims concerning the voluntariness of his guilty pleas had previously been determined or could have been raised earlier, and that the requested materials did not constitute newly discovered evidence sufficient to avoid the applicable time bar.

Holdings

1. Brown was bound by the prior determination that his guilty pleas were voluntary and could not continue to raise the same issues in subsequent petitions and proceedings.
2. The materials Brown sought were not newly discovered evidence because Brown admitted that they existed at the time of his guilty plea.
3. The District Court properly denied Brown's motion for discovery, and the order was affirmed.

Questions Presented

1. Whether the District Court properly denied Brown's motion to compel discovery sought to support an anticipated postconviction-relief petition.
2. Whether Brown could relitigate the voluntariness of his guilty pleas in a subsequent petition or proceeding after that issue had been determined in an earlier proceeding.
3. Whether materials that existed at the time of Brown's guilty plea qualified as newly discovered evidence sufficient to avoid the statutory time bar for postconviction relief.

Disposition

affirmed