State v. Scott
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The Supreme Court reversed the judgment of the district court designating Defendant as a persistent felony offender (PFO) and imposing an enhanced sentence under Mont. Code Ann. 46-18-502 , holding that the PFO designation failed.
Defendant was convicted of distributing dangerous drugs. The State sought to designate Defendant as a PFO based on a 2014 Montana conviction for burglary and a 1994 federal conviction for bank robbery. The district court sentenced Defendant to the minimum PFO sentence enhancement. The Supreme Court reversed, holding that Defendant's federal bank robbery conviction was not reasonably equivalent to a Montana robbery conviction, and therefore, it may not be used as a predicate violent offense under Mont. Code Ann. 46-1-202(18) to impose a persistent felony offender sentence enhancement.
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