Great Falls v. Kuntz
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In Montana, Hannah Rose Kuntz was charged with Violation of a Protective Order and pleaded not guilty. The City of Great Falls requested multiple continuances due to witness unavailability, with the final one being due to a key witness being quarantined due to exposure to COVID-19. The trial was set for a date beyond the statutory six-month deadline for a speedy trial, prompting Kuntz to file a motion to dismiss for lack of speedy trial. The Municipal Court denied the motion, citing good cause due to public health concerns and uncertainty about the ability to convene the requisite number of jurors due to the COVID-19 pandemic. Kuntz changed her plea to guilty and later appealed the Municipal Court's order to the District Court. The District Court affirmed the Municipal Court's determination of good cause for delay.
Upon Kuntz's appeal, the Supreme Court of the State of Montana affirmed the lower courts' decisions. The Supreme Court found that the Municipal Court's factual findings were not clearly erroneous and that its legal conclusions were correct. It was determined that the totality of the facts and circumstances surrounding trial scheduling and the COVID-19 pandemic provided good cause for the delay in Kuntz's trial. The Supreme Court also highlighted that the Municipal Court was in the best position to assess local trends and manage its docket in accordance with health risks. The court concluded that there was no prejudice to Kuntz and that the public health risks outweighed any potential prejudice, providing good cause to delay the trial two days beyond the deadline.
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