State v. M. Blaz
398 P.3d 247, 2017 MT 164, 388 Mont. 105 (2017)
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Rule of Law:
Evidence of other crimes, wrongs, or acts is admissible under M. R. Evid. 404(b) for a non-propensity purpose, such as proving identity or absence of accident, when the prior act demonstrates a unique pattern of behavior or 'criminal signature' that links the defendant to the charged offense.
Facts:
- On July 10, 2013, Matthew John Blaz, while intoxicated, assaulted Jennifer, the mother of his infant daughter, Matti.
- During the assault, Blaz grabbed Jennifer by the hair and threw her to the floor while she was holding 16-day-old Matti, then began banging Jennifer's head against the floor.
- As a result of this incident, Blaz pleaded guilty to Partner or Family Member Assault (PFMA).
- On August 16, 2013, Blaz was at home caring for his 53-day-old daughter, Matti.
- Blaz later claimed that a neighbor boy entered the house, picked up Matti, and dropped her, causing her fatal injuries.
- The neighbor boy testified that he had only tickled Matti and did not pick her up.
- Later that day, Jennifer observed that Matti's skin was ashen, her breathing was unusual, and her eyes were bulging.
- Matti was taken to the hospital, where she died from craniocerebral and cervical trauma, which a medical examiner concluded was caused by a 'very strong, forceful slam against some broad object' and classified as a homicide.
Procedural Posture:
- Matthew John Blaz was charged with Deliberate Homicide in the Second Judicial District Court, Silver Bow County.
- Before trial, the State sought to introduce evidence of Blaz's prior conviction for Partner or Family Member Assault (PFMA).
- Blaz filed a motion in limine to exclude the evidence, which the District Court denied.
- At trial, the District Court admitted the PFMA evidence over Blaz's objection.
- A jury convicted Blaz of Deliberate Homicide.
- Blaz (appellant) appealed the judgment to the Supreme Court of Montana, with the State as the appellee.
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Issue:
Did the District Court abuse its discretion by admitting evidence about the defendant's prior Partner or Family Member Assault (PFMA) conviction under M. R. Evid. 404(b)?
Opinions:
Majority - Justice Rice
No, the District Court did not abuse its discretion. Evidence of a defendant's prior bad acts is admissible under M. R. Evid. 404(b) if offered for a purpose other than proving character, such as to show a pattern of behavior that establishes identity or to show an absence of mistake or accident. The court found that Blaz's prior PFMA and the acts causing Matti's death shared a unique pattern or 'criminal signature': both involved violence against female family members in the home, targeted the head, and involved slamming the victim's head against a broad, flat surface. This evidence was not used to show Blaz had a bad character, but to rebut his defense that the neighbor boy accidentally killed Matti and to identify Blaz as the perpetrator through his distinctive method of assault. The court concluded that a limiting instruction to the jury was sufficient to cure any unfair prejudice.
Dissenting - Justice McKinnon
Yes, the District Court abused its discretion. The prior PFMA evidence should not have been admitted because its relevance depended on an impermissible inference about Blaz's character. The majority's 'criminal signature' theory fails because the alleged similarities—violence against family members in the home involving head trauma—are generic characteristics of many domestic violence crimes, not a unique or distinctive methodology that would point only to Blaz. The evidence does not establish a modus operandi 'so unique that both crimes can be attributed to one criminal.' Admitting this evidence created a substantial risk that the jury convicted Blaz not for the charged crime, but because his prior PF-MA conviction portrayed him as a bad person with a propensity for violence.
Analysis:
This case clarifies the application of the 'pattern' or 'modus operandi' exception under Montana's Rule 404(b), particularly in domestic violence cases. The majority's decision lowers the threshold for what constitutes a 'unique' pattern, allowing evidence of prior domestic assaults to be admitted based on similarities in the mechanics of the violence and the relationship between the parties. This holding provides prosecutors with a powerful tool to introduce prior acts of domestic violence to rebut defenses like accident or mistaken identity. However, as the dissent forcefully argues, it also risks eroding the rule against propensity evidence by re-labeling generic features of domestic abuse as a unique 'criminal signature,' potentially prejudicing defendants.
