State v. K. Proctor

Summary

The Court upheld Proctor’s conviction after concluding that the district court properly admitted testimony concerning nonaccidental trauma under Montana’s expert-evidence framework. Although the cellphone warrant was impermissibly broad, the Court held that the limited evidence admitted from the search was harmless, and it declined plain-error review of improper prosecutorial comments because they did not undermine the trial’s fundamental fairness. The Court also rejected Proctor’s ineffective-assistance claim for lack of prejudice.