State of Montana, Plaintiff and Appellee v. James Derbyshire, Defendant and Appellant

Summary

The court held that the trial court improperly admitted repeated references to Derbyshire's probationary status and the witnesses' status as probation officers. The evidence was not admissible under the applicable other-acts rule or the transaction rule because the legality and circumstances of the search were not elements or facts in dispute, and the error was not harmless given its highly prejudicial and repeated nature. Justice Warner, dissenting, agreed the evidence was irrelevant but would have affirmed because the evidence of guilt and the limiting instructions eliminated any reasonable possibility of prejudice.