State v. Spangler (2025 MT 244N): Nonprecedential Reaffirmation that Single-Witness Testimony Can Sustain Unlawful Restraint; Remand to Correct Judgment to Attempted Assault with a Weapon

State v. Spangler (2025 MT 244N): Nonprecedential Reaffirmation that Single-Witness Testimony Can Sustain Unlawful Restraint; Remand to Correct Judgment to Attempted Assault with a Weapon

Introduction

In a noncitable memorandum opinion, the Supreme Court of Montana affirmed in part and reversed in part the judgment against Christopher Lee Spangler arising from an altercation in Helena on September 24, 2021. The case centers on two discrete appellate questions: whether the State’s evidence was sufficient to sustain a conviction for Unlawful Restraint under § 45-5-301, MCA; and whether the written judgment erroneously reflected a conviction for completed Assault with a Weapon rather than Attempted Assault with a Weapon under §§ 45-4-103 and 45-5-213(1)(a), MCA, as charged in the amended information and returned by the jury.

The Court, applying settled sufficiency-of-the-evidence principles, held that a rational juror could find that Spangler substantially interfered with the liberty of his then-girlfriend, C.J., based on the eyewitness testimony of Trent Emmart, who saw Spangler pulling C.J. by her hair through a truck window and described her as “stuck in the car.” The Court further remanded for the district court to correct a clerical error to reflect that the jury convicted Spangler of Attempted Assault with a Weapon.

Importantly, the Court emphasized that this memorandum opinion “shall not be cited and does not serve as precedent,” and expressly noted that the appeal presented no constitutional issue, no question of first impression, and did not modify existing law. Even so, the decision is instructive for practitioners on the evidentiary threshold for unlawful restraint and on the necessity for accuracy between the jury’s verdict and the written judgment.

Summary of the Opinion

The Court (Shea, J.) resolved two claims:

  • Sufficiency of the evidence for Unlawful Restraint affirmed. Viewing the record in the light most favorable to the State, Emmart’s testimony that he heard a woman cry for help, saw Spangler pulling C.J. by the hair through the driver’s window, and that C.J. was “stuck in the car” sufficed for a rational juror to find a knowing or purposeful restraint that substantially interfered with C.J.’s liberty. The Court cited the statutory definition in § 45-5-301(1), MCA, the Commissioners’ Note emphasizing that even temporary detention is covered, and Montana precedents confirming that a single witness can prove a fact and that credibility determinations belong to the jury.
  • Judgment corrected from completed to attempted Assault with a Weapon. Because the State amended the information to Attempted Assault with a Weapon and both parties agreed the jury convicted on that charge, the Court reversed in part and remanded solely to amend the judgment to conform to the verdict: Attempted Assault with a Weapon under §§ 45-4-103 and 45-5-213(1)(a), MCA.

The Court decided the case under Section I, Paragraph 3(c) of its Internal Operating Rules (memorandum opinions), making it noncitable.

Analysis

1) Precedents and Authorities Cited

  • State v. Burnett, 2022 MT 10, ¶ 15, 407 Mont. 189, 502 P.3d 703. The Court reiterated that Montana reviews insufficiency claims de novo. Although de novo, the appellate lens remains the familiar sufficiency construct—ask whether, when viewing the evidence in the State’s favor, any rational juror could find each element beyond a reasonable doubt.
  • City of Helena v. Strobel, 2017 MT 55, ¶ 8, 387 Mont. 17, 390 P.3d 921. Quoted for the core sufficiency standard: a conviction stands if any rational trier of fact could find the essential elements beyond a reasonable doubt when the evidence is viewed most favorably to the prosecution.
  • State v. Rosling, 2008 MT 62, ¶ 45, 342 Mont. 1, 180 P.3d 1102. Cited to explain that kidnapping-related statutes require “restraint” without a specific duration. In this case, that principle supports the notion that even a short-lived restraint can satisfy unlawful restraint, consistent with legislative design spanning kidnapping offenses.
  • State v. Kaske, 2002 MT 106, ¶ 25, 309 Mont. 445, 47 P.3d 824. Authority for the proposition that the uncorroborated testimony of a single witness can be sufficient to prove a fact. This is central here because C.J. did not testify; the State’s proof turned principally on Emmart’s eyewitness account.
  • State v. McCoy, 2021 MT 303, ¶ 36, 406 Mont. 375, 498 P.3d 1266. Reaffirmed that credibility and weight of testimony are the exclusive province of the jury. Appellate courts do not second-guess the jury’s assessments based on perceived inconsistencies absent legal insufficiency.
  • Statutes:
    • § 45-5-301(1), MCA (Unlawful Restraint): A person commits unlawful restraint by knowingly or purposely, and without lawful authority, restraining another so as to substantially interfere with the person’s liberty. The Court also referenced the Commissioners’ Note emphasizing that the offense addresses the “lowest form of interference” and includes temporary detentions.
    • § 45-4-103, MCA (Attempt): Defines the elements of criminal attempt (purposely engaging in conduct that constitutes a substantial step toward commission of the offense).
    • § 45-5-213(1)(a), MCA (Assault with a Weapon): The underlying substantive offense to which the attempt applied. The opinion notes the subsection but confines the remedy to correcting the judgment to attempted assault.
  • Internal Operating Rules: Section I, Paragraph 3(c) authorizes memorandum opinions that are noncitable and nonprecedential. The Court invoked this rule and expressly disclaimed creating or modifying precedent.

2) The Court’s Legal Reasoning

The Court’s reasoning tracks established sufficiency doctrine and the statutory contours of unlawful restraint:

  • Evidence viewed most favorably to the State. The Court carried forward the standard from Burnett/Strobel. On appeal, the question is not whether contrary or competing inferences exist, but whether a rational juror, crediting the State’s proof, could find the elements beyond a reasonable doubt.
  • Substantial interference with liberty can be brief and is fact-driven. The Court relied on § 45-5-301(1), MCA, and the Commissioners’ Note reflecting legislative intent to treat even temporary detentions as unlawful restraint—“the lowest form of interference.” Rosling supported the no-duration requirement in related kidnapping contexts. Here, Emmart’s eyewitness testimony supplied the key inference: by grabbing and pulling C.J. by the hair through the truck window, pinning her ability to move, and prompting a cry for help, Spangler knowingly and purposefully restricted her freedom of movement. The fact that the episode lasted “a matter of minutes” did not undermine the element; duration is not determinative.
  • Single-witness sufficiency and jury credibility prerogative. Kaske permits a conviction based on a single witness. McCoy confines credibility assessments to the jury. Spangler’s attempts to impeach Emmart with inconsistencies about the beer bottle’s impact or Emmart’s injury went to weight, not legal sufficiency. The jury, by convicting, necessarily credited Emmart’s account.
  • Clerical correction for the assault count. The State amended the assault count to “Attempted Assault with a Weapon.” Both sides agreed on appeal that the jury convicted on the attempt, yet the written judgment recited the completed offense. The Court treated this as a correctable clerical error, reversing in part and remanding for an amended judgment to conform to the verdict: Attempted Assault with a Weapon under §§ 45-4-103 and 45-5-213(1)(a), MCA.

3) Impact and Practical Implications

Although nonprecedential and noncitable, the opinion reflects consistent applications of Montana law with practical takeaways:

  • Proving unlawful restraint without victim testimony. Where a third-party eyewitness observes conduct that plainly restricts a person’s movement (e.g., hair pulling that leaves the person “stuck” in a vehicle, coupled with a distress call), that testimony can suffice. Prosecutors should elicit specific observations establishing loss of freedom of movement and the actor’s purposeful or knowing conduct.
  • Temporary restraint is enough. Even a brief interference during a rapidly unfolding altercation may satisfy § 45-5-301(1), MCA. The absence of a long detention, isolation, or transport does not defeat the charge if substantial interference is shown.
  • Weapon-based charges and attempt. When the evidence shows a swing or strike with an object capable of causing harm (here, a beer bottle) but the State cannot establish all elements of the completed offense, an attempt charge may be appropriate. Charging instruments and verdict forms should track proof; judgments must conform to the verdict to avoid later corrective remands.
  • Appellate posture on credibility. Insufficiency challenges are uphill when they turn on attacking a witness’s credibility rather than on the absence of proof for an element. Appellate courts defer to the jury on credibility and resolve evidentiary conflicts in favor of the verdict.
  • Administrative accuracy matters. Even when the merits are affirmed, mislabeling the offense in a written judgment requires correction. Counsel should audit judgments against the charging document and verdict to prevent post-judgment remedial proceedings.

Because this is a memorandum opinion under the Court’s Internal Operating Rules, it cannot be cited as authority in future filings. Its value lies in signaling, rather than setting, how Montana courts continue to apply well-settled principles to common street- and domestic-context altercations involving brief restraint and the use (or attempted use) of improvised weapons.

Complex Concepts Simplified

  • Noncitable memorandum opinion. A short appellate decision issued when the Court perceives no new legal ground is broken. It resolves the parties’ dispute but cannot be cited as precedent in other cases.
  • Sufficiency of the evidence (criminal). On appeal, the court asks whether any rational juror could have found each element beyond a reasonable doubt when the evidence is viewed in the light most favorable to the State. The court does not reweigh evidence or reassess witness credibility.
  • Unlawful Restraint. The crime consists of knowingly or purposely restraining someone without lawful authority in a way that substantially interferes with their liberty. It covers the “lowest” level of liberty interference—brief detentions qualify.
  • Restraint vs. Bodily Injury. Causing pain or injury does not negate restraint; conduct can both inflict harm and restrain movement. For unlawful restraint, the focus is on interference with liberty; physical harm is not required, though it may be present.
  • Attempt. A person commits attempt by purposely taking a substantial step toward committing a crime, even if the completed crime does not occur. Here, the assault count was tried and returned as an attempt.
  • Credibility determinations. Juries decide whom to believe. Inconsistencies in testimony affect weight but do not automatically create legal insufficiency.
  • Clerical error vs. substantive error. A clerical error is a mismatch between what the court intended (or what the jury actually found) and what the written judgment says. It can be corrected without re-trying or re-arguing the case.

Conclusion

State v. Spangler (2025 MT 244N) is a nonprecedential but instructive application of Montana’s well-established sufficiency standards to an unlawful restraint conviction arising from a brief, volatile encounter. The Court reaffirmed that:

  • Single-witness testimony can prove an element beyond a reasonable doubt;
  • “Substantial interference” with liberty under § 45-5-301(1), MCA, encompasses even short-lived restraints;
  • Credibility assessments are for the jury, not the appellate court;
  • Judgments must accurately reflect the offense of conviction—here, Attempted Assault with a Weapon, not the completed offense.

While it sets no new precedent, the opinion provides a clear illustration of how Montana courts scrutinize unlawful restraint and attempt charges, and it underscores the importance of precise alignment between charges, verdicts, and final judgments.

Case Details

Year: 2025
Court: Supreme Court of Montana

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