State v. Maggi
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Shane Maggi, an inmate at Montana State Prison, was convicted of aggravated assault, assault with a weapon, and possession of a deadly weapon by a prisoner. The charges stemmed from an incident where Maggi and another inmate attacked Wesley Smith in his cell, causing puncture wounds and a fractured facial bone. At sentencing, the Third Judicial District Court, Powell County, declared Maggi a persistent felony offender and used that designation to impose a life sentence on the aggravated assault charge.
The District Court's decision was appealed to the Supreme Court of the State of Montana. The appellant argued that the District Court erred in imposing a life sentence under § 46-18-220, MCA, for aggravated assault when Maggi had not previously been designated a persistent felony offender. The State had sought sentence enhancements related to the offenses being committed while Maggi was in official detention, including life imprisonment for the aggravated assault charge.
The Supreme Court of the State of Montana agreed with the appellant's argument. The court held that a defendant must have been previously declared a persistent felony offender, prior to the defendant’s subsequent, present felony conviction for which the offender is being sentenced, to count as an aggravating circumstance. The court found that the District Court had incorrectly used its simultaneous designation of Maggi as a persistent felony offender to enhance his sentence for the same felony conviction. As such, the Supreme Court reversed the District Court's decision and remanded the case for a new sentencing. The court did, however, uphold the District Court's decision to order Maggi’s sentences to run consecutively to all prior sentences but his Powell County matter DC-20-30.
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