Skyler Griebel v. Sheriff Brad Bichler, Attorney General of the State of Montana

CourtDistrict Court, D. Montana
DecidedJanuary 7, 2026
Docket1:25-cv-00140
StatusUnknown

This text of Skyler Griebel v. Sheriff Brad Bichler, Attorney General of the State of Montana (Skyler Griebel v. Sheriff Brad Bichler, Attorney General of the State of Montana) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Skyler Griebel v. Sheriff Brad Bichler, Attorney General of the State of Montana, (D. Mont. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA BILLINGS DIVISION SKYLER GRIEBEL, Cause No. CV 25-140-BLG-DWM Petitioner, vs. ORDER SHERIFF BRAD BICHLER, ATTORNEY GENERAL OF THE STATE OF MONTANA, Respondents.

Petitioner Skyler Griebel (“Griebel”), a state pro se prisoner, filed a petition seeking a writ of habeas corpus pursuant to 28 U.S.C. § 2254 and brief in support. (Docs. 1 & 2.) Griebel subsequently filed a supplement to his petition. (Doc. 3.) The Court is required to screen all actions brought by prisoners who seek relief. 28 U.S.C. § 1915(a). The Court must dismiss a habeas petition or portion

thereof if the prisoner raises claims that are legally frivolous or fails to state a basis upon which relief may be granted. 28 U.S.C. § 1915A(b)(1), (2). The Court must dismiss a habeas petition “[i]f it plainly appears from the petition and any attached exhibits that the petitioner is not entitled to relief.” Rule 4 Governing Section 2254 Cases.

Background This is Griebel’s third habeas petition challenging the Deliberate Homicide charge filed against him in Montana’s Sixth Judicial District, Park County. The

first two petitions Griebel filed as a pretrial detainee, he now stands convicted. The procedural history of his criminal matter has been discussed at length in prior orders but will briefly be summarized herein. Griebel was originally arrested and charged with Deliberate Homicide in

February of 2022. In his initial federal petition, he alleged : (1) the State of Montana denied him an evidentiary hearing, pursuant to Franks v. Delaware, 438 U.S. 154 (1978), in contravention of clearly established federal law; and (2) the

Montana Supreme Court unlawfully denied his motion to disqualify the trial judge following the judge’s public reprimand and thirty-day suspension by the Judicial Standards Commission. This petition was filed while Griebel was awaiting trial. Judge Watters considered Griebel’s petition and determined that all of the factors

set forth in the abstention doctrine of Younger v. Harris, 401 U.S. 37 (1971), were met, precluding this Court’s review. See, Griebel v. State, et al., Cause No. CV- 23-88-BLG-SPW, Or. at 7-9 (D. Mont. Aug. 7, 2023). Further, Judge Watters

determined there was no extraordinary circumstance that would warrant this Court’s intervention in Griebel’s ongoing state proceedings. (Id. at 8-9.) The matter was dismissed.

Griebel’s underlying state case was vigorously litigated and the parties engaged in heavy pretrial motion practice, including Griebel’s challenge to a purported denial of his right to a speedy trial. See e.g., State v. Griebel, 2024 MT

295N, ¶¶4-14, 2024 WL 5055583. Following a hearing on the speedy trial motion, the district court found that Griebel’s speedy trial right had been violated and granted Griebel’s motion to dismiss. The State appealed. The Montana Supreme Court considered each of the

balancing factors set out in State v. Ariegwe: (1) the length of the delay; (2) the reasons for the delay; (3) the accused’s response to the delay; and (4) prejudice to the accused. Griebel, at ¶17, citing Ariegwe, 2007 MT 204, ¶¶106-111, 228 Mont.

442, 167 P. 3d 815. The Court found that the first factor weighed significantly against the State because the 619-day delay in Griebel’s trial greatly exceeded the 200-day threshold. Griebel, at ¶¶18-19. The second factor weighed lightly against the State, as each delay that occurred was institutional in nature. Id. at ¶¶22-29.

Similarly, the fourth factor weighted lightly against the State. While there was a loss of some witnesses and diminished memory of others, Griebel took no steps to mitigate the prejudice to his case. Id. at ¶¶34-41. Importantly, the Court weighed the third factor heavily against Griebel. It found that he engaged in extensive motion practice that had dubious legal merit

and was largely repetitive in nature. Particularly, two motions to dismiss were denied, as were writs of supervisory control, in addition to Griebel’s federal habeas petition. Id. at ¶31. Griebel’s “clear disinterest in bringing his case to trial,

expressed by both his actions and his counsel’s words” considerably diminished the weight of the other three factors. The Court determined Griebel was not deprived of his right to a speedy trial. Id. at ¶41. The lower court’s dismissal was reversed, and the matter was remanded for further proceedings.

While Griebel was awaiting his October 20, 2025, trial date, he filed a second federal habeas petition, pursuant to 28 U.S.C. § 2241. See, Griebel v. Bilcher, Cause No. 25-CV-44-BLG-DWM, Pet. (filed April 4, 2024.)

See, (Doc. 14-109.) Although Griebel was represented by counsel in the criminal matter, he filed his petition pro se. There, Griebel alleged: (1) his Sixth Amendment right to a speedy trial was violated in his state criminal proceedings; (2) the State violated his right to due

process by failing to turn over discovery, destroying evidence, and the losing witnesses; and (3) the Montana Supreme Court’s decision reversing the dismissal of his case via a non-cite opinion demonstrated bad faith and harassment. Griebel asked this Court to reverse and remand the Montana Supreme Court’s decision with instructions to uphold the district court’s original dismissal. (Id.)

The State was directed to respond and argued that Griebel’s second and third claims were not cognizable and that abstention under the rule of Younger v. Harris was appropriate. See, Griebel v. Bilcher, Cause No. 25-CV-44-BLG-DWM, Ans.

(filed June 13, 2024.) The State also contended that Griebel’s right to a speedy trial was not violated. It was determined that Griebel was still in the midst of a “single criminal prosecution” and that consideration of his petition was barred by Younger and its

progeny. Griebel v. Bilcher, Cause No. 25-CV-44-BLG-DWM, Ord. at 5-6 (D. Mont. Oct. 1, 2025.) Because all of the Younger factors were met and there was no clear demonstration of bad faith, or irreparable injury by the state, review of

Griebel’s Section 2241 was precluded. (Id. at 6-8.) The matter was dismissed. Griebel’s Claims In the instant petition, Griebel asserts again that his right to a speedy trial was violated, and the Montana Supreme Court erred in its decision reversing the

district court. (Doc. 1 at 4.) In his supplement, Griebel alleges the State changed the theory of their speedy trial argument on appeal, thus, unjustly presenting a new legal argument. (Doc. 3.) Griebel asks that the Montana Supreme Court’s order

finding no speedy trial violation occurred be reversed. Analysis On October 20, 2025, a jury convicted of Griebel of Deliberate Homicide.

He is scheduled to be sentenced on January 23, 2026. Following his conviction, Griebel’s attorneys filed several post-trial motions including, a motion for a new trial and/or to change the verdict, and supplemental filings in support. See

generally, Register of Action, State v. Griebel, Cause No. DC-22-33.1 It appears that a speedy trial issue is one of the claims that defense counsel is advancing in the motion for a new trial. A review of Griebel’s petition reveals his belief that it would be appropriate

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Picard v. Connor
404 U.S. 270 (Supreme Court, 1971)
Franks v. Delaware
438 U.S. 154 (Supreme Court, 1978)
Rose v. Lundy
455 U.S. 509 (Supreme Court, 1982)
Gray v. Netherland
518 U.S. 152 (Supreme Court, 1996)
O'Sullivan v. Boerckel
526 U.S. 838 (Supreme Court, 1999)
Slack v. McDaniel
529 U.S. 473 (Supreme Court, 2000)
Miller-El v. Cockrell
537 U.S. 322 (Supreme Court, 2003)
Baldwin v. Reese
541 U.S. 27 (Supreme Court, 2004)
Rasul v. Bush
542 U.S. 466 (Supreme Court, 2004)
Burton v. Stewart
549 U.S. 147 (Supreme Court, 2007)
Joel White v. John Lambert, Superintendent
370 F.3d 1002 (Ninth Circuit, 2004)
Masters v. Davis Logging
743 P.2d 104 (Montana Supreme Court, 1987)
State v. Ariegwe
2007 MT 204 (Montana Supreme Court, 2007)
Davis v. Silva
511 F.3d 1005 (Ninth Circuit, 2008)
State v. S. Griebel
2024 MT 295N (Montana Supreme Court, 2024)

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Bluebook (online)
Skyler Griebel v. Sheriff Brad Bichler, Attorney General of the State of Montana, Counsel Stack Legal Research, https://law.counselstack.com/opinion/skyler-griebel-v-sheriff-brad-bichler-attorney-general-of-the-state-of-mtd-2026.