State v. Lowry

2025 MT 222N
CourtMontana Supreme Court
DecidedSeptember 30, 2025
DocketDA 23-0725
StatusUnpublished

This text of 2025 MT 222N (State v. Lowry) is published on Counsel Stack Legal Research, covering Montana Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Lowry, 2025 MT 222N (Mo. 2025).

Opinion

09/30/2025

DA 23-0725 Case Number: DA 23-0725

IN THE SUPREME COURT OF THE STATE OF MONTANA

2025 MT 222N

STATE OF MONTANA,

Plaintiff and Appellee,

v.

BOBBY FRANCIS LOWRY,

Defendant and Appellant.

APPEAL FROM: District Court of the First Judicial District, In and For the County of Lewis and Clark, Cause No. BDC 2022-131 Honorable Michael F. McMahon, Presiding Judge

COUNSEL OF RECORD:

For Appellant:

James Murnion, Murnion Law, Missoula, Montana

For Appellee:

Austin Knudsen, Montana Attorney General, Selene Koepke, Assistant Attorney General, Helena, Montana

Kevin Downs, Lewis and Clark County Attorney, Ann Beth Penner, Deputy County Attorney, Helena, Montana

Submitted on Briefs: August 20, 2025

Decided: September 30, 2025

Filed:

__________________________________________ Clerk Justice Laurie McKinnon delivered the Opinion of the Court.

¶1 Pursuant to Section I, Paragraph 3(c), Montana Supreme Court Internal Operating

Rules, this case is decided by memorandum opinion and shall not be cited and does not

serve as precedent. Its case title, cause number, and disposition shall be included in this

Court’s quarterly list of noncitable cases published in the Pacific Reporter and Montana

Reports.

¶2 Bobby Francis Lowry (Lowry) appeals from the August 14, 2023 Order of the First

Judicial District Court, Lewis and Clark County, denying his motion to dismiss for lack of

speedy trial. He additionally asserts his right to a fair and impartial trial were violated by

comments made in the prosecution’s closing argument. We affirm.

¶3 Lowry assaulted his wife, L.L., on October 6, 2020. L.L. disclosed the assault to

law enforcement over one year later. The State charged Lowry with Partner or Family

Member Assault (PFMA) under § 45-5-206(1)(a), MCA, on March 25, 2022. Lowry made

his initial appearance in Justice Court on the PFMA charge on March 7, 20221. Lowry

failed to appear at his arraignment on March 29, 2022. The first trial date was set for

September 26, 2022. Lowry’s public defender moved to withdraw as counsel on July 28,

2022, after discovering a conflict. Lowry was subsequently assigned new counsel on

August 31, 2022, and trial was continued to March 13, 2023. Lowry filed a motion to

continue trial set for March 13, 2023, requesting an additional three months to consult with

counsel and obtain more evidence from the State. The District Court granted the motion

1 The speedy trial clock begins once the defendant is accused. State v. Ariegwe, 2007 MT 204, ¶ 113, 338 Mont. 442, 167 P.3d 815. 2 and reset trial for August 28, 2023. Following his motion to continue, Lowry filed a waiver

of speedy trial on March 6, 2023. Lowry filed his motion to dismiss for lack of speedy

trial on August 9, 2023, alleging he endured prejudice due to lost video evidence along

with stress and anxiety from the case. A total of 539 days elapsed from Lowry’s initial

appearance on March 7, 2022, to his final trial date of August 28, 2023.

¶4 The District Court denied the motion to dismiss for lack of speedy trial and a

two-day trial commenced on August 28, 2023. In the State’s rebuttal closing, the

prosecutor stated, “[Lowry] is guilty, in the State’s eyes, of partner/family member assault.

Please find him guilty.” The jury found Lowry guilty on August 29, 2023. He was

sentenced the same day to the Montana State Prison for five years.

¶5 On appeal, Lowry argues the Court should conclude his right to a speedy trial was

violated and dismiss his PFMA charge. Alternatively, Lowry argues the Court should

exercise plain error review of the alleged prosecutorial misconduct and grant him a new

trial.

Lowry’s Speedy Trial Claim

¶6 We turn first to Lowry’s argument that he was denied his right to a speedy trial.

¶7 “A criminal defendant’s right to a speedy trial is a fundamental constitutional right

guaranteed by the Sixth and Fourteenth Amendments to the United States Constitution and

Article II, Section 24 of the Montana Constitution.” State v. Zimmerman, 2014 MT 173,

¶ 12, 375 Mont. 374, 328 P.3d 1132 (citing State v. Ariegwe, 2007 MT 204, ¶ 20, 338

Mont. 442,167 P.3d 815; State v. Stops, 2013 MT 131, ¶ 18, 370 Mont. 226, 301 P.3d 811).

Whether a speedy trial violation occurred is a question of constitutional law. Ariegwe,

3 ¶ 119 (citing City of Billings v. Bruce, 1998 MT 186, ¶ 18, 290 Mont. 148, 965 P.2d 866;

State v. Spang, 2007 MT 54, ¶ 7, 336 Mont. 184, 153 P.3d 646). A trial court’s conclusions

of law are reviewed de novo “to determine whether the court’s interpretation and

application of the law are correct.” Ariegwe, ¶ 119 (citing Bruce, ¶ 18; Spang, ¶¶ 7, 32).

Factual findings underlying a speedy trial analysis are reviewed for clear error. Ariegwe,

¶ 119 (citing Spang, ¶ 7).

¶8 A balancing test is used to determine whether a violation of the right has occurred.

Zimmerman, ¶ 12. Four factors are taken “into consideration: (1) the length of the delay,

(2) the reasons for the delay, (3) the accused’s responses to the delay, and (4) prejudice to

the accused as a result of the delay.” Zimmerman, ¶ 12. A single factor is not dispositive

and each factor must be considered in light of other circumstances. Zimmerman, ¶ 12

(citing Ariegwe, ¶ 112).

Factor One: The Length of the Delay

¶9 The District Court calculated that there was a 4-day overage of the 200-day speedy

trial threshold. The District Court only identified the first delay between Lowry’s initial

appearance and first trial date reasoning that Lowry was responsible for any subsequent

delay. However, a speedy trial analysis requires a court to assess the entire period of time

between the day a defendant is accused to the defendant’s trial date. Ariegwe, ¶ 113.

Although the District Court erred in its calculation of the length of delay, we agree that the

speedy trial clock was triggered.

¶10 “[T]he presumption that pretrial delay has prejudiced the accused exists as of the

200-day trigger date for speedy trial analysis.” Ariegwe, ¶¶ 56, 113. The presumption of

4 prejudice escalates over time. Ariegwe, ¶¶ 56, 113. A long delay weighs heavily against

the State absent a showing of no prejudice against the accused. State v. Flynn, 2024 MT

236, ¶ 26, 418 Mont. 331, 557 P.3d 934 (citing Ariegwe, ¶¶ 56, 113). Under factor one,

the second inquiry is “the extent to which the delay stretches beyond the trigger date.”

Ariegwe, ¶ 38.

¶11 We must first determine whether the time between Lowry’s initial appearance and

the scheduled trial date is over the 200-day threshold, which triggers a speedy trial analysis.

Ariegwe, ¶ 121. Lowry initially appeared on March 7, 2022. Lowry’s first trial date was

set for September 26, 2022. The District Court determined this amount to be 204 days.

Although 204 days triggers a speedy trial analysis, the District Court conflated the length

of delay with factor two, the reasons for delay.

¶12 Here, Lowry and the State agree that the time began running with Lowry’s initial

appearance on March 7, 2022. Lowry’s final date for trial was set for August 28, 2023, a

total delay of 539 days, 339 days beyond the 200-day threshold. Accordingly, the speedy

trial analysis is triggered by this 339-day delay.

Factor Two: Reasons for Delay

¶13 Under factor two, the Court must identify “each period of delay in bringing the

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Related

Smith v. Hooey
393 U.S. 374 (Supreme Court, 1969)
United States v. Lovasco
431 U.S. 783 (Supreme Court, 1977)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
State v. Stops
2013 MT 131 (Montana Supreme Court, 2013)
State v. Musgrove
582 P.2d 1246 (Montana Supreme Court, 1978)
State v. Campbell
787 P.2d 329 (Montana Supreme Court, 1990)
State v. Stringer
897 P.2d 1063 (Montana Supreme Court, 1995)
City of Billings v. Bruce
1998 MT 186 (Montana Supreme Court, 1998)
State v. Highpine
2000 MT 368 (Montana Supreme Court, 2000)
State v. Martin
2001 MT 83 (Montana Supreme Court, 2001)
State v. Blair
2004 MT 356 (Montana Supreme Court, 2004)
State v. Roubideaux
2005 MT 324 (Montana Supreme Court, 2005)
State v. Ariegwe
2007 MT 204 (Montana Supreme Court, 2007)
State v. LaGree
2007 MT 65 (Montana Supreme Court, 2007)
State v. Spang
2007 MT 54 (Montana Supreme Court, 2007)
State v. Jeremiah Green
2009 MT 114 (Montana Supreme Court, 2009)
State v. G. Makarchuk
2009 MT 82 (Montana Supreme Court, 2009)
State v. Lacey
2009 MT 62 (Montana Supreme Court, 2009)
State v. Rose
2009 MT 4 (Montana Supreme Court, 2009)
State v. Couture
2010 MT 201 (Montana Supreme Court, 2010)

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2025 MT 222N, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lowry-mont-2025.