State v. Snyder

── State v. Snyder ── Court: Montana Supreme Court Date: May 12, 2026 Category: Direct Appeal 05/12/2026 DA 23-0576 Case Number: DA 23-0576 IN THE SUPREME COURT OF THE STATE OF MONTANA 2026 MT 103N STATE OF MONTANA, Plaintiff and Appellee, v. TYLER THOMAS SNYDER, Defendant and Appellant. APPEAL FROM: District Court of the Eighth Judicial District, In and For the County of Cascade, Cause No. DDC-22-047 Honorable John Parker, Presiding Judge COUNSEL OF RECORD: For Appellant: Tammy A. Hinderman, Appellate Defender Division Administrator, Jeavon C. Lang, Managing Appellate Defender, Helena, Montana For Appellee: Austin Knudsen, Montana Attorney General, Christine Hutchison, Assistant Attorney General, Helena, Montana Joshua A. Racki, Cascade County Attorney, Stephanie Fuller, Deputy Count Attorney, Great Falls, Montana Submitted on Briefs: April 15, 2026 Decided: May 12, 2026 Filed: __________________________________________ Clerk Justice Katherine M. Bidegaray 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 Tyler Thomas Snyder appeals his August 2023 judgment and sentence in the Montana Eighth Judicial District Court, Cascade County. First, Snyder contends that the court committed reversible plain error in accepting his May 2023 guilty pleas on the offenses of DUI and felony criminal possession of dangerous drugs without a sufficient factual basis to do so. Next, Snyder contends that the court illegally sentenced him under § 61-8-1007(1)(a)(ii), MCA, because his 2009 DUI conviction was not a previous conviction for sentencing purposes under § 61-8-1011(1)(b), MCA. ¶3 We hold that Snyder has not shown reversible error in the District Court’s acceptance of his guilty pleas. Even assuming Snyder’s unpreserved factual-basis challenge is reviewable under the plain error doctrine despite his failure to move to withdraw his pleas, Snyder’s admissions, considered as a whole, supplied a factual basis under § 46-12-212(1), MCA. We further hold that, because Snyder’s 2009 DUI was more than ten years old at the time of his 2022 offense, the District Court was not authorized to sentence him under § 61-8-1007(1)(a)(ii), MCA. Accordingly, we affirm Snyder’s sentence on criminal possession of dangerous drugs, vacate the DUI sentence, and remand 2 for entry of an amended judgment and lawful DUI sentence in accordance with this Opinion. ¶4 In January 2022, the State charged Snyder by information with one count felony criminal possession of dangerous drugs, § 45-9-102, MCA; one count misdemeanor criminal possession of drug paraphernalia, § 45-10-103, MCA; one count misdemeanor driving without vehicle insurance, § 61-6-301, MCA; and one count DUI (second offense), § 61-8-1002(1)(a), MCA. As pertinent, the underlying probable cause affidavit alleged that, on January 22, 2022, a Montana Highway Patrol trooper stopped to assist Snyder, who was standing next to his vehicle which was broken down alongside Highway 89. The officer observed that Snyder’s pupils were restricted, the whites of his eyes were yellow, and, in plain view, three loaded syringes sat on the dashboard conta