City of Helena v. Frankforter

Justice Laurie McKinnon delivered the Opinion of the Court.

***278¶ 1 Ryan Scot Frankforter appeals a decision of the First Judicial District Court, Lewis and Clark County, affirming two convictions of partner or family member assault (PFMA) from Helena Municipal Court. We reverse one PFMA conviction and clarify our jurisprudence regarding jurisdiction and venue in criminal cases, addressing the following issues:

1. Does a defendant waive his right to object to the county in which a charge is filed if he fails to object before the first witness is sworn at trial?

2. Does a defendant waive his…