Montana Supreme Court
State v. E. Adams
June 23, 20262026 MT 130
Summary
The Court affirmed Adams’s convictions for incest and sexual intercourse without consent, holding that the District Court did not abuse its discretion by admitting testimony from Adams’s other adopted daughter under Rule 403. The testimony was highly probative of motive, intent, and common scheme or plan because of its substantial similarities to the charged conduct, and the limiting instruction reduced the risk of unfair prejudice. The Court also rejected Adams’s ineffective-assistance claim because counsel was not required to request multiple limiting instructions and Adams failed to show a reasonable probability of a different result.