Supreme Court Overturns Sentencing in Whitefish Arson Case

James Wallace Langley was sentenced to 10 years with the Department of Corrections for arson last year

By Justin Franz

The Montana Supreme Court has overturned the sentencing for a Whitefish man accused of setting his ex-girlfriend’s house on fire.

In the ruling issued on March 22, the high court overturned James Wallace Langley’s commitment to the Department of Corrections because Flathead County District Court Judge Robert Allison did not allow the man to withdraw his plea before sentencing last year.

The district court will now have to hold another sentencing hearing.

Langley was sentenced to 10 years with the Department of Corrections with five years suspended on charges of felony arson stemming from a 2013 fire in Whitefish.

According to court documents, the Whitefish Fire Department responded to an early morning house fire on Oct. 8, 2013 on Highland Drive. One of the residents told police they had woken up after seeing a flash outside their window. The man looked outside and saw an oil can and the siding of the house on fire. The man was able to get the fire out but later discovered it was not extinguished when he noticed smoke coming from the light fixtures.

The homeowners told detectives that they believed their daughter’s ex-boyfriend, Langley, had set the fire. Langley denied the allegations and let police take a DNA sample from him. Later, Langley admitted that he was at the victims’ house early Oct. 8. The DNA evidence Langley voluntarily gave later connected him to the oil can and he was charged with arson on Feb. 3, 2014.

In January 2015, attorney Jack Quatman and prosecutors crafted a deal in which Langley would enter a plea of no contest and the state would recommend a six-year deferred sentence. Langley entered his plea in front of Judge Allison on Jan. 22. A no-contest plea is entered when defendants acknowledge that prosecutors have enough evidence to convict them but still maintain that they are innocent.

At the initial sentencing hearing, however, Judge Allison told Langley and his attorney that he would not follow the plea agreement because of the seriousness of the crime. Allison said he would give the defendant more time to come up with testimony as to why he should be given a deferred sentence and the sentencing was postponed.

On April 20, Langley filed a motion to withdraw his plea. In the motion, Quatman argued that Allison displayed a bias when he likened lighting someone’s house on fire to firing randomly into a home with an assault rifle and that it was clear he has “very strong personal feelings concerning arson.” Judge Allison later denied Langley’s motion to withdraw. On June 11, Langley was sentenced to the Department of Corrections.

Exactly five months after his sentencing, on Nov. 11, attorney Colin Stephens filed an opening brief with the Montana Supreme Court requesting that Langley’s sentence be overturned and that he be allowed to withdraw his no-contest plea. In it, he argued that Langley’s sentencing was illegal because the court violated the sentencing process as required in Montana Code Annotated.

In their ruling, justices Beth Baker, Mike McGrath, Patricia Cotter, James Jeremiah Shea and Michael Wheat agreed with Langley’s attorney and stated that Judge Allison did not properly follow the required procedures for rejecting a plea agreement.

“We reverse the District Court’s judgment and remand with instructions to conduct another sentencing hearing,” the five-judge panel wrote. “If the court accepts the plea agreement at that time, the court shall sentence Langley in accordance with the plea agreement. If the court rejects the plea agreement again, it must issue the full statutory advisement and give Langley the opportunity to withdraw his plea and proceed to trial.”

A new sentencing date has not been set.

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