Justia Montana Supreme Court Opinion Summaries

Yellowstone River, LLC (YR) commenced an action against Meriwether Land Fund and Meriwether Land Company (collectively, Meriwether), seeking a determination that it had an easement to access its property over Meriwether's adjacent property. Through summary judgment proceedings, the issue was narrowed to the sole question of whether YR had an easement by necessity. The district court ruled that an easement by necessity did not exist over Meriwether's property for the benefit of YR's property. The Supreme Court affirmed, holding (1) the district court erred in concluding that unity of title did not exist in this case, but (2) the court nevertheless reached the correct result because the easement failed for several reasons related to the history of ownership of the land and the fact that granting an easement would be against public policy.

Mayson Simmons pleaded guilty to criminal distribution of dangerous drugs for providing medical marijuana to someone without a user card, distribution for providing oxycodone pills, and theft by insurance fraud. The district court sentenced Simmons to twenty years in prison with ten years suspended. Simmons appealed her sentence, arguing that the district court violated her right to due process by considering evidence of her behavior while incarcerated at the Ravalli County Detention Center (RCDC). The Supreme Court affirmed, holding that Simmons' due process rights were not violated when the district court referenced her negative behavior while at RCDC because (1) the court considered numerous pieces of evidence pertaining to Simmons' potential for rehabilitation and the severity of the crimes she committed, and (2) Simmons did not meet her burden of showing the sentencing court relief on materially false allegations in forming the sentence.

CLR Properties and Choice Land Corporation (collectively, CLR) hired Waynco Construction (Waynco) as the general contractor for a commercial real estate improvement project. Waynco solicited a bid from AAA Construction of Missoula (AAA) to perform concrete work. After AAA submitted its bid, Waynco used AAA's bid to formulate Waynco's general contract bid to CLR. CLR accepted Waynco's bid. While AAA completed a majority of the work outlined in its bid by the time it left the project, a dispute arose between Waynco and AAA about the parties' subcontract agreement. Waynco eventually failed to pay AAA for any labor or materials. AAA filed a complaint against CLR and Waynco, alleging that Waynco had breached the contract and CLR had been unjustly enriched from AAA's work. The district court granted CLR's motion for summary judgment on the unjust enrichment claims and, after a trial, held for AAA. The Supreme Court affirmed, holding (1) the district court properly concluded that AAA's bid constituted a binding contract between the parties; (2) substantial evidence supported the district court's conclusion that Waynco was the materially breaching party; and (3) the district court properly denied CLR's claim for attorney fees.

Plaintiff Walter Fasch was injured in a single-vehicle ATV accident that occurred within a construction area on a U.S. highway. Fasch filed a negligence action against the Montana Department of Transportation, the construction contractor, and the subcontractor (collectively, Defendants). The district court entered findings of fact, conclusions of law, and an order granting summary judgment in favor of Defendants, concluding that Defendants owed no duty to Fasch because Fasch was an unforeseeable plaintiff who was not in the zone of risk. The Supreme Court reversed, concluding that reasonable minds could differ as to the resolution of certain factual issues, that the factual issues should be resolved by trial, and that resolution of the factual issues would also affect the determination of the legal issue of duty.

This was an original proceeding brought to the Supreme Court on a certified question from a bankruptcy judge from the District of Montana. The question of law was whether, under Montana's liberal construction of exemptions, debtors may claim an exemption in a Yamaha four-wheel all-terrain vehicle (ATV) as a sporting good pursuant to Mont. Code Ann. 25-13-609(1). The Supreme Court accepted the certified question and answered that, under Montana law, debtors may not claim an exemption in a Yamaha four-wheel ATV as a sporting good because (1) an ATV is motor vehicle under Montana's motor vehicle code, (2) an ATV is subject to registration and title requirements that do not apply to firearms and sporting goods, and (3) since the Legislature provided a specific and separate exemption for a motor vehicle, it follows that the exemption for firearms and other sporting goods was not intended to include motor vehicles.

Alicia Hocter was caring for a six-month-old when she swung the child's head into the top bar of her crib and failed to seek medical attention for the child. Hocter pled guilty to charges of aggravated assault and criminal endangerment, after which she withdrew her guilty plea. A jury found Hocter guilty of both charges. The Supreme Court affirmed, holding (1) the district court did not err when it denied Hocter's motion to dismiss the charge of criminal endangerment as Hocter had actual notice of the facts that the State was obligated to prove to support its theories of criminal endangerment; and (2) the district court did not err in instructing the jury on criminal endangerment predicated on a defendant's omission or failure to act as the instructions properly required the jury to determine whether Hocter breached that duty.

Patrick Chesterfield was convicted in district court of driving or being in actual physical control of a motor vehicle while under the influence of alcohol or drugs (DUI), his fourth offense. Chesterfield appealed, arguing that the district court erred by denying his motion to dismiss without holding an evidentiary hearing concerning his claim that his three prior convictions for DUI were constitutionally infirm because he was denied his right to counsel. The Supreme Court affirmed, holding that Chesterfield failed in his burdens of production and persuasion to demonstrate that his three prior DUI convictions were constitutionally infirm, and accordingly, the district court did not err by denying Chesterfield's motion to dismiss.

Shannon and Travis Johnson married, after which Shannon gave birth. Travis was named on the birth certificate as Child's father. Later DNA tests revealed Justin Walak was actually Child's father. When Shannon and Travis filed for dissolution of their marriage, Walak intervened, seeking a judicial establishment of a parental relationship with Child. Shannon and Travis then reconciled and sought to exclude Walak from establishing a relationship with Child. The district court issued an order (Order I) concluding it was not in Child's best interests to establish a parental relationship with Walak. Subsequently, Walak filed a motion challenging the court's factual findings and order. The district court then issued an order vacating Order I (Order II), which granted Walak parental rights. The Supreme Court reversed, holding that the district court abused its discretion in granting Walak's posttrial motion and vacating its earlier order as it had no statutory or other authority to vacate Order I, change its legal conclusions, and issue a wholly contrary Order II.

Ed Chamberlin filed for divorce from Trina Chamberlin. The district court entered a decree of dissolution that (1) awarded the couple's house and property to Ed without counting a loan from Ed's father as a liability against the house, (2) awarded Trina's car to her, (3) awarded primary custody of the couple's child to Trina, and (4) allocated parenting time to Ed. The Supreme Court affirmed, holding (1) the district court equitably divided the marital estate, (2) the district court properly awarded Trina primary parenting of the parties' minor child, and (3) because Ed's appeal did not rise to the level of lacking good faith, Trina's request for attorney fees and costs was denied.

Leslie Staebler was convicted by a jury in municipal court of misdemeanor driving while intoxicated and violation of the seatbelt law. The district court affirmed, holding that Staebler's fundamental right to a fair trial was not violated. The Supreme Court affirmed but on different grounds, holding that the district court did not err in affirming the municipal court where (1) the City attorney did not unfairly imply that Staebler's conduct was worse than it actually was; (2) comments of one juror did not inflame or prejudice other members of the jury against Staebler; (3) the City attorney did not err during rebuttal to Staebler's closing argument when she inferred that because Staebler was not able to brake appropriately for oncoming traffic, he would not have been able to brake properly had a child been playing in the road; and (4) the evidence was sufficient to support Staebler's conviction.