Justia Montana Supreme Court Opinion Summaries

Plaintiffs sought a declaratory ruling that Mont. Code Ann. 13-35-227(1) violated their constitutional rights to free speech by prohibiting political expenditures by corporations on behalf of or opposing candidates for public office. Plaintiffs argued that the U.S. Supreme Court's decision in Citizens United v. FEC barred Montana from prohibiting independent and indirect corporate expenditures on political speech, and that Montana's century-old ban on independent corporate expenditures therefore was invalid. The district court granted ATP's motion for summary judgment on the merits of its constitutional claim, declared section 13-35-227(1) unconstitutional, and denied ATP's request for attorneys' fees. The Supreme Court reversed, concluding (1) the statute was constitutional; and (2) Plaintiffs' cross-appeal on the attorneys' fee issue, therefore, was moot. The Court's decision thereafter was reversed by the U.S. Supreme Court. The Montana Supreme Court then returned to ATP's cross-appeal on the issue of attorneys' fees and affirmed the district court's order declining to award attorneys' fees to Plaintiffs, holding that equitable considerations did not require the district court to award fees against the State under either the Uniform Declaratory Judgments Act or the private attorney general doctrine. View "W. Tradition P'ship, Inc. v. Attorney Gen." on Justia Law

Russell Sherman obtained loans for over $1,594,282 from the Whitefish Credit Union (WCU). Russell defaulted in paying the loans. WCU subsequently gave notice of default in a ten-day demand letter. Receiving no response from Russell or his wife, Joan, WCU waited an additional thirty days and then requested that the sheriff serve the Shermans. As it turned out, only Russell was served; Joan was not personally served with process. Russell failed to enter a timely appearance or answer WCU's complaint, and accordingly, the district court entered default judgment against the Shermans. Thereafter, the Shermans filed a motion to vacate and set aside the default judgment. The court denied the motion insofar as it applied to Russell but granted the motion insofar as it applied to Joan. Russell appealed. The Supreme Court affirmed, holding that the district court did not slightly abuse its discretion in denying Russell's motion to vacate and set aside the default judgment entered against him. View "Whitefish Credit Union v. Sherman" on Justia Law

Defendant pled guilty to felony arson for setting fire to a car and two dumpsters. After a sentencing hearing, the district court sentenced Defendant to a four-year suspended DOC commitment and required him to pay $1600 in restitution. It further imposed recommended probationary conditions, including that Defendant register as a violent offender and complete anger management classes and chemical dependency and mental health evaluations. Defendant challenged the sentencing condition requiring him to register as a violent offender. The Supreme Court affirmed, holding that the district court's sentencing condition requiring that Defendant register as a violent offender did not violate his constitutional right to privacy, as whatever limited expectation of privacy Defendant had as a violent offender in his whereabouts and residential information, the State's compelling interest in requiring that he register justified the enactment of the statute requiring registration. View "State v. Brooks" on Justia Law

Employee was injured while working for Employer. Because Employer failed to retain current worker's compensation insurance, Employee filed a claim with the Uninsured Employer's Fund, which the Fund accepted. The Fund sought indemnity from Employer for Employee's damages, and the parties agreed to an interim payment plan. However, the Fund ultimately turned Employer over to collection. Employer responded by suing the Fund for breach of contract. The district court granted Employer's summary judgment motion on the issue of whether the Fund had breached the repayment agreement. The district court then awarded damages to Employer in the amount of $198,749. The damages awarded largely centered on the court's implicit conclusion that the Fund's actions had interfered with Employer's ability to obtain financing, which, in turn, hurt Employer's sales. The Supreme Court affirmed, holding that the district court properly (1) determined Employer was entitled to summary judgment on the question of whether the Fund had breached the payment plan agreement; (2) determined Employer could receive consequential damages for the Fund's breach of contract; (3) denied the Fund's motion for post-trial relief; (3) calculated damages; and (4) denied Employer's damage claim for ten years of lost profits. View "Elk Mountain Motor Sports, Inc. v. Dep't of Labor & Indus." on Justia Law

Shortly after Defendant was charged with DUI, she notified the police department that she believed she had been given a "date rape" drug that caused her impairment. Before trial commenced, Defendant claimed she would assert the involuntary intoxication defense to show she did not commit a voluntary act by driving. The municipal court granted the City's motion to prevent Defendant from claiming involuntary intoxication as a defense and from calling witnesses about the use of "date rape" drugs in the City. The district court affirmed, concluding that involuntary intoxication can only be used where the mental state of the defendant is an element of the crime. Defendant appealed, contending that the lower court erred by failing to apply the voluntary act element of Montana's DUI statute. The Supreme Court reversed and remanded, holding (1) the lower court erred by precluding Defendant from raising automatism as an affirmative defense to the DUI charge; and (2) if Defendant was able to lay the proper foundation, she could elicit from certain law enforcement officers evidence regarding their personal knowledge, opinions, and statements regarding whether Defendant was unknowingly drugged, and voluntarily drove a vehicle. View "City of Missoula v. Paffhausen" on Justia Law

Plaintiff commenced an action in the district court seeking a preliminary injunction preventing Defendants, their neighbors, from crossing Plaintiff's land, or in the alternative, a declaratory judgment stating that Defendants did not have a prescriptive easement. The district court granted a prescriptive easement in Defendants' favor but limited the width of the easement to twenty feet. Defendants appealed. Plaintiff cross-appealed, arguing that the district court erred in granting summary judgment because genuine issues of material fact existed concerning whether Defendants' use was permissive, whether the prescriptive easement included residential and recreational uses, and the width of the prescriptive easement. The Supreme Court (1) affirmed the district court's grant of summary judgment on the existence of a prescriptive easement; (2) reversed and remanded the portion of the district court's judgment concluding that the prescriptive easement included residential and recreational uses; and (3) reversed and remanded the district court's decision to limit the width of the prescriptive easement to twenty feet for the purpose of trailing cattle. View "Brown & Brown of MT, Inc. v. Raty" on Justia Law

This appeal pertained to the location of a partially-constructed horse barn in a planned unit development (PUD). Plaintiffs were the owner of the barn, the owner's contractor, and FPR Properties. After it was notified that the barn did not comply with the regulations and covenants and must be removed, FPR submitted an application to modify the conditional use permit of the PUD development to bring the location of the barn into compliance. The planning and zoning commission affirmed the code compliance specialist's determination that the barn violated zoning regulations and applicable covenants. The commission also denied FPR's request to modify the conditional use permit for the PUD. On appeal, the district affirmed the commission's rulings and dismissed FDR's takings claim without conducting a trial. The Supreme Court affirmed, holding that the district court did not err in (1) affirming the commission's determination that the partially-constructed barn violated applicable zoning regulations and covenants and must be removed; (2) affirming the commission's denial of FPR's application to modify the PUD's conditional use permit; and (3) dismissing FPR's constitutional takings claim. View "Botz v. Bridger Canyon Planning & Zoning Comm'n" on Justia Law

Defendant was convicted of attempted sexual intercourse without consent, a felony. The district court sentenced Defendant to Montana State Prison for a term of fifteen years, with five suspended. The Supreme Court affirmed, holding (1) the court did not violate Defendant's right to due process by excluding evidence of alleged sexual conversations between the complainant and Defendant and photos of third parties allegedly sent by the complainant to Defendant on the basis that they were irrelevant or more prejudicial than probative under the rules of evidence; and (2) Defendant's claim of ineffective assistance of counsel was better examined within a postconviction relief proceeding. View "State v. Bishop" on Justia Law

The district court involuntarily committed and authorized the involuntary medication of thirty-year-old C.R. after it determined that he suffered from a mental disorder and that his condition met the statutory criteria for involuntary commitment to the Montana State Hospital. The Supreme Court affirmed, holding (1) the district court properly disregarded C.R.'s hearing testimony, as substantial evidence supported the court's findings that the testimony was unreliable; (2) the district court's failure to offer C.R. a court-appointed friend did not violate C.R.'s statutory or constitutional rights, as the appointment of a friend was not statutorily mandated; and (3) C.R. received effective assistance of counsel. View "In re C.R." on Justia Law

Katherine Beehler-Goodson was the mother of minor children E.G. and R.G., the wife of Plaintiff Robert Goodson, and the sister of Plaintiff Tony Beehler. While Katherine was undergoing a myelogram, bacteria were introduced into her cerebrospinal fluid, resulting in a meningitis infection, which caused her death. Plaintiffs filed a medical malpractice claim against Eastern Radiological Associates; Dr. Anne Giuliano, the radiologist who performed the myelogram; and St. Vincent Healthcare, alleging that Dr. Giuliano negligently failed to wear a mask during the myelogram, which resulted in bacteria traveling from Dr. Giuliano's uncovered mouth into Katherine's spinal column. The district court granted summary judgment for Defendants, finding (1) Plaintiff's proposed expert witness, Dr. Patrick Joseph, was not qualified to offer expert testimony on the applicable standards of care, breach, or causation; and (2) without Dr. Joseph's expert testimony, Plaintiffs lacked the necessary expert witness to establish the elements of medical negligence. The Supreme Court reversed and remanded, holding that the court abused its discretion by excluding Dr. Joseph's testimony on the applicable standards of care and causation. View "Beehler v. E. Radiological Assocs., P.C." on Justia Law