Justia Montana Supreme Court Opinion Summaries

By decree of the district court, the marriage of Husband and Wife was dissolved. The decree also divided the marital estate. Husband appealed, challenging various aspects of the property division. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) did not err in valuing the estate as of 2009 instead of 2002, when the parties separated; (2) did not err in its valuation of businesses owned or partly owned by Husband; (3) erred by failing to award Husband an offset credit for thousands of dollars paid to Wife between 2002 and 2009; and (4) erred by ordering that Husband pay $1.259 million equalization payment to Wife without providing a method of payment. Remanded for adoption of a reasonable payment plan for payment of the large equalization payment. View "Schwartz v. Harris" on Justia Law

After a jury trial, Defendant was found guilty of one count of deliberate homicide and one count of aggravated assault. The Supreme Court affirmed, holding (1) the district court did not err by excluding evidence of justifiable use of force as a defense to the charge of deliberate homicide; and (2) the Court declined to exercise plain error review of Defendant's claims that the district court erred by excluding evidence of the victim's prior mental health history, suicide attempts, and cutting behavior, and that this exclusion violated Defendant's Sixth Amendment right to compulsory process and confrontation and Fourteenth Amendment right to due process. View "State v. King" on Justia Law

Plaintiffs leased an apartment from Defendant for thirteen months. Before the lease term expired, a dispute arose between the parties. Plaintiffs subsequently filed a complaint against Defendant, alleging breach of the terms of the lease, negligence, and negligence per se. The justice court found in favor of Plaintiffs. Defendant appealed, seeing a trial de novo. After a bench trial, the district court ruled in Plaintiffs' favor on their breach of lease claim and awarded them damages, costs, and attorney's fees. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it allowed Plaintiffs to amend their complaint to add a claim that had not been pled during the justice court proceedings; (2) the district court did not abuse its discretion when it denied Defendant's motion in limine to prohibit any reference to the testimony and evidence presented during the justice court proceedings; and (3) because the district court's references to the prior proceedings did not suggest that the district court was unduly influenced by the justice court proceedings, Defendant was not denied her right to a trial de novo. View "McDunn v. Arnold" on Justia Law

After a hearing, the district court determined that S.C. should be committed involuntarily to Montana State Hospital (MSH). The State later conditionally released S.C. from MSH. The State then filed an untimely petition to extend S.C.'s conditional release, which the district court granted. The State subsequently filed a second untimely petition to extend S.C.'s conditional release, which the district court also granted. Thereafter, the State filed a third untimely petition to extend S.C.'s conditional release. S.C. objected, arguing that the State's third petition to extend his commitment period failed to comply with the timeliness requirements of Mont. Code Ann. 53-21-198. The district court granted the State's petition. The Supreme Court reversed, holding (1) the expiration of S.C.'s commitment period before the State's first petition to extend S.C.'s conditional release left the district court without jurisdiction; and (2) consequently, the district court was without authority to extend the period of S.C.'s conditions of release when the State filed the second and third petitions. View "In re S.C." on Justia Law

Paula Ehrmantraut-Kiosee sought tax deductions for educational expenses incurred in pursuit of a doctoral degree in psychology. The Montana Department of Revenue disallowed the deductions sought by Paula individually in 2007, and jointly with Randy Myrup in 2008 and 2009. The Office of Dispute Resolution affirmed the disallowance, and the State Tax Appeal Board (STAB) upheld the disallowance. The district court denied Taxpayers' petition for judicial review. After noting that educational expenses will be deemed nondeductible as qualification for a new trade or business if the education is a step towards obtaining a certification that, once obtained, would qualify the taxpayer to perform tasks significantly different from those the taxpayer performed before receiving the education, the Supreme Court affirmed, holding (1) the findings of STAB and the district court that Paula pursued her education in an effort to become a clinical psychologist, rather than simply to improve her skills as a counselor, were supported by substantial evidence; and (2) therefore, Taxpayers failed to demonstrate that the educational expenses were deductible under either 26 C.F.R. 1.162-5(a)(1) or (2). View "Myrup v. State, Dep't of Revenue" on Justia Law

Petitioner served two terms as a Public Service Commissioner (PSC). While serving his first term at the PSC, Respondent, campaign manager for Petitioner's opponent in the upcoming election, filed four complaints against Petitioner with the Commissioner of Political Practices (Commissioner), alleging that Petitioner had violated the statutory Code of Ethics by accepting gifts of substantial value from two corporations with which the PSC regularly dealt and by using state resources to aid his reelection campaign and for personal business. Following a three-day hearing on Respondent's complaints, a hearing examiner determined that Petitioner violated Mont. Code Ann. 2-2-104 two times by receiving "gifts of substantial value" and violated Mont. Code Ann. 2-2-121 five times by using state facilities and equipment for election purposes. The Commissioner affirmed, ordering Petitioner to pay $5,750 in fines and $14,945 for the costs of the hearing. The district court affirmed. The Supreme Court affirmed, holding that the district court did not err by concluding (1) Respondent had legal standing to file ethics complaints against Petitioner; (2) Petitioner received unlawful gifts; (3) Petitioner improperly used State facilities for political purposes; and (4) the penalty statute for ethics violations was not unconstitutionally vague. View "Molnar v. Fox" on Justia Law

Mother was an enrolled member of the Chippewa Cree Tribe. Her two minor children both qualified as Indian children under the Indian Child Welfare Act (ICWA). After the Department of Public Health and Human Services was granted temporary legal custody of the children, the county attorney filed a petition requesting termination of Mother's parental rights due to failure to comply with a court-ordered treatment plan. At the conclusion of the hearing, the district court terminated Mother's parental rights. Mother appealed, alleging that the court terminated her parental rights without following the requirements of the ICWA. The Supreme Court reversed and remanded for a new termination hearing, holding that the termination proceedings did not comply with the mandates of ICWA and its parallel state provisions. View "In re K.B." on Justia Law

Following a jury trial, Defendant was convicted of felony DUI. The trial was held after several delays. Defendant was sentenced as a persistent felony offender to twenty years imprisonment with ten years suspended and ordered to pay restitution. Defendant appealed the district court's denial of his motion to dismiss based on an alleged violation of his speedy trial rights. The Supreme Court affirmed, holding that the district court (1) provided sufficient findings of fact and conclusions of law to enable appellate review of Defendant's speedy trial arguments; and (2) did not err in concluding that Defendant's speedy trial rights had not been violated under the circumstances. View "State v. Stops" on Justia Law

After a jury trial in 1984, Defendant was convicted of deliberate homicide and sentenced to 100 years imprisonment without the possibility of parole. In 2008, Defendant filed a second petition for postconviction relief, alleging that newly discovered evidence proved his actual innocence. The district court held a three-day hearing and took testimony from witnesses that suggested a group of teenage girls had killed the victim. The district court subsequently concluded that Defendant had presented sufficient evidence of his "actual innocence" to warrant a new trial. The Supreme Court reversed and dismissed Defendant's petition for postconviction relief, holding that the district court erred by concluding that Defendant was entitled to a new trial, as, applying the proper standard of review to the new evidence offered by Defendant, Defendant failed to sustain his burden of demonstrating either a freestanding claim or a gateway claim of "actual innocence." View "State v. Beach" on Justia Law

Mother and Father were divorced pursuant to a decree of dissolution entered in 1995. The decree required Father to pay child support until the parties' daughter "reaches majority, graduates from high school or is otherwise emancipated." Father paid child support of $6,977 per month for over ten years, until the daughter's eighteenth birthday. In 2012, Mother filed a petition seeking additional child support payments for the period between their daughter's eighteenth birthday in November 2006 and her graduation in July 2007. The district court granted the petition, concluding that Father's child support obligation did not terminate until the daughter graduated from high school. The Supreme Court affirmed, holding (1) since the decree of dissolution did not expressly provide the termination date for child support payments, Mont. Code Ann. 40-4-208(5) controlled and provided for a termination date upon the daughter's graduation from high school; and (2) the doctrine of equitable estoppel did not apply to preclude Mother's claim for back child support. View "In re Marriage of Pfeifer" on Justia Law