Justia Montana Supreme Court Opinion Summaries

After police officers knocked on the door to Defendant's residence to ask for directions they confiscated forty plants of marijuana. Defendant pled guilty to criminal production or manufacture of dangerous drugs, a felony. Defendant appealed the denial of his motion to suppress the results of the search of his residence, arguing that because officers had no reason to enter his property, they were not lawfully in a place where they could see the marijuana in plain view. The Supreme Court (1) affirmed the district court's denial of Defendant's motion to suppress, as the officers were lawfully on Defendant's property, and thus their observations of the marijuana in plain view were an appropriate basis for the charges; but (2) reversed the district court's imposition of the cost of court-appointed counsel, as the amount of that cost exceeded the statutorily allowed amount. View "State v. Phillips" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual assault and sentenced to concurrent 100 year sentences, with fifty years of each sentence suspended. The Supreme Court affirmed, holding that Defendant's trial counsel did not render ineffective assistance in (1) failing to object to the admission of certain incidences of hearsay testimony by various witnesses, as the testimony either fell among the hearsay exceptions provided for in the Montana Rules of Evidence or defense counsel may have had strategic reasons for not objecting; and (2) stipulating to the admission of multiple items of evidence that Defendant alleged contained otherwise inadmissible hearsay evidence, as Defendant's allegations implicated questions of trial strategy that exceeded the scope of the record. View "State v. Mederos" on Justia Law

Defendant pleaded no contest to one count of felony criminal endangerment pursuant to a plea agreement. Prior to sentencing, Defendant filed a motion to withdraw his plea, which the district court denied. The district court then imposed a ten-year suspended sentence. Defendant filed a motion to withdraw his plea, arguing that the district court failed to establish a sufficient factual basis for his no contest plea, and therefore, there was doubt as to whether Defendant entered his plea voluntarily. The Supreme Court affirmed, holding that the district court did not err by denying Defendant's motion to withdraw plea, as the district court established a sufficient factual basis for the offense, Defendant was made aware of the consequences of the plea, and the plea was made voluntarily. View "State v. Jackson" on Justia Law

Thomas Warner filed a complaint against Robert and Rebecca Hanke for conversion and negligence after Robert Hanke asserted ownership over some personal property Warner was storing on the Hanke's property. At the time the action was filed, Robert and Rebecca Hankes maintained home insurance coverage from a subsidiary of Horace Mann Insurance Company. The Hankes filed a claim with Horace Mann to request a defense against Warner's suit. Horace Mann filed a declaratory judgment action requesting a determination whether the insurance policy required Horace Mann to defend the Hankes. The district court concluded that Horace Mann did not owe coverage to the Hankes for the Warner dispute. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) properly determined that the Hankes' insurance policy failed to cover the Warner dispute; (2) correctly determined that Horace Mann's decisions to provide a defense and to pay the settlement of Warner's claims nevertheless allowed Horace Mann to pursue reimbursement for the Hankes' share of the settlement; and (3) abused its discretion in awarding attorney's fees to Horace Mann. View "Horace Mann Ins. Co. v. Hanke" on Justia Law

Defendants, an attorney and a law firm, structured a tax-deferred exchange for Plaintiffs, a husband and wife and the cattle ranch they owned. It was later determined that the exchange did not qualify for deferred tax treatment under 26 U.S.C. 1031, resulting in significant tax liability for Plaintiffs. Defendants filed an action against Defendants for professional negligence, breach of fiduciary duty, breach of contract, breach of the implied covenant of good faith and fair dealing, and misrepresentation. The district court granted summary judgment to Defendants on all claims on grounds that Plaintiffs' claims were time barred. The Supreme Court reversed, holding (1) Plaintiffs' tort claims were timely filed, and the issue of whether Plaintiffs' timely filed their misrepresentation claim was a question of material fact to be resolved by a jury; (2) Plaintiffs properly stated a claim for breach of contract and the claim was not time barred; and (3) the district court erred in granting Defendants a protection order to prevent discovery of alleged work product and attorney-client communications, as further analysis and fact finding were necessary to determine which documents were discoverable and which qualified for work product or attorney-client protection. Remanded. View "Draggin' Y Cattle Co., Inc. v. Addink" on Justia Law

C.R. Weaver formed Mikart Transport, LLC in January 2011. At that time, the articles of organization named Weaver and Michael Smith as members or managers. In March 2011, Smith submitted a credit application with Tri-County Implement, Inc. After Smith failed to pay Tri-County for work it performed on two vehicles, including a Volvo semi-truck titled in Weaver's name, Tri-County refused to release the Volvo from its possession pursuant to its asserted agisters' lien on the vehicle. Weaver subsequently filed a complaint against Tri-County. In response, Tri-County filed a counterclaim against Weaver and a third-party complaint against Mikart. The district court entered judgment against Mikart, ordering it to pay for the work it performed, and awarded Tri-County attorney fees and costs. The court also held Mikart, Smith, and Weaver jointly and severally liable for these amounts. The Supreme Court reversed the portion of the district court's imposition of personal liability on Weaver for the work performed on the two vehicles, as there was no basis to hold Weaver individually liable for the obligations of Mikart to Tri-County. Remanded. View "Tri-County Implement, Inc. v. Weaver" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony sexual abuse of children for having engaged in sexually-related conduct online with a deputy sheriff who represented himself as a fourteen-year-old female. Defendant was arrested based on his potential plans to travel to Montana to meet the supposed fourteen-year-old in person. The Supreme Court affirmed Defendant's convictions, holding (1) Montana's sexual abuse of children statute does not violate the First Amendment and the Commerce Clause by sweeping too broadly; and (2) the district court properly authenticated extensive internet chat logs and properly admitted them into evidence, and the court's ruling did not unfairly prejudice Defendant. View "State v. Hantz" on Justia Law

After the district court adjudicated A.R.B. a youth in need of care, A.R.B. was placed in foster care with a Utah family. A.R.B.'s mother (Mother), who traveled from Utah to Montana to have her baby, filed a motion to relinquish jurisdiction from Montana to Utah, arguing (1) once Mother went to Utah and the Department placed A.R.B. with the Utah foster family, Montana no longer had exclusive, continuing jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act; and (2) the district court should decline to exercise jurisdiction because Utah constituted a more convenient forum. The district court denied Mother's motion to relinquish jurisdiction and terminated Mother's parental rights. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in declining to relinquish jurisdiction in this case; and (2) the district court was within its discretion in declining Mother's request to declare Montana an inconvenient forum. View "In re A.R.B." on Justia Law

In this water right adjudication, the Water Master concluded that the water right of Claimants, property owners, had been abandoned. Claimants filed an objection to the Water Master's report, arguing, among other things, that the Water Master's application of 79 Ranch v. Pitsch to their existing right was an impermissible retroactive application of the law. The Water Court ruled (1) 79 Ranch applied to Claimants' case; but (2) the Water Master erred in finding that Claimants had failed to produce sufficient evidence to rebut the presumption of intent to abandon. The Supreme Court affirmed, holding that the Water Court (1) correctly applied 79 Ranch analysis; and (2) correctly concluded that Claimants submitted sufficient evidence to rebut the presumption of abandonment. View "Heavirland v. State" on Justia Law

Bank and Lumber Company had business and financial relationships with Sawmill. A few years into its operation, Sawmill began experiencing serious financial difficulties. Sawmill defaulted on approximately $1.4 million in loan obligations to Bank and owed Lumber Company approximately $900,000. Proceedings were initiated in bankruptcy court and district court. While the cases were pending, Sawmill was destroyed by fire. Bank recovered approximately $980,000 from Sawmill's insurance proceeds. In a subsequent case between Bank and Lumber Company, the jury determined that neither Bank nor Lumber Company was entitled to recover damages from the other. The Supreme Court affirmed, holding that the district court did not abuse its discretion in refusing to admit into evidence a particular letter written by the Bank president. View "H.E. Simpson Lumber Co. v. Three Rivers Bank of Mont." on Justia Law