Justia Montana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of accountability to burglary and theft. The Supreme Court affirmed Defendant’s conviction and sentence for accountability to burglary and reversed Defendant’s conviction for theft, holding (1) the district court did not err by instructing the jury on the theory of accountability when the State had not directly charged an accountability based offense, as the circumstances surrounding the trial put Defendant on notice that the State would pursue an accountability theory; (2) defense counsel’s submission of a jury instruction defining “purposely” in Montana’s accountability statute as a conduct-based rather than result-based mental state resulted in no prejudice to Defendant’s position at trial; and (3) defense counsel rendered ineffective assistance by failing to object to Defendant’s theft conviction on the grounds that it violated Montana’s statutory restriction on multiple charges. View "State v. Tellegen" on Justia Law

On November 26, 2011, the State charged Defendant with five misdemeanor offenses. On June 13, 2012, Defendant moved to dismiss the case on the ground that trial was being held beyond the six-month deadline imposed by Mont. Code Ann. 46-13-4013(2). The justice court denied Defendant’s motion, reasoning that good cause existed for holding Defendant’s trial past the deadline. The district court affirmed. The Supreme Court affirmed, holding that the lower courts did not err in finding that good cause existed for holding Defendant’s trial eight days past the six-month deadline. View "State v. Luke" on Justia Law

Morrison-Maierle, Inc. (MMI) was hired by two counties to provide engineering services and supervision on a road improvement contract. The counties retained JEM Contracting, Inc. (JEM) to provide the construction services on the project. JEM filed suit against MMI alleging detrimental reliance and fraudulent inducement for promises MMI allegedly made during the job that JEM would be paid for unanticipated costs incurred during pulverization of the old road. The district court granted summary judgment for MMI, concluding that JEM could not prove it had been harmed by MMI’s alleged representations. The Supreme Court affirmed, holding that the district court did not err by (1) concluding that JEM was required to continue performance pending approval of a change order under a certain contract provision, as the provision was not void as against public policy; and (2) granting summary judgment to MMI on the ground that JEM failed to show it was harmed by the representations made by MMI. View "JEM Contracting, Inc. v. Morrison-Maierle, Inc." on Justia Law

After a jury trial, Defendant was convicted of criminal distribution of dangerous drugs, a felony. Defendant appealed, arguing that the district court erred by instructing the jury on the elements of the offense prior to the delivery of opening statements. The Supreme Court affirmed, holding (1) the district court erred by, before opening statements, reading the jury instructions regarding the elements of the offense of criminal distribution of dangerous drugs without finding good cause; but (2) under the circumstances, Defendant’s substantial rights were not prejudicially affected by the error. View "State v. Otto" on Justia Law

Defendant was charged with one count of burglary and two counts of misdemeanor assault. Defendant pleaded guilty to the assaults but proceeded to a jury trial on the burglary charge. Defendant filed a motion to excuse a certain juror for cause based on the juror’s answers during voir dire to questions as to whether the juror inherently thought a law enforcement officer was more believable than a non-officer. The trial court denied the motion, and Defendant was subsequently convicted of burglary. The Supreme Court affirmed, holding that the district court did not err in denying Defendant’s motion to excuse the juror for cause. View "State v. Johnson" on Justia Law

Defendant pled guilty to one count of felony assault with a weapon. The district court sentenced Defendant to a ten-year term commitment to the Department of Corrections (DOC) with five years suspended. After Defendant’s probation officer filed a report of violation, a petition for revocation was filed in district court. Following a hearing, the district court sentenced Defendant to a five-year commitment to DOC with recommended placement at a prerelease facility. The Supreme Court affirmed, holding (1) the district court did not err when it denied Defendant’s motion to dismiss the petition for revocation; and (2) the district court did not violate Defendant’s due process rights by considering the criminal history information in the presentencing investigation report, nor did it abuse its discretion by requiring Defendant to serve the remainder of his original sentence. View "State v. Edmundson" on Justia Law

Ruby Valley National Bank (RVNB) obtained and recorded a deed of trust (DOT) on certain real property subsequent to a previously recorded DOT. Wells Fargo Delaware Trust Co. (Wells Fargo) claimed to be the beneficiary of the first DOT. RVNB filed for judicial foreclosure of its interest in the property. The district court granted summary judgment for RVNB, holding that RVNB’s DOT was entitled to priority over the earlier DOT held by Wells Fargo because Wells Fargo had not proven the elements necessary for judicial foreclosure and was unable to do so because its trial witness and exhibit list had been stricken. The Supreme Court reversed, holding (1) Wells Fargo was not required to file a counterclaim for foreclosure to protect its interest in the property; and (2) because the undisputed facts established that Wells Fargo was the current beneficiary of the first DOT, the undisputed facts established that Wells Fargo was entitled to judgment as a matter of law that its indenture held priority over RVNB’s indenture. View "Ruby Valley Nat'l Bank v. Wells Fargo Del. Trust Co., N.A." on Justia Law

After the district court adjudicated Child a youth in need of care, the State filed a petition to terminate Mother’s parental rights. Child was placed with Father before the termination hearing. The district court subsequently terminated Mother’s parental rights and denied Mother’s motion to dismiss the termination petition. The Supreme Court affirmed, holding (1) Mother failed to articulate a substantive due process claim that required the State’s petition to terminate be dismissed; (2) the placement of Child with Father did not require that the State’s petition to terminate be dismissed; and (3) the State’s petition to terminate was not filed prematurely. View "In re L.V-B." on Justia Law

Then-owners of real property entered into a “Waiver of Right to Protest” the creation of special improvement districts (SIDs) for the purpose of making road and intersection improvements to Cottonwood Road between Huffine Lane and West Babcock Street. The waiver stated that the parties to the waiver would participate in alternate financing methods for completion of the road improvements if the SIDs were not utilized. No SIDs were implemented, and Covenant Investments, Inc. (Covenant) undertook and paid for all improvements to the intersection of Huffine and Cottonwood. First Security Bank (FSB), a successor to the original covenantor, subsequently constructed a building at the intersection. After FSB refused to reimburse Covenant for the costs of the street improvements, Covenant sued FSB seeking enforcement of the waiver agreement. The district court dismissed Covenant’s complaint, concluding that the waiver did not contain the essential elements of a contract and therefore did not bind FSB. The Supreme Court affirmed the dismissal of the complaint, holding (1) the waiver’s alternative financing provision was void for lack of certainty, (2) by acting unilaterally Covenant waived its right to belatedly demand enforcement of the waiver provision, and (3) Covenant’s complaint was barred by the statute of limitations. View "Covenant Invs., Inc. v. First Sec. Bank" on Justia Law

In the 1990s, Defendants (Employers) created a sick-leave policy allowing employees to bank their sick leave in a continued illness bank (CIB). In 2002, Employers modified the terms of the CIB to create the CIB pay-out benefit, which allowed a capped amount of unused CIB hours to be paid to departing employees who completed twenty-five years or more of service. In 2008, Employers terminated the CIB pay-out benefit, and only employees who had reached twenty-five years of employment with Employers were entitled to their earned but unused CIB hours upon termination. Plaintiffs in this case represented employees who had not reached twenty-five years of service before the benefit ended. Plaintiffs brought a class action complaint against Employers. The district court granted summary judgment for Employers. The Supreme Court affirmed, holding that the district court did not err in determining that (1) Employers’ policies did not constitute a standardized group employment contract; (2) the CIB pay-out benefit was not deferred compensation or wages under the Montana Wage and Wage Protection Act; and (3) the covenant of good faith and fair dealing did not apply to Plaintiffs’ claims. View "Chipman v. Northwest Healthcare Corp." on Justia Law