Justia Montana Supreme Court Opinion Summaries

The State charged Defendant with aggravated assault against his wife and criminal endangerment. After a jury trial, Defendant was convicted of criminal endangerment and the lesser offense of assault. Defendant appealed, arguing (1) criminal endangerment is a lesser-included offense of aggravated assault, and charging both crimes is prohibited by statute, and (2) his counsel provided ineffective assistance when he failed to invoke Mont. Code Ann. 46-18-225, which requires a sentencing court to evaluate specific criteria when assessing imprisonment alternatives for non-violent offenders. The Supreme Court affirmed, holding (1) Defendant was not simultaneously convicted on a lesser and greater offense; and (2) Defendant suffered no prejudice from his counsel’s conduct at sentencing. View "Zink v. State" on Justia Law

After a jury trial, Defendant was convicted of felony theft by insurance fraud. The Supreme Court affirmed the conviction, holding (1) the district court did not err when it instructed the jury that an insurance administrator is a person who adjusts or settles claims; (2) the Court declines to exercise plain error review of the State’s remarks during closing argument; (3) the district court did not err by ordering Defendant to pay restitution when the affidavit of loss was prepared by an independent adjuster; and (4) Defendant’s claim that he received ineffective assistance of counsel must be raised in a postconviction proceeding before a district court, where an evidentiary record may be developed. View "State v. Schaeffer" on Justia Law

After a jury trial, Appellant was convicted of incest in violation of Mont. Code Ann. 45-5-507. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the district court correctly interpreted the Court’s decision in State v. Anderson, and did not abuse its discretion, when it prohibited Appellant from examining the victim regarding alleged false accusations of sexual assault; (2) the jury instructions fairly and fully instructed the jury as to the applicable law; (3) the district court did not abuse its discretion in denying Appellant’s motion for a new trial on grounds of juror misconduct; and (4) several portions of Appellant’s sentence were illegal, including conditions of parole, the order to pay restitution, and the requirement to pay “all future costs of incarceration and medical costs while incarcerated.” View "State v. Ring" on Justia Law

After a jury trial, Defendant was convicted of felony incest involving his fourteen-year-old son and six-year-old daughter and of tampering with the evidence. The Supreme Court affirmed. Defendant later petition for postconviction relief, setting forth three grounds upon which he claimed that his trial counsel provided ineffective assistance. The district court denied Defendant’s petition for postconviction relief, concluding that even if Defendant’s representation was deficient, it would not have created a reasonable probability that the outcome of the trial would have been any different. The Supreme Court affirmed, holding that the district court did not err in concluding that even if counsel’s conduct was constitutionally deficient, Defendant failed to show that he was prejudiced. View "Stock v. Montana" on Justia Law

Plaintiff was involved in a motor vehicle accident caused by another driver. As a result of the accident, Plaintiff sustained both bodily injury and property damage. Plaintiff carried an automobile insurance policy through United Services Automobile Association General Indemnity Company (USAA). USAA paid vehicle repair and car rental costs, after which it sought subrogation for the property damage expenses from the tortfeasor’s automobile liability insurer. Plaintiff subsequently filed an action on behalf of himself and a putative class of plaintiffs, alleging that USAA violated Montana law by seeking subrogation for property damage loss before its insured had been made whole with respect to related personal injuries. The U.S. district court certified a question to the Montana Supreme Court, which answered by holding that Montana law does not prohibit an insurer from exercising its right of subrogation under the limited, specific circumstances presented in the certified question. View "Orden v. United Servs. Auto. Ass'n" on Justia Law

After a jury trial, Defendant was convicted of one count of sexual assault, a felony, and sentenced to twenty years imprisonment. The Supreme Court affirmed, holding (1) the prosecutor’s statements during closing argument regarding the truthfulness of witness testimony did not rise to the level of plain error; and (2) the district court did not deny abuse its discretion when it determined that a new trial was not warranted in the interest of justice after the court sua sponte questioned a key defense witness, as the inquiry did not serve to deny Defendant a fair trial. View "State v. Walton" on Justia Law

Mid-Continent Casualty Company provided comprehensive general liability insurance to Scentry Biologicals, the manufacturer of NoMate, a pest control product designed to protect agricultural crops from destructive insects. Applewood Orchards purchased NoMate from Wilbur-Ellis (W-E), a distributor of NoMate, and used the product on its apple crop to protect against moths. After Applewood discovered significant moth damage, it filed a tort action against Scentry and W-E. Scentry and W-E requested that Mid-Continent defend them under Scentry’s policy. Mid-Continent agreed to defend Scentry, reserving its right to determine its coverage obligations later, but refused to defend W-E. Applewood settled with W-E, and a court ruled against Scentry and in favor of Applewood. Meanwhile, Scentry filed a declaratory judgment against against Mid-Continent seeking declaratory relief on coverage issues. W-E and Applewood intervened. The district court granted summary judgment for and awarded damages to Scentry, Applewood, and W-E. The Supreme Court affirmed, holding that the district court did not err in granting the summary judgment motions filed by Scentry, Applewood, and W-E. View "Scentry Biologicals, Inc. v. Mid-Continent Cas. Co." on Justia Law

In 2011, Amber Crowley filed a petition for dissolution of her marriage to Dennis Crowley. In 2012, the district court entered a final decree of dissolution and a final parenting plan. Dennis appealed, challenging many of the trial court’s determinations. The Supreme Court (1) reversed the district court’s apportionment of property and remanded for further findings of fact, holding that the district court’s findings were insufficient for the Court to determine whether all of the parties’ assets and liabilities were properly considered; (2) affirmed the court’s award of arrears for past due family support; (3) reversed the court’s maintenance order and remanded for further findings, holding that the court’s brief findings did not sufficiently address the statutory factors; (4) affirmed the court’s determination to award primary residential custody of the parties’ child to Amber; and (5) reversed the court’s order requiring Dennis to pay costs and attorney’s fees, holding that the evidence was not sufficient to support a determination that the requested fees were reasonable. View "In re Marriage of Crowley" on Justia Law

In 2012, Mother and Father divorced. The decree of dissolution provided that the couple’s two children would reside permanently with Mother. In 2013, Mother died in a fire. The children’s maternal grandmother (Grandmother) immediately took control of the children. Father subsequently filed a petition for exclusive parental control, and Grandmother requested that she be awarded a parental interest in the children. The district court entered an order granting Father exclusive parental control and authority over the children, concluding that Grandmother had not established a parent-child relationship between her and the children. The Supreme Court affirmed, holding that the district court’s decision was supported by substantial, credible evidence. View "Hansen v. Moats" on Justia Law

In 2007 and 2008, Defendant was convicted of four felonies. In 2010, Defendant absconded from a pre-release center. Several months later, Defendant was extradited from Idaho to Montana. Defendant pled guilty to escape. Defendant was sentenced to ten years imprisonment and ordered to pay restitution to the State for the costs incurred in extraditing him back to Montana from Idaho. On appeal, Defendant challenged the restitution requirement. The Supreme Court reversed, holding that the district court erred when it ordered Defendant to pay restitution to the State for expenses incurred in extraditing him from Idaho to Montana, as the court lacked the statutory authority to impose restitution for extradition costs. View "State v. Macy" on Justia Law