Justia Montana Supreme Court Opinion Summaries

Plaintiff, registered voters seeking to invalidate the Montana Districting and Apportionment Commission’s (Commission) assignment of two “holdover senators” in its final 2013 redistricting plan, filed a complaint against the State and Secretary of State (collectively, "State") seeking injunctive and declaratory relief. The district court granted the State’s motion for summary judgment and denied Plaintiff’s motion for summary judgment. The Supreme Court affirmed, holding that the district court did not err in concluding that (1) the Commission did not violate the public’s “right to know”; (2) the Commission is part of the legislative branch and is not an agency, and that it is therefore exempt from statutes promulgating the right of participation; and (3) Plaintiffs’ argument that the Commission violated Plaintiffs’ right of suffrage was without merit. View "Willems v. State" on Justia Law

In 2013, the Montana Legislature enacted Legislative Referendum 127 (LR-127) as a referendum to be put to a public vote at the time of the November 2014 general election. Petitioners filed a petition challenging the legal sufficiency of LR-127, alleging that the Attorney General’s legal review of the proposed ballot measure was incorrect and seeking to enjoin the State from placing the measure on the general election ballot. The Supreme Court ordered that the State was enjoined from placing LR-127 on the 2014 general election ballot, holding that the proposed ballot measure was not legally sufficient because the title of LR-127 did not comply with the plain meaning of the Legislature’s 100-word limit found in Mont. Code Ann. 5-4-102. View "MEA-MFT v. Fox" on Justia Law

In 2011, IndyMac Bank foreclosed on a certain property. JAS, Inc. purchased the property and subsequently initiated a quiet title action. Defendants Countrywide Home Loans and Mortgage Electronic Registration Systems (MERS) defaulted. Bank of America (BOA), which had acquired Countrywide in 2008, was not named as a party defendant and did not appear in the proceeding. Final judgment was issued quieting title to the property in JAS’s name. Countrywide and MERS subsequently moved to have the entries of default entered against them set aside, and BOA filed a motion to intervene in the proceeding and sought to have the default entered against Countrywide set aside. The district court granted the motions. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in granting BOA’s motions to intervene and to set aside the default judgment entered against Countywide, as BOA met the express requirements of Mont. R. Civ. P. 24(a), and Countrywide had no present interest in the subject property at the time suit was filed; and (2) did not manifestly abuse its discretion by granting MERS’s motion to set aside the default judgment entered against it, as MERS established good cause to set aside the default judgment. View "JAS, Inc. v. Eisele" on Justia Law

J.S., born in 1998, was an “Indian child” under the Indian Child Welfare Act (ICWA). In 2002, J.S. was adjudicated a youth in need of care, and temporary custody was granted to the Department of Public Health and Human Services (Department). In 2012, the Department filed a petition for legal guardianship. Ultimately, the district court granted guardianship over J.S. to J.S.’s foster family. Father appealed. The Supreme Court affirmed, holding (1) the State’s failure to provide notice to Father and his tribe at the outset of these proceedings did not provide a basis to overturn the district court’s ultimate guardianship order; (2) 25 U.S.C. 1912(d) did not provide a basis to overturn the district court’s award of guardianship to the foster family based on the State’s alleged failure to make “active efforts” to provide services and promote the relationship between Father and J.S.; and (3) contrary to Father’s contention, 25 U.S.C. 1912(e) did not apply to this case and did not serve to invalidate the district court’s award of guardianship. View "In re J.S." on Justia Law

After a jury trial, Defendant was convicted of charges stemming from the sexual assault of his stepdaughter. Defendant subsequently filed a petition for post-conviction relief (PCR). One day before his reply brief was due, Defendant sought leave to file an amended petition. The district court granted the motion but prohibited him from asserting new claims. Defendant then filed his amended PCR petition, which the district court denied. The Supreme Court (1) affirmed the district court’s limitation of new claims in Defendant’s amended PCR petition; but (2) reversed the district court’s denial of Defendant’s PCR petition and remanded for reconsideration of Defendant’s amended PCR petition by a new judge because the judge that ruled on the petition had an impermissible conflict of interest based on his previous representation of Defendant’s wife in a divorce proceeding. View "Bullman v. State" on Justia Law

From 2003 to 2011, Jasvinder Singh worked for America’s Best Contractors, Inc. (ABC) as a salesperson and estimator. After his employment with ABC ended, Singh filed a claim with the Montana Department of Labor and Industry (DOLI), alleging that he was owed unpaid commissions for the period of June 2010 to June 2011. The DOLI hearings bureau determined that ABC owed Singh unpaid commissions and a penalty totaling $60,575. The district court affirmed DOLI’s final agency decision. The Supreme Court affirmed, holding (1) the hearing officer did not adjudicate collateral matters beyond DOLI’s jurisdiction when he excluded certain payments; and (2) the hearing officer’s factual determinations that certain checks issued to Singh were payments on collateral obligations were supported by the evidence. View "America's Best Contractors, Inc. v. Singh" on Justia Law

In 1972, Phyllis and Clarence Hudson granted an easement to Burlington Northern, Inc. Plaintiffs were the successors in interest to the Hudsons, and Defendant was a successor to Burglinton Northern. The easement was a road or driveway that ran from a public road to Plum Creek’s property, crossing Plaintiffs’ property. Plaintiffs filed a complaint against Plum Creek seeking to extinguish the scope of the easement, alleging, inter alia, extinguishment of the easement due to non-use and limitation on use of the easement. The district court granted summary judgment for Plum Creek. The Supreme Court reversed, holding (1) the district court erred in granting Plum creek’s motion for summary judgment, as an issue of material fact existed as to whether the easement had terminated; and (2) the district court erred in determining the scope of the easement. Remanded. View "Whary v. Plum Creek Timberlands, L.P." on Justia Law

Sudan Drilling, Inc. filed a complaint against Glen and Clarice Anacker seeking to foreclose on a construction lien. The district court granted summary judgment for the Anackers and directed the county clerk and recorder to remove Sudan’s lien from the public record. The Anackers recorded the judgment with the clerk and record’s office. The Supreme Court reversed and remanded, holding that genuine issues of material fact precluded summary judgment. On remand, the Anackers filed a motion for summary judgment, arguing that the lien was unenforceable because the recording of the district court’s prior judgment effectively discharged and released the lien, even though the Supreme Court reversed the judgment on appeal. The district court once again granted summary judgment for the Anackers. The Supreme Court reversed, holding that the recording of the previous judgment did not discharge Sudan’s construction lien or render Sudan’s claims moot. View "Sudan Drillings Inc. v. Anacker" on Justia Law

Plaintiff was injured in an accident while driving a business vehicle owned by Mattress King, Inc. and insured by Mountain West Farm Bureau. Plaintiff, whose personal vehicles were insured by Safeco Insurance Company of Illinois, filed a claim with Safeco for medical payment benefits. Plaintiff received medical payment benefits from Safeco and an undisclosed amount of underinsured motorist benefits from Mountain West. Believing Safeco wrongfully refused to pay additional claimed benefits, Plaintiff brought a class action suit against Safeco. The district court ultimately ruled in favor of Safeco. The Supreme Court affirmed, holding that the “other insurance” clauses in Plaintiff’s automobile liability policy were valid and, as applied in this case, did not constitute de facto subrogation. View "Scheafer v. Safeco Ins. Co. of Ill." on Justia Law

C.S., who turned eighteen in March 2012, received special education services from the Butte School District until June 2013. In January 2013, the Montana Office of Public Instruction directed the School District to obtain appointment of a surrogate parent for C.S., who lived with his Foster Father, for educational purposes. The district court subsequently appointed Mary Jo Mahoney as C.S.’s surrogate parent. In March 2013, C.S. filed a motion to vacate the appointment of Mahoney and to substitute Foster Father as his surrogate parent. The court denied the request. The Supreme Court reversed, holding (1) the district court’s refusal to vacate its appointment of Mahoney was not mooted even though C.S. no longer qualified for special education services from the School District; and (2) the district court erred when it refused to remove Mahoney and appoint Foster Father as C.S.’s surrogate parent for educational purposes. View "In re C.S." on Justia Law