Justia Montana Supreme Court Opinion Summaries

In 1998, Steven and Susan Buck were married in California. For the next twenty years, the Bucks lived outside of the United States. In 2001, while living in Indonesia, the Bucks purchased land near Kalispell and built a house. In 2010, Susan moved to Florida, and Steven remained in Indonesia. In 2013, Susan filed a petition for dissolution of marriage in Montana. Steven moved to dismiss the petition for lack of subject-matter jurisdiction because Susan neither resided in nor was domiciled in Montana for the ninety days preceding her petition for dissolution. The district court denied the motion, concluding that it had jurisdiction over the matter. The Supreme Court affirmed, holding that any jurisdictional defect was cured when Susan established domicile for ninety days and filed a supplemental pleading alleging as much. View "In re Marriage of Buck" on Justia Law

In 1988, Defendant pled guilty to sexual intercourse without consent and was sentenced to thirty years imprisonment with ten years suspended. In 1992, Defendant escaped from prison. After he was apprehended, he was convicted with escape and other charges. In 2007, Defendant was discharged to serve the suspended portion of his sentence. In 2011, the district court orally found that Defendant had substantially violated the conditions of his parole. The court then imposed a new sentence of ten years with all time suspended and imposed fourteen new conditions to Defendant’s suspended sentence. Thereafter, the district court revoked Defendant’s suspended sentence, sentenced Defendant to ten years imprisonment with five years suspended, and reimposed the fourteen new conditions on his suspended sentence. The Supreme Court affirmed, holding that the imposition of fourteen new conditions on Defendant’s suspended sentence for his 1988 crime did not violate ex post facto principles. Remanded. View "State v. Piller" on Justia Law

After a jury trial, Defendant was found guilty of sexual assault and sexual intercourse without consent. Defendant appealed, raising three allegations of error. The Supreme Court reversed, holding that the district court abused its discretion by allowing the State to elicit testimony from Defendant’s girlfriend and others who knew the couple regarding Defendant’s sexual habits. Further, the tainted evidence was inflammatory in nature and likely contributed to Defendant’s conviction. The district court further erred by permitting a primary investigator to act as both a representative of the State and a witness during trial. Remanded. View "State v. Nichols" on Justia Law

S.B.C. was a Naive American child whose biological parents were enrolled members of the Blackfeet Tribe (Tribe). When S.B.C. was approximately four months old he was removed from Mother’s care and placed with Foster Mother. The district court later terminated both Mother’s and Father’s parental rights and granted legal custody to Child Services with the right to consent to the adoption of S.B.C. The Supreme Court affirmed, holding that the district court (1) did not err by denying the Tribe’s motion to transfer jurisdiction to the Blackfeet Tribal Court; (2) did not abuse its discretion by terminating Father’s parental rights; and (3) did not abuse its discretion by terminating Mother’s parental rights. View "Matter of S.B.C." on Justia Law

After a jury trial, Defendant was convicted of accountability for robbery. Defendant was sentenced to thirty years imprisonment with ten years suspended and ordered to pay restitution in an unspecified amount. The Supreme Court affirmed in part and remanded in part, holding that the district court (1) properly instructed the jury on accountability for robbery; (2) did not err in denying Defendant’s motion to dismiss for insufficient evidence; and (3) erred in requesting that correctional authorities determine restitution upon Defendant’s release. Remanded for a determination of the amount of restitution Defendant owed for the victim’s medical expenses. View "State v. Hanna" on Justia Law

After a jury-waived trial, Defendant was found guilty of assault with a weapon and sentenced to twenty years with the Department of Public Health and Human Services. Defendant appealed, arguing that the district court (1) erred when it determined that he was not mentally fit to stand trial at a fitness proceeding in which he was not present, and (2) erred by failing to complete the initial appearance process. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by his absence from the fitness proceeding; and (2) Defendant was not prejudiced by the district court’s failure to provide the advisories in Mont. Code Ann. 46-7-102. View "State v. White" on Justia Law

The Bixby family owned approximately one-third of Wyo-Ben’s class A stock. In 2011, Wyo-Ben’s shareholders voted to reclassify the shares to give class B shares the right to vote, which resulted in an overall decrease to the Bixby voting rights. The Bixby family dissented and, after the vote, sent a payment demand for all of their shares. Wyo-Ben, Inc. filed a petition seeking a declaration that the dissenters were not entitled to any payment for their class B shares and contesting the dissenters’ demand for a high value of the class A shares. The Bixbys, in turn, sought a declaration that they were entitled to payment for both classes of shares at the higher value. The Bixbys also counterclaimed, asserting that Wyo-Ben’s decision to dilute their voting rights constituted oppressive conduct. The district court dismissed the oppression claim and ruled that the Bixbys were not entitled to be paid for their class B shares under Montana’s dissenters’ right statute. The Supreme Court primarily affirmed, holding that the district court did not err in (1) dismissing the Bixbys oppression claim; (2) denying class B payments to all but one of the Bixby appellants; and (3) valuing the class A shares. View "Wyo-Ben, Inc. v. Bixby" on Justia Law

In 2008, William Corrigan filed for a divorce from his wife, Mary Helen Corrigan. The district court issued temporary restraining order (TRO) that prohibited William and Mary from changing the beneficiaries of any insurance. However, the TRO was never served on Mary. In 2012, William amended the terms of his IRA account with State Farm, removing Mary as beneficiary and naming his adult children as primary beneficiaries. After William died, Mary alerted State Farm that she would make an elective share claim on the IRA. Litigation ensued. The district court granted summary judgment to the adult children, concluding that the TRO was invalid. The Supreme Court affirmed, holding (1) because William did not serve Mary with the TRO in the three years allotted for service, the TRO was rendered ineffective, and therefore, William was not prohibited from amending his IRA; and (2) as a result, the district court did not err in finding that the adult children were the primary beneficiaries of the IRA account. View "In re Estate of Corrigan" on Justia Law

After a bench trial, Defendant was found guilty of assault with a weapon and sentenced to twenty years with the Department of Public Health and Human Services. Defendant appealed, arguing that the district court erred by determining that he was not mentally fit to stand trial at a hearing in which he was not present and by failing to complete the initial appearance process. The Supreme Court affirmed, holding (1) even if Defendant was improperly excluded from the proceeding at which his fitness to proceed was determined, his absence from the proceeding did not render the result unjust or unfair; and (2) Defendant was not prejudiced by the district court’s failure to provide the advisories in Mont. Code Ann. 46-7-102. View "State v. White" on Justia Law

In 2011, Cahill Seeds, Inc. (Cahill) began planning the construction of a new seed washing plant and submitted requests for electric service to Montana-Dakota Utilities (MDU) and Sheridan Electric Co-op, Inc. MDU subsequently upgraded its transmission and distribution systems near Cahill, which allowed MDU to provide three-phase Wye power to Cahill. MDU then began providing three-way Wye power to Cahill. In 2013, Sheridan filed a complaint alleging that MDU violated the Montana Territorial Integrity Act (MTIA) when it extended power to Cahill. The district court found that Sheridan had the right to serve Cahill under the priority provisions of the MTIA. Specifically, the court found that the 1.33 mile distance from Sheridan’s three-phase Wye transmission line to Cahill gave Sheridan priority over MDU, whose three-phase Wye line was 6.5 miles away. The Supreme Court affirmed, holding that Mont. Code Ann. 69-5-105(1) unambiguously granted priority to Sheridan because it had the line nearest to Cahill and the distribution system capacity to serve Cahill. View "Sheridan Elec. Coop, Inc. v. MT-Dak Utils." on Justia Law