Justia Montana Supreme Court Opinion Summaries

S.C.B. was born in 2006 to Father and Mother. In 2014, Grandmother filed a petition in Flathead County seeking to establish a parenting plan in which she would be designated as S.C.B.’s primary care giver. Grandmother then moved for a restraining order against Mother and for an interim parenting plan. While Grandmother’s motions were pending, Mother filed a motion for change of venue seeking to transfer the proceeding to Hill County. The district court granted Mother’s motion and transferred the proceeding to a district court in Hill County. The Supreme Court reversed, holding (1) even if Hill County could be considered a proper county for venue purposes, so too was Flathead County, and because there were two proper counties in which the parenting proceeding could have commenced, it was error for the district court to grant a change of venue; and (2) for purposes of determining the propriety of venue, there was sufficient prima facie evidence of a parent-child relationship between Grandmother and S.C.B. View "In re Parenting of S.C.B." on Justia Law

Defendant pleaded guilty to fraudulently obtaining dangerous drugs. The district court stayed sentencing until Defendant completed a twelve-month drug and alcohol addiction treatment program. After completing the treatment program, Defendant relapsed and was taken into custody. At sentencing, Defendant requested that the district court give her credit for the time she spent in the treatment program. The district court denied the request. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) did not err in denying Defendant credit for time served in the residential treatment facility, as Defendant’s enrollment in the program was not the equivalent to incarceration; and (2) erred in its order as it pertained to Defendant’s payment of defense counsel fees, as the court’s oral pronouncement of sentence pertaining to the counsel fees conflicted with the corresponding provision in the written judgment. View "State v. Byrd" on Justia Law

The Milky Whey, Inc., a dairy broker based in Montana, bought products from Dairy Partners, LLC, a dairy supply company located in Minnesota. This appeal concerned Milky Whey’s purchase of a product from Dairy Partners that Dairy Partners shipped to Utah. When Milky Whey picked up the product, it had become moldy and unusable. Milky Whey filed suit, alleging breach of contract, breach of warranty, unjust enrichment, and breach of an obligation to pay. Dairy Partners moved to dismiss the complaint for lack of personal jurisdiction. The district court dismissed the action, concluding that Dairy Partners did not come within Montana’s long-arm jurisdiction statute. The Supreme Court affirmed, holding that the district court did not err in determining that it could not exercise personal jurisdiction over Dairy Partners. View "Milky Whey, Inc. v. Dairy Partners, LLC" on Justia Law

Mother was the birth mother of L.M.F. and J.A.B. Father was the birth father of J.A.B. Due to Mother’s and Father’s drug use, the Department filed a petition for termination of Mother and Father’s parental rights with respect to J.A.B. and for termination of Mother’s parental rights with respect to L.M.F. After a hearing, the district court terminated Mother’s parental rights to L.M.F. and J.A.B. and Father’s rights to J.A.B. The Supreme Court affirmed, holding the district court did not err (1) in terminating Mother’s parental rights to L.M.F. on the basis that Mother failed to complete her treatment plan and that her condition was unlikely to change within a reasonable time; and (2) in terminating Mother and Father’s parental rights as to J.A.B. without reunification services on the basis that they had subjected L.M.F. to aggravated circumstances. View "In re J.A.B." on Justia Law

Plaintiffs - three generations of the Meine family - filed this action against Defendants - a small corporation operated by family members - seeking a determination that they held a prescriptive easement over a road where it crossed Defendants’ land and a permanent injunction prohibiting Defendants from blocking or impeding the use of this easement. The district court concluded that Plaintiffs established a prescriptive easement over Defendants’ land and permanently enjoined Defendants from blocking or impairing the easement. The Supreme Court affirmed, holding (1) the district court correctly interpreted and applied the law when it found that a prescriptive easement may exist despite the dominant and servient estates being non-contiguous; (2) the evidence supported a finding that Defendants used their land for many lawful purposes; (3) the evidence supported the district court’s finding of a prescriptive easement; and (4) the district court did not err in determining the nature and the scope of the prescriptive easement. View "Meine v. Hren Ranches, Inc." on Justia Law

In 2009, the municipal court granted the petition filed by the mother of A.L. for an order of protection restraining Defendant from being near A.L. From 2009 until 2012, A.L. received counseling for alleged sexual abuse by Defendant. In 2012, Defendant was found guilty of one count of violating an order of protection. The district court ordered Defendant to pay restitution for all of A.L.’s counseling. Defendant appealed the restitution order, arguing that the district court erred by ordering him to pay restitution for losses that were not caused by his violation of the order of protection. The Supreme Court vacated the order, holding that the district court erred by ordering restitution for counseling expenses that did not result from Defendant’s violation of the order of protection. Remanded. View "State v. Thorpe" on Justia Law

Defendant was arrested for driving under the influence (DUI). Defendant was arraigned on May 23, 2012, and trial was set for August 27, 2012. Defendant’s trial, however, was postponed upon his motion to vacate the initial trial date for a change of plea. On October 1, 2012, the municipal court rearraigned Defendant, and he pled not guilty to the DUI. Defendant subsequently moved to dismiss on the grounds that his right to a speedy trial had been violated. The municipal court summarily denied Defendant’s motion without conducting any analysis. Defendant moved for reconsideration of his motion to dismiss under both the misdemeanor speedy trial statute and constitutional speedy-trial provisions. On May 9, 2013, Defendant pled guilty to DUI. The district court denied Defendant’s appeal. The Supreme Court reversed, holding (1) Defendant’s statutory speedy-trial right was not violated because his motion to vacate his trial date for a change of plea made the misdemeanor speedy-trial statute inapplicable; but (2) in regards to Defendant's constitutional speedy-trial violation claim, the delay in Defendant’s case was sufficient to trigger analysis under the factors set forth in State v. Ariegwe. Remanded. View "City of Helena v. Heppner" on Justia Law

Gail Patton filed for dissolution of her marriage to Bill Patton. After a bench trial, the Standing Master appointed to oversee the case entered her findings of fact, conclusions of law, and final decree of dissolution. Gail filed a motion for additional evidence pursuant to Mont. R. Civ. P. 59. Gail was subsequently diagnosed with breast cancer and filed a motion to amend the findings of reopen the case to consider evidence of her diagnosis in its division of the marital estate and maintenance (Motion to Amend). The district court declined to rule on Gail’s post-trial motions, concluding that it was not appropriate to take additional evidence about events occurring since the filing of the Standing Master's Report. The district court then adopted the Report with only minor adjustments. The Supreme Court reversed, holding that the district court erred (1) by failing to rule on Gail’s motion or otherwise to recommit the matter to the Standing Master with instructions to rule on these motions; and (2) by adopting the Report to the extent the Standing Master’s conclusions of law failed properly to consider Gail’s contributions to the marriage as a homemaker and her qualification for maintenance payments. View "In re Marriage of Patton" on Justia Law

Twelve days after Justin Schiller was involuntarily committed to the Montana State Hospital (MSH), Schiller was released. A few months later, Schiller killed his former girlfriend, Catherine Woods, and then himself. Catherine’s parents filed a complaint alleging that MSH had a statutory duty to warn Catherine of the risk of violent behavior by Schiller. The district court granted summary judgment in favor of the State and MSH, concluding that MSH had no duty to warn Catherine or take precautions for her protection because Schiller never communicated any specific threat of violence against Catherine during his commitment. The Supreme Court affirmed, holding that because no actual, specific threat was communicated in this case, the duty to warn was not triggered. View "Woods v. Mont. State Hosp." on Justia Law

In 2012, after auditing Cloud Peak Energy Resources, LLC’s Montana Coal Tax payments for years 2005-2007, the Department levied a deficiency assessment for additional taxes owing from sales involving non-arm’s length (NAL) agreements. Cloud Peak filed a complaint alleging that the Department’s methodology for determining market value was illegal and that it had also illegally assessed taxes on coal additives for the years 2005-2007. The district court (1) held in Cloud Peak’s favor on the first issue, concluding that the market value of coal sold under NAL agreements is determined by comparing its price with that of coal sold under arm’s length contracts negotiated in a similar timeframe; and (2) ruled in the Department’s favor on the issue regarding additives. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) correctly found that market value is properly based upon similarly negotiated contracts, but the additional language included in the order was inappropriate; and (2) did not err in holding that coal additives used from 2005-2007 are subject to Montana Coal Taxes. View "Cloud Peak Energy Res., Inc. v. Dep’t of Revenue" on Justia Law