Justia Montana Supreme Court Opinion Summaries

The case revolves around the petitioner, Tom Nichols, also known as Nikki, who is currently serving a prison sentence for sex crimes against children. Nikki, a transgender woman in the process of transitioning, filed a petition for a sealed-record name change, arguing that an open-record proceeding could jeopardize her safety due to her gender identity.The District Court of the Third Judicial District initially denied Nikki's petition. The court's decision was based on the fact that Nikki failed to demonstrate probable cause that her safety was at risk, a requirement under Section 27-31-201, MCA, for a petition to proceed on a sealed-record basis. The court also had to be satisfied that the petitioner was not attempting to avoid debt or hide a criminal record.Upon appeal, the Supreme Court of the State of Montana affirmed the lower court's decision. The Supreme Court noted that district courts have broad discretion to grant or deny a petition for a sealed-record name change. The Supreme Court would only reverse a district court decision if it was arbitrary or exceeded the bounds of reason, resulting in substantial injustice. In this case, the Supreme Court found that Nikki failed to provide specific instances of abuse or explain why an open-record proceeding would change her circumstances at the Montana State Prison. Furthermore, Nikki did not provide any support for the alleged risk of harm from members of the public. Therefore, the Supreme Court concluded that the District Court did not abuse its discretion when it determined the evidence was insufficient to support Nikki’s petition. View "In re Name Change of Nichols" on Justia Law

This case involves a dispute between neighbors Matthew Olds and Mark Huelskamp, which escalated into an altercation on July 18, 2018. The details of the incident are contested, with Olds alleging that Huelskamp pointed a gun at him and punched him in the nose, while Huelskamp claims that Olds spat in his face and threatened him, leading Huelskamp to defensively strike Olds. Olds filed a civil suit against Huelskamp for negligence, assault, battery, actual malice, and negligent infliction of emotional distress.The case was initially scheduled for trial in May 2020, but due to the COVID-19 pandemic, the trial was postponed multiple times. During this period, Huelskamp decided to present an expert witness, Shawn Paul, and disclosed this in September 2020. Olds objected to this, arguing that the disclosure was untimely and that Paul lacked the requisite training and experience to testify. The District Court initially allowed Paul to testify, but reversed this decision on the second day of trial, ruling that the disclosure was untimely.The jury found Huelskamp guilty of assault and battery, awarding Olds $13,700 in compensatory damages and $75,000 in punitive damages. The District Court later reduced these amounts to $13,700 and $10,500 respectively, and also reduced Olds' claimed attorney fees from $105,869 to $91,300. Huelskamp was thus ordered to pay Olds a total of $115,500.In the Supreme Court of the State of Montana, the court found that the District Court had abused its discretion by excluding Huelskamp's expert witness from testifying. The court noted that Huelskamp had disclosed the expert witness over 13 months prior to trial, giving Olds sufficient time to prepare for cross-examination. The court therefore reversed the District Court's decision and remanded the case for a new trial. View "Olds v. Huelskamp" on Justia Law

The case revolves around Kyle Severson, who was convicted for mitigated deliberate homicide after shooting Tyler Hayden. Severson, his girlfriend, her sister, and his daughter were at a convenience store when Hayden and Dalton Watson arrived. Hayden approached Severson's car, and Severson shot him, claiming he feared Hayden would harm him or his daughter. Severson was charged with deliberate homicide and later found guilty of mitigated deliberate homicide, resulting in a forty-year prison sentence.Severson appealed his conviction, arguing that the District Court erred in denying his motion to dismiss based on the State's failure to disclose favorable evidence and that the cumulative effect of errors in the District Court denied him a fair trial. The undisclosed evidence included law enforcement investigative reports of a burglary at Severson's home and the contents of Watson's cell phone.The Supreme Court of the State of Montana concluded that the cumulative effect of errors in the proceedings denied Severson his constitutional rights to a fair trial and due process. The court found that the prosecutor's misconduct and the State's failure to disclose certain evidence had a direct bearing on the credibility of the witnesses at trial. The court reversed Severson's conviction and remanded the case for a new trial. View "State v. Severson" on Justia Law

The case involves T.S. (Mother) and A.A. (Father) who appealed the termination of their parental rights to their minor children (D.A., L.A., and F.A.) by the Montana Second Judicial District Court. The Child and Family Services Division of the Montana Department of Health and Human Services (Department) became involved with the family in August 2019 when two of the children were found wandering the streets unsupervised. The Department had previously been involved with the family due to allegations of child abuse or neglect. In August 2019, the Department removed the children from the parents' care and placed them in a protective kinship placement. The parents were given treatment plans to follow for potential reunification with their children.Despite multiple extensions to complete their treatment plans, neither parent had successfully completed all requirements by January 2022. As a result, the Department transitioned to court-ordered guardianships as the new permanency plan for the children. In March 2022, the Department petitioned for termination of parental rights due to the parents' failure to complete their treatment plans and their inability to provide adequate parental care. The District Court issued judgments terminating the parents' respective parental rights.The Supreme Court of the State of Montana affirmed the lower court's decision. The court found that the District Court's findings of fact were supported by substantial evidence and that the parents had failed to demonstrate that any material District Court finding of fact was clearly erroneous. The court also held that the District Court did not terminate the parents' respective parental rights without clear and convincing evidence that the Department made reasonable family preservation and reunification efforts. The court concluded that the District Court correctly terminated the parents' respective parental rights under § 41-3-609(1)(f), MCA. View "In re F.A." on Justia Law

The case involves a group of plaintiffs, including Forward Montana, Leo Gallagher, Montana Association of Criminal Defense Lawyers, and Gary Zadick, who challenged the constitutionality of two amendments to Senate Bill 319 (SB 319) passed by the Montana Legislature during the 2021 legislative session. The amendments, added during a closed-door committee meeting, were unrelated to the original subject of the bill, which was campaign finance. The plaintiffs argued that the amendments violated two sections of the Montana Constitution: Article V, Section 11(1), which requires that a law not be so altered or amended on its passage through the legislature as to change its original purpose, and Article V, Section 11(3), which requires that each bill contain only one subject, clearly expressed in its title.The District Court of the First Judicial District ruled in favor of the plaintiffs, finding that the amendments violated the aforementioned sections of the Montana Constitution. The court permanently enjoined the enforcement of the contested sections of SB 319. The State of Montana, the defendant in the case, did not appeal the decision, effectively acknowledging the unconstitutionality of the bill.The plaintiffs then sought attorney fees under the private attorney general doctrine and the Uniform Declaratory Judgments Act (UDJA). The District Court denied the request, finding that the case was a "garden-variety" constitutional challenge undeserving of attorney fees under the doctrine. The court also denied fees under the UDJA, finding that the circumstances did not make fees equitable.The Supreme Court of the State of Montana reversed the District Court's decision, ruling that the plaintiffs were entitled to attorney fees under the private attorney general doctrine. The court found that the plaintiffs had vindicated important constitutional rights and that private enforcement was necessary due to the State's defense of the unconstitutional law. The court remanded the case to the District Court for calculation of attorney fees. View "Forward Montana v. State" on Justia Law

The parties, Nancy M. Steward and Joseph H. Steward, were married in 2006 and divorced in 2020, with two minor children. The court adopted their Stipulated Parenting Plan (SPP), which included a child support arrangement. After the court adopted the SPP, Joseph requested a modification of child support from the Montana Child Support Services Division (CSSD). CSSD issued a modified order determining Joseph's child support obligation to be less than initially stipulated. Nancy contested the date of commencement of the modified child support, asserting it should not have commenced until the month after she received notification from CSSD of the modified amount.The issue on appeal was whether the District Court abused its discretion in commencing modified child support prior to Nancy receiving actual notification of the modified child support order and amount from CSSD. Nancy argued that under § 40-4-208, MCA, and Healy, child support may only be modified subsequent to her receipt of actual notice of the CSSD modification notice and order. Joseph argued that the statute supported modification of the court’s original child support order for any installments accruing subsequent to when he served Nancy notice of his request for hearing on child support modification with CSSD.The Supreme Court of the State of Montana affirmed the District Court's decision. The Supreme Court ruled that the District Court correctly interpreted the law and appropriately determined the commencement of the modified child support after notice to Nancy of Joseph’s request to modify child support, as permitted by § 40-4-208(1), MCA. The Supreme Court also overruled any interpretation of Healy that limits a district court’s authority to modify child support installments accruing after a party’s receipt of actual notice of the CSSD modification notice and order when that party was appropriately put on notice of the other party’s pursuit of modification of child support well before CSSD’s notice and order. View "In re Marriage of Steward" on Justia Law

In this case, the Supreme Court of Montana reversed and remanded a decision of the Thirteenth Judicial District Court, Yellowstone County. The case involved Saddlebrook Investments (Saddlebrook), assignee of Stuart Simonsen, and Krohne Fund, L.P. (Krohne Fund). Saddlebrook appealed against the district court’s order granting summary judgment in favor of Krohne Fund on Saddlebrook’s claims of malicious prosecution and abuse of process.The Supreme Court found that the district court had erred in applying the doctrine of judicial estoppel to bar Saddlebrook from pursuing its claims. The court noted that a party is not judicially estopped from asserting a cause of action not raised in a reorganization plan or otherwise mentioned in the debtor’s schedules or disclosure statements. However, this does not apply when the bankruptcy trustee is pursuing the action for the benefit of creditors. Once substituted, a bankruptcy trustee is free to pursue the debtor’s nondisclosed claim.In this case, the Trustee had knowledge of Simonsen’s claims and authorized the state court suit. The Supreme Court concluded that because the Trustee had control of Simonsen’s abuse of process claim through the bankruptcy estate, the District Court erred when it estopped Saddlebrook from pursuing that claim. Therefore, Saddlebrook is not judicially estopped from pursuing its malicious prosecution and abuse of process claims against Krohne Fund. View "Saddlebrook Investments v. Krohne Fund" on Justia Law

The Supreme Court of the State of Montana ruled on a case involving a dispute over a proposed ballot initiative related to reproductive rights. In the case, Montanans Securing Reproductive Rights and Samuel Dickman, M.D. (MSRR) sought a declaratory judgment arguing that the Attorney General’s proposed ballot statement for Constitutional Initiative 14 (CI-14) was argumentative, prejudicial, and inaccurate. MSRR also contended that their own proposed ballot statement was clear and impartial and should have been approved by the Attorney General.The court considered whether MSRR could challenge the Attorney General’s ballot statement under relevant statutes and whether the Attorney General had violated certain sections of the Montana Code Annotated by submitting an argumentative, prejudicial, and/or inaccurate ballot statement for CI-14 and by declining to approve MSRR’s proposed ballot statement.The court concluded that the Attorney General’s interpretation of the statute led to an absurd result that abrogated due process. Therefore, MSRR could challenge the Attorney General’s ballot statement under the relevant statutes. The court also found the Attorney General’s ballot statement for CI-14 failed to comply with statutory requirements as it did not fairly present the voters with what was proposed within the Initiative.However, the court disagreed with MSRR’s contention that the Attorney General was required to approve its ballot statement. The court concluded that while the Attorney General’s statement was deficient, he had the statutory authority to determine if MSRR's ballot statement complied with the requirements. The court then crafted a new ballot statement that complied with statutory requirements. View "Montanans Securing Reproductive Rights v. Knudsen" on Justia Law

This case concerns the constitutionality of several Montana election laws. The plaintiffs, a variety of political and human rights organizations, sued the Montana Secretary of State, arguing that certain election laws were unconstitutional. The challenged laws included provisions restricting absentee voting, changing voter registration deadlines, banning paid absentee ballot collection, and revising voter ID requirements.The Montana Supreme Court affirmed the lower court's judgment, finding that each of the challenged statutes were unconstitutional. The Court held that the laws either impermissibly interfered with or minimally burdened the right to vote, a fundamental right under the Montana Constitution. The Court applied a strict scrutiny or a middle-tier analysis, depending on the extent of the burden on the right to vote, and determined that the state failed to show that the laws were the least onerous path to a compelling state interest or were reasonable and more important than the burden on the right to vote. The Court rejected the Secretary of State's argument that the laws were necessary for administrative efficiency and to ensure the integrity, reliability, and fairness of the election process. View "Democratic Party v. Jacobsen" on Justia Law

This case involves a dispute between members of Black Gold Enterprises, LLC, a company formed in 2013, including plaintiff Adam Pummill, plaintiff Kurtis Robertson, and defendant Joshua T. Patterson. The source of the dispute was the payment of rent from Patterson's businesses to Black Gold for the use of a property. Patterson eventually stopped paying rent, leading to the involvement of a receiver, James Galipeau, to manage the property.The Supreme Court of the State of Montana considered the appeal by Patterson against the award of fees to the receiver and his attorney from interplead funds held by the Clerk of Court, arguing that the District Court abused its discretion. Patterson also contested the District Court's decision that the lien on the property, arising from a loan agreement between Patterson's business and Black Gold, was invalid.The Supreme Court, applying the Hickey factors to assess the reasonableness of the receiver's fees, found no abuse of discretion by the District Court. The court concluded that the receiver's work in the complex, time-consuming case was essential, and the sale of the property (Black Gold's only asset) was reasonably executed. The court also found that the District Court had the inherent power to distribute interplead funds for services related to the receivership, rejecting Patterson's claim that the dispersal should have waited until a final disposition.Thus, the Supreme Court affirmed the District Court's decisions regarding the award of the receiver and attorney fees and the method of their payment. The court did not address the issue of the validity of the lien on the property. View "Pummill v. Patterson" on Justia Law