Justia Montana Supreme Court Opinion Summaries

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

The Supreme Court reversed judgments issued by the district court in these consolidated appeals concerning the interpretation of the Montana Residential Mobile Home Lot Rental Act as it related to mobile home owners who had been evicted from their lots, holding that the Act does not allow for a no-cause termination of a periodic tenancy.David and Doreen Lockhart appealed the order issued by the district court upholding the order for possession issued by the justice court and ordering them to vacate and remove all personal property from a mobile home lot owned by Westview Mobile Home Park, LLC. Hydi Cunningham appealed the district court orders following the justice court's judgment and order for possession of property and writ of issuance ordering Cunningham to vacate the mobile home lot she had been renting from Greener Montana Property Management, LLC. The Supreme Court reversed in both causes, holding (1) the Act does not allow a lot-only landlord to terminate a homeowner tenant's month-to-month lease without cause; and (2) therefore, the no-cause terminations of both leases in this case were illegal and invalid. View "Greener Montana Property Management LLC v. Cunningham" on Justia Law

The Supreme Court affirmed in part the judgment of the district court dismissing Plaintiffs' request for class certification, holding that the district court did not abuse its discretion by holding that Plaintiffs' certification request did not meet the requirements of Mont. R. Civ. P. 23.Plaintiff lived in apartment complexes owned and operated by Defendants. Plaintiffs alleged that their leases contained multiple provisions violating Montana law. Plaintiffs sought certification as a class under Rule 23 to include other tenants who entered into similar lease agreements with Defendants. The district court dismissed most claims but denied the dismissal of two claims as to one plaintiff. The district court also denied Plaintiffs' request for class certification. The Supreme Court affirmed in part and remanded for further proceedings, holding that the district court did not err in dismissing Plaintiffs' request for class certification. View "Vulles v. Thies & Talle Management, Inc." on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the order of the district court dismissing Plaintiff’s claims under the Montana Residential Landlord and Tenant Act of 1977 (Landlord-Tenant Act) and alleging violations of restrictive covenants, holding that the district court erred by dismissing Plaintiff’s claims alleging violations of the property covenants’ business use restrictions. Specifically, the Court held (1) where Plaintiff did not allege he was a landlord, tenant or guest or that he otherwise suffered an injury on the premises, Plaintiff could prove no set of facts in support of his claim that would entitle him to relief under the Landlord-Tenant Act; and (2) Plaintiff’s business use allegations satisfied notice pleading requirements, and Plaintiff pled sufficient facts to allege a violation of the covenants based on noxious or offensive activity. View "Cossitt v. Flathead Industries, Inc." on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the order of the district court dismissing Plaintiff’s claims under the Montana Residential Landlord and Tenant Act of 1977 (Landlord-Tenant Act) and alleging violations of restrictive covenants, holding that the district court erred by dismissing Plaintiff’s claims alleging violations of the property covenants’ business use restrictions. Specifically, the Court held (1) where Plaintiff did not allege he was a landlord, tenant or guest or that he otherwise suffered an injury on the premises, Plaintiff could prove no set of facts in support of his claim that would entitle him to relief under the Landlord-Tenant Act; and (2) Plaintiff’s business use allegations satisfied notice pleading requirements, and Plaintiff pled sufficient facts to allege a violation of the covenants based on noxious or offensive activity. View "Cossitt v. Flathead Industries, Inc." on Justia Law

In this landlord-tenant dispute, Landlord complied with the requirements of the Montana Residential Tenants’ Security Deposits Act prior to deducting costs of cleaning from the vacating Tenant’s security deposit, and therefore, Tenant was entitled to a return of her security deposit.Tenant filed an action in justice court asserting that Landlord improperly withheld a portion of her security deposit that the Landlord spent to clean the vacated property, in violation of Mont. Code Ann. 70-25-201(3). The justice court found that Landlord had violated the statute by failing to provide Tenant written notice of cleaning deficiencies or twenty-four hours to clean or fix any issues found during the inspection. The district court reversed. The Supreme Court affirmed, holding that Landlord complied with the requirements of state law before deducing the cost of cleaning from Tenant’s security deposit. View "Hines v. Topher Realty LLC" on Justia Law

The district court did not err in dismissing, for lack of jurisdiction, Tenants’ appeal pursuant to Rule 14 of the Uniform Municipal Court Rules of Appeal to District Court (U. M. C. R. App.) prior to ruling on Tenants’ previously filed motion to proceed in forma pauperis. However, the justice court err in awarding a money judgment in excess of the court’s jurisdiction limit.Tenants appealed an underlying judgment of the justice court. The justice court dismissed the appeal for failure to timely file an appellate brief pursuant to U. M. C. R. App. 14. Tenants filed the notice of appeal together with a motion and application to proceed in forma pauperis. The district court summarily dismissed Tenants’ appeal pursuant to Rule 14(c). The Supreme Court affirmed the dismissal of the appeal for Tenants’ failure to timely file an appellate brief but reversed and remanded for entry of a corrected judgment against Tenants in the amount of $13,426, holding that the justice court erred by awarding a money judgment $8,527 in excess of the court’s $12,000 jurisdictional limit. View "Alto Jake Holdings LLC v. Donham" on Justia Law

Appellants were the owners of multi-unit apartment buildings located in Montana and the property management companies that managed Owners’ apartment complexes during the time relevant to this suit. Appellees were current or former tenants of Owners’ apartment complexes who signed leases for those apartments through the property management companies. Appellees filed a complaint on behalf of themselves and other unnamed plaintiffs alleging that certain provisions included in the leases were prohibited by law. The district court granted Appellees’ motion for class certification. The Supreme Court affirmed, holding that the district court did not abuse its discretion by certifying the class under Mont. R. Civ. P. 23(b)(3). View "Worledge v. Riverstone" on Justia Law

Plaintiff, who leased commercial property from Defendant, filed a complaint with the Montana Human Rights Bureau, alleging that Defendant violated the Montana Human Rights Act (MHRA) by sexually harassing her. The Montana Human Rights Commission ruled that Plaintiff could proceed with her claim because the MHRA “prohibits unlawful discrimination in commercial property transactions, as well as all other real estate transactions.” The district court vacated the Commission’s decision and reinstated the hearing officer’s, ruling that the Commission violated Defendant’s right to due process by analyzing Plaintiff’s action under the MHRA’s real estate provisions. The Supreme Court remanded, directing the district court to resolve the issue that formed the alternate basis for Defendant’s challenge to the Commission’s decision - whether the MHRA’s real estate provisions applied to Plaintiff’s commercial lease. On remand, the district court ruled that the MHRA’s real estate provisions prohibit discrimination in commercial real estate transactions. The Supreme Court affirmed, holding that the MHRA applies to Plaintiff’s commercial lease. View "Bates v. Neva" on Justia Law

Plaintiff rented an apartment from Defendant, a residential hotel. After Plaintiff’s tenancy terminated, she filed suit against Defendant for failing to return her $500 security deposit within thirty days. During the discovery process, Defendant failed to provide informal or formal discovery, resulting in entry of an order compelling discovery and granting Plaintiff her attorney fees as a sanction against Defendant. Plaintiff subsequently filed a motion for sanctions due to Defendant's continued failure to provide discovery. After a hearing at which Defendant did not appear, the court granted the motion for sanctions and entered judgment in favor of Plaintiff. Defendant filed a motion for relief from judgment, which the justice court denied. Defendant filed a notice of appeal, which Plaintiff moved to dismiss, contending that the notice of appeal was not timely filed and that, although the judgment had already been satisfied, Defendant’s failure to file an undertaking required dismissal. The district court granted the motion to dismiss. The Supreme Court reversed, holding that the notice of appeal was timely filed and that no undertaking was required due to the satisfaction of judgment. Remanded. View "Guethlein v. Family Inn" on Justia Law