Justia Montana Supreme Court Opinion Summaries

David Stanley was convicted in the Montana Eighteenth Judicial District Court, Gallatin County, for felony criminal possession of methamphetamine. Stanley appealed, arguing that the District Court erred in denying his motion to suppress drug evidence found during a post-arrest jail intake search. The key issue was whether the police had the requisite particularized suspicion to justify the investigative stop that led to Stanley's arrest and the subsequent discovery of the drugs.In the lower court, the District Court found that the police lacked particularized suspicion to justify the stop. However, it ruled that the "attenuation doctrine" exception to the exclusionary rule applied, meaning the drug evidence did not need to be suppressed despite the initial unlawful stop. Stanley then pled guilty under a plea agreement that reserved his right to appeal the suppression ruling.The Montana Supreme Court reviewed the case and held that the police had a reasonable particularized suspicion to stop Stanley. The court noted that the police received an anonymous tip about a fugitive, Daniel Sobrepena, who was reportedly wearing a distinctive red curly wig to avoid arrest. When Officer Ahmann saw Stanley wearing a similar wig in the area described, it was reasonable to suspect he might be Sobrepena or have information about him. The court found that the initial stop and subsequent questioning were justified and conducted within a reasonable scope and duration.The Montana Supreme Court concluded that the District Court reached the correct result in denying the motion to suppress, albeit for different reasons. The court affirmed Stanley's conviction, holding that the investigative stop was lawful and the resulting drug evidence was admissible. View "State v. Stanley" on Justia Law

David Rodman Ash petitioned to dissolve his marriage with Bree Elliot in September 2022. The Eleventh Judicial District Court, Flathead County, issued a decree dissolving the marriage and dividing the marital property on July 13, 2023. Ash moved to amend the decree, arguing that the court had disregarded his labor contributions in constructing a shared home and his poor health and limited future income prospects. The District Court denied his motion on October 2, 2023. Ash appealed the allocation of the marital assets.The District Court awarded 80% of the value of the Eastman Property to Elliot and 20% to Ash. Ash argued that the distribution was inequitable, given his significant nonmonetary contributions to the construction and maintenance of the marital properties. The court found that Elliot had invested $1,150,000 in the Eastman Property, while Ash's interest was valued at $325,385, including his initial investment and documented cash contributions.The Supreme Court of the State of Montana reviewed the case. The court held that the District Court abused its discretion by diminishing the value of Ash's nonmonetary contributions to the marital estate. The court noted that Ash's labor in constructing the Lodge and maintaining the properties was significant and should have been considered in the distribution of the marital assets. The court also found that the District Court erred by seeking to return the parties to their premarital positions, which is not a factor under Montana law for equitable apportionment.The Supreme Court reversed the distribution of the marital assets and remanded the case to the District Court for further proceedings consistent with its opinion. View "In re Marriage of Ash" on Justia Law

The case involves the Parrot Ditch Company (PDC) and its four water rights in the Jefferson River. PDC delivers water to its shareholders through the Parrot Ditch, which runs parallel to the Jefferson River in Basin 41G. The ditch was constructed in 1895, and PDC was organized in 1916 to manage and distribute water through the ditch. PDC issued shares that correspond to water entitlements, and the company stopped issuing shares in 1981. Two of the water rights were litigated in 1926 in the Carney case, which established shareholders' interests in PDC and referenced priority dates and volumes for two water rights.The Montana Water Court issued a Temporary Preliminary Decree in 1989, which included abstracts for PDC's four water rights. PDC objected to the place of use for one of the rights in 1990 and later requested amendments to the flow rate and irrigated acreage. The Water Court adopted various recommendations over the years, ultimately increasing the place of use to 6,710.78 acres. In 2018, the Water Court issued a Preliminary Decree, and PDC objected, seeking a larger service area and other corrections. Objectors (AMD) also raised objections to various elements of PDC's water rights.The Montana Supreme Court reviewed the case and affirmed the Water Court's decisions. The Court held that PDC failed to provide sufficient evidence to support a larger service area beyond 6,710.78 acres. The Court also found that the Carney decision did not adjudicate water rights and that AMD provided sufficient evidence to overcome the prima facie status of PDC's claims regarding the Townsend and Methodist rights. Finally, the Court upheld the Water Court's modification of the Nolte flow rate to 100 cfs, based on the lack of notice to affected water users when PDC requested the amendment in 1997. View "Parrot Ditch v. Ashcraft" on Justia Law

In 2018, Robert Spoklie purchased land neighboring the property of the Paul Phillip Bardos and Mary L. Bardos Revocable Trust (Bardos) near Kalispell, Montana. Spoklie divided his land into smaller parcels for residential development and entered into an Easement Agreement with Bardos, granting mutual easements for access. Spoklie's easement allowed him to use a 60-foot-wide path through Bardos's property for ingress, egress, and utility installation. Spoklie used this easement to transport construction equipment, sometimes parking it temporarily within the easement boundaries, which Bardos contested.The Eleventh Judicial District Court, Flathead County, denied Bardos's request for a preliminary injunction and later granted summary judgment in favor of Spoklie. The court found that Spoklie's activities, including temporary parking and unloading of construction equipment within the easement, were within the scope of the easement agreement. Bardos appealed, arguing that material facts were in dispute and that Spoklie's actions constituted trespass and nuisance.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The court held that the easement's language allowed for temporary parking and unloading of construction equipment as reasonably necessary for ingress and egress. The court also found that Spoklie's actions did not constitute trespass or nuisance since they were within the scope of the easement. Additionally, the court noted that the issue of Spoklie's proposed mailbox structure was not ripe for adjudication as no substantial steps had been taken toward its construction. The court concluded that there were no genuine issues of material fact and that the District Court correctly applied the law. View "Bardos Revocable Trust v. Spoklie" on Justia Law

Laura Marie Obert, a former Broadwater County Commissioner, was investigated by the Montana Department of Justice Division of Criminal Investigation (DCI) in 2015 for allegedly receiving unlawful overtime pay and potential ethics violations. In 2016, Obert entered a deferred prosecution agreement with the Assistant Attorney General, agreeing to repay the excess wages and abstain from voting on matters where she had a conflict of interest. In 2019, based on new allegations of violating the agreement, Obert was charged with felony theft and misdemeanor official misconduct. The district court dismissed these charges in 2021, finding Obert had complied with the agreement and there was insufficient evidence for the misconduct charge.Obert then sued the State of Montana and Broadwater County Attorney Cory Swanson, alleging breach of contract, bad faith, due process violations, and malicious prosecution. The First Judicial District Court dismissed her claims, leading to this appeal.The Montana Supreme Court reviewed the case and made several determinations. It reversed the lower court's dismissal of Obert's breach of contract and good faith and fair dealing claims, holding that these claims were not time-barred and did not accrue until the criminal charges were dismissed. However, the court affirmed the dismissal of Obert's bad faith claim, finding no special relationship existed between Obert and the State that would support such a claim. The court also upheld the dismissal of the malicious prosecution claim, ruling that Swanson was protected by prosecutorial immunity as he acted within his statutory duties. Lastly, the court affirmed the dismissal of the due process claim, concluding that Obert's procedural due process rights were not violated as the State followed proper procedures in charging her and the district court provided an appropriate forum to address the alleged breach of the agreement. View "Obert v State" on Justia Law

D.A. Davidson & Co. initiated an interpleader action to resolve a dispute over funds held in an investment account for Whitefish Masonic Lodge 64. The Grand Lodge of Ancient Free and Accepted Masons of Montana revoked Whitefish Lodge's charter and claimed the funds. Donald Slaybaugh, a member of Whitefish Lodge, contested the revocation and the transfer of funds, arguing that the Grand Lodge did not follow proper procedures.The Eleventh Judicial District Court, Flathead County, granted summary judgment in favor of the Grand Lodge, dismissing Slaybaugh's cross claims. The court determined that Slaybaugh lacked standing to bring claims against the Grand Lodge on behalf of Whitefish Lodge or in his individual capacity. The court found that Whitefish Lodge, having had its charter revoked, no longer existed as a legal entity capable of bringing claims. Additionally, the court concluded that Slaybaugh did not have the authority to act on behalf of the Lodge, as he was not an elected officer and his previous authority to oversee the investment account had been revoked.The Supreme Court of the State of Montana affirmed the District Court's decision. The court held that Slaybaugh did not have standing to bring claims on behalf of Whitefish Lodge because the Lodge was dissolved and could not appear in litigation. The court also rejected Slaybaugh's argument that he had standing as a fiduciary or under a derivative action, noting that he did not meet the pleading requirements for a derivative action and that his fiduciary authority had been revoked. Finally, the court found no evidence to support claims of fraud or arbitrary action by the Grand Lodge in revoking the Lodge's charter. View "D.A. Davidson v. Slaybaugh" on Justia Law

In this case, Billy Lee Henderson appealed the denial of his petition for postconviction relief from his 2019 conviction for Aggravated Sexual Intercourse Without Consent (SIWC). The conviction stemmed from a series of assaults on Jane Doe over five days in April 2018. Henderson was found guilty of multiple related offenses, including witness tampering and protective order violations. He was sentenced to 75 years in prison, with 25 years suspended.Henderson's petition for postconviction relief was based on newly discovered evidence, specifically Doe's recantation of her trial testimony. Doe had initially testified that Henderson forced her to have non-consensual sex, but later, in recorded conversations and an interview, she claimed the intercourse was consensual and that she had been pressured by authorities to testify otherwise. The District Court of the Fourth Judicial District, Missoula County, denied the petition, finding Doe's recantations inconsistent and lacking credibility, especially given Henderson's history of witness tampering.The Montana Supreme Court reviewed the case, focusing on whether the District Court applied the correct standards in assessing the newly discovered evidence. The Supreme Court affirmed the lower court's decision, holding that the District Court did not err in its evidentiary assessment. The court emphasized that Doe's recantations were not sufficiently credible or weighty to warrant a new trial, especially in light of her inconsistent statements and the context of Henderson's attempts to influence her testimony. The Supreme Court concluded that the District Court's findings were supported by substantial evidence and were not clearly erroneous. View "Henderson v. State" on Justia Law

Richard Shreves, while incarcerated at the Montana State Prison, received medical care and subsequently filed a complaint against Dr. Paul Rees with the Board of Medical Examiners at the Montana Department of Labor and Industry (DLI). The Correctional Health Care Review Team (CHCRT) reviewed the complaint and found no violation of law or practice rules by Dr. Rees, leading to the closure of the complaint without forwarding it to the Board of Medical Examiners. Shreves then petitioned for judicial review, challenging the CHCRT's decision and the lack of detailed findings in their response.The First Judicial District Court dismissed Shreves's petition, concluding that he lacked standing. The court reasoned that the CHCRT process did not implicate Shreves's legal rights, as it was designed to screen complaints for potential disciplinary action against the healthcare provider, not to adjudicate the complainant's rights.The Supreme Court of the State of Montana affirmed the District Court's dismissal. The court held that Shreves did not have standing to petition for judicial review because the statute governing the CHCRT process did not authorize judicial review at the behest of the complainant. The court also found that Shreves's constitutional challenge to the CHCRT's authority did not confer standing, as he lacked a personal stake in the outcome. Additionally, the court determined that any alleged mishandling of filings by the District Court did not affect the outcome, as the legal conclusions regarding standing were correct. View "Shreves v. Montana Dept. of Labor" on Justia Law

Tanya Twoteeth was convicted by a jury in the First Judicial District Court of Montana for Tampering with Witnesses and Informants. The case arose from an investigation into car thefts, where Tanya's daughter, Desirae, was a suspect. Desirae's aunt, Roberta, initially reported seeing Desirae in a stolen vehicle. Before Desirae's trial, she made calls to Tanya, discussing concerns about Roberta's potential testimony. Tanya assured Desirae that she would speak to Roberta. Subsequently, Roberta changed her statement, claiming she did not see anyone in the car.The District Court admitted Roberta's initial statement to police as non-hearsay, over Tanya's objection. Tanya was charged with tampering based on the recorded calls and Roberta's changed testimony. Tanya moved to dismiss the case for insufficient evidence, but the District Court denied the motion, finding enough evidence for the jury to decide.The Montana Supreme Court reviewed the case. It held that the District Court did not err in admitting Roberta's statement as non-hearsay, as it was used to show the trajectory of the investigation and not for the truth of the matter asserted. The court also found sufficient evidence to support Tanya's conviction. The recorded calls and the change in Roberta's testimony provided a reasonable basis for the jury to infer that Tanya had influenced Roberta. The court affirmed the conviction, concluding that the evidence supported the jury's verdict beyond a reasonable doubt. View "State v. Twoteeth" on Justia Law

Wes Lee Whitaker was convicted by a jury of sexual intercourse without consent (SIWC), incest, and sexual assault. The case involved allegations that Whitaker sexually abused his stepdaughter, L.M., who was a young child at the time. The abuse was reported by L.M.'s mother, Jessica, after she observed suspicious behavior and L.M. disclosed inappropriate touching by Whitaker. L.M. provided detailed accounts of the abuse during a forensic interview and a medical examination, although she could not recall many details during the trial.The District Court of the Fourth Judicial District, Missoula County, presided over the trial. Whitaker raised several issues on appeal, including the admission of testimony via video from a federal prisoner, the admission of L.M.'s prior statements, and a claim of double jeopardy regarding his convictions for SIWC and sexual assault. The District Court allowed the video testimony due to COVID-19 concerns and admitted L.M.'s prior statements as inconsistent with her trial testimony.The Supreme Court of the State of Montana reviewed the case. The court held that the District Court did not violate Whitaker's confrontation rights by allowing the video testimony, as the decision was justified by the pandemic and the witness's incarceration status. The court also found no abuse of discretion in admitting L.M.'s prior statements, as her inability to recall details at trial constituted a material inconsistency. However, the court agreed with Whitaker and the State that his convictions for SIWC and sexual assault violated double jeopardy, as they were based on the same act. Consequently, the court reversed the sexual assault conviction and remanded for entry of an amended judgment, while affirming the other convictions. View "State v. Whitaker" on Justia Law