Justia Montana Supreme Court Opinion Summaries

Parker Noland operated a construction debris removal business in Flathead County, Montana, but was ordered by the Montana Public Service Commission to cease operations due to lacking a required Class D motor carrier certificate. Noland formed PBN LLC and applied for the certificate, but withdrew his application after finding the administrative process—including requests for sensitive financial information by competitors—too burdensome. He then limited his business to activities not requiring the certificate. Subsequently, Noland filed suit in the Eleventh Judicial District Court of Flathead County, seeking a declaratory judgment that two provisions of the Montana Motor Carrier law, known as the public convenience and necessity (PCN) provisions, were unconstitutional under both the Montana and United States Constitutions.The District Court granted summary judgment in favor of the State of Montana and Evergreen Disposal, Inc., which had intervened. The court held that Noland lacked standing to bring an as-applied constitutional challenge, reasoning he sought to vindicate only a future injury and had not shown how the statutes would be unconstitutionally applied to him. However, the court found Noland had standing to bring a facial challenge, but ruled against him, concluding the provisions were not facially unconstitutional because some applicants had previously received Class D certificates.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s rulings de novo. The Montana Supreme Court affirmed the District Court’s decision that Noland lacked standing for an as-applied challenge, holding that he failed to demonstrate a concrete injury or how the statutes were applied to him. The Court reversed the District Court’s denial of Noland’s facial challenge, holding that he had standing to challenge the statute’s constitutionality on its face, since the procedural requirements themselves could constitute injury regardless of outcome. The case was remanded for further consideration of the facial constitutional challenges. View "Noland v. State" on Justia Law

An individual was accused of sexually assaulting his fiancée’s seven-year-old niece while visiting the child’s home. The child reported the incident to her sibling, who then informed their mother. Law enforcement conducted interviews with the child, her family, and the accused, and collected physical evidence, including a blanket identified by the child. DNA analysis of the blanket matched the accused. The accused was charged with sexual assault and sexual intercourse without consent. At trial, the child, family members, law enforcement, and crime lab personnel testified. The defense focused on challenging the investigation rather than the child’s credibility. The accused was found guilty on both charges.After conviction, the accused appealed directly to the Supreme Court of Montana, raising several issues including claims of ineffective assistance of counsel. The Supreme Court of Montana affirmed the conviction. The accused then sought postconviction relief in the District Court of the Sixteenth Judicial District, Fallon County, arguing that his trial counsel was ineffective, particularly in the cross-examination of a law enforcement officer. The District Court denied the petition, finding the claims both procedurally barred and without merit. The defense attorney was later disbarred and did not participate in the postconviction proceedings.The Supreme Court of the State of Montana reviewed the denial of postconviction relief. The Court held that the accused did not establish ineffective assistance of counsel under the standard set by Strickland v. Washington. The Court found that the defense counsel’s cross-examination strategy fell within the wide range of reasonable professional assistance and did not prejudice the outcome, given the strong physical evidence and the content presented to the jury. The Supreme Court of Montana affirmed the District Court’s denial of postconviction relief. View "Kapps v. State" on Justia Law

In this case, a man was charged with multiple felony counts arising from sexual abuse allegations involving two victims: his adopted daughter, who disclosed in 2021 that she had been repeatedly molested by him from age 10 to 14, and his sister-in-law, who reported a 2009 incident in which he sexually assaulted her when she was 17. After investigations and forensic interviews, the defendant was charged with one count of felony sexual assault and three counts of felony sexual intercourse without consent. The charges related to both victims were tried together before a jury.Prior to trial in the Thirteenth Judicial District Court, Yellowstone County, neither party objected to the joinder of charges or moved to sever them. During voir dire, a Yellowstone County Undersheriff, whose office had investigated the case, was seated as a juror without objection or peremptory strike from either party. During trial, the State raised concerns about the Undersheriff’s impartiality, but the defendant’s counsel argued against removing him, and the District Court declined any implied motion to strike. The jury found the defendant guilty on all counts, and he was sentenced to 100 years in prison.On appeal to the Supreme Court of the State of Montana, the defendant raised three issues: whether the presence of the Undersheriff as a juror or the joinder of charges should be reviewed under the plain error doctrine, and whether he received ineffective assistance of counsel for failing to object to either issue. The Supreme Court held that neither issue merited plain error review because the defendant had affirmatively waived challenges below, and there was no manifest miscarriage of justice. The Court further determined that the record was insufficient to review the ineffective assistance of counsel claim on direct appeal, leaving that question for postconviction proceedings. The Court affirmed the conviction. View "State v. Soapes" on Justia Law

A convenience store employee in Plentywood, Montana, discovered a small bag containing methamphetamine on the store floor during her shift and called law enforcement. Surveillance footage was reviewed, and a deputy identified Shawn Andersen as a person who had been in the area where the bag was found. The deputy did not watch all of the footage but focused on the time around when the bag appeared. Later, another bag of methamphetamine was found in Andersen’s pocket when he was arrested at the county jail. Both baggies tested positive for methamphetamine. At trial, the State’s case relied heavily on the surveillance footage and related testimony to link Andersen to the drugs found at the store.The Fifteenth Judicial District Court in Sheridan County presided over Andersen’s jury trial. During deliberations, the jury asked to review the surveillance footage. While they watched, the State’s legal assistant audibly commented, “There it is,” as the video showed the disputed moment. Andersen’s counsel immediately moved for a mistrial, arguing that the comment could have improperly influenced the jury. The District Court denied the motion, and the jury convicted Andersen on all counts. Andersen was sentenced to a combination of suspended and consecutive sentences for possession of dangerous drugs and possession of drug paraphernalia.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by denying Andersen’s motion for mistrial. The Supreme Court held that the legal assistant’s comment constituted improper third-party jury misconduct, creating a presumption of prejudice. Because the District Court neither declared a mistrial nor conducted an inquiry to rebut this presumption, the Supreme Court found this to be an abuse of discretion. The conviction was reversed, and the case was remanded for a new trial on all counts. View "State v. Andersen" on Justia Law

A married couple in Montana accumulated substantial assets and debts over a 31-year marriage, primarily through farming and related businesses. When the marriage ended, disputes arose over the valuation and distribution of assets, especially a 25% interest in a family ranch partnership held by the husband. The wife, who had managed bookkeeping, sought full financial disclosure, which the husband resisted. The court ultimately found the wife’s expert valuation of the partnership more credible and ordered an equalization payment schedule requiring the husband to pay the wife monthly installments over 17 years, with a provision allowing transfer of the partnership interest if payments were not made.Following the initial decree, the husband failed to make any payments, attempted to unilaterally transfer the partnership interest, and also moved funds from accounts awarded to the wife. During post-judgment proceedings in the Seventh Judicial District Court, the wife uncovered delays, asset transfers, and changes in the partnership agreement that reduced the value and control associated with the 25% interest. The husband argued he had a choice between payments or the transfer, but the court found his actions obstructive and not in compliance with its orders. The court found the partnership interest had been materially altered, making it inequitable for the wife to accept in satisfaction of the judgment.The Supreme Court of the State of Montana affirmed the District Court’s rulings, holding that the husband was properly found in contempt for failing to comply with the decree and for obstructive conduct. The Supreme Court also upheld the District Court’s modification of the property distribution, striking the provision allowing transfer of the partnership interest and ordering restoration of funds to the wife. The Court concluded these actions were within the District Court’s equitable powers and supported by the evidence. View "In re Marriage of Steinbeisser" on Justia Law

A motor vehicle accident occurred in Butte, Montana, when a snow grader operated by a city employee backed into a sedan driven by the plaintiff at a very low speed. The grader was engaged in snow removal operations, reversing in the process, and displaying flashing lights and a backup alarm. The plaintiff, after passing the grader, positioned her car behind it and came to a stop. The grader then struck her vehicle. Testimony at trial included differing accounts of whether warning devices were observable and whether the plaintiff was attentive to the grader’s movements. The plaintiff claimed injuries resulting from the collision, though evidence regarding the severity and causation of her injuries was contested.The Second Judicial District Court, Butte-Silver Bow County, conducted a jury trial. The jury found the plaintiff 54% negligent and the city 46% negligent, barring her recovery under Montana’s comparative negligence statute. The plaintiff moved for a new trial, arguing irregularity in the proceedings and insufficient evidence to support the verdict. The District Court granted the motion for a new trial on both grounds, relying on statements made by the city’s counsel during closing arguments and finding the evidence did not support the jury’s comparative negligence finding.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in granting a new trial. The Supreme Court held that the plaintiff had not preserved her objections to alleged irregularities in the proceedings because she failed to object contemporaneously or through a specific motion in limine. The Court also determined that the plaintiff had judicially admitted that comparative negligence was a factual issue for the jury, thereby waiving her right to challenge the sufficiency of the evidence. Furthermore, the Supreme Court found that there was substantial evidence supporting the jury’s verdict. The Supreme Court reversed the District Court’s order granting a new trial and reinstated the jury’s verdict. View "Shahood v. Butte-Silver Bow" on Justia Law

A man was originally convicted of felony burglary for breaking into a bar in Montana and received a twenty-year prison sentence with five years suspended. After serving time and being released, he began the suspended portion of his sentence. The State later filed a petition to revoke his suspended sentence based on several alleged probation violations, including failing to register as a sex offender. While represented by counsel, he admitted to the failure-to-register allegation, and the court set a dispositional hearing to determine the consequences.The Montana Ninth Judicial District Court presided over the revocation proceeding. At the dispositional hearing, the man appeared without counsel after his attempts to retain private counsel failed and after his appointed counsel was allowed to withdraw. He requested reappointment of a public defender but none was assigned before the hearing. The court conducted no inquiry into whether he knowingly and voluntarily waived his right to counsel and proceeded with resentencing him to five years in prison. The man appealed, arguing he was denied his right to counsel at a critical stage and that he did not waive that right.The Supreme Court of the State of Montana held that the district court erred by conducting the dispositional hearing and resentencing without counsel and without a valid waiver of the right to counsel. The Court found this to be a structural error requiring automatic reversal, noting the man’s consistent efforts to obtain representation and the absence of any meaningful waiver inquiry. The Court vacated the dispositional order and remanded for a new hearing at which the man must be represented or must validly waive representation. The Court declined to resolve his request to withdraw his earlier admission, leaving it for further proceedings if appropriate. View "State v. Lambert" on Justia Law

A man was charged with felony criminal possession of dangerous drugs after being found with methamphetamine and paraphernalia following a single-vehicle crash in Sanders County, Montana. During his hospital treatment after the crash, law enforcement recovered drugs and a pipe from his clothing, and further investigation at the scene yielded additional drugs, firearms, and related items. He was prosecuted for possession of dangerous drugs, while several other related charges were dismissed prior to trial.At his jury trial in the Twentieth Judicial District Court, the defendant participated in the morning proceedings but failed to return after the lunch break. The court, over his attorney’s objection, continued the trial in his absence under Montana law, which allows the trial to proceed if a felony defendant is voluntarily absent and the crime is not punishable by death. The jury found him guilty while he was absent. He was later arrested and sentenced to five years in prison. On appeal, he argued that the trial court erred by proceeding in his absence and that his attorney was ineffective for not moving to suppress evidence found in his clothing.The Supreme Court of the State of Montana held that the district court did not err in resuming the trial in the defendant’s absence, concluding that he voluntarily absented himself and thereby waived his right to be present. The Court further held that, when voluntary absence is established, there is no need for the trial court to exercise additional due diligence to secure a defendant’s presence for the verdict. The Court also determined that the record was insufficient to review his ineffective assistance of counsel claim on direct appeal. The district court’s judgment was affirmed. View "State v. McKnight" on Justia Law

A proposed constitutional initiative in Montana sought to require that Supreme Court and district court elections remain nonpartisan, reflecting a legal tradition in Montana since 1935. The proponent organization submitted both the initiative and a draft explanatory ballot statement to the Secretary of State, which was then reviewed by the Legislative Services Division. The organization’s draft statement explained the initiative would constitutionalize the existing statutory requirement, making future changes possible only by constitutional amendment.After the statutory review process, the Attorney General concluded the initiative met legal sufficiency but chose to substitute his own revised ballot statement, claiming the revision would improve clarity and better inform voters of the initiative’s effects. He did not detail any statutory deficiencies in the proponent's original statement. The proponent organization, joined by another organization interested in nonpartisan judicial elections, challenged the Attorney General’s authority to revise the statement without a written determination that the original was not clear or impartial. The Attorney General responded that only the proponent of the specific initiative could bring such a challenge.The Supreme Court of the State of Montana first found that only the proponent organization had statutory standing to pursue this challenge, dismissing the second organization from the proceeding. The Court then held that the Attorney General lacked authority to revise the proponent’s ballot statement because he had not made the required written determination that the original was statutorily noncompliant. The Court concluded that the proponent’s original statement was clear, impartial, and met statutory requirements. Accordingly, the Court certified the proponent’s original statement to the Secretary of State and ordered its use in the ballot process. View "MFIJ v. Knudsen" on Justia Law

On November 23, 2019, the appellant was driving an Acura with three children, including her own, when her vehicle was rear-ended by another driver. Witnesses testified that after this collision, the Acura accelerated rapidly, left the road, then reentered it and collided head-on with a Yukon. The crash resulted in the death of one child and serious injury to another. At the time, the appellant’s driver’s license was suspended, and she was not permitted unsupervised contact with her children due to prior involvement with Child Protective Services.The State of Montana charged the appellant with multiple offenses, including negligent homicide, criminal endangerment, and driving with a suspended license. The Thirteenth Judicial District Court, Yellowstone County, presided over a six-day jury trial. The jury found the appellant guilty on all counts. The appellant’s defense argued that the initial rear-end collision was the cause of the subsequent crash, while the prosecution maintained that the appellant’s actions, including improperly restraining the children and fleeing the scene, were negligent and directly led to the fatal incident.On appeal to the Supreme Court of the State of Montana, the appellant challenged the sufficiency of the evidence for the negligent homicide conviction, asserted ineffective assistance of counsel, objected to the admission of certain expert testimony, sought a mistrial based on inadmissible testimony, and disputed the order of restitution for lost wages. The Montana Supreme Court affirmed the District Court’s judgment. It held that there was sufficient evidence for the negligent homicide conviction, found no ineffective assistance of counsel, ruled that the District Court did not abuse its discretion in admitting expert testimony or denying a mistrial, and upheld the restitution award, finding it legally appropriate under Montana law. View "State v. Mullendore" on Justia Law