Justia Montana Supreme Court Opinion Summaries

A high school student attended Colstrip High School, participating in extracurricular activities, including basketball, until academic difficulties during the COVID-19 pandemic led him to repeat his sophomore year. His family consulted with the school’s athletic director, who suggested, but did not confirm, that he would be eligible to play basketball as a fifth-year senior. After repeating a grade, the student regained academic eligibility and continued to play basketball. However, before his fifth year, the school principal informed the student he would be ineligible to participate under the Montana High School Association’s (MHSA) “Semester Rule,” which limits eligibility to four consecutive years after entering ninth grade. The student’s family appealed to the MHSA Executive Board for a waiver, but the Board denied the request without providing written reasons directly to the family.The family filed suit in the Sixteenth Judicial District Court, seeking judicial review and declaratory and injunctive relief, arguing that the MHSA’s actions deprived the student of his constitutional right to participate in extracurricular activities and violated due process. The District Court denied their motion for a preliminary injunction, finding no constitutional right to participate in extracurricular sports, and later granted summary judgment to the MHSA, concluding the case was moot after the student’s graduation and the season’s end.The Supreme Court of the State of Montana reviewed the case. It held that the matter was not moot under the public interest exception to mootness, given the recurring nature and public importance of MHSA eligibility determinations. The Court reversed the District Court’s summary judgment, holding that Montana students have a constitutionally protected interest in participating in offered extracurricular activities and that the MHSA failed to provide constitutionally sufficient due process. The Supreme Court remanded the case for entry of declaratory relief, specifying that due process requires notice, a meaningful opportunity to be heard, and a written decision sufficient for judicial review. View "Hert v. MHSA" on Justia Law

A man was convicted in 2012 of felony murder following the death of a two-year-old child for whom he was the primary caretaker. The child had suffered severe head injuries consistent with nonaccidental trauma and was pronounced brain dead after being transported to a hospital. Law enforcement interviewed the man, who was advised of his Miranda rights and did not confess but offered alternative explanations for the injuries. He received a 100-year sentence without parole.After his conviction, the man filed a petition for postconviction relief in the Montana Eighth Judicial District Court, primarily alleging ineffective assistance of counsel on several grounds, including failure to move to suppress his statements to police, not hiring an independent medical expert, conceding in closing argument that the child’s injuries were not accidental, and not allowing him to testify. Initially denied without counsel, the case was remanded for appointment of counsel and a new hearing. With counsel, he renewed his claims and added an allegation that the State had not produced certain discovery related to a drug investigation at the residence. After a second evidentiary hearing, the District Court denied all claims, finding either they were procedurally barred, unsupported by evidence, or reflected reasonable trial strategy.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s findings for clear error and its legal conclusions de novo. Applying the two-prong test from Strickland v. Washington, the Supreme Court held that the man failed to demonstrate deficient performance by either his trial or appellate counsel, or resulting prejudice. The Court found that counsel’s actions were reasonable strategic decisions under the circumstances and that no meritorious claims for ineffective assistance or other postconviction relief were established. Accordingly, the Supreme Court affirmed the District Court’s denial of the petition. View "Hyslop v. State" on Justia Law

Four children were removed from their parents’ custody after reports of exposure to domestic violence and methamphetamine use. Both parents tested positive for methamphetamine, and the father had a recent suicide attempt and a history of violent incidents, including an incident where he was charged with strangulation. The children had previously tested positive for methamphetamine and had been removed from the home in a prior proceeding but were later returned after the parents complied with treatment plans. Following the 2023 removal, the father was offered a court-approved treatment plan with requirements such as chemical dependency treatment, drug testing, mental health counseling, and stable housing and income. The father failed to meaningfully engage with the treatment plan for nearly a year, continued to use methamphetamine, and was inconsistent with drug testing and other requirements. Despite eventual partial compliance, concerns remained regarding his substance use, lack of protective capacity, and minimal progress addressing mental health issues.The Thirteenth Judicial District Court in Yellowstone County adjudicated the children as youths in need of care and approved the Department’s petitions for removal and temporary custody. The father stipulated to the treatment plan, but failed to comply with its requirements. The Department petitioned for termination of parental rights based on chronic abuse/neglect and failure to complete the treatment plan. Following a multi-day hearing, the District Court found the father’s unfitness was unlikely to change within a reasonable time, given his delayed engagement, ongoing substance use, and inability to protect the children from their mother’s influence.The Supreme Court of the State of Montana affirmed the District Court’s decision. The Court held that the father waived his right to challenge the appropriateness of the treatment plan by failing to object to it when it was created. The Court found that substantial evidence supported termination under § 41-3-609(1)(f), MCA, and the District Court was not required to consider guardianship before termination. View "Matter of A.J.C." on Justia Law

The decedent died intestate in January 2018, survived by his spouse and two adult children from a prior marriage. The spouse successfully petitioned to be appointed personal representative of the estate. After several years of inactivity in the probate proceedings, the spouse’s attorney withdrew due to her lack of cooperation. The decedent’s son then petitioned to have the spouse removed as personal representative, alleging breach of fiduciary duty. The District Court granted the petition, replaced the spouse with the son as personal representative, and found the spouse liable for any damages resulting from her breach of duty.Subsequently, the son petitioned the District Court for determination of heirs, adjudication of intestacy, approval of final account, and distribution of the estate, alleging the spouse had improperly transferred funds to herself. The son proposed that the spouse receive certain assets already in her possession, and that the remainder of the estate be divided between the two children. Notice was sent to the spouse, but she did not appear or object. The District Court distributed the estate according to the son’s proposal and discharged him as personal representative. Over a year later, the spouse, with new counsel, moved under Montana Rule of Civil Procedure 60(b) to set aside the decree, arguing lack of proper notice and improper distribution. The District Court denied the motion, finding she had not demonstrated grounds for relief under Rule 60(b).The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s order. The Supreme Court held that the District Court did not abuse its discretion in denying the spouse’s Rule 60(b) motion because proper notice was given, the spouse was not entitled to relitigate issues via Rule 60(b) that should have been raised on direct appeal, and her arguments did not establish the specific grounds required for relief. View "Estate of: Lea" on Justia Law

A father and mother, married in 2009, have a child, R.A.A., who was born in 2015. The family lived in Colorado before moving to Montana around 2020. The father frequently travels for work, while the child was homeschooled in Montana. In June 2022, R.A.A. began living in the Netherlands with the mother and attended public school there. After a brief attempt to reconcile in the United States, the mother and child returned to the Netherlands without the father’s consent. The mother initiated divorce and custody proceedings in the Netherlands in February 2024. The father later filed a petition in the Netherlands for the child’s return under the Hague Convention, but both the District Court and the Court of Appeal of The Hague denied his petition, finding that although the child’s removal was wrongful, she had become settled in the Netherlands.The father then filed an emergency motion for temporary custody and a petition for a permanent parenting plan in the Nineteenth Judicial District Court, Lincoln County, Montana, in September 2025. The Montana District Court dismissed both filings, concluding it lacked jurisdiction because Montana was not R.A.A.’s “home state” under Montana law, as she had not lived there for more than two years, and that it must recognize and enforce the custody determination from the Netherlands. The father appealed to the Supreme Court of the State of Montana.The Supreme Court of the State of Montana affirmed the District Court’s decision. It held that Montana courts do not have jurisdiction to make an initial child custody determination when the state is not the child’s “home state” as defined by the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), and that Montana courts must recognize and enforce valid foreign judgments in such matters. The order of dismissal without prejudice was deemed a final, appealable order. View "IN RE THE PARENTING OF R.A.A." on Justia Law

A driver was stopped by a county deputy after allegedly committing traffic violations that led the officer to suspect impaired driving. The officer noted possible signs of intoxication and requested that the driver submit to alcohol testing, which the driver refused. Under Montana’s implied-consent law, the officer seized the driver’s license and issued a notice of automatic six-month suspension. The next day, the driver petitioned for judicial review, arguing that the officer lacked sufficient suspicion for the stop and the test requests.The Eighth Judicial District Court set an evidentiary hearing, but delays resulted from a combination of the petitioner’s request for a continuance due to jury duty and procedural orders requiring both parties to file briefs before a hearing could be held. The petitioner filed a brief, but the State did not, leaving the hearing vacated. Before the court ruled, the six-month suspension expired and the license was reinstated. When the petitioner moved to reset the hearing, the State moved to dismiss the case as moot, arguing that the only relief available was the return of the license, which had already occurred. The District Court agreed and dismissed the petition as moot.The Supreme Court of the State of Montana reviewed whether the expiration of the suspension and reinstatement of the license rendered the case moot. The court held that the case was not moot because the petitioner’s timely challenge could still result in relief, such as removal of the suspension from his driving record and potential reimbursement of reinstatement fees. The court found that the statute contemplates judicial review even after the suspension period if the challenge was timely filed and pursued. The Supreme Court reversed the District Court’s dismissal and remanded the case for further proceedings. View "Kalafat v. State" on Justia Law

The defendant was arrested in October 2021 and charged with robbery and disorderly conduct. Initial proceedings raised concerns about his mental fitness, and he was evaluated at Montana State Hospital. Multiple evaluations between December 2021 and April 2023 determined that he was unfit to proceed, largely due to his refusal to take medication. In October 2022, the court authorized involuntary medication following a Sell v. United States hearing. By April 2023, the defendant was found fit to proceed, and at a subsequent hearing, he was arraigned and entered a plea of not guilty to both charges. In July 2023, a plea agreement was reached where the defendant pleaded guilty to attempted robbery in exchange for dismissal of the disorderly conduct charge.The Fourth Judicial District Court accepted the defendant’s guilty plea after confirming it was entered voluntarily, knowingly, and intelligently. At the change of plea hearing, the defendant expressed concern about a potential speedy trial violation and asked to have it noted for the record. The court acknowledged the statement but declined to accept briefing on the issue, and neither the defendant nor his counsel filed a motion or objected further. The defendant was subsequently sentenced to ten years, with credit for time served.On appeal, the Supreme Court of the State of Montana considered whether the lower court abused its discretion by refusing to accept briefing on the speedy trial issue and whether the issue was preserved for review. The Supreme Court held that by voluntarily and knowingly pleading guilty without first obtaining an adverse ruling on a timely filed motion, the defendant waived all nonjurisdictional defects, including claims of speedy trial violations. The Court also declined to review the claim under the plain-error doctrine, finding no manifest miscarriage of justice. The judgment was affirmed. View "State v. Hill" on Justia Law

Police investigated a domestic disturbance in December 2020 involving the appellant, who was subsequently charged in Yellowstone County, Montana, with his fourth DUI-related offense. The State later amended the charges to include DUI per se for operating a noncommercial vehicle with a blood alcohol concentration of 0.08 or more, fourth or subsequent offense. The appellant entered a plea agreement, pleading guilty to the amended charge in exchange for dismissal of the original DUI charge. At sentencing, both parties recommended specific incarceration and treatment conditions, and agreed to a $5,000 fine. The appellant requested that certain fees be waived due to his financial circumstances.The Thirteenth Judicial District Court accepted the plea, dismissed the original charge, and imposed the recommended sentence, including the mandatory-minimum $5,000 fine under § 61-8-731(1)(a)(iii), MCA (2019). The court also orally stated it would waive several fees. However, the written judgment subsequently entered required the appellant to pay a variety of fees and surcharges, contrary to the oral pronouncement. The appellant appealed, arguing that the mandatory fine was unconstitutional and that the imposition of fees conflicted with the oral pronouncement.The Supreme Court of the State of Montana reviewed the case. Guided by its recent decision in State v. Cole, the Court held that sentencing courts must consider a defendant’s ability to pay when imposing the mandatory-minimum fine and may suspend the portion a defendant is unable to pay. Because the District Court made no findings regarding the appellant’s ability to pay, the Supreme Court reversed the fine and remanded for further proceedings consistent with Cole. The Court also ordered the written judgment to be amended to conform to the fees waived in open court. View "State v. C. Horn" on Justia Law

The defendant was charged in three separate cases with felony offenses in Lake County, Montana, including driving under the influence for a fourth or subsequent offense. The State also sought to revoke a previously imposed suspended sentence in another DUI case. A global plea agreement was reached, and the Twentieth Judicial District Court conducted a combined sentencing hearing. The court imposed consecutive prison terms and, as relevant here, imposed a $5,000 fine for the felony DUI, which it fully suspended after considering the defendant’s financial situation. The written judgment also included a condition allowing the probation office to reinstate suspended fines and fees if the defendant failed to comply with probation terms.The defendant appealed, challenging only two aspects of the judgment: the legality of the $5,000 fine, and the condition permitting the probation office to reinstate suspended financial penalties. The State conceded that the delegation to the probation office was improper but otherwise defended the judgment. The defendant argued that the mandatory minimum fine was unconstitutional, relying on a recent Montana Supreme Court decision. The State countered that the statute at issue was not addressed in that case and urged affirmance.The Supreme Court of the State of Montana reviewed the case. The court held that, consistent with its more recent decision in State v. Cole, it is permissible for a sentencing court to impose the statutory $5,000 minimum fine for felony DUI, provided the court determines the defendant’s ability to pay and uses its authority to suspend the fine as appropriate. The court affirmed the imposition and suspension of the fine, finding the sentence lawful. However, the court held that the district court lacked authority to delegate to the probation office the power to reinstate suspended fines and fees. The case was remanded for entry of an amended judgment striking that condition. View "State v. Trombley" on Justia Law

A county board created a port authority in 2003 to encourage economic development, administering a business park on contaminated land formerly operated by a lumber company. In 2022, the port authority entered into agreements with a private company to clean up and potentially develop the property, culminating in the sale of 105 acres for $1.6 million, with a credit for cleanup costs. The plaintiff alleged that between May 2022 and April 2025, the port authority failed to provide adequate public notice of its meetings or opportunities for public participation regarding the land transactions, in violation of Montana’s open meeting and right to participate laws.The Nineteenth Judicial District Court, Lincoln County, reviewed a motion for a preliminary injunction, which sought to halt any actions pursuant to the port authority’s decisions during the contested period and to void the land sale and related contracts. The District Court denied the injunction, reasoning that the relief sought would not merely enforce open meeting laws but would invalidate completed transactions and disrupt the property’s new ownership and development. The court found that the plaintiff had not demonstrated a likelihood of success on the merits, particularly given the significant passage of time and changes to the property. The court did not resolve contested factual issues about notice or participation, nor did it make any final rulings on the underlying claims.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court manifestly abused its discretion in denying the preliminary injunction. The Supreme Court affirmed, holding that the District Court did not abuse its discretion because the plaintiff failed to establish all required elements for preliminary injunctive relief. The Supreme Court emphasized that the lower court had not decided the merits of the open meeting law claims and left those questions for future proceedings. View "Torgison v. Lincoln County" on Justia Law