Justia Montana Supreme Court Opinion Summaries

David L. Murphy Properties, LLC and John Schaffer own property adjacent to Painted Rocks Cliff, LLC on Flathead Lake. Painted Rocks constructed a dock after obtaining a permit from Lake County. Murphy Properties claimed the dock violated the Lakeshore Protection Act, interfered with their prescriptive easement, and constituted a nuisance.The Twentieth Judicial District Court dismissed Murphy Properties' Lakeshore Protection Act claim against Lake County and granted summary judgment in favor of Painted Rocks on all claims. The court found that the dock did not interfere with navigation or lawful recreation under the Act, as Murphy Properties could still access the cove with smaller watercraft. The court also ruled that Murphy Properties could not establish a prescriptive easement because their use of the cove was not exclusive, given the public's right to use the waters. Additionally, the court dismissed the nuisance claim, as it was contingent on the alleged violation of the Lakeshore Protection Act.The Supreme Court of the State of Montana affirmed the lower court's rulings. The court held that the Lakeshore Protection Act does not mandate denial of a permit if a project impacts navigation or recreation, but rather favors issuance if it does not. The court agreed that Murphy Properties' use of the cove was not exclusive and thus could not support a prescriptive easement. The court also upheld the dismissal of the nuisance claim, as it was based on the failed Lakeshore Protection Act claim. The judgment in favor of Lake County and Painted Rocks was affirmed. View "David L. Murphy Properties, LLC v. Painted Rocks Cliff, LLC" on Justia Law

Christopher J. Lamm and Amanda R. Kinney Anderson are the parents of F.L.F.L.K. Christopher lives in Williston, North Dakota, and Amanda lives in Bainville, Montana. They were not married, and after the birth of their child, Christopher filed a Petition for Parenting Plan in the District Court on March 1, 2023. The court held a hearing on May 23, 2023, where both parties, representing themselves, participated in an informal manner. The court established an interim parenting plan, allowing Christopher supervised visits with the goal of gradually increasing his parenting time.The District Court issued an order on January 22, 2024, setting a hearing for a final parenting plan under the new Informal Domestic Relations Trial (IDRT) process, which came into effect on October 1, 2023. The court held the hearing on February 5, 2024, where it questioned both parties about their lives and their ability to care for the child. The court issued its final parenting plan on February 7, 2024, designating Amanda as the primary custodian and gradually increasing Christopher's parenting time, with the goal of transitioning to overnight visits once the child turned two.Christopher appealed, arguing that the District Court failed to fully inform him of the IDRT process and did not consider the best interests of the child statutes. The Montana Supreme Court found that while the District Court did not fully explain the IDRT process, Christopher did not object and fully participated in the hearing. The court also found no substantial prejudice to Christopher from the IDRT process. The Supreme Court affirmed the District Court's decision, finding no abuse of discretion in the manner the IDRT was conducted or in the formulation of the final parenting plan. View "In re Parenting of F.L.F.L.K." on Justia Law

Kevin Charles Walla was charged with Deliberate Homicide after shooting and killing Richard Allen Bowers in his apartment on December 31, 2019. Walla claimed he acted in self-defense, citing Bowers' history of drug use, criminal behavior, and aggression. The State sought to exclude Walla's testimony about Bowers' character. During the trial, the parties reached an agreement on certain evidentiary disputes and jury instructions, including a provision allowing Walla's counsel to make an offer of proof about Walla's testimony outside the jury's presence. However, Walla ultimately decided not to testify.The Sixth Judicial District Court, Sweet Grass County, presided over the trial. Walla's counsel agreed to strike the provision regarding the offer of proof after Walla decided not to testify. Walla also proposed a supplemental verdict form to ensure the jury's unanimous decision on his self-defense claim, which the court rejected, stating that the standard verdict form and jury instructions were sufficient. The jury found Walla guilty of Deliberate Homicide, and he was sentenced to 100 years in prison, with an additional 10-year Weapons Enhancement.The Supreme Court of the State of Montana reviewed the case. The court held that the District Court did not improperly reject the procedural agreement's provision, as Walla's decision not to testify rendered the issue moot. Additionally, the court found no abuse of discretion in rejecting the supplemental verdict form, as the jury instructions clearly required a unanimous verdict and adequately informed the jury of the State's burden to prove Walla's actions were not justified. The Supreme Court affirmed the District Court's judgment and sentence. View "State v. Walla" on Justia Law

Warren Dan Eddleman passed away on August 5, 2022, leaving a will that named Tom Wagoner as the personal representative (PR) and John Pinkerton as the sole devisee. Several creditors, including Eddleman's ex-wife Sandra, daughter Madelyn, sister Jobey, the Eddleman Oar Lock Ranch, LLC, and the Madelyn Lue Eddleman Trust, filed claims against the estate. The PR disallowed some claims and allowed others in part. The PR and the claimants agreed to a first extension of time for the claimants to respond to the disallowances, extending the deadline to June 23, 2023. As the deadline approached, the PR's counsel assured the claimants that he would not seek to bar their claims if a second extension was not granted by the deadline.The District Court of the Thirteenth Judicial District initially granted the second extension but later rescinded it upon John Pinkerton's motion to reconsider, effectively barring the pending creditors' claims. The claimants appealed, arguing that the PR had the authority to extend the timeframe without the devisee's consent, that the devisee's consent had been obtained in a prior memorandum of understanding, and that the estate was estopped from asserting the claims were time-barred based on the PR's counsel's representations.The Supreme Court of the State of Montana reviewed the case and concluded that the PR lacked the authority to unilaterally extend the timeframe for the claimants to respond to the disallowances without the consent of the sole devisee, John Pinkerton. However, the court also found that the estate was equitably estopped from raising a claim processing time-bar defense due to the PR's counsel's assurances to the claimants. The court reversed the District Court's decision and remanded the case for further proceedings, allowing the claimants' petitions for allowance to be considered as timely filed. View "In re Estate of Eddleman" on Justia Law

Bill B. Bokma, the petitioner, was arrested in December 2020 for felony driving under the influence of alcohol. He was released on the condition that he abstain from alcohol, which he failed to do, leading to another arrest. Bokma entered into a plea agreement with the State, which included alternative sentences contingent upon his acceptance into the Eighth Judicial District Adult Drug Treatment Court Program (ADTC). He pleaded guilty and was accepted into ADTC. However, Bokma violated the treatment court’s conditions, leading to a report of violation and a request for his termination from ADTC.The District Court initially dismissed the State’s petition to terminate Bokma from ADTC after he began engaging in the treatment program. However, due to repeated violations, the State again sought to terminate his participation in November 2022. Bokma stipulated that he was unable to complete ADTC, and the District Court revoked his suspended sentence, committing him to the Department of Corrections (DOC) for a three-year term with credit for twenty-seven days of jail time and eight days of elapsed time.The Supreme Court of the State of Montana reviewed Bokma’s petition for a writ of habeas corpus, requesting additional credit for jail time and elapsed time. The court determined that Bokma was entitled to an additional twenty-two days of jail time credit, bringing the total to forty-nine days. The court also addressed the issue of whether the Montana Incentives and Interventions Grid (MIIG) should have been applied to Bokma’s revocation. The court concluded that although the District Court erred in classifying Bokma’s failure to complete ADTC as a non-compliance violation, the revocation was proper due to his repeated violations and failure to complete the treatment program.The Supreme Court granted Bokma’s petition in part, remanding the case to the District Court to amend its order to include the additional jail time credit. The court denied Bokma’s other claims and closed the matter. View "Bokma v. Olsen" on Justia Law

The case involves Protect the Gallatin River (PTGR) appealing a decision by the Gallatin County Floodplain Administrator to issue a floodplain permit for the Riverbend Glamping Getaway project proposed by Jeff and Jirina Pfeil. The project includes developing a campground with non-permanent structures on an island in the Gallatin River. PTGR argued that the public's right to participate was violated and that the Floodplain Administrator's decision was erroneous.The Eighteenth Judicial District Court of Gallatin County reviewed the case and issued an order on November 13, 2023, resolving competing summary judgment motions. The court denied PTGR's motions for partial summary judgment, granted summary judgment in favor of Gallatin County and the Pfeils regarding PTGR's complaint, and addressed other related claims. PTGR then appealed to the Supreme Court of the State of Montana.The Supreme Court of Montana reviewed the case and affirmed the lower court's decision. The court held that the Floodplain Administrator did not violate PTGR's right to participate, as the public was given a reasonable opportunity to comment, and the decision not to re-open public comment was not arbitrary or capricious. The court also found that the Floodplain Administrator's participation in the appeal process before the Commission was appropriate and lawful, as it did not involve post hoc rationalizations. Finally, the court held that the Floodplain Administrator's decision complied with the Gallatin County Floodplain Regulations and was not an abuse of discretion. The Supreme Court affirmed the District Court's summary judgment orders. View "Protect the Gallatin v. Gallatin Co." on Justia Law

Katelyn Hove was hospitalized in 2018 for pregnancy complications, and the Billings Clinic billed Blue Cross Blue Shield (BCBS) of Montana for her services. BCBS of Montana indicated that BCBS of Texas was her insurance provider. BCBS of Texas paid part of the bill, leaving a balance that Hove did not pay. The clinic assigned the unpaid debt to CB1, a debt-collection agency, which then sued the Hoves for breach of contract, breach of obligation, and unjust enrichment. The Hoves named BCBS of Montana as a third-party defendant. CB1 moved for summary judgment, supported by affidavits from the clinic. Hove responded with a written declaration disputing the charges, including an EOB from BCBS of Texas and an email from the Montana Commissioner of Securities and Insurance.The Thirteenth Judicial District Court, Yellowstone County, granted summary judgment in favor of CB1, reasoning that Hove's declaration and attached EOB were unverified and inadmissible. The court entered a final monetary judgment against the Hoves. The Hoves filed a motion to amend the judgment, attaching a sworn affidavit with the same information as the declaration. The District Court denied the motion, stating that the declaration and its attachments were inadmissible hearsay and that the declaration did not meet the statutory criteria under § 1-6-105, MCA.The Supreme Court of the State of Montana reviewed the case and found that a declaration under § 1-6-105, MCA, is equivalent to an affidavit. The court determined that Hove's declaration, which stated she never spent time in the ICU despite being billed for it, raised a genuine issue of material fact. The court reversed the District Court's summary judgment and remanded the case for trial on the merits. View "CB1 v. Hove" on Justia Law

Beau Avidiya was convicted by a jury of Aggravated Assault, Aggravated Burglary, and Criminal Destruction of or Tampering with a Communication Device after breaking into his great-grandmother Myrtle Anderson's home, assaulting her, and stealing her purse. Anderson, who was 87 years old, suffered a broken finger and other injuries during the attack. She did not initially recognize her assailant but later evidence, including surveillance footage and green paint found on Avidiya, linked him to the crime.The Nineteenth Judicial District Court of Lincoln County presided over the trial. Avidiya requested jury instructions on the lesser-included offenses of Assault, Theft, and Trespass, but the District Court denied these requests, stating that the evidence did not support such instructions. The jury subsequently convicted Avidiya on all charges, and he was sentenced to twenty years with fifteen years suspended.The Supreme Court of the State of Montana reviewed the case. Avidiya argued that the District Court abused its discretion by not instructing the jury on the lesser-included offenses. The Supreme Court examined whether the District Court had erred in its decision, focusing on whether there was sufficient evidence to warrant the lesser-included offense instructions.The Supreme Court held that the District Court did not abuse its discretion. It found that the evidence presented did not support the lesser-included offenses. The court noted that the violent nature of the assault and the circumstances of the burglary did not provide a rational basis for the jury to convict Avidiya of the lesser offenses instead of the greater ones. Consequently, the Supreme Court affirmed the District Court's judgment and sentence. View "State v. Avidiya" on Justia Law

Garrett Alan Lee, a 25-year-old, engaged in an online conversation with an undercover law enforcement officer posing as a 12-year-old girl. Lee discussed meeting the girl for sex and was apprehended by law enforcement when he arrived at the arranged location. He was charged with Sexual Abuse of Children under Montana law and pleaded guilty.The Thirteenth Judicial District Court sentenced Lee to 100 years at the Montana State Prison, with 65 years suspended, and imposed a 25-year parole restriction. Lee appealed, arguing that the mandatory 25-year parole restriction was unconstitutional and that the District Court violated his due process rights by considering information from a prior psychosexual examination not admitted into evidence.The Montana Supreme Court reviewed the case. The court held that Lee's constitutional and statutory arguments concerning the mandatory parole restriction were not properly before the court because he was not sentenced under the mandatory minimum provision. Instead, the District Court imposed the parole restriction under its discretionary sentencing power. The court also found that Lee's due process rights were not violated, as he had the opportunity to rebut or correct any information in the presentence investigation report, and the information was not materially false.The Montana Supreme Court affirmed the District Court's judgment, concluding that Lee's sentence was legal and within the statutory parameters. The court declined to review the constitutional and statutory claims related to the mandatory parole restriction and did not find plain error in the due process claim. View "State v. Lee" on Justia Law

Roger and Therese Hutchinson purchased rural property in Madison County, Montana, in 2016, which included an easement for access via a private road. They obtained a title insurance policy from Old Republic National Title Insurance Company. Disputes arose with Nugget Creek Ranch, the owner of the adjoining property, over the use and control of gates on the easement. In 2020, the Hutchinsons sued Nugget Creek, which counterclaimed for declaratory judgment, trespass, nuisance, negligence, slander, defamation, vexatious litigation, and reverse adverse possession. The reverse adverse possession claim was dismissed by the court.The Hutchinsons requested Old Republic to defend them against Nugget Creek's counterclaims, but Old Republic denied coverage, citing policy exclusions for disputes arising from the easement and for actions taken by the insured after the policy date. The Hutchinsons filed a lawsuit against Old Republic for breach of contract and unfair claim settlement practices. The District Court granted summary judgment in favor of Old Republic, finding no duty to defend because the policy excluded coverage for disputes related to the easement and for actions occurring after the policy date.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The court held that Old Republic had no duty to defend the Hutchinsons because the policy explicitly excluded coverage for disputes arising from the easement and for actions taken by the insured after the policy date. The court also noted that the policy did not cover tort claims or actions that occurred after the policy's effective date. Thus, the court concluded that Old Republic unequivocally demonstrated a lack of coverage under the policy. View "Hutchinson v. Old Republic" on Justia Law