Justia Montana Supreme Court Opinion Summaries

The case concerns Del Orrin Crawford, who was involved in a deadly altercation outside the South Fork Saloon in Martin City, Montana, on August 26, 2022. After a dispute regarding a golf cart escalated, Crawford fired a handgun, resulting in the death of Whisper Sellers and serious injury to Douglass Crosswhite. Crawford fled the scene, called 911 multiple times claiming self-defense, and was later apprehended by law enforcement. Upon arrest, Crawford surrendered unarmed, and the firearm he used was not immediately recovered. Law enforcement questioned Crawford about the firearm’s location and conducted further interrogation after transporting him to the sheriff’s office.The Eleventh Judicial District Court in Flathead County presided over Crawford’s jury trial. Crawford moved to suppress two sets of statements made to law enforcement after he invoked his right to counsel. The court denied most of his motion, suppressing only statements related to his alcohol consumption before his second Miranda advisement. Crawford was subsequently convicted by the jury of Deliberate Homicide, Attempted Deliberate Homicide, Assault with a Weapon, and Tampering with Physical Evidence, and sentenced to 100 years in prison.On appeal, the Supreme Court of the State of Montana reviewed whether the district court erred in admitting Crawford’s statements regarding the firearm’s location after he requested counsel and whether it was correct in finding that Crawford reinitiated conversation and knowingly waived his right to counsel before making further statements. The Supreme Court held that even if admitting the statements about the firearm’s location was erroneous, any error was harmless beyond a reasonable doubt due to cumulative admissible evidence. The Court further held that Crawford voluntarily reinitiated conversation and validly waived his right to counsel before providing additional statements. The judgment of conviction was affirmed. View "State v. Crawford" on Justia Law

The case concerns a defendant who was charged with abusing his elderly stepfather, resulting in both mental injury and physical harm. The elderly victim, who had declining health and required assistance, was subjected to several years of verbal threats, intimidation, and, on at least one occasion, physical assault when the defendant struck him in the face. The victim’s daughter and other family members observed concerning behavior, including an incident where the defendant shook the victim in a manner described as threatening. The victim, before passing away, gave a recorded deposition detailing the abuse, his fear, and its emotional toll. The charges included abuse of an elderly person and first-offense partner or family member assault.Prior to trial, the defendant sought to enforce an alleged plea agreement, but the District Court found no such agreement had been accepted, following a hearing. Although a jury trial was scheduled, the defendant requested a bench trial, and the Tenth Judicial District Court, Fergus County, confirmed that he knowingly and voluntarily waived his right to a jury trial, albeit orally rather than in writing. After a two-day bench trial, the court found the defendant guilty on both counts and imposed a prison sentence. The defendant appealed, arguing insufficient evidence due to a lack of expert testimony on mental injury, an improper waiver of jury trial, and that the elder abuse statute was unconstitutionally vague and overbroad.The Supreme Court of the State of Montana held that expert testimony is not required to establish “mental injury” under the relevant statute, as a reasonable person standard applies and lay testimony was sufficient. The court found no manifest miscarriage of justice in accepting the oral waiver of a jury trial. The court also rejected the facial constitutional challenges, as the defendant’s conduct was clearly proscribed by statute. The judgment of the District Court was affirmed. View "State v. Pein" on Justia Law

On March 16, 2017, outside a bar in Helena, Montana, Andrew Lake stabbed Ryan Zitnik following an altercation. Both men were regulars at the bar and had known each other for years. The events leading to the stabbing were disputed, with each party claiming the other was the aggressor. Lake asserted the affirmative defense of justifiable use of force. Witnesses observed the initial confrontation inside the bar but did not witness the stabbing itself. After the incident, Lake was arrested and interrogated, where he discussed contentious remarks he had made about child sex abuse, which had strained his relationship with Zitnik and other patrons.Lake was initially convicted of attempted deliberate homicide in the First Judicial District Court, Lewis and Clark County. He appealed, and the Montana Supreme Court reversed the conviction, holding that the District Court had improperly allowed explicit and repetitive testimony about Lake’s child sex abuse comments, which was unfairly prejudicial under Rule 403 (State v. Lake, 2022 MT 28). The case was remanded for a new trial.Following retrial, Lake was again convicted and appealed to the Supreme Court of the State of Montana. On appeal, Lake argued that the District Court erred by admitting testimony about his child sex abuse comments, claiming its prejudicial effect outweighed its probative value under Rule 403. The Supreme Court reviewed only those instances where Lake made timely objections, finding that the District Court had carefully balanced probative value and prejudice, admitted only limited references, and did not abuse its discretion. The Supreme Court held that the danger of unfair prejudice from the admitted evidence did not substantially outweigh its probative value and affirmed the conviction. View "State v. Lake" on Justia Law

The defendant, Maas, and his friend, Auclaire, had a falling out over stolen property, leading Maas to threaten Auclaire. Later, Maas attempted to reconcile, and he, Auclaire, and Caldwell spent time together at a hotel. Maas shifted suspicion to Wagoner regarding the stolen property. After visiting bars, Maas and Auclaire went to Wagoner's residence, where Maas entered with a gun. A confrontation ensued, and Maas shot Wagoner, claiming self-defense because Wagoner allegedly threatened Auclaire with a bat. Various witnesses, including neighbors and law enforcement, testified about Wagoner's statements identifying Maas as the shooter and describing the altercation. Wagoner survived for a period, making statements to police and family before dying from his injuries.The Eleventh Judicial District Court in Flathead County presided over Maas’s jury trial. The jury found Maas guilty of deliberate homicide. The court sentenced him to 80 years in prison. Maas objected to the admission of Wagoner's statements, arguing they violated the Confrontation Clause, and challenged questioning about a juvenile prior bad act. He also asserted that any error was not harmless and prejudiced his justifiable use of force defense.The Supreme Court of the State of Montana reviewed the case. It held that most statements made by Wagoner were nontestimonial and properly admitted, as they were made during an ongoing emergency or to non-government agents. However, statements Wagoner made to Detective Webster at Harborview were testimonial and erroneously admitted. The Court found this error harmless because cumulative evidence established the same facts, and the disputed testimony had minimal impact. The Court also determined the District Court abused its discretion in admitting evidence of Maas’s juvenile BB gun incident but found the error harmless given overwhelming admissible evidence against Maas. The conviction and sentence were affirmed. View "State v. Maas" on Justia Law

Gregory Engellant, after suffering a traumatic brain injury, was placed under guardianship, with his brother Ken acting as guardian and conservator. In 2012, Greg engaged attorney Dan McLean of Crowley Fleck, PLLP to update his estate plan, expressing a wish to gift his shares in Engellant Ranch Corporation to his niece, Shana Diekhans, who had been operating the ranch. Greg executed a new will in 2012 reflecting this intent and transferred his shares to Shana, valued at about $1.7 million. In 2015, Greg signed several documents prepared by Daren Engellant, purporting to revoke the 2012 will, but the circumstances surrounding these documents were contested, as Greg signed multiple versions without noticing changes. Greg died in 2019, and Daren, as personal representative, petitioned to probate the 1978 will, which devised Greg’s estate equally to Daren, Kevin, and Shana.In the District Court of the First Judicial District, Daren sued Crowley Fleck for malpractice, alleging the firm failed to adequately investigate Greg’s capacity and Ken’s conduct before facilitating the stock transfer. Crowley Fleck joined Ken and Shana as third-party defendants. During trial, Shana learned Daren had withheld information about the 2015 revocation documents and sought to admit the 2012 will to probate. The District Court allowed evidence on the validity of the 2012 will, and the jury found it was Greg’s last valid will, meaning the estate suffered no damages from Crowley Fleck’s actions. The court entered judgment for Crowley Fleck and denied Kevin Engellant’s post-trial motion to intervene as untimely.The Supreme Court of the State of Montana affirmed the District Court’s judgment. The Court held that evidence regarding the 2012 will’s validity was relevant to causation and damages in the malpractice claim, that Crowley Fleck’s defense was properly pleaded, and that the jury could determine the validity of the 2012 will for the purposes of the malpractice case. The Court also upheld the exclusion of settlement agreement evidence and the denial of Kevin’s intervention. View "Engellant v. Crowley Fleck" on Justia Law

Stephanie M. Cordeiro sought a temporary order of protection against Steven R. Cordeiro in September 2023, which was granted by the Montana Eighth Judicial District Court, Cascade County. The parties appeared before Judge Kutzman, stipulated to an extension of the temporary order, and agreed that the dissolution court could issue superseding orders. Separately, Stephanie filed for dissolution of marriage, and over time, both cases came under Judge Deschamps’s purview, though they were not formally consolidated. Throughout subsequent hearings, both parties engaged the dissolution court on matters relating to the protective order, including agreeing to further extensions and discussing the drafting of a master restraining order in connection with their parenting plan.As proceedings continued, the parties failed to agree on a final restraining order, prompting Stephanie to move for a permanent protective order. Steven objected to the court’s jurisdiction and to the admission of evidence from before the original stipulation but acknowledged the matters had effectively been joined. Judge Deschamps denied Steven’s motion to exclude evidence, held an evidentiary hearing, and ultimately issued a permanent protective order for Stephanie and the minor children.On appeal, the Supreme Court of the State of Montana addressed whether the district court presiding over the dissolution had jurisdiction to enter a permanent protection order, whether it erred in extending the order without a hearing, and whether it abused its discretion by considering evidence from prior to the parties’ stipulation. The Supreme Court held that the district court had statutory authority and proper jurisdiction, that the parties had waived any right to an evidentiary hearing for the earlier extensions by their stipulation, and that the court did not abuse its discretion in admitting evidence or issuing the permanent order. The judgment of the District Court was affirmed. View "In re Marriage of Cordeiro" on Justia Law

A school principal and special education teacher sought a protective order against the mother of an autistic student after an incident at a local gas station. The mother, who worked at the station, threw change at the principal and made a comment interpreted as a threat. The event was captured on security cameras. The principal petitioned for a temporary order of protection, alleging assault and fear of bodily injury.The Richland County Justice Court held two hearings. At the evidentiary hearing, it reviewed testimony and video footage, determining the change had been thrown purposefully as a message, and that the accompanying statement was threatening. While the court concluded the act was not an assault in a criminal sense, it found that the totality of the actions and words caused reasonable apprehension of bodily injury. The Justice Court granted a permanent order of protection for one year, barring the mother from approaching the principal and certain locations, and prohibiting any contact. The mother appealed to the Seventh Judicial District Court, arguing that no crime had been committed and the protective order was unwarranted. The District Court affirmed the Justice Court’s decision, finding that the mother had caused reasonable apprehension of bodily injury and had not preserved an objection to the scope of the order for appeal.On further appeal, the Supreme Court of the State of Montana determined the case was not moot due to the public interest exception. It clarified that the standard of proof for making an order of protection permanent is a preponderance of the evidence, not a separate “good cause” standard. The Supreme Court affirmed the District Court’s findings, holding that sufficient evidence supported the protective order and that the appellant had not preserved a challenge to its scope. View "Nelson v. Frisk" on Justia Law

The case concerns a woman who was convicted of felony incest involving her stepson. After allegations surfaced against her then-husband for sexually abusing her daughter, forensic interviews were conducted with all three children in early 2018. The husband pleaded guilty to two counts of incest. Later, one of the daughters disclosed that her stepbrother had been abused by the petitioner, alleging that she had asked him to touch her breasts. This led to an investigation and the petitioner being charged with two counts of incest, corresponding to two distinct time periods. At trial, the jury convicted her of one count and acquitted her of the other.On direct appeal to the Montana Supreme Court, the petitioner challenged the denial of pretrial interviews with the children, alleged the State's failure to disclose exculpatory forensic interviews, and argued that the lack of a specific jury instruction was reversible error. The court affirmed her conviction, finding that the missing interview did not affect the outcome and that other claims lacked merit.Following this, the petitioner sought post-conviction relief in the District Court of the Tenth Judicial District, asserting prosecutorial misconduct, ineffective assistance of counsel, actual innocence, and errors in post-conviction discovery. She argued that certain records were not disclosed and that there was a conspiracy to charge her. The District Court denied all claims, determining that any purported new evidence was either not new, not material, or cumulative, and that her counsel had provided effective representation. The District Court’s denial was issued without a hearing or a response from the State.On appeal, the Montana Supreme Court reviewed the District Court’s denial and, after an in camera review of the forensic interviews, concluded that only one additional interview should have been disclosed, but its content would not have affected the outcome. The court affirmed the denial of post-conviction relief, holding there was no prosecutorial misconduct, no ineffective assistance, no abuse of discretion in managing discovery, and no showing of actual innocence. View "Mathis v. State" on Justia Law

A dispute arose regarding the right to use a private roadway, Forgotten Lane, which crosses property owned by Shan and Dana Tompkins and abuts parcels owned by Christine Brock as co-trustee of a family trust. The properties, all originally part of a single tract, were divided over several decades by a series of conveyances beginning in the 1940s. The parties disagreed about whether Brock held an easement over Forgotten Lane, the nature of historical use of the road, and whether any rights to use the road continued to exist after the division of the property. In 2016–2017, physical barriers were placed on the disputed road, leading to this litigation after Brock claimed an easement and sought to remove the obstructions.The Twenty-First Judicial District Court, Ravalli County, first considered only Brock’s claim of an express easement based on a certificate of survey, ultimately denying summary judgment to both sides but inviting Brock to amend her complaint to include implied, prescriptive, and public easement theories. The court permitted the amendment and later bifurcated the proceedings, assigning the express, implied, and public easement claims to a bench trial, while reserving the prescriptive easement and trespass counterclaims for a potential jury trial. After a bench trial, the District Court found Brock did not prove an express easement but held she had established an implied easement across the Tompkins’ property and issued a permanent injunction. When the implied easement was found to provide the relief sought, the District Court dismissed the remaining claims and counterclaims as moot and denied Brock’s request for attorney fees on procedural grounds.The Supreme Court of the State of Montana reviewed the case and held that the District Court erred by not granting summary judgment to the Tompkins on the original express-easement claim, but that this error did not affect the fairness of proceedings on the amended complaint. The Supreme Court reversed the judgment finding an implied easement, vacated the permanent injunction, and remanded for further proceedings on any unresolved alternative theories, including public and prescriptive easements, and the trespass counterclaim. It also reversed the procedural denial of Brock’s request for costs and fees, remanding for a new determination after final judgment. Other procedural and bifurcation orders were affirmed. View "Brock v. Tompkins" on Justia Law

In this case, a dispute arose over membership interests in Freedom Pass Partners, LLC, which owns undeveloped property near Big Sky, Montana. Carol Hudson, through her estate and beneficiaries Alan and Jeffrey Johnson, claimed that Hudson funded the purchase of the property based on assurances she would be a member of Freedom Pass. After Hudson’s death, her sons, acting as trustees and beneficiaries of her trust, filed suit asserting multiple claims including breach of contract, fraud, unjust enrichment, and conversion, alleging Hudson’s investment entitled her to membership or ownership interests.The Eighteenth Judicial District Court reviewed the claims and granted summary judgment for Freedom Pass Partners, LLC. It found that the Johnsons lacked standing because the estate’s personal representative had not joined the litigation, and concluded that all claims were time-barred based on the statute of limitations. The court also denied Johnsons’ motions to amend the complaint, to compel discovery identifying a prospective property buyer, and for relief from judgment regarding the dissolution of a lis pendens notice.The Supreme Court of the State of Montana reviewed the District Court’s decisions de novo for summary judgment and for abuse of discretion on the remaining motions. It held that genuine disputes of material fact existed about whether Hudson knew or should have known she was not a member of Freedom Pass, particularly given conflicting evidence and potential concealment or fiduciary duties. The Supreme Court also found the denial of leave to amend the complaint was an abuse of discretion because adding the estate’s personal representative could cure the standing defect. The denial of discovery and failure to consider mootness regarding the lis pendens were also found to be abuses of discretion. The Supreme Court reversed the District Court’s rulings and remanded the case for further proceedings. View "Hudson Revocable Trust v. Freedom Pass" on Justia Law