Justia Montana Supreme Court Opinion Summaries

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

A pickup truck driven by Lilly Laroque collided head-on with another vehicle on a Montana highway, resulting in serious injuries to Laroque and the death of the other driver, Delaney Doherty. At the crash scene, law enforcement found marijuana-related items in Laroque’s vehicle, and evidence suggested Laroque had been texting and using marijuana while driving shortly before the crash. While hospitalized after the accident, Sergeant Stoner of the Montana Highway Patrol requested a blood sample from Laroque to test for intoxicants, reading her the Montana Implied Consent Advisory. Laroque did not respond verbally to repeated requests for consent, and the officer directed medical staff to draw her blood, which later tested above the legal limit for THC.The Eighteenth Judicial District Court of Montana reviewed Laroque's motion to suppress the blood sample and toxicology report, considering arguments that the warrantless blood draw violated her constitutional protections against unreasonable searches and seizures. The State argued that Montana’s Implied Consent statute authorized the blood draw, relying on precedent from City of Great Falls v. Allderdice. The District Court found Laroque did not exhibit understanding or consent required by the Implied Consent Advisory, distinguishing her case from Allderdice. The court suppressed the evidence, finding no exception to the warrant requirement applied and declined to apply the good faith exception. The State appealed this suppression order.The Supreme Court of the State of Montana reviewed whether the District Court’s finding that Laroque did not consent was clearly erroneous. Applying the clear error standard, the Supreme Court found substantial evidence supported the District Court’s conclusion that Laroque did not consent to the warrantless blood draw. The Supreme Court affirmed the suppression of the blood sample and toxicology report, holding the District Court’s factual findings were not clearly erroneous and declining to address the State’s good faith doctrine argument, as it was not raised below. View "State v. Laroque" on Justia Law

A man was charged with multiple felonies following a high-speed pursuit in Lincoln County, Montana. Law enforcement attempted to arrest him on an outstanding warrant, but he fled in a truck, initiating a chase that involved several officers. During the pursuit, the man lost control on a snowy forest road, then accelerated and struck a highway patrol trooper with his vehicle. The passenger in his truck exited as the chase continued, and the man was ultimately apprehended after colliding with a Fish, Wildlife & Parks vehicle. A search of the truck revealed methamphetamine, testosterone enanthate, and a pistol. He was charged with attempted deliberate homicide, criminal endangerment, criminal mischief, criminal possession of dangerous drugs, and aggravated kidnapping.The Nineteenth Judicial District Court held a jury trial. The defendant objected to the presence of a “large” number of uniformed law enforcement officers in the gallery, arguing their presence could intimidate the jury. He requested the officers wear civilian clothes or, alternatively, that the jury be instructed not to let the officers’ presence influence their decision. The court denied the request for civilian clothes but was open to a curative instruction, which the defense did not pursue. The defendant also objected to the admission of a particular photograph from the crime scene and later argued ineffective assistance of counsel because his attorney did not request a specific jury instruction. The jury found him guilty of all charges.The Supreme Court of the State of Montana reviewed the case. It held that the district court did not abuse its discretion in allowing uniformed officers to attend the trial, as their presence was not inherently prejudicial and there was no evidence of improper influence. The court declined to consider the ineffective assistance of counsel claim on direct appeal, leaving it for possible postconviction proceedings. Finally, even if admitting the contested photograph was error, it was harmless given the other evidence. The convictions and judgment were affirmed. View "State v. Miller" on Justia Law

The defendant was charged with multiple counts of Sexual Intercourse Without Consent (SIWOC) and Sexual Assault involving two underaged victims. One victim reported ongoing abuse from age six to thirteen, and a second reported being assaulted by the defendant while intoxicated at his residence. After charges were filed, the defendant was released on bail. The court later severed the charges, and a plea agreement was reached: the defendant pled guilty to one SIWOC count involving the second victim in exchange for dismissal of the other charges. He was sentenced to twenty years with the Montana Department of Corrections (DOC), with fifteen years suspended and five years to be served under community supervision.Following his release to community supervision, the defendant was arrested on new SIWOC charges involving another underage victim. His parole officer filed a violation report, and a petition to revoke his suspended sentence was filed. Throughout 2021 and 2022, the defendant was intermittently detained and released on bond related to the new charges and revocation proceedings. At the revocation hearing, the Fifth Judicial District Court found he had violated the conditions of his community supervision and revoked the suspended sentence, imposing a new fifteen-year DOC sentence with no time suspended. The court awarded the defendant thirty-four days of credit for time served but declined to credit an additional 112 days, stating that period had already been applied to the earlier five-year sentence.The Supreme Court of the State of Montana reviewed whether the District Court erred in calculating credit for time served. The Court held that the defendant was entitled to credit for the 112 days only toward the initial five-year sentence, not the revoked fifteen-year sentence. The Court affirmed the District Court’s judgment, concluding the thirty-four days of credit awarded was appropriate and that the defendant was not entitled to additional credit on the revocation sentence. View "State v. Mitchell" on Justia Law