Justia Montana Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the district court concluding that the Montana Public Service Commission (PSC) arbitrarily and unlawfully reduced solar qualifying facility (QF) standard-offer rates by excluding carbon dioxide emissions costs and NorthWestern Energy's avoided costs of operating its internal combustion engine resource units from the avoided-cost rate, holding that the district court did not err.Specifically, the Supreme Court held that the district court did not err in determining that the PSC did not comply with the Public Utility Regulatory Policies Act (PURPA) and Montana's mini-PURPA when it set the standard-offer contract rates and maximum contract lengths for qualifying small (QF-1) solar power producers. The PSC's decision to reduce the standard-offer QF-1 rates was arbitrary and unreasonable because the PSC failed to consider future carbon costs and failed to provide a reasoned decision in departing from its recent precedent. Further, the PSC unreasonably failed to consider NorthWestern's cost of operating its new internal combustion engine resources when setting the avoided-cost rate. View "Vote Solar v. Montana Department of Public Service Regulation" on Justia Law

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The Supreme Court reversed the judgment of the district court holding Trinity Lutheran Church liable under a theory of unjust enrichment, holding that the district court erred as a matter of law in determining that Trinity Lutheran was unjustly enriched.Montana Digital, LLC contracted with Trinity Lutheran to provide unlimited telephone and internet services to Trinity Lutheran. Trinity Lutheran's system was later hacked and used by a theft to make international telephone calls to Africa at a service cost of $47,977. Montana Digital was invoiced for the cost of the calls, and Montana Digital paid the full amount of the invoice. Montana Digital then initiated this action against Trinity Lutheran, asserting a claim for unjust enrichment. The district court found Trinity Lutheran liable and awarded Montana Digital the same of $47,977. The Supreme Court reversed, holding that, under the circumstances, a claim of unjust enrichment was not established against Trinity Lutheran as a matter of law. View "Montana Digital, LLC v. Trinity Lutheran Church" on Justia Law

Posted in: Contracts
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The Supreme Court reversed Defendant's conviction of sexual intercourse without consent (SIWC), a felony, holding that the district court abused its discretion in allowing the State to cross-examine Defendant regarding a prior SIWC allegation as rebuttal evidence and in precluding Defendant from impeaching the testimony of the State's complaining witness with evidence of marijuana use prior to reporting the alleged offense.On appeal, Defendant argued, among other things, that the district court abused its discretion in allowing the State to cross-examine him regarding an unsubstantiated 2003 SIWC allegation for the purpose of rebutting his self-serving good character testimony and erroneously precluded him from impeaching the testimony of the State's complaining witness with evidence of marijuana use prior to reporting the alleged offense. The Supreme Court agreed and remanded the case for a new trial, holding that, under the circumstances of this case, the district court erred as to both issues and that the errors were prejudicial. View "State v. Pelletier" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the district court denying Defendant's motion to suppress testimony regarding statements he made during a phone conversation with the victim, holding that the testimony was not subject to exclusion.A.O. and her friend Tricia alleged that Defendant had committed sexual offenses against A.O. While A.O. was at the police department, Defendant called A.O. Police officers listened in on the conversation, during which Defendant admitted to raping A.O. Defendant moved to suppress the evidence. The district court ruled that the officer testimony regarding the conversation would be excluded but that A.O. and Tricia, as private actors, could testify as to the conversation. Defendant appealed, arguing that the testimony of A.O. and Tricia as to the contents of the conversation must be excluded as attributable to an unconstitutional privacy intrusion by a government actor. The Supreme Court affirmed, holding that the district court correctly denied the motion to suppress because A.O. and Tricia's testimony resulted from their own private actions, not from unconstitutional monitoring and recording by police. View "State v. Wolfe" on Justia Law

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The Supreme Court reversed the judgment of the district court ordering Defendant to pay $31,903 in restitution for losses resulting from offenses committed by another, holding that the district court erred in ordering Defendant to pay restitution.Defendant pled guilty to criminal possession of dangerous drugs and criminal possession of drug paraphernalia. At sentencing, the parties disagreed as to restitution for costs associated with remediating a co-defendant's apartment from methamphetamine contamination. The district court imposed the restitution requested by the State. On appeal, Defendant argued that the court erred in requiring him to pay restitution for losses committed by another absent evidence of criminal accountability or a causal connection between his offense and those losses. The Supreme Court agreed, holding that the State failed to establish a causal link between Defendant's admitted possession of methamphetamine and the rehabilitation claimed. View "State v. Cole" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed in part and reversed in part the judgment of the district court granting class certification in this action alleging breach of contract and violation of Montana's Unfair Trade Practices Act (UTPA), Mont. Code Ann. 33-18-101 et seq., holding that a sufficient factual basis was established to justify certification of the classes.Plaintiffs filed this action against Fergus Farm Mutual Insurance Company (FFM), alleging that FFM breached its insurance contract with Plaintiffs and all other insureds by failing to include general contractor overhead and profit in the cost to repair or replace Plaintiffs' property. The district court granted Plaintiffs' motion for class certification. The Supreme Court reversed in part, holding (1) the district court did not abuse its discretion by determining that common questions of law predominate the litigation and support certification of the class; but (2) certain conclusions reached by the district court were a "bridge too far" at this stage of litigation. View "Kramer v. Fergus Farm Mutual Insurance Co." on Justia Law

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The Supreme Court affirmed in part and vacated in part the district court order temporarily enjoining two Montana election laws, holding that the court erred by enjoining a ballot deadline.At issue was the district court's grant of a preliminary injunction regarding two election laws. One law required absentee ballots to be returned to local election officers no later than 8 p.m. on Election Day and the other law restricted the delivery of such ballots by persons other than the elector. The Supreme Court affirmed the preliminary injunction against the Ballot Interference Prevention Act (BIPA) and vacated the preliminary injunction against the election-day ballot-receipt deadline, holding (1) the district court did not manifestly abuse its discretion by granting the preliminary injunction against enforcement of BIPA; and (2) the district court erred by enjoining the ballot deadline. View "Driscoll v. Stapleton" on Justia Law

Posted in: Election Law
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The Supreme Court upheld the order of the district court prohibiting the office of the Secretary of State from qualifying the Montana Green Party as a minor party eligible for the 2020 election ballot, holding that the district court did not err.Mont. Code Ann. 13-10-601(2) requires the political party seeking to nominate its candidates through a primary election to present the petition seeking to hold a primary election to select the party's noises for office and to obtain ballot access for those nominees for the November 2020 general election to election administrators. The Montana Green Party was not involved and did not endorse the petition process at the time the signatures were gathered and presented to election administrators. The district court concluded that the petition failed to meet the requirements of section 13-10-601(2) and enjoined the Secretary from giving any effect to the petition. The Supreme Court affirmed, holding that the petition failed to satisfy the statutory requirements of section 13-10-601(2). View "Montana Democratic Party v. Stapleton" on Justia Law

Posted in: Election Law
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The Supreme Court affirmed the order of the district court denying Appellant's petition compelling Appellee, the Missoula County Clerk and Recorder, to record Appellant's certificate of survey (COS), holding that Appellee did not have a clear legal duty to record the COS.The district court dismissed Appellant's petition for writ of mandamus, finding that Appellee was not under a clear, non-discretionary, legal duty to record Appellant's COS bearing language certifying that a subdivision qualified for an exemption that the relevant reviewing authority found to be inapplicable and declined to approve. The Supreme Court affirmed holding that the district court was correct in dismissing the petition for writ of mandamus because Appellee was not under a clear legal duty to record a COS bearing a certification of exemption from sanitary review that Appellant was not approved for. View "Richards v. Gernant" on Justia Law

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The Supreme Court affirmed the order of the district court that Dan Cook's last will and testament be confirmed and admitted to probate and that Kim Smith be appointed personal representative of the estate, holding that, although the district court erred in applying an incorrect burden of proof to determine the validity of the will, the error was harmless.Specifically, the Supreme Court held (1) the district court did not err in concluding that Smith did not exceed her general power of attorney granted her by Cook when she transferred Cook's money; (2) the district court did not err in finding that Cook had the requisite capacity to enter into a valid marriage with Smith shortly before his death; and (3) while the court erred in applying an incorrect burden of proof in determining the validity of Cook's will, the error was harmless because the court's findings of fact were sufficient under the correct burden of proof to support the conclusion that Cook was competent to create and amend a valid will. View "In re Estate of Cook" on Justia Law

Posted in: Trusts & Estates