Justia Montana Supreme Court Opinion Summaries

The case involved a man who was charged with felony intimidation after an incident at a pre-release center in Helena, Montana. While reporting for a required urinalysis as a condition of probation, the defendant became upset with a staff member, Curt McAlpin, after being told his test was positive and would be reported to authorities. He was accused of threatening to “shoot up” the center if he had a gun, which caused alarm to McAlpin and led to subsequent police involvement. This event also formed the basis for revoking the defendant’s previously suspended sentence for earlier felony violations of an order of protection.Previously, in the First Judicial District Court, Lewis and Clark County, the defendant was convicted by a jury of felony intimidation. The court denied his motions to dismiss for insufficient evidence and for a directed verdict of acquittal. The court also revoked his probation and resentenced him on the prior convictions, giving him credit for certain periods without violations. The defendant was sentenced to consecutive five-year prison terms for the intimidation conviction and the probation revocation. He then appealed both the conviction and the sentence.The Supreme Court of the State of Montana reviewed the consolidated appeals. It held that there was sufficient evidence for a rational juror to convict the defendant of intimidation, the jury instructions were proper or any error was harmless, and the trial court did not abuse its discretion regarding evidentiary rulings. The court found no reversible plain error, no ineffective assistance of counsel on the record-based claims, and no cumulative error. The calculation of elapsed-time credit for the probation revocation was upheld as legal. The Supreme Court affirmed both the conviction and the sentence. View "State v. Strobel" on Justia Law

A mother and father who share three minor children divorced, with their July 2022 parenting plan providing for equal parenting time, strict communication protocols, public schooling, and mutually-approved counseling for the children. After the mother relocated to a different city, she moved to amend the parenting plan, arguing that her move made the existing 50/50 arrangement impractical. Both parents agreed a change was warranted due to the relocation, but each sought primary residential custody. The mother also alleged the father was violating the parenting plan and interfering with her access to the children. Over the course of the proceedings, several professionals, including a court-appointed guardian ad litem (GAL) and various counselors, provided reports and affidavits with conflicting recommendations regarding the children’s best interests and parental conduct.The Nineteenth Judicial District Court, Lincoln County, issued an order on April 23, 2025, that amended the parenting plan based on the parties’ affidavits and written submissions from the children’s counselor, without holding an evidentiary hearing. The amended plan divided primary residence between the parents: the youngest child would reside primarily with the mother, while the two older children would remain with the father. The court expressly relied on written reports from the children’s counselor, granting her discretion over certain parenting determinations. The father objected, arguing that the lack of an evidentiary hearing and opportunity to cross-examine the counselor and GAL violated his rights.The Supreme Court of the State of Montana held that the district court erred by amending the parenting plan without first conducting an evidentiary hearing, as required by Montana law, and by denying the father the opportunity to examine professional personnel whose opinions were relied upon. The Supreme Court reversed the amended parenting plan, vacated the district court’s order as to the amendment, and remanded the case for an evidentiary hearing and new findings consistent with statutory requirements. View "Marriage of Handy" on Justia Law

The appellant was convicted of felony strangulation of a partner or family member after an incident in which she physically assaulted S.R., her romantic partner. During their relationship, the appellant exhibited a pattern of abusive behavior, including emotional and physical abuse, financial control, and threats. The charged offense occurred during a confrontation related to S.R.’s Facebook communication with another person. During this incident, the appellant took S.R.’s phone and, after a struggle, placed S.R. in a chokehold, applying significant weight that caused pain and lightheadedness but did not result in loss of consciousness. S.R. did not immediately report the assault but later confided in her sister, who helped her contact law enforcement. The appellant was subsequently interviewed by detectives, during which her statements about the incident changed multiple times.The First Judicial District Court for Lewis and Clark County initially declared a mistrial due to comments made in the presence of the jury regarding the controlling nature of the relationship. In preparation for the second trial, the court considered the admissibility of evidence of other acts of domestic violence by the appellant. The court ultimately allowed testimony regarding a pattern of abuse and control, excluding only allegations of prior sexual assault as unduly prejudicial, and permitted limited testimony about prior strangulation.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by admitting evidence of other acts under Montana Rules of Evidence 403 and 404(b). The Supreme Court held that the evidence was properly admitted for non-propensity purposes, specifically to demonstrate motive, explain the relationship dynamics, and clarify the victim’s behavior and credibility. The Court concluded that the District Court did not abuse its discretion and affirmed the conviction. View "State v. Mann" on Justia Law

A motorcyclist was injured when his motorcycle collided with a vehicle that was pulling out of a parking lot onto a public roadway. The driver of the vehicle was attempting to make a left turn but her view was obstructed by a line of stopped cars waiting to enter the lot. The motorcyclist, traveling northbound, collided with the vehicle in the northbound lane and suffered serious injuries. He had no memory of the crash. The motorcyclist sued the driver for negligence, alleging that she failed to yield as required by state law. The driver denied liability and argued that the motorcyclist was also negligent.The case was tried in the Montana Eighteenth Judicial District Court. The motorcyclist sought partial summary judgment, arguing that the driver was negligent per se for violating a statute requiring vehicles entering from a driveway to yield. The District Court denied summary judgment, finding disputes of material fact about the parties' respective conduct. At trial, the jury found both parties negligent, attributing 65% of the fault to the motorcyclist and 35% to the driver, resulting in a defense verdict. The court entered judgment for the driver. The motorcyclist moved for a new trial, arguing errors in evidentiary rulings, jury instructions, and the exclusion of demonstrative videos. The District Court denied the motion.On appeal, the Supreme Court of the State of Montana affirmed the District Court's rulings. The Supreme Court held that summary judgment was properly denied due to disputed factual issues about both parties’ actions at the time of the collision. The Supreme Court found no abuse of discretion in the District Court’s decisions to admit expert testimony from the crash investigator, exclude videos taken after the accident, allow certain cross-examination of an expert, and give jury instructions reflecting the statutory law. The Supreme Court affirmed the judgment. View "Murray v. Steinmetz" on Justia Law

A Montana ballot initiative, known as BI-9, sought to amend the state constitution by creating a new section that would define and limit the powers of “artificial persons,” such as corporations and other entities, by prohibiting them from spending money or anything of value to influence electoral outcomes. The initiative arose after a previous attempt (BI-4) by the same proponents was rejected for violating the state’s constitutional separate-vote requirement. The Montana Attorney General again found BI-9 legally insufficient, determining that it combined multiple unrelated constitutional changes in a single proposal and therefore violated Article XIV, Section 11, of the Montana Constitution.After the Attorney General’s finding, the proponents petitioned the Supreme Court of the State of Montana for declaratory judgment, challenging the Attorney General’s assessment. The Attorney General argued that BI-9 not only added new material to the constitution but also limited the powers of artificial persons, affected a wide range of entities beyond corporations, and implicitly amended other constitutional provisions, all of which, in his view, required separate votes.The Supreme Court of the State of Montana reviewed the initiative and disagreed with the Attorney General’s conclusions. The Court held that BI-9 constituted a single constitutional amendment under Article XIV, Section 11, because the proposal’s various components were closely related and did not amount to “logrolling” or voter deception. The Court distinguished the current proposal from prior rejected initiatives and found that the specification of affected entities and the consequences of political spending restrictions did not require separate votes. The Court reversed the Attorney General’s rejection of BI-9 and ordered him to prepare and forward a ballot statement to the Secretary of State. View "Transparent Election Initiative v. Knudsen" on Justia Law

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