Justia Montana Supreme Court Opinion Summaries

A Montana-based workers’ compensation insurer was sued by a Texas company in federal court, with the suit alleging breach of contract and seeking over $8 million in damages. The litigation was settled confidentially, but before settlement, the insurer filed its annual financial statement with the Montana Commissioner of Securities and Insurance, failing to specifically disclose the existence of the federal lawsuit. The Commissioner repeatedly directed the insurer to amend its statement to include the ongoing litigation, but the insurer declined to do so.After the insurer refused to comply, the Commissioner initiated administrative proceedings, seeking both a supplement to the annual statement and a $25,000 fine. A Hearing Examiner partially granted summary judgment, permitting the Commissioner to supplement the statement with the existence of the litigation but not the settlement, since the settlement occurred outside the reporting period. The Special Deputy Insurance Commissioner adopted these findings and imposed the maximum fine. The First Judicial District Court, Lewis and Clark County, reviewed the agency’s final decision and affirmed it fully, holding that the Commissioner was empowered to impose the fine without explanation.On appeal, the Supreme Court of the State of Montana affirmed the lower courts’ and agency’s finding that the insurer violated the Insurance Code by failing to disclose the federal lawsuit in its annual statement. The Court held that the Commissioner’s orders to supplement the statement were lawful and within statutory authority. However, the Court reversed the imposition of the $25,000 fine, concluding that the agency’s failure to explain its exercise of discretion in setting the fine amount was arbitrary and capricious. The case was remanded for the agency to provide a cogent explanation before imposing any fine. View "Victory Insurance v. State Auditor" on Justia Law

The defendant was cited for driving under the influence of alcohol, driving without proof of insurance, and driving without valid registration outside Big Timber in December 2022. A bench trial was held in Sweet Grass County Justice Court in October 2023, resulting in convictions for all three offenses. As first-time offenses, the defendant received a suspended custodial sentence, mandatory treatment, and fines. She appealed to the Sixth Judicial District Court for a trial de novo.After the appeal, the District Court issued multiple scheduling orders requiring the defendant’s personal appearance at jury trial verification hearings, warning that failure to appear could result in vacating the trial or other consequences. The defendant missed the first hearing but appeared at the second after a continuance, explaining she had been out of state and unaware of the hearing. Her trial was rescheduled along with another verification hearing, but she failed to appear again. With no explanation for her absence provided by counsel, the State moved to dismiss the appeal, and the District Court granted the motion.The Supreme Court of the State of Montana reviewed the District Court’s dismissal for abuse of discretion and considered whether counsel’s performance was ineffective. The Court held that the District Court did not abuse its discretion under § 46-17-311(5), MCA, because the defendant was ordered to personally appear, failed to do so without explanation, and had repeated opportunities to show good cause. Statutory notice was deemed sufficient to inform her of the consequences. The Court further found the record insufficient to resolve the ineffective assistance of counsel claim on direct appeal. The judgment of the District Court was affirmed. View "State v. Green" on Justia Law

A county attorney in Montana advised local officials not to provide confidential criminal justice information (CCJI) to Immigration and Customs Enforcement (ICE) for civil purposes without a court order, citing Montana law. The Montana Attorney General disagreed, asserting that ICE is a “criminal justice agency” entitled to access such information and ordered the county attorney to change her policy. When the county attorney requested a formal opinion, the Attorney General refused, then formally asserted supervisory control, requiring the county attorney to issue a memo permitting full disclosure of CCJI to ICE. The county attorney complied under protest and filed a petition with the Supreme Court of Montana seeking a declaratory judgment on the matter.The Attorney General claimed the dispute was nonjusticiable, arguing it was a political question, that the county attorney lacked standing, and that any opinion would be advisory. The Supreme Court of Montana found these arguments unpersuasive. The Court determined that the county attorney had standing because she is an independently elected official with statutory duties, including advising county officials, and the Attorney General’s supervisory authority does not extend to this advisory function. The Court also concluded that the dispute did not present a political question or an advisory opinion and thus was justiciable.The Supreme Court of the State of Montana held that the county attorney’s petition is properly before the Court and that the Attorney General exceeded his authority by attempting to direct the county attorney’s legal advice to county officials. The Court declared the Attorney General’s order unenforceable. The Court did not decide whether ICE is a “criminal justice agency” under Montana law but ordered further briefing on that issue and whether such agencies are automatically entitled to CCJI solely by virtue of their status. View "Cromwell v. Knudsen" on Justia Law

A married couple with two minor children separated, and the wife initiated dissolution proceedings. They reached agreements on parenting and property, specifying that child support would be calculated under Montana Child Support Guidelines via the Child Support Services Division (CSSD). The husband was to maintain health insurance for the children if available at a reasonable cost, and the parties would split tax exemptions. CSSD issued a temporary support order, but the wife later challenged the calculation, arguing it contained errors regarding parenting days, incomes, and health-insurance credits, and she requested recalculation and back support.After the Office of Administrative Hearings denied her request for review as untimely, the wife sought recalculation in the Montana Fourth Judicial District Court. The parties eventually agreed on key financial inputs, and several support calculations were considered. The District Court initially ordered support based on a worksheet not admitted into evidence, modified the tax and insurance provisions from the parties’ agreement, and declined to award retroactive support. On appeal, the Montana Supreme Court remanded for more detailed findings.Following remand, the District Court clarified income, parenting days, and tax allocations, and maintained that the wife should enroll the children in Healthy Montana Kids rather than private insurance. However, the adopted support calculation continued to credit the husband for private insurance premiums, contradicting the findings. The court again declined to award retroactive support, finding both parents had met the children’s needs and had received family assistance.The Supreme Court of the State of Montana held that the District Court’s child-support calculation did not implement its findings regarding health insurance and reversed that portion of the order, remanding for a corrected calculation consistent with the findings. The denial of earlier retroactive support was affirmed. The husband’s request for sanctions was denied. View "In re Marriage of Christofferson" on Justia Law

A Montana Highway Patrol officer stopped the defendant for a vehicle malfunction and observed signs of marijuana use. After the defendant admitted to smoking marijuana and submitted to field sobriety tests, he was arrested for driving under the influence. The officer transported him to a hospital, where a certified phlebotomist drew his blood. The State charged the defendant with felony operation of a vehicle with a THC concentration of 5 ng/ml or more, based on the blood toxicology report, and related misdemeanors. The defendant contested the foundational requirements for admitting the blood test, specifically the statutory requirement that the phlebotomist be supervised by a physician or registered nurse, and challenged the use of his certified driving record to establish prior DUI convictions for felony sentencing.The District Court of the Twenty-First Judicial District, Ravalli County, admitted the blood test evidence, overruling the defense’s objection and finding hospital employment sufficient to imply supervision. The court also relied on the defendant’s certified driving record to find at least three prior DUI convictions, sentencing him as a fourth or subsequent DUI offender. The defense appealed, arguing both the blood test admission and the sentencing enhancement lacked proper foundation.The Supreme Court of the State of Montana reviewed the case. It held that the District Court abused its discretion by treating hospital employment as sufficient to establish the statutory supervision requirement for blood draws. However, the Supreme Court found the defendant waived his objection by failing to make it in a timely manner before the evidence was introduced. Regarding sentencing, the Supreme Court held that the certified driving record constituted competent evidence of at least three prior DUI convictions and affirmed the sentencing enhancement. The Supreme Court affirmed the conviction. View "State v. Rogers" on Justia Law

A property once owned by the Vinings in Ravalli County, Montana, had two groundwater wells historically used for commercial beaver pens, with statements of claim filed in 1982. The property also included a pond not originally specified in the water rights claims. After the mid-1990s, the Vinings discontinued use of the wells for beaver pens, instead using the water for irrigation and livestock, without obtaining the required authorization to change the beneficial use. In 2020, YC Properties, LLC acquired the property and associated water rights. In 2023, YC Properties sought to amend the claims to include the historic pond, prompting objections from neighboring landowners who argued the water rights had been abandoned.The Montana Water Court consolidated the claims and, after motions from both sides, granted summary judgment to the objectors. The Water Court determined that use of the water for irrigation and livestock by the Vinings and YC Properties, instead of the claimed commercial beaver pen use, constituted unauthorized use. The Water Court concluded that the long period of unauthorized use was the functional equivalent of non-use and intent to abandon, thus triggering a presumption of abandonment. The court found YC Properties failed to rebut this presumption and dismissed the water rights claims.On appeal, the Supreme Court of the State of Montana reviewed whether the Water Court erred in its abandonment analysis. The Supreme Court held that while post-1973 conduct could be considered in abandonment determinations, unauthorized water use is not per se equivalent to intent to abandon under Montana’s common law. The Supreme Court reversed the summary judgment, holding that abandonment is a factual question requiring consideration of all circumstances, including whether water was continuously put to beneficial use, even if unauthorized. The case was remanded for further proceedings consistent with this ruling. View "YC Properties v. Connolly" on Justia Law

The defendant was charged with deliberate homicide following an arrest in March 2021. Initially released on bond, he was later taken into custody after missing a required hearing. At a pretrial release revocation hearing, the State was represented by then-Deputy County Attorney Brett Linneweber. Over time, the defendant changed attorneys multiple times, displaying distrust toward counsel and initially refusing to accept any plea agreement. Ultimately, after negotiations, he agreed to plead guilty to mitigated deliberate homicide in exchange for a binding sentencing recommendation and dismissal of other charges. Before the plea hearing, Judge Linneweber, who had since been appointed to the bench, was assigned to the case. Although he had previously appeared for the State in a related proceeding, he determined his involvement was minimal and did not recuse himself, accepting the defendant’s guilty plea.After his plea, the defendant filed a motion for Judge Linneweber’s disqualification, which was referred to the Montana Supreme Court. Judge Linneweber then recused himself, and the motion was denied as moot. The defendant later sought to withdraw his guilty plea, citing involuntariness, ineffective assistance of counsel, newly discovered evidence, and pressure to accept the plea, but did not explicitly raise the disqualification issue as a basis for withdrawal. The Thirteenth Judicial District Court denied the motion, finding no evidence that the plea was not knowing or voluntary and that the new evidence could have been discovered earlier.The Supreme Court of the State of Montana reviewed whether the failure to recuse constituted good cause for plea withdrawal. The Court held that Judge Linneweber’s prior involvement as counsel required disqualification by statute and rule. The failure to recuse was a due process violation and constituted good cause to withdraw the guilty plea. The Court reversed the District Court’s order and remanded for further proceedings. View "State v. Notafraid" on Justia Law

The defendant sent a series of text messages to the Lincoln County Dispatch using the text-to-911 feature on three separate dates in January and February 2024. He repeatedly contacted dispatch to complain about a cell phone he claimed was not returned by law enforcement a decade earlier. Despite being told that his complaint was not an emergency and being directed to appropriate reporting avenues, he continued to send numerous messages, including profanity and statements perceived as threatening. Over these incidents, dispatchers testified that the frequent alerts from his texts interfered with their work.A criminal complaint was filed in Lincoln County Justice Court, initially alleging multiple counts of obstructing a peace officer based on these communications. The State later amended the complaint to include additional offenses after further investigation. The District Court ultimately charged the defendant with ten counts, including intimidation, obstructing a peace officer, false reports to peace officers, and privacy in communications, with offenses tied to each date of conduct. At trial, the jury acquitted the defendant of intimidation but convicted him on the remaining nine counts. The District Court imposed suspended jail terms and a partially suspended Department of Corrections sentence, with some sentences running concurrently and one consecutively.The Supreme Court of the State of Montana reviewed whether the defendant’s counsel was ineffective for not objecting to multiple convictions under Montana’s multiple charges statute, and whether there was sufficient evidence to support one privacy in communications conviction. The court held that the offenses occurred on distinct dates and were not part of the same transaction. It found no deficiency in counsel’s performance and concluded that sufficient evidence supported the privacy in communications conviction. The Supreme Court affirmed all convictions. View "State v. Savage" on Justia Law

A Montana Highway Patrol trooper stopped the defendant for speeding and discovered signs of intoxication, including the smell of alcohol and slurred speech. The defendant admitted to drinking, and after refusing a blood sample, a search warrant was obtained. A certified phlebotomist, supervised by a registered nurse in a “distant” manner, drew the defendant’s blood at the county detention center. The blood test showed a blood-alcohol concentration of 0.136. The defendant was charged with operation of a vehicle with a blood-alcohol concentration of 0.08 or more, fourth or subsequent offense, and related misdemeanors.The Twenty-First Judicial District Court, Ravalli County, presided over the trial. The defendant moved to exclude the blood-test evidence, arguing improper supervision under Montana Code Annotated § 61-8-1019(1). The District Court denied the motion, finding both the phlebotomist’s qualifications and the supervisory relationship sufficient. At sentencing, the defendant disputed a 1995 DUI conviction listed in the PSI. The District Court relied on a certified driving record and other documents, finding competent proof of the 1995 conviction and sentencing the defendant under § 61-8-1008(2), MCA, as a fifth offense, imposing prison time, credit for time served, fines, statutory surcharges, and an audit-hearing provision.The Supreme Court of the State of Montana reviewed the case. It held that the blood-test evidence was properly admitted, as the statutory requirements for supervision were satisfied. The Court affirmed that the certified driving record constituted competent proof of the disputed 1995 DUI conviction. It also held that the defendant was properly sentenced under § 61-8-1008(2), MCA, as the predicate conviction remained valid. However, the Court reversed the sentence in part, remanding for resentencing to correct jail credit, reduce surcharges, and strike the audit-hearing provision due to lack of statutory authority. View "State v. Rogers" on Justia Law

A married couple executed a Marital and Property Settlement Agreement (MPSA) in 2012, which allocated their marital debts, including a Parent PLUS student loan, to the husband. He agreed to be solely responsible for the debt and indemnify his former wife. While he resolved other debts, he did not pay the Parent PLUS loan until the wife sought contempt in 2022. The parties then stipulated that the husband would make monthly loan payments and apply proceeds from a business sale toward the loan. The wife remained the borrower, but the husband assumed responsibility for payments. After further nonpayment, the wife again sought contempt in 2024.The Montana Eleventh Judicial District Court, Flathead County, held the husband in contempt for failing to pay monthly amounts due in August and September 2024, denied his request for expanded account access, entered an immediately collectible judgment for the entire unpaid loan balance in favor of the wife, and awarded her attorney fees. The court determined that the husband had willfully failed to comply with his payment obligation and found that his unauthorized changes to the account justified restricted access.The Supreme Court of the State of Montana affirmed the denial of unrestricted account access and the contempt determination based on August and September 2024 nonpayments. It also affirmed the award of $3,237.50 in attorney fees to the wife. However, the Supreme Court vacated the full-balance judgment for the loan, holding that the parties’ agreements did not authorize immediate acceleration of the entire debt based on missed monthly payments. The Court remanded for determination of an enforcement remedy consistent with the agreements and applicable law, and for reasonable appellate attorney fees, while denying appellate sanctions. The underlying allocation of debt and adjudicated obligations from June 2024 remain undisturbed. View "In re Marriage of Kearns" on Justia Law