Justia Montana Supreme Court Opinion Summaries

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

The appellant was convicted by a jury in 2011 of vehicular homicide while under the influence, failure to stop immediately at an accident scene involving an injured person, and driving without a valid driver’s license, and received a forty-year prison sentence. Over the years, she challenged her conviction through direct appeal and postconviction relief in the Montana Supreme Court, raising issues such as the limitation of cross-examination, undisclosed witnesses, ineffective assistance of counsel, and alleged Brady violations. Each of her challenges was rejected by the Montana Supreme Court, which found no reversible error or constitutional violation.After exhausting state remedies, the appellant petitioned for federal habeas corpus relief in the United States District Court for the District of Montana, which partially granted relief based on ineffective assistance of counsel. The federal district court ordered the State to either retry the appellant or release her. In response, the State reinstated criminal proceedings in the state District Court, and the appellant filed a motion to substitute the presiding judge. However, while those state proceedings were pending, the United States Court of Appeals for the Ninth Circuit reversed the federal district court’s grant of habeas relief, upholding the Montana Supreme Court’s findings and nullifying the order that had set aside the conviction.Following the Ninth Circuit’s reversal, the Fourth Judicial District Court, Missoula County, reinstated the appellant’s convictions and custody. On appeal, the Supreme Court of the State of Montana held that the appellant was not entitled to judicial substitution because no new criminal action or proceeding had commenced following the federal habeas reversal. The Court affirmed the District Court’s reinstatement of the convictions, concluding that the statutory requirements for judicial substitution had not been triggered. View "State v. Garding" on Justia Law

A developer formed a company in 2006 and purchased property in the Town of West Yellowstone, Montana, intending to construct a 48-unit condominium project. The developer obtained a building permit and a “Will Serve Letter” from the Town, confirming that water, sewer, and storm drainage services would be provided. Construction began in 2007 but ceased in 2011, after which the building permit expired due to inactivity. The developer did not reapply for a permit, nor did it renew related approvals. In 2019, the Town adopted a resolution limiting new wastewater connections due to capacity concerns. In 2020, the developer attempted to sell the property, contingent on confirmation that service connections would still be honored. The Town responded that hookups would be permitted when capacity allowed but did not guarantee immediate service.The Eighteenth Judicial District Court, Gallatin County, denied the Town’s argument that the developer’s claims were time-barred under statutory limitations, ruling that the claims accrued only when the Town refused to guarantee connections in 2020. However, the District Court granted summary judgment for the Town on the merits, finding that the Will Serve Letter did not create an enforceable contract or vested right to service after years of inactivity and expired permits, and that the Town did not owe a special duty under the public duty doctrine.The Supreme Court of the State of Montana affirmed the District Court’s rulings. It held that the developer’s claims were timely but that, even assuming a contract existed, any right to service under the Will Serve Letter expired after a prolonged period of project inactivity and lapsed permits. The Court further held that the Town owed no special duty to the developer beyond its general obligations to the public, and summary judgment for the Town was appropriate. View "West Development, LLC v. Town of W. Yellowstone" on Justia Law

A 37-year-old paraplegic man communicated online with someone he believed to be a 12-year-old girl, soliciting nude images and arranging a meeting for sexual activity. He sent sexual images and videos and admitted to prior sexual contact with minors. Law enforcement arrested him at a planned meeting. During investigation, he admitted his intentions and possession of child sexual abuse material, including images of young children. Authorities found child pornography and bestiality images on his phone. He was charged with two counts of sexual abuse of children under 12 and one count of possession of child sexual abuse material. He entered a plea agreement, resulting in dismissal of one count and amendment of the other, with a recommended sentence of 30 years and a concurrent 10-year term.The Thirteenth Judicial District Court, Yellowstone County, held a sentencing hearing, considering mitigating and aggravating factors such as his health, military service, lack of remorse toward victims, and risk of re-offending. The court sentenced him according to the plea agreement and included recommendations from presentence reports in the written judgment. The court labeled his offenses as "crimes of violence" and included statements regarding his criminal history and imposed various fees and surcharges. The defendant filed a motion to amend the judgment, arguing that certain statements were factually incorrect and that the financial obligations were improperly imposed, but the District Court denied the motion.The Supreme Court of the State of Montana reviewed the case. The Court held that the District Court erred in labeling the offenses as "crimes of violence" and making certain factually erroneous statements, as well as in including recommendations for financial obligations that did not conform to the oral pronouncement of sentence. The Supreme Court affirmed the judgment but remanded with instructions to strike the erroneous statements and financial recommendations from the written judgment. View "State v Hatfield" on Justia Law

Two couples, who were friends and interested in purchasing vacation property to accommodate their families, entered into identical purchase agreements in 2015 with the owner of a luxury resort in Montana. The agreements granted each couple a fractional interest in a three-bedroom villa, with the understanding that they would be transferred to a four-bedroom villa once one was constructed. Until that time, they were to be exempt from maintenance fees and allowed use of a four-bedroom cabin. Both couples paid the purchase price and received warranty deeds for the three-bedroom villas but never received the promised upgrade, as no four-bedroom villas were ever constructed. In 2023, the resort owner demanded maintenance fees and cancelled their reservations when the couples refused to pay, citing the unfulfilled contractual obligation. After the resort was sold to a new owner, the couples received no further communication or access.The couples sued for breach of contract and under the Montana Consumer Protection Act (MCPA), seeking damages and attorney fees. The Montana Nineteenth Judicial District Court granted summary judgment in their favor on the breach of contract claim, finding the agreements valid and breached by the owner for failing to provide the upgrade and improperly charging fees. The court denied summary judgment on the MCPA claim, which went to a jury along with the issue of contract damages. The jury awarded $250,000 in contract damages to each couple but found for the defendant on the MCPA claim. The court subsequently awarded all attorney fees and costs to the couples, finding these were inseparable from the contract claim.On appeal, the Supreme Court of the State of Montana affirmed. It held that substantial credible evidence supported the jury’s damages award, including damages for loss of use after the property changed hands, and that the verdict was consistent with the instructions and supported by the evidence. The court also upheld the award of full attorney fees, finding the claims and related work inseparable, and remanded for a determination of fees and costs incurred on appeal. View "McNain Holdings v. Wilderness Preserve" on Justia Law

A child, A.M.S., was born in 2014 to A.M.N.L. (the mother) and T.J.S. (the father). A.M.S. has always lived with her mother, who has been her primary caregiver. Since 2020, the mother has been in a committed relationship with Q.O., with whom she had another child in 2022. T.J.S. has a significant criminal history, including domestic violence, and is currently subject to a 20-year order of protection obtained by A.M.N.L. against him. T.J.S. had limited visitation with A.M.S. under a parenting plan, but his visitation was suspended after a 2022 arrest for domestic violence. He made only a single small child support payment between 2022 and 2025, accumulating over $15,000 in arrears. In September 2024, the mother and Q.O. petitioned to terminate T.J.S.’s parental rights and for Q.O. to adopt A.M.S., asserting T.J.S. was unfit and had not maintained a substantial relationship with the child.The Eleventh Judicial District Court, Flathead County, appointed counsel for T.J.S., granted him a 90-day continuance to prepare, but denied a subsequent request for a further continuance. At the termination/adoption hearing, the parties stipulated that the Indian Child Welfare Act (ICWA) did not apply, and the court proceeded to hear evidence. The court found T.J.S. unfit, concluded he had failed to maintain a substantial relationship and had waived his parental rights, and granted the adoption.The Supreme Court of the State of Montana reviewed whether the District Court erred in accepting the parties’ ICWA stipulation, in denying a second continuance, and whether T.J.S. received ineffective assistance of counsel. The Supreme Court held that although it was error for the District Court to accept a stipulation that ICWA did not apply, this was harmless because the facts did not trigger ICWA. The Court also found no abuse of discretion in denying the second continuance and concluded that T.J.S. did not receive ineffective assistance of counsel. The decision was affirmed. View "In re Parenting and Adoption of A.M.S." on Justia Law

Janice Graham died in a car accident after Michael Howell, driving a vehicle he jointly owned with his wife Victoria Howell, crossed the centerline and collided with the Grahams’ car. Witnesses described the road as icy and slushy, and Michael’s blood test showed marijuana levels roughly three times the legal limit. Earlier that day, Victoria and Michael discussed the weather and road conditions. After Michael left, Victoria texted him while he was driving. The Estate of Janice Graham sued Victoria for negligence, alleging she was aware Michael was under the influence and should not have entrusted him with the vehicle or texted him while he was driving.The Twenty-First Judicial District Court in Ravalli County granted summary judgment to Victoria Howell. The court found that, under the Estate’s theories of negligence, Victoria did not owe a duty of care to Janice Graham. It concluded Victoria lacked exclusive or superior control over the vehicle as Michael was a joint owner, and therefore, she could not negligently entrust it to him. Additionally, the court determined that Victoria’s act of texting Michael did not create a foreseeable risk or impose a duty to refrain from remote communication.The Supreme Court of the State of Montana reviewed the case de novo. The Court held that negligent entrustment liability requires a defendant to have superior control or an exclusive legal right to the vehicle, which Victoria did not possess. The Court also held that sending a text to a person known to be driving does not, by itself, create a legal duty unless the sender knows or has reason to know their message is likely to distract the driver. The Supreme Court affirmed the District Court’s grant of summary judgment in favor of Victoria Howell. View "Est. of Graham v. Howell" on Justia Law

A dispute arose regarding access across a roadway known as Forgotten Lane, which traverses land owned by the Tompkins and provides access to two parcels owned by Christine Brock as co-trustee of a family trust. All parcels derived from a common 1940s title, but complex conveyances and subdivision actions followed over the decades. Brock asserted she had the right to use Forgotten Lane, citing several legal theories, while the Tompkins contested any private easement and at times blocked the road.Ravalli County District Court initially denied both parties’ motions for summary judgment on Brock’s original express-easement claim, instead inviting Brock to amend her complaint to include implied, prescriptive, and public easement theories. After amendment, the court bifurcated the proceedings, assigning Brock’s express, implied, and public easement claims to itself and reserving prescriptive easement and trespass counterclaims for a jury. Following a bench trial, the court found in Brock’s favor on the implied easement by preexisting use, issued a permanent injunction, and dismissed the remaining claims as moot. Brock’s requests for costs and attorney fees were denied as untimely.The Supreme Court of the State of Montana reviewed the case. It held that the District Court should have granted summary judgment to the Tompkins on the original express-easement theory, but this error did not prejudice further proceedings after Brock amended her complaint. The Supreme Court reversed the judgment on implied easement, finding that Brock had not established, by clear and convincing evidence, an implied easement benefiting either parcel. The permanent injunction and mootness dismissals were vacated, and any preserved alternative easement theory not addressed on the merits was remanded. The Court also reversed the denial of Brock’s request for costs and attorney fees as untimely, remanding for further determination after final judgment. Other procedural and bifurcation orders were affirmed. View "Brock v. Tompkins" on Justia Law