Justia Montana Supreme Court Opinion Summaries

John Chaussee was charged with driving under the influence of alcohol. The offense was alleged to be Chaussee's fourth DUI conviction, making it a felony. Chaussee filed a motion to dismiss, arguing that two of his prior DUI convictions were constitutionally invalid. The district court denied the motion. Chaussee pleaded guilty, reserving his right to appeal the denial of his motion. At issue on appeal was whether Chaussee sufficiently demonstrated that his prior convictions were constitutionally infirm. The Supreme Court affirmed the district court's denial of Chaussee's motion to dismiss, holding that Chaussee failed in his burdens of production and persuasion to demonstrate that his prior convictions were constitutionally invalid.

Victor Tacke failed to pay real property taxes on his property in Lake County from 2005 to 2008. In 2006, the County conducted a tax sale for the year 2005, at which the County purchased the tax lien. In 2009, the County assigned its interest in the tax lien to Montana Lakeshore Properties (Lakeshore) in exchange for payment of the past due taxes and issued a tax sale certificate to Lakeshore. The County subsequently issued a tax deed to Lakeshore. In 2010, Tacke filed an action to quiet title in the property, seeking a judicial declaration that the tax deed was void. The district court granted summary judgment in favor of Lakeshore. At issue on appeal was whether Lakeshore violated Mont. Code Ann. 15-17-212(3) by paying the back taxes two hours and forty-five minutes short of two weeks after giving notice to Tacke. The Supreme Court affirmed, holding that the district court did not err by granting summary judgment upholding the tax deed obtained by Lakeshore because this case fit within the general principle that "the law regards the day as an indivisible unit" and discards fractional days in most time computations.

Norma Jean King worked for the Hays/Lodge Pole School District for more than thirty-five years, holding positions of elementary school teacher, elementary school principal, and high school principal. After serving as the high school principal for three years, the school district board of trustees reassigned her to an elementary school teaching position. On appeal, the county superintendent and, subsequently, the state superintendent affirmed the board's reassignment decision. The district court reversed the state superintendent's ruling, holding that the state superintendent erred in ruling that a principal position was comparable to a teaching position. The Supreme Court reversed the judgment of the district court, holding that the district court erred in concluding that the positions of teacher and principal were not comparable positions of employment under the applicable statutes. Remanded.

In an effort to regulate gravel pits within the county, the Gallatin County Board of Commissioners (Commission) created an interim zoning district and proposed creation of four permanent zoning districts throughout the county. The Gateway Opencut Mining Action Group (GOMAG) sought an injunction against the Commission, claiming the public comment provision of the applicable zoning statute, Mont. Code Ann. 76-2-205(6), was unconstitutional. Subsequently, GOMAG and Gallatin County agreed to defer certain statutorily-required actions until GOMAG's injunction request was heard by the district court. Meanwhile, several county farms and ranchers and two gravel pit owners (Intervenors) intervened in the action, seeking summary judgment on the ground that the Commission had failed to act within the statutorily-required time and, therefore, the case was moot. The district court granted Intervenors' motions for summary judgment. On appeal, the Supreme Court affirmed, holding that because protests filed under the challenged statute had no impact on the course of the Commission proceedings and that no constitutional violation capable of repetition occurred here, the district court did not err in granting summary judgment to Intervenors on the basis of mootness.

Defendant Lang and Sons owned and operated a cattle ranch. Plaintiff Burlington Resources Oil and Gas Company leased the rights to oil and gas beneath Lang's surface estate. Burlington reinstated use of an abandoned well on Lang's property for the disposal of wastewater, which Lang objected to. Burlington filed a complaint with the district court to compel access to Lang's property, and Lang counterclaimed that it had a right to compensation for the use of the pore space beneath the abandoned well. The district court determined that Burlington had no obligation to compensate Lang separately for injecting wastewater into the pore space and that Lang had failed to prove entitlement to damages under the Surface Owner Damage and Disruption Compensation Act (SODDCA). On appeal, the Supreme Court affirmed, holding (1) the district court correctly concluded that Lang failed to establish that it was due separate compensation under SODDCA and the facts of this case, and (2) the district court correctly refused to defer to witnesses employed by the Montana Board of Oil and Gas Conservation in interpreting the SODDCA.

Defendant Sebastian Olivares-Coster pled guilty to deliberate homicide and attempted deliberate homicide and was sentenced to three life sentences. The district court did not orally impose any parole restrictions but presumed that Defendant would be eligible for parole after sixty years of incarceration. On appeal, the Supreme Court reversed the judgment and commitment of the district court to the extent it provided that Defendant would be eligible for parole after sixty years, holding that because Defendant was a juvenile at the time he committed the offenses, the sixty-year restriction on Defendant's parole eligibility pursuant to Mont. Code Ann. 46-23-201(4) was expressly prohibited by Mont. Code Ann. 46-18-222(1), which provides that restrictions on parole eligibility do not apply if the offender was less than eighteen years old at the time of the commission of the offense.

The Larsens, plaintiffs, commenced an action seeking to quiet title to a 26.96-acre parcel of land. The Richardsons, defendants, counterclaimed that they held an easement by prescription over a portion of that land. Subsequently, the Richardsons amended their counterclaim to allege they owned the northernmost 9.74 acres of the parcel outright, retaining their easement theory as an alternative ground for relief. The district court (1) ruled that the Larsens owned the entire 26.96 acres and that the Richardsons did not hold a prescriptive easement, and (2) awarded some of the Larsens' requested costs and denied their request for attorney's fees in its entirety. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in determining that the Larsens owned the disputed 9.74 acres; (2) the district court did not err in determining that the Richardsons did not hold a prescriptive easement; (3) the district court did not err in denying the Larsens' request for attorney's fees; and (4) the district court erred in denying the Larsens' request for costs for the reasonable expenses incurred in preparing additional maps and surveys for purposes of trial. Remanded.

Joseph Graziano, an owner of property in the Stock Farm subdivision and a member of the Stock Farm Homeowners Association, filed a complaint against the Association and Stock Farm LLC (SFLLC), asserting several claims, including negligence, breach of fiduciary duties, defamation, and constructive fraud. The Association and SFLLC moved to stay the proceedings and compel arbitration pursuant to a provision of Stock Farm's Covenants, Conditions, and Restrictions (CCRs). The district court granted the motion, finding the CCRs were an enforceable agreement to arbitrate all the claims in Graziano's complaint. On review, the Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in finding the CCRs were not a contract of adhesion and were within Graziano's reasonable expectations, and thus were enforceable; (2) the district court erred in finding Graziano's claim of breach of fiduciary duty was not a personal injury claim exempt from arbitration under Mont. Code Ann. 27-5-114(2)(a); and (3) all of Graziano's remaining claims were subject to the valid and enforceable arbitration provision and must be arbitrated pursuant to the CCRs. Remanded.

Upon divorcing, Holly and Walter Wolf executed a dissolution agreement that was incorporated into a dissolution decree. Pursuant to the agreement, Walter agreed to pay Holly spousal maintenance. Holly later married Joseph Loftis, after which Walter stopped making payments to Holly. The district court subsequently declared the marriage between Holly Joseph to be invalid. Holly then filed a motion for partial summary judgment on her action contesting Walter's termination of maintenance payments, asserting that Walter's maintenance obligation was reinstated after Holly and Joseph stopped living together and arguing that Walter was in arrears. The district court ultimately granted summary judgment to Holly, concluding that the dissolution agreement unambiguously obligated Walter to continue paying Holly maintenance despite her remarriage. The Supreme Court reversed, holding (1) the district court erred in concluding that Mont. Code Ann. 40-4-208(4) was inapplicable in determining Walter's maintenance obligations under the dissolution agreement upon Holly's remarriage; and (2) under the plain language of the statute, Walter's maintenance obligation to Holly terminated by operation of law upon Holly's marriage to Joseph. Remanded.

Appellants filed suit against Appellees under the Uniform Declaratory Judgment Act (UDJA), alleging that they possessed a prescriptive easement over a roadway on Appellees' property. The district court concluded that Appellants had failed to establish the elements for a prescriptive easement and awarded attorney fees to Appellees. Appellants appealed, contending that the district court abused its discretion in granting attorney fees because nothing in the UDJA allowed an award of attorney fees solely on the basis that one party prevails over the other, or that one party had to defend property rights. On review, the Supreme Court reversed the district court's award of attorney fees to Appellees, holding that Appellees failed to establish the threshold determination that equitable considerations supported the award.