Justia Montana Supreme Court Opinion Summaries

When Plaintiff brought her daughter to play in a city park, the child fell from a slide in the playground area and suffered a severe head injury. Plaintiff sued the City for negligently failing to maintain a safe depth of impact-absorbing material in the area under the slide. The district court granted summary judgment to the City, (1) determining that the "public duty doctrine" applied in this case, that the City owed no duty to Plaintiff's daughter, and therefore, the City could not be held liable for the accident; and (2) rejecting Plaintiff's argument that the recreational use statute applied to this case and imposed liability upon the City for willful or wanton misconduct. The Supreme Court reversed, holding (1) based upon an analysis of foreseeability, it was reasonable and proper to hold the City to a duty to exercise reasonable care in maintaining its public parks, and thus, the public duty doctrine did not apply here; and (2) the recreational use statute applied to this case, and the determination of whether the City's conduct rose to the level of willful or wanton misconduct should be decided at trial. View "Gatlin-Johnson v. Miles City" on Justia Law

Petitioners filed a complaint with the Montana Public Service Commission (PSC), alleging that Northwestern Energy had been overcharging consumes for its street lighting services. The PSC dismissed the petition. The Supreme Court affirmed but remanded with instructions to remand the case to the PSC for a redetermination of whether to allow the filing of an amended complaint. On remand to the district court, Petitioners filed a motion seeking $1,137 in costs incurred while responding to objections before the PSC and courts. Petitioners also renewed a motion asking the district court to initiate an immediate rate reduction pending the PSC's final decision. The district court denied both of the Petitioners' requests and remanded to the PSC. The Supreme Court affirmed that order, holding that the district court did not err in (1) denying Petitioners their costs for the initial proceedings in district court and first appeal to the Supreme Court, and (2) denying Petitioners' request for a temporary rate decrease, pending the PSC's decision on remand. View "Williamson v. Mont. Pub. Serv. Comm'n" on Justia Law

After an agent with the Tri-Agency Safe Trails Task Force purchased quantities of marijuana from Defendants in excess of what was legal under the Medical Marijuana Act, law enforcement arrested Defendants. Officers executed search warrants for Defendants' vehicles, their residence, and the garage Defendants frequented, retrieving four times the amount of marijuana Defendants were allowed to possess as caregivers and patients under the Act. Defendants were charged with several drug-related counts. Defendants filed a joint motion to suppress and dismiss, arguing that the state engaged in "outrageous government conduct" by obtaining evidence against them in violation of their federal due process rights. The district court granted the motion because the agent broke numerous laws under the banner of law enforcement. The Supreme Court reversed, holding that because the agent's conduct stopped short of violating the fundamental fairness shocking to the universal sense of justice mandated by the due process clause, the district court erred in dismissing Defendants' charges based on the outrageous government conduct defense. View "State v. Fitzpatrick" on Justia Law

Mike Alexander was one of two former employees of Bozeman Motors who filed suit against Bozeman Motors and its president and managers, alleging negligence, battery, and negligent or intentional infliction of emotional distress. Plaintiffs claimed long-term physical and emotional injuries resulting from exposure to carbon monoxide and propane. Alexander died after filing suit. Bozeman Motors moved for summary judgment on the basis that the claims against it were barred by the exclusive remedy provision of Montana's Workers' Compensation Act. The district court granted Bozeman Motors' motion, holding that the conduct of Defendants did not rise to the level of deliberate intent to cause specific harm, and that Mont. Code Ann. 39-71-413, which provides an exception to the exclusive remedy provision of the Act, was constitutional. The Supreme Court reversed and remanded with respect to Alexander's claims. On remand, the jury returned a verdict for Defendants on all claims. The Supreme Court affirmed, holding (1) section 39-71-413(2) does not create an impermissible class of employees in violation of equal protection; (2) the district court did not err in instructing the jury; and (3) the court did not err in denying Plaintiffs' motion to exclude Alexander's cause of death. View "Alexander v. Bozeman Motors, Inc." on Justia Law

Plaintiff was injured in a car accident when the car in which he was a passenger and which Defendant was driving crashed after Defendant lost control of the vehicle. Plaintiff filed an action against Defendant seeking damages for injuries allegedly caused by Defendant's negligence. Following a jury trial, the jury found in favor of Plaintiff and awarded him $27,000. Plaintiff, having presented evidence of past medical expenses totaling $35,030, filed a motion for a new trial on the issue of damages. The district court denied the motion. The Supreme Court affirmed, holding (1) substantial evidence supported the jury's conclusion that Plaintiff was not entitled to the full amount of damages he requested; and (2) thus, the district court did not abuse its discretion by denying Plaintiff's motion for a new trial. View "Murray v. Whitcraft" on Justia Law

After a jury trial, Defendant was convicted of attempted theft and sentenced to ten years imprisonment. Defendant appealed, arguing that the district court abused its discretion in finding a sufficient chain of custody for the admission of latent fingerprint evidence and forensic analysis. At issue was two fingerprint cards used to take the prints. In specific, in contention was discrepancies between dates written on the back of the cards and their storage in a law enforcement officer's patrol car and office. The Supreme Court affirmed, holding that because the State adequately established the chain of custody of the prints cards, the district court did not abuse its discretion by admitting the latent print evidence. View "State v. McCoy" on Justia Law

In December 2004, Plaintiff, an on-duty law enforcement officer with the Federal Reserve Bank, was injured in an altercation on the bank premises with Defendant, who had trespassed onto the Federal Reserve property while intoxicated. In March 2009, Plaintiff sued for negligence. Defendant moved for summary judgment, arguing that the three-year statute of limitations expired by the time the complaint was filed. The district court granted Defendant's motion. The Supreme Court reversed, holding that the district court erred in granting summary judgment in favor of Defendant, as the evidence of when the statute of limitations began to run on Plaintiff's claim against Defendant was conflicting. Remanded for trial. View "Siebken v. Voderberg" on Justia Law

An underground mine with surface facilities located in Musselshell County (Musselshell) extended underground into Yellowstone County (Yellowstone) and produced coal mined from both Musselshell and Yellowstone. Based upon a report of the counties from which the coal was mined, the Department of Revenue allocated approximately two-thirds of the mine's taxable coal gross proceeds to Musselshell, for a tax of $328,617, and the remainder to Yellowstone, for a tax of $126,909. Musselshell sued Yellowstone and the Department seeking a declaratory judgment that the Department wrongfully allocated a portion of the tax to Yellowstone. The district court upheld the Department's apportionment of the tax between the two counties, holding that Montana law contemplates taxation of the gross proceeds of coal in the county where the coal is mined and that the Department was not required to adopt administrative rules prior to apportioning the tax. The Supreme Court affirmed, holding that the Department correctly apportioned the coal gross proceeds tax from the mine between Musselshell and Yellowstone and was not required by law to create an administrative rule before making that apportionment. View "Musselshell County v. Yellowstone County" on Justia Law

After the district court awarded the Department of Health and Human Services temporary legal custody of Mother's two children, the court adjudicated the children as youths in need of care. The State subsequently petitioned to terminate Mother's parental rights. After a termination hearing, the district court concluded it was in the children's best interests to terminate Mother's parental rights and issued an order to that effect. The Supreme Court affirmed the district court's order, holding that the court did not abuse its discretion in concluding that the State established by clear and convincing evidence that the best interests of the children would be served by termination of the parent-child legal relationship. View "In re H.R." on Justia Law

Decedent's will divided his estate among his wife (Wife) and his sons and left to Wife all of their jointly-owned vehicles and other property. At the time of Decedent's death he and Wife owned a motor home as joint tenants with the right of survivorship. There was an outstanding purchase money security interest on the motor home, and both Decedent and Wife signed the loan document, which specifically provided that each of them was independently obligated for the full amount of the debt. Wife filed a claim against Decedent's Estate for one half the debt on the motor home. The Estate's Personal Representative denied Wife's claim. The district court (1) applied a majority common-law rule from other states providing that Decedent's estate has an equitable duty to pay its aliquot share of debts on such jointly-held property, and (2) held the equitable outcome was to allow Wife's claim against the Estate. The Supreme Court reversed, holding that the district court erred in concluding that Montana law would, as a matter of equity under common law, require Decedent's Estate to pay half of the outstanding security interest in the motor home that became Wife's sole property upon Decedent's death. View "In re Estate of Afrank" on Justia Law