Justia Montana Supreme Court Opinion Summaries

Peter Carter was driving a Ford Explorer rented from Overland West when Todd Durham's vehicle collided with Carter's vehicle. The impact caused the Explorer to roll five times, partially ejecting Carter and killing him. Carter's estate filed a wrongful death and survival claim against Ford, Overland, and Durham (collectively, Defendants) under strict products liability and negligence theories. After a jury trial, the district court concluded that Durham was liable in negligence and that Ford and Overland were not liable. The Supreme Court affirmed, holding that the district court did not err by (1) denying the estate's motion for default judgment on liability as a sanction against Ford for withholding evidence of other incidents; (2) excluding the estate's proffered evidence of other incidents; (3) excluding evidence related to Ford's actions in making a Safe Canopy System a standard feature in the United States in 2007 and some other countries in 2002, and by permitting Ford to present a "consumer-choice" defense; and (4) excluding an indemnity agreement between Ford and Overland and limiting questioning about the agreement and the parties' prior adversarial position. View "Stokes v. Ford Motor Co." on Justia Law

After a jury trial, Defendant was convicted of driving under the influence of alcohol. The district court affirmed the municipal court's denial of Defendant's motion to suppress that had challenged the particularized suspicion to stop Defendant based on the obstruction of a license plate. The Supreme Court affirmed Defendant's conviction but vacated his sentence, holding (1) the municipal court did not err in denying Defendant's motion to suppress, as Defendant's right to be free from unreasonable searches was not violated; (2) counsel did not render ineffective assistance by failing to elicit certain testimony from the arresting officers at trial and not renewing the motion to suppress once those facts were elicited; but (3) Defendant's sentence violated his due process rights because it was based on his indigency. Remanded for resentencing. View "State v. Haldane" on Justia Law

Plaintiffs acquired the assets of a restaurant. Defendant owned the real property on which the building was located. Plaintiffs and Defendant entered into an agreement granting Plaintiffs a ten-year lease of Defendant's real property. The lease granted Plaintiffs the option to purchase Defendant's real property in 1999 at the expiration of the lease. Plaintiffs claimed they provided written notice to Defendant of their interest in purchasing the property and that Defendant agreed to the appointment of an independent appraiser in 2000, but Defendant never followed through in procuring an appraisal. In 2009, Plaintiffs filed a complaint requesting a declaratory judgment and order requiring Defendant to select an independent appraiser and sell the property. The district court dismissed Plaintiffs' complaint on statute of limitations grounds and granted Defendant's motion for summary judgment on her unlawful detainer counterclaim. The Supreme Court affirmed, holding (1) Plaintiffs failed to demonstrate a set of facts that would enable them to equitably estop Defendant from raising her statute of limitations defense; and (2) the district court did not improperly consider matters outside the pleadings in reaching its decision to dismiss Plaintiffs' complaint. View "Situ v. Smole" on Justia Law

This was the fourth appeal involving public access across Appellee's Teton County property. In previous litigation, Public Land/Water Access Association established public prescriptive easements over two roads and a bridge connecting the roads, which together formed a route across the property. In this appeal, the Association challenged a decision of the district court denying its petition for supplemental relief and dismissing its complaint against Appellee for damages resulting from his removal of the bridge. The Supreme Court reversed, holding that the district court erred by dismissing the Association's claims and denying its petition for supplemental relief after Appellee removed the bridge, as (1) the district court's dismissal of the Association's complaint was based on an incorrect legal interpretation; and (2) given the scope of the prescriptive easement, the Association was entitled to consideration of its petition for supplemental relief. View "Pub. Land/Water Access Ass'n, Inc. v. Jones" on Justia Law

After Respondent voluntarily admitted herself to the behavioral health unit of a hospital, Respondent requested to be discharged. However, the county attorney's office filed a petition requesting that Respondent be committed for further evaluation and treatment. The district court appointed a public defender to represent Respondent, and following a hearing on the petition for commitment, the court committed Respondent to the Montana State Hospital with a treatment order that included the involuntary administration of medication. The Supreme Court affirmed, holding (1) plaint error review of this issue was not warranted; and (2) Respondent was not denied the effective assistance of counsel during the hearing. View "In re J.S.W." on Justia Law

Plaintiff was driving her vehicle on a public highway when she was struck by a truck owned by Stockton Oil Company (Stockton) and driven by Ronald Gerber. Plaintiff filed a complaint against Stockton and Gerber seeking damages for the injuries she sustained as a result of the accident. Stockton was served but Gerber was not. Stockton did not respond to the complaint, and a default was subsequently entered against it in February 2011. A judgment for damages was entered in April 2011. In October 2011, Stockton moved to set aside the default judgment. Sixty-eight days later, the district court granted Stockton's motion. The Supreme Court reversed, holding that the district court (1) erred in granting Stockton's motion to set aside default judgment, as the court ignored the expiration of the sixty-day deadline in doing so; (2) thus, the motion was deemed denied by operation of law; and (3) the deemed denial did not constitute a slight abuse of discretion. Remanded for reinstatement of the default judgment. View "Green v. Gerber" on Justia Law

Defendant jointly owned real property as tenants in common with her sister, Plaintiff. Plaintiff filed a partition action, seeking equitable partition of the property or, in the alternative, a forced sale of the property and equal division of the net sale proceeds. Three partition referees appointed by the district court submitted a final report recommending that the property be divided into two parcels. Defendant presented offers of proof challenging the referees' final report, but the district court confirmed the proposed partition. Defendant appealed, arguing that the district court erred by denying her request for an evidentiary hearing. The Supreme Court reversed the district court's final partition judgment, holding (1) when a party makes a substantiated claim of factual or legal error in the referees' report, due process and equitable concerns require the district court to hold a hearing to determine whether the referees' report equitably divides the real property prior to confirming, changing, or modifying the report; and (2) in this case, Defendant's objections were sufficient to compel the district court to hold an evidentiary hearing. Remanded for an evidentiary hearing. View "Britton v. Brown" on Justia Law

Defendant pled guilty to one count of felony negligent vehicular assault and one count of felony criminal endangerment. The district court sentenced Defendant to the Department of Corrections for six years with eighteen months suspended on each count, to run concurrently, ordered Defendant to complete 100 hours of community service, and imposed twenty-nine enumerated conditions of probation. The Supreme Court affirmed, holding (1) the district court imposed a legal sentence on Defendant; (2) the district court did not impose unreasonable and unconstitutional probation conditions on Defendant; and (3) Defendant's argument that the sentence review division process was unconstitutional was not ripe for judicial determination. View "State v. Whalen" on Justia Law

Kristy Johnston, Judy Olsen, and their mother, Joyce Johnston, owned real property as tenants in common. Joyce left her one-third interest in the property to Kristy when she died. Kristy sent a letter to Judy in 2009 in which she offered to buy Judy's interest in the property or to sell her interest to Judy. Judy accepted Kristy's offer to sell. Kristy subsequently attempted to reject Judy's acceptance and revoke her offer to sell. Judy filed a complaint against Kristy. The court granted Judy's motion for summary judgment, determining that the letters exchanged between Judy and Kristy had created an enforceable contract that satisfied the statute of frauds. The Supreme Court affirmed, holding that the district court properly concluded that the parties' exchange of letters created an enforceable contract. View "Olsen v. Johnston" on Justia Law

Defendants in this suit included the St. Labre Indian Education Association, Inc. and the St. Labre Home for Indian Children and Youth (collectively, St. Labre). After St. Labre experienced a decrease in government funding, St. Labor began a fundraising campaign that NCT asserted resulted in millions of dollars donated to St. Labre through efforts that marketed the plight and need of NCT. NCT filed suit against Defendants alleging (1) St. Labre's fundraising system created a constructive trust on behalf of NCT and St. Labre wrongfully converted those funds to its own use, thus unjustly enriching itself; (2) contract and fraud type issues; and (3) St. Labre unconstitutionally committed cultural genocide against NCT. The district court dismissed all of NCT's motions. The Supreme Court (1) reversed the district court's grant of summary judgment on NCT's claim for unjust enrichment and the imposition of a constructive trust that may arise from St. Labre's fundraising activities after 2002; (2) reversed the district court's grant of summary judgment regarding St. Labre's fundraising activities before 2002; and (3) affirmed the court's grant of summary judgment on all of NCT's remaining claims. View "N. Cheyenne Tribe v. Roman Catholic Church" on Justia Law