Justia Montana Supreme Court Opinion Summaries

Two police officers observed Defendant in a bar holding a beer can. Believing that Defendant was younger than twenty-one years old, the officers asked how old Defendant was then asked for identification to verify Defendant's age. The officers subsequently told Defendant to accompany the officers outside. After Defendant provided a false first name and birthdate, the officers placed Defendant under arrest. After confirming that Defendant was under twenty-one years old, the State charged Defendant with minor in possession and obstructing a police officer. The city court granted Defendant's motion to suppress. The district court affirmed, determining the officers had violated Defendant's right against self-incrimination by requesting Defendant's name, birthdate, and identification. The Supreme Court affirmed, holding that the officers had sufficient particularized suspicion to approach Defendant and ask his age, but the officers improperly expanded their investigation by taking Defendant outside without additional articulable facts. View "State v. Driscoll" on Justia Law

Plaintiff submitted an online application for a payday loan with Geneva-Roth Ventures, which charged Plaintiff an interest rate of 780 percent APR. The loan agreement contained an arbitration clause. Plaintiff entered into the contract over the Internet and did not separately sign or initial the arbitration clause. Plaintiff brought a putative class action against Geneva-Roth for charging an interest rate higher than the thirty-six percent APR permitted by the Montana Consumer Loan act for payday loans. Geneva-Roth filed a motion to compel arbitration pursuant to the arbitration clause in the loan agreement. The district court denied the motion, determining that the arbitration clause was unenforceable. The Supreme Court affirmed, holding that the arbitration clause qualified as a contract of adhesion and fell outside Plaintiff's reasonable expectations. Therefore, the arbitration clause was unconscionable. View "Kelker v. Geneva-Roth Ventures, Inc." on Justia Law

Appellant was a fifty-five-year-old male with a history of schizoaffective disorder. The State filed a petition to involuntarily commit Appellant, alleging that Appellant was unable to care for his basic needs and appeared to pose a danger to himself and others. After a hearing, the district court granted the State's petition and involuntarily committed Appellant to the Montana State Hospital (MSH), authorizing MSH to administer appropriate medication involuntarily. The Supreme Court affirmed, holding (1) the district court did not violate Appellant's statutory and due process rights when it failed to obtain a personal waiver of rights under Mont. Code Ann. 53-21-119(1), as Appellant effectively waived his rights by allowing his counsel to inform the judge of his desire to do so; and (2) the district court complied with the statutory requirements in ordering Appellant to take medications as prescribed by his doctors, and this directive was sufficient to authorize involuntary medication. View "In re R.W.K." on Justia Law

This action arose from easement disputes at Big Sky Lake. Plaintiffs were homeowners who owned lakeshore lots. The access road was owned by the Homeowners Association and provided the access to each lakeshore lot. Later, the larger tracts of land outside the access road were divided between the Hollinger and Williams families. The Hollingers' land did not abut the lakeshore and did not abut the lakeshore lots. Plaintiffs claimed a right, based upon language in various documents that arose from the initial development of the lake, to an express easement allowing them the unrestricted use of four roads or trails on the Hollingers' lands for motorized access. After the Hollingers installed gates at several points to block motorized access to the disputed roads, Plaintiffs sued in district court. The district court granted summary judgment to the Hollingers, holding that none of the documents relied upon by Plaintiffs established an easement across the Hollingers' land. The Supreme Court affirmed, holding that the district court properly applied the facts and the law to conclude that Plaintiffs had not established any right to easements over the Hollingers' land. View "Thayer v. Hollinger" on Justia Law

Edythe Rice, who was in her late eighties, owned a cattle ranch. Edythe's son, Clark Rice, assisted Edythe in performing ranch duties. In 2006, Clark was driving a tractor in "advanced twilight" without illuminated lights. Juanita Stands struck the tractor's left rear tire. The impact caused Juanita's vehicle to spin into the neighboring lane, where it collided with Vianna Stewart's vehicle. Juanita and Vianna sustained injuries from the accident. The tractor and automobiles were total losses. After five years in litigation, the district court (1) concluded that Clark was negligent per se for violating three traffic statutes; (2) determined Edythe was vicariously liable for the injuries; and (3) concluded that Clark and Edythe were jointly and severally liable for eighty percent of Juanita's claimed damages and one hundred percent of Vianna's claimed damages. The Supreme Court (1) reversed the district court's judgment against Edythe, holding that the district court erred by proceeding to trial without addressing Edythe's competency or ensuring the parties met statutory notice requirements; and (2) otherwise affirmed. Remanded the case for an evaluation of Edythe's need for a conservator and new trial as to Edythe's vicarious liability only. View "Stewart v. Rice" on Justia Law

Defendant's vehicle hit Brian Beaver from behind, and Beaver died from severe blunt force trauma to his head. Defendant was assigned a public defender for his criminal case. Eight days before his trial, Defendant provided the district court with a pro se motion for appointment of different counsel, claiming that appointed counsel's representation was deficient. Defendant also filed a request for a continuance so that he could retain private counsel. The court denied Defendant's request for substitution of counsel, determining that counsel was providing adequate representation. The court also denied Defendant's motion to continue, determining that Defendant had lacked diligence in seeking private counsel. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by finding that Defendant's counsel was providing effective assistance of counsel; and (2) did not abuse its discretion in determining that Defendant had not made a good faith, diligent effort to retain substitute counsel. View "State v. Holm" on Justia Law

After a jury trial, Defendant was found guilty of felony aggravated assault and misdemeanor unlawful restraint. Defendant subsequently filed a petition for postconviction relief, raising twelve issues. The district court determined that Defendant's petition did not demonstrate any kind of error, cumulative or otherwise, and dismissed the petition. Defendant appealed pro se to the Supreme Court. The Supreme Court affirmed, holding that the district court did not err in finding that Defendant did not meet his burden of establishing that any error of his pre-trial and trial counsel prejudiced his right to a fair trial. View "Rukes v. State" on Justia Law

In 2012, the Yellowstone County Attorney's Office filed a petition for involuntary commitment of Appellant. After an evidentiary hearing, the district court determined that Appellant met the statutory criteria for involuntary commitment and involuntarily committed Appellant to the Montana State Hospital. The Supreme Court affirmed, holding (1) there was sufficient evidence presented for the district court to determine that Appellant required commitment because he was unable to care for his basic needs and presented an imminent threat of injury to himself or others; and (2) Appellant failed to make a substantial showing that his trial counsel was ineffective. View "In re R.F." on Justia Law

Child was born with numerous medical issues and hospitalized for the first three months of his life. The suspected cause of Child's medical problems was maternal drug use. The Department of Public Health and Human Services filed a petition to adjudicate Child as a youth in need of care. After an adjudicatory hearing, the district court found, based upon a preponderance of the evidence, that Child was a youth in need of care. The district court then awarded custody of Child to Father. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in finding that Child was a youth in need of care; and (2) did not err when it granted custody of Child to Father. View "In re M.J." on Justia Law

Plaintiff filed a complaint against Judge Deborah Christopher (Judge), alleging that Judge violated a number of his constitutional rights. The district court granted Judge's motion for summary judgment, concluding that Judge was entitled to judicial immunity from Plaintiff's claims. The district court also determined that Plaintiff's claims were barred by the doctrine of res judicata and collateral estoppel after taking judicial notice of a U.S. district court complaint filed by Plaintiff against Judge, among other defendants. The Supreme Court affirmed, holding (1) the district court properly granted Judge judicial immunity from Plaintiff's claims; and (2) the doctrine of res judicata barred Plaintiff from relitigating his claims. View "Hartsoe v. Christopher" on Justia Law