Justia Montana Supreme Court Opinion Summaries

Pursuant to a plea agreement, Defendant pleaded guilty to felony DUI. Defendant appealed, arguing that the district court erred in denying his motion to dismiss the charge based on an alleged violation of his speedy trial rights. The Supreme Court affirmed the conviction, holding (1) Defendant suffered substantial pretrial delay largely attributed to the State's institutional delay in bringing him to trial, but Defendant failed to demonstrate that the delay caused undue prolonged disruption of his life or aggravated his anxiety beyond the expected level; and (2) Defendant failed to demonstrate that this delay substantially prejudiced his ability to defend against the charges. View "State v. Steigelman" on Justia Law

A trust (Trust) purchased lots in an RV park. The purchase agreement for the lots granted Trust an easement for access to a lake over and across lakefront property. At the time of the purchase, the lake property was encumbered by a deed of trust issued by Bank. After the owners of the lake property became delinquent on their loan obligations, Bank attempted to foreclose on the lake property by way of a trustee's sale, at which it purchased the property. Because Bank failed to provide Trust with notice of the sale, Bank subsequently noticed a second trustee's sale of the lake property, this time providing notice to Trust. Trust filed a complaint against Bank, claiming the Bank was precluded from holding the second sale and that it therefore could not extinguish its easement via the second sale. Bank subsequently purchased the property at the second trustees sale. The district court concluded (1) the first trustee's sale was invalid, but the second trustee's sale was valid; and (2) Trust's easement claims were therefore subordinate to Bank's interests in the lake property. The Supreme Court affirmed, holding that the district court correctly concluded that Bank effectively foreclosed on Trust's easement through the second trustee's sale. View "Terry L. Bell Generations Trust v. Flathead Bank of Bigfork" on Justia Law

Plaintiff purchased property from Defendants in 1993. The warranty deed for the property contained no express mention of water rights, ditch easements, or appurtenances. Plaintiff nevertheless believed that a water right came with the property and that a ditch easement existed to transport the water to his property. Defendants later purchased real property which historically contained a ditch. It was subsequently discovered the property did have a ditch that traversed from a creek, across Defendants' property, to a 20-acre "place of use" on the properly now owned by Plaintiff. Plaintiff subsequently attempted to reopen use of the ditch and filed an action against Defendants seeking a declaration that he had a ditch easement across Defendants' property. The district court ruled in favor of Defendants. The Supreme Court affirmed, holding that the district court properly determined that Plaintiff had no ditch easement across property owned by Defendants. View "Roland v. Davis" on Justia Law

Three individuals (collectively, "Pallister") were unnamed members in a class action suit against insurers Blue Cross and Blue Shield of Montana, Inc. (BCBSMT) and Montana Comprehensive Health Association (MCHA). The suit generally sought damages from the insurers for the companies' delayed payments of benefits and for benefits improperly withheld. BCBSMT, MCHA, and the named class members subsequently entered into a proposed settlement. Pallister objected to the settlement agreement and filed a motion to conduct discovery into the fairness of the proposed settlement. The district court denied the motion. The Supreme Court reversed and vacated the district court's approval of the settlement agreement. The Court remanded to the district court with instructions to allow discovery into the settlement negotiations. Pallister then filed a motion for substitution of the district court judge. The judge denied the motion. The Supreme Court affirmed, holding (1) Pallister was not a party for purposes of substitution; and (2) Mont. Code Ann. 1-804(12) did not provide for substitution on remand in this case. View "Pallister v. Blue Cross & Blue Shield of Mont., Inc." on Justia Law

After Sarah West was involved in a motor vehicle accident, West made a claim against her insurer, State Farm, for underinsured motorist benefits of $75,000. State Farm paid only $20,000 in benefits. Attorney Tracey Morin subsequently filed a complaint against State Farm on behalf of Sarah and her parents, Ausra and James West, for breach of contract, violation of the Montana Unfair Trade Practices Act, and breach of the implied covenant of good faith and fair dealing. At the conclusion of the action, the district court imposed sanctions on Morin individually under Mont. R. Civ. P. 11. Morin appealed, contending that the depth and breadth of the sanctions constituted an abuse of discretion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in imposing the level of sanctions imposed in this case. View "Morin v. State Farm Mut. Auto. Ins. Co." on Justia Law

In 2012, Plaintiff sought and obtained a temporary order of protection against Defendant in a civil action. Subsequently, Plaintiff obtained a no contact order against Defendant in a criminal action. Defendant moved to have the civil action dismissed with prejudice as a discovery sanction. Plaintiff moved to have the civil action dismissed without prejudice in the event she needed a future civil order of protection. The district court granted Plaintiff's motion and dismissed the civil action without prejudice. The Supreme Court affirmed, holding (1) under the circumstances, it made sense to dismiss the action without prejudice so that, if necessary, Plaintiff could resurrect her action quickly; and (2) Defendant failed to establish that Plaintiff should be sanctioned with a dismissal of her proceeding with prejudice for her failure to appear for a deposition. View "Lear v. Jamrogowicz" on Justia Law