Justia Montana Supreme Court Opinion Summaries

James and Rachel Earl filed an action against Pavex Corporation seeking declarations concerning two overlapping easements that burdened the Earls' land for the benefit of Pavex's land. One of the easements was 100 feet in width and the other thirty feet in width. The Earls asserted (1) the 100-foot-wide easement was unenforceable because it did not appear in the chain of title to the Earls' property, and (2) in the alternative, even if the 100-foot-wide easement was valid, they were not required to remove structures and cropland that encroached upon both easements. The district court concluded (1) the 100-foot-wide easement did not burden the Earls' property, and (2) the Earls may be required to remove the structures and cropland from the easements - if the Supreme Court found the 100-foot-wide easement to be valid - to the extent necessary to effectuate the purposes of the easements. The Supreme Court (1) reversed the district court's conclusion that Pavex's 100-foot-wide easement was extinguished by failure to properly record it; and (2) affirmed the district court's ruling that encroachments must be removed from the two easements to the extent they constituted unreasonable interference with Pavex's easement rights. Remanded. View "Earl v. Pavex" on Justia Law

Teresa and Dee Carestia sued Jeffrey Robey, claiming damages resulting from a car accident. The jury found Jeffrey's negligence was the cause of the accident and that Dee was contributorily negligent. The jury awarded Teresa $872 in medical expenses but awarded nothing for her past and future pain and suffering or loss of capacity to pursue her established course of life. Both parties subsequently filed a bill of costs. The district court allowed the Carestias to recover costs from Jeffrey and Jeffrey to recover costs from the Carestias. Teresa appealed. The Supreme Court reversed in part and affirmed in part, holding (1) a portion of the jury's damage award was not supported by substantial credible evidence, as Teresa was entitled to some award of damages for her past pain and suffering proven in this case; and (2) the district court did not abuse its discretion when it denied the Carestias' objection to Jeffrey's bill of costs. Remanded. View "Carestia v. Robey" on Justia Law

The Lincoln County Commissioners created the Bull Lake Rural Fire District and appointed a Board of Trustees to govern the District. The District and County later disputed the permissible scope of the District's services and the circumstances under which the District could be dispatched. The district court granted summary judgment to the County, holding (1) the County delegated to the District only the authority to provide limited firefighting services, and only the County could authorize the District to expand the scope of its services; and (2) the District was only entitled to receive notice of emergencies in its geographical area, and Troy Dispatch had the discretion whether to dispatch the District to respond to any particular emergency. The Supreme Court reversed, holding (1) the District's Trustees and the fire chief determined the scope of the District's services under Montana law, and the District was not required to seek prior approval of the County before providing any of those emergency services; and (2) the District was entitled to be notified of a request for service in its geographical area, and Troy Dispatch had the responsibility to determine how to provide the notification and which emergency service provider to dispatch in each instance. View "Bull Lake Fire Dist. v. Lincoln County" on Justia Law

In Brown I, the Supreme Court held that the district court properly found that Defendants had a prescriptive easement to cross Plaintiff's land that included residential and recreational uses but improperly limited the width of the easement to twenty feet for the purposes of trailing cattle. The Supreme Court remanded the case to the district court to clarify the scope of recreational and residential uses authorized by the easement and to modify its order regarding the easement's width. After the case was remanded, Plaintiff appealed. The Supreme Court once more remanded the matter to the district court to modify its order to better define the character and frequency of the recreational and residential use, holding that the district court erred by failing to delineate the scope of Defendants' residential and recreational prescriptive easements across Plaintiff's real property. View "Brown & Brown of Mont., Inc. v. Raty" on Justia Law

Five City employees were disciplined by the City for accessing pornography on their government computers. The local newspaper requested access to documents detailing the investigation of the misconduct and the employees' punishment. The City disclosed some documents, refused to release the disciplinary corrective action forms, and redacted all information that could be used to identify the disciplined employees or uninvolved third parties. The newspaper filed a petition for declaratory relief and writ of mandamus. The district court ordered that the City release copies of the investigative documents and disciplinary forms without redactions. The Supreme Court reversed, holding that the district court erred by ordering that identifying information for the five City employees be released to the newspaper, as the employees' reasonable expectation of privacy in their identities with regards to internal disciplinary proceedings clearly outweighed the limited merits of public disclosure. View "Billings Gazette v. City of Billings" on Justia Law

Appellant was convicted of criminal distribution of dangerous drugs and sentenced to a ten-year term of incarceration. On appeal, Appellant argued that insufficient evidence supported his conviction because the State did not produce sufficient evidence at trial that the substance given to a third party was marijuana, a dangerous drug. The State responded that although the substance was not tested, the third party's testimony and the fact that Appellant had a medical marijuana card were sufficient to prove that the substance was marijuana. The Supreme Court reversed Appellant's conviction, holding that the evidence presented at trial was insufficient to allow a rational trier of fact to conclude beyond a reasonable doubt that the substance in question was a dangerous drug. View "State v. Burwell" on Justia Law

Plaintiffs were covered by the State's employee healthcare benefit program established under Title 2, chapter 18, MCA ("the Plan"). Both Plaintiffs were injured in separate automobile accidents. All of the medical bills of both plaintiffs were paid by either the Plan or by third-party insurers. In both cases, medical care providers returned a claim payment to the Plan because the claim had been paid by other insurers. Plaintiffs asserted that the Plan should not have retained the payments returned by the medical providers but should have paid those amounts to Plaintiffs unless they had been made whole or fully compensated for all losses they incurred as a result of the automobile accidents. The district court concluded that the State's operation of the Plan was subject to the "made-whole" provisions Title 2, and thus, no insurer had a right to subrogation unless the insured was made whole for all losses. The Supreme Court affirmed, holding that the made-whole requirement of Mont. Code Ann. 2-18-902(4) applied to the Plan insofar as it had withheld payments or had retained payments returned by a healthcare provider because the medical expenses had been paid by a third party. View "Diaz v. State" on Justia Law

Appellant entered Alford pleas to the felony offenses of aggravated kidnapping, aggravated assault, assault with a weapon, intimidation, and aggravated burglary. Appellant later moved to withdraw his Alford pleas, contending that his mental state at the time of the pleas precluded him from knowingly and voluntarily making a plea decision, he was innocent to the changes against him, and the district court's colloquy was insufficient to determine whether the pleas were knowingly and voluntarily made. The district court denied Appellant's motion. The Supreme Court affirmed, holding (1) Appellant failed to establish that there was good cause to allow him to withdraw his prior Alford pleas to the charges against him; and (2) the matter should be remanded to the district court for a determination of the total amount of restitution for the victim's future counseling costs. Remanded. View "State v. Peterson" on Justia Law

Appellant, a vocational agricultural teacher at a high school, served as faculty advisor for the school's chapter of the National FFA Organization. Appellant obtained a loan on behalf of the school FFA and opened a checking account into which she deposited the loan proceeds. Because Appellant did not deposit the funds in an account maintained by the school district, Appellant violated the school district financial policy and was suspended. Appellant then made out a check to herself to purportedly reimburse herself for expenses incurred in setting up a hay cutting business. The Board of Trustees subsequently terminated Appellant's employment. The Montana Department of Labor and Industry determined that Appellant was eligible to receive benefits, but a hearing officer concluded that Appellant had been discharged for misconduct and was ineligible to receive unemployment insurance benefits. The Board of Labor Appeals affirmed the determination. The Supreme Court affirmed, holding that Appellant's actions constituted misconduct, and she was therefore ineligible to receive unemployment insurance benefits. View "Roberts v. State Bd. of Labor Appeals" on Justia Law

This case involved L.A., who suffered from schizophrenia. Following her release from her previous commitment, the State filed a petition for involuntary commitment of L.A. After a trial, the jury concluded by special verdict that L.A. was suffering from a mental disorder, was unable to provide for her basic needs, and was a threat of injury to herself or others. The jury also found that if L.A.'s condition were left untreated, it would deteriorate. Following the verdict, the district court adopted an order of commitment and transport order prepared by the State that committed L.A. to the state hospital and approved involuntary medication if it was deemed necessary. The Supreme Court affirmed, holding that the district court did not err by (1) failing to make a detailed statement of facts in its post-trial disposition order; and (2) failing to detail the particular evidence upon which its findings and conclusions were based in authorizing L.A's involuntary medication. View "In re L.A." on Justia Law