Justia Montana Supreme Court Opinion Summaries

Meadow Brook owned land that it developed into lots with covenants, conditions, and restrictions. Meadow Brook then decided to develop an undeveloped tract as an independent subdivision. The existing homeowners, however, argued that the covenants granted them exclusive use of three roads that future homeowners would need to use to access the subdivision. A court concluded that the covenants did not reserve an easement over the three roads for use by future lot owners. First American Title Insurance Company and First American Title Company of Montana (collectively, First American), which had issued Meadow Brook a title insurance policy, subsequently denied Meadow Brook’s claim for coverage and refused to further defend against the homeowners’ counterclaims. Meadow Brook settled with the homeowners in the easement litigation and then sued First American for, inter alia, breach of contract and negligence. The district court granted summary judgment to Meadow Brook as to the breach of contract claim, concluding First American had insured under the policy that the three roads would be open to public access. The Supreme Court affirmed, holding that the district court did not err in granting Meadow Brook’s motion for partial summary judgment on the breach of contract claim. View "Meadow Brook, LLP v. First Am. Title Ins. Co." on Justia Law

L.N. was the fourth child born to Mother and Father. After L.N. was born, the State petitioned for termination of parental rights. After a hearing, the district court found that the State had proven by clear and convincing evidence that Mother and Father had subjected L.N.’s siblings to chronic and severe neglect and that the parental rights of Mother and Father to L.N.’s siblings had been terminated under circumstances relevant to their ability to care for L.N. The court then concluded that reasonable efforts at reunification were not required and terminated the parental rights of Mother and Father to L.N. The Supreme Court affirmed, holding that, under the circumstances of this case, the district court did not abuse its discretion when it terminated the parental rights of Mother and Father.View "In re L.N." on Justia Law

Appellant was an officer with the Glacier County Sheriff’s Office (GCSO) from 1995 to 2010 and occasionally investigated the deaths of people he knew. In 2010, Appellant pled guilty to two misdemeanors and resigned from the GCSO. In 2011, Appellant applied for disability retirement benefits from the Sheriffs’ Retirement Systems, alleging that he was permanently disabled due the post-traumatic stress disorder (PTSD) he developed while working at the GCSO. The Montana Public Employees’ Retirement Board (PERB) denied Appellant’s disability claim, concluding that Appellant’s PTSD was not permanently disabling. The district court affirmed PERB’s decision to deny benefits. The Supreme Court affirmed, holding that the district court did not misapprehend the effect of the evidence presented and properly determined that the findings of PERB were not clearly erroneous.View "Fauque v. Mont. Pub. Employees Ret. Bd." on Justia Law

In 2010, Todd Schmidt petitioned to dissolve his marriage to Aimee Schmidt. In 2012, the district court entered a decree of dissolution setting forth a parenting schedule and dividing the marital property 50/50. The Supreme Court affirmed the findings, conclusions, and decree entered by the district court with one exception, holding that the district court (1) did not clearly abuse its discretion in the parenting plan it adopted; (2) erred by including Aimee’s credit union account twice in a spreadsheet format in its calculation of the marital estate; (3) did not err in determining the value of the Three Rivers bank account; and (4) did not err by including the value of a post-separation account held under the name of Jeffrey S. Lamoreaux, who was living with Aimee at the time of the hearing, in its distribution of the marital estate.View "In re Marriage of Schmidt" on Justia Law

In 2010, the City of Whitefish passed Resolution 10-46, which authorized the City to enter into an interlocal agreement with Flathead County concerning planning and zoning authority over a two-mile area surrounding the City. In 2011, voters in Whitehead passed a referendum repealing the Resolution. Plaintiffs, residents of the City and the County, filed the present lawsuit claiming that the citizens’ power of referendum and initiative did not extend to the Resolution. The district court agreed with Plaintiffs and granted summary judgment to Plaintiffs and the County. The Supreme Court affirmed, holding that the district court (1) did not err by not dismissing the suit as untimely based upon the doctrine of laches; and (2) did not err by determining that the Resolution was not subject to the right of voter initiative and referendum because the Resolution was an administrative act by the City.View "Phillips v. City of Whitefish" on Justia Law

Martin Vincent Lau was charged with deliberate homicide. Lau claimed that the fatal shooting was an act of self-defense. Lau sought to offer his own out-of-court statement to prove that at the time of the shooting, he knew of specific instances of violence by the victim. The State moved in limine to prohibit Lau from introducing the statement on hearsay grounds. Lau, in turn, argued that the exclusion of his statement would limit his ability to put forth a defense and that he would be required to testify in order to establish his knowledge of specific instances of conduct by the victim. The district court ruled that Lau would be permitted to cross-examine witnesses about the victim's specific acts of violence and Lau’s knowledge of those acts, as contained in his statement. The Supreme Court granted the State’s petition for writ of supervisory control, holding that the Montana Rules of Evidence did not permit Lau to offer his own out-of-court statement in support of his claim of justifiable use of force.View "State v. District Court" on Justia Law

Defendant was charged with trespass to property and possession of dangerous drugs, both misdemeanor offenses. Defendant subsequently decided to enroll in the Mineral County Treatment Court. Defendant was aware that he could be sanctioned with incarceration if he was dishonest during his participation in the Treatment Court. During his participation in the Treatment Court Defendant tested positive for drug use and was interviewed by the Treatment Team regarding the results. Subsequently, a member of the Treatment Team sent a report to law enforcement detailing the information he learned from the interviews with Defendant. Defendant was subsequently charged with distribution of dangerous drugs and two counts of possession of dangerous drugs. Defendant filed motions to suppress and dismiss, arguing that the State violated the confidentiality provision of Mont. Code Ann. 46-1-1111(4) and his Fifth Amendment right against compelled self-incrimination by disclosing the confidential Treatment Court material to law enforcement. The district court denied the motions. The Supreme Court reversed the district court’s denial of Defendant’s motions to suppress and dismiss, holding that the State violated section 46-1-1111(4) by disclosing confidential drug testing information to law enforcement in order to investigate a new criminal offense.View "State v. Plouffe" on Justia Law

After a jury trial, Defendant was convicted of two counts of deliberate homicide. The Supreme Court affirmed the conviction on appeal. Defendant subsequently filed a petition for postconviction relief alleging that the State had failed to disclose exculpatory and impeachment evidence relevant to the case in violation of Brady v. Maryland and that his trial attorneys failed to provide effective assistance of counsel. The district court denied the petition. The Supreme Court affirmed, holding (1) the district court properly denied Defendant’s postconviction petition because the petition did not fulfill the elements of a Brady violation; and (2) any alleged error on the part of trial counsel did not prejudice Defendant, and therefore, the trial court did not err in concluding that Defendant had not received ineffective assistance of counsel.View "McGarvey v. State" on Justia Law

In 2011, Defendant was charged with driving under the influence of alcohol (DUI) and disorderly conduct. Defendant pleaded not guilty and requested a jury trial. The trial court later informed Defendant that his scheduled trial was rescheduled because an older case had been set for trial on the same day. Before his rescheduled trial, Defendant moved to have his case dismissed for lack of a speedy trial. The municipal court granted the motion. The district court reversed. On remand, Defendant was convicted of DUI and acquitted of disorder conduct. The Supreme Court reversed the district court ruling reversing the municipal court’s dismissal of the charges, holding that the City failed to meet its burden of showing “good cause” for the delay in bringing Defendant to trial.View "City of Helena v. Broadwater" on Justia Law

Greg LeMond had an oral contract to purchase a five-acre lot (Lot 11) at the Yellowstone Mountain Club from the lot's owner, Yellowstone Development. Yellowstone Development allegedly breached its contract with LeMond by combining twenty-three acres of additional property with Lot 11 to create what became the Overlook Lots, comprising a total of twenty-eight acres. LeMond sued, claiming that Yellowstone Development breached its contract to convey Lot 11 and was under an equitable duty to convey the entirety of Overlook Lots to LeMond. In its final determination, the district court quieted title to the Overlook Lots in favor of LeMond. The Supreme Court reversed in part, holding that the district court did not provide adequate insight into the equitable considerations involved in granting LeMond title to the Overlook Lots, as Yellowstone Development was obligated to transfer Lot 11 to LeMond and was unjustly enriched by failing to do so, but LeMond was entitled to enforce a constructive trust worth only the equitable value of the parties’ bargain. View "LeMond v. Yellowstone Dev., LLC" on Justia Law