Justia Montana Supreme Court Opinion Summaries

The Milky Whey, Inc., a dairy broker based in Montana, bought products from Dairy Partners, LLC, a dairy supply company located in Minnesota. This appeal concerned Milky Whey’s purchase of a product from Dairy Partners that Dairy Partners shipped to Utah. When Milky Whey picked up the product, it had become moldy and unusable. Milky Whey filed suit, alleging breach of contract, breach of warranty, unjust enrichment, and breach of an obligation to pay. Dairy Partners moved to dismiss the complaint for lack of personal jurisdiction. The district court dismissed the action, concluding that Dairy Partners did not come within Montana’s long-arm jurisdiction statute. The Supreme Court affirmed, holding that the district court did not err in determining that it could not exercise personal jurisdiction over Dairy Partners. View "Milky Whey, Inc. v. Dairy Partners, LLC" on Justia Law

In 1998, Steven and Susan Buck were married in California. For the next twenty years, the Bucks lived outside of the United States. In 2001, while living in Indonesia, the Bucks purchased land near Kalispell and built a house. In 2010, Susan moved to Florida, and Steven remained in Indonesia. In 2013, Susan filed a petition for dissolution of marriage in Montana. Steven moved to dismiss the petition for lack of subject-matter jurisdiction because Susan neither resided in nor was domiciled in Montana for the ninety days preceding her petition for dissolution. The district court denied the motion, concluding that it had jurisdiction over the matter. The Supreme Court affirmed, holding that any jurisdictional defect was cured when Susan established domicile for ninety days and filed a supplemental pleading alleging as much. View "In re Marriage of Buck" on Justia Law

All but one of the events giving rise to Plaintiff’s claims occurred in Florida. Plaintiff sued Defendants, alleging that Defendants had procured a wire transfer from Plaintiff to a public adjusting company under false pretenses and with the intent to defraud him. The district court granted summary judgment to Defendants, concluding that general personal jurisdiction did not exist because Defendants’ contacts with Montana were neither continuous nor systematic and that specific personal jurisdiction did not exist because all of the substantial activity underlying Plaintiff’s claims occurred in Florida. The Supreme Court affirmed, holding that the district court correctly concluded that it lacked personal jurisdiction because Defendants formed no “jurisdictionally relevant contacts” with Montana, and Plaintiff’s single act of authorizing his local bank in Montana to wire funds to the public adjusting company was insufficient to establish that his action accrued in Montana for purposes of Mont. R. Civ. P. 4(b)(1)(B). View "Tackett v. Duncan" on Justia Law

Within thirty days of the Town of Eureka’s passage of an annexation ordinance Darrell Sharp filed a petition naming himself, his wife, and “John Does 1-200” as petitioners. After the thirty-day deadline for filing the petition had passed, Sharp filed an amended petition naming himself, his wife, eighty-nine other individuals, and “John Does 1-10” as petitioners. Eureka filed a motion to dismiss. The district court converted Eureka’s motion to dismiss to a motion for summary judgment and granted summary judgment for Eureka, concluding that Mont. Code Ann. 7-2-4741 does not allow relation back of amended pleadings. The Supreme Court affirmed, holding (1) the requirements of section 7-2-4741 do not contemplate relation back of an amendment adding the names of a majority of real property owners to the petition after the thirty-day deadline has passed; and (2) Eureka was entitled to judgment as a matter of law because the petition in this case was not filed within thirty days of the passage of the annexation ordinance by a majority of real property owners in the area to be annexed. View "Sharp v. Eureka" on Justia Law

Plaintiff filed a constructive discharge claim naming the Musselshell County Sheriff’s Office as the sole defendant. Defendant filed a motion to dismiss, arguing that it was not an independent legal entity subject to suit. Plaintiff subsequently moved for leave to amend the complaint to add Musselshell County as a defendant. The district court denied Plaintiff’s motion to amend and granted Defendant’s motion to dismiss. The Supreme Court reversed, holding (1) the district court’s order was appealable; and (2) under the circumstances, the district court’s refusal to allow Defendant to add the correct party constituted an abuse of discretion and resulted in substantial prejudice to Defendant. Remanded. View "Seamster v. Mussellshell County Sheriff's Office" on Justia Law