Justia Montana Supreme Court Opinion Summaries

After child R.M.T. had been in the custody of the Montana Department of Public Health and Human Services for two years, the Department petitioned for termination of Father's and Mother's rights. After finding that Father's attempts to comply with his treatment plan failed to reach the level necessary to complete the plan, the court determined that the termination of Father's parental rights was in R.M.T.'s best interest. The court then terminated both Father's and Mother's parental rights. Father appealed. The Supreme Court affirmed, holding (1) the lower court did not abuse its discretion when it terminated Father's rights; and (2) the lower court violated Father's due process rights when at the termination hearing the court declined Father's request to cross-examine the guardian ad litem, who submitted a factual report to the court, but because the report provided no new information to the court, the exclusion of the guardian ad litem's testimony did not cause substantial injustice to Father.

Harold Caldwell was injured when he fell at an airport where he worked as manager. The airport's insurer, MACo, paid Caldwell's medical and wage-loss benefits. MACo, however, denied Caldwell rehabilitation benefits based on Mont. Code Ann. 39-71-710. Caldwell challenged the constitutionality of the statute on the basis that its categorical termination of benefits based on a claimant's eligibility for social security violated equal protection principles. The Workers' Compensation Court (WCC) agreed, concluding that the statute creates two similarly situated classes and treats them disparately without being reasonably related to a legitimate government interest. MACo appealed. The Supreme Court affirmed, holding (1) the statute creates two similarly situated classes and treats them differently, and (2) the categorical elimination of rehabilitation benefits in the statute based solely on age-defined eligibility for social security does not rationally relate to any governmental interest. Therefore, the statute violates the Equal Protection clause insofar as it deems disabled workers ineligible to receive rehabilitation benefits based on their eligibility for social security benefits.

Montana resident Robin Jordan petitioned for a temporary protective order in a Montana county court against Ohio resident Mark Kalin. The court issued the temporary protective order, and Kalin appealed. In the district court, Kalin moved to dismiss for lack of jurisdiction. The district court did not rule on the motion but found it had jurisdiction in its findings issued after the substantive hearing. The district court then adopted a permanent order of protection prohibiting Kalin from having any contact with Jordan or her husband. Kalin appealed. The Supreme Court affirmed, holding (1) the district court did not err in failing to grant Kalin's motion to dismiss as the allegations of the petition were sufficient to confer jurisdiction on the district court; (2) the evidence was sufficient for the district court to issue a permanent order of protection; and (3) the district court's order of protection did not punish Kalin for exercising his constitutional right to defend himself in court.

Following a jury trial, James Main Jr. was convicted of deliberate homicide and felony murder. Main appealed, arguing that (1) the district court erred in denying his motion to suppress statements he made to two police officers while he was being driven to the police station and while at the police station; (2) the district court erred by denying Main's motion to dismiss for insufficient evidence at the close of the state's case-in-chief; and (3) Main was denied effective assistance of counsel. The Supreme Court affirmed, holding that (1) Main voluntarily, knowingly, and intelligently waived his Miranda rights; (2) the evidence was sufficient to permit the jury to find the elements of the crime had been committed beyond a reasonable doubt; and (3) Main's ineffective assistance of counsel claims should be addressed in a postconviction proceeding.