Justia Montana Supreme Court Opinion Summaries

Mont. Code Ann. 39-8-207(8)(b)(i), which extends the exclusivity remedy of the Workers’ Compensation Act (WCA) from a professional employer organization (PEO) to its client, does not violate Mont. Const. art. II, 16 by depriving an injured worker of full legal redress.PEOs hire employees and assign them to the PEO’s client businesses on an ongoing basis. Defendant entered into a contract with a licensed PEO. The PEO hired Plaintiff and assigned him to Defendant. After Plaintiff suffered an on-the-job injury, Plaintiff filed suit against Defendant, alleging that his injuries occurred because of Defendant’s failure to provide a safe workplace. The district court granted summary judgment for Defendant, concluding that Plaintiff’s claim was barred by the exclusivity provision of the WCA. The Supreme Court affirmed, holding that since both the PEO and Defendant were immediate employers who hired Plaintiff and provided workers’ compensation coverage, they were both entitled to the exclusive remedy of Article II, Section 16. View "Ramsbacher v. Jim Palmer Trucking" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that the weighted average discount ratio (WADR), codified in Mont. Code Ann. 16-2-101(2)(b)(ii)(B), violated liquor store owners’ (collectively, Storeowners) rights to substantive due process and equal protection.The WADR was effective from 1995 to 2016. The State, Department of Revenue (DOR) sold liquor to certified liquor stores (agency liquor stores) and provided those stores with three discounts, one of which was the WADR. The agency liquor stores sold the liquor to individual retail customers and licensed taverns and bars (licensees). When the agency liquor stores sold to licensees whole or unbroken cars of liquor, known as case lots, section 16-2-201(1) required them to provide a separate discount (case discount). Four liquor store owners certified as a class representing similarly situated liquor store owners filed suit challenging the constitutionality of the WADR. Specifically, Storeowners claimed that the WADR should have fully reimbursed them for the cost of providing the case discount to Licensees. The district court concluded that the WADR was unconstitutional. The Supreme Court reversed, holding that the WADR did not violate Storeowners’ rights to substantive due process and equal protection and was, rather, a constitutional part of a statutory scheme designed to privatize liquor stores in Montana. View "Kohoutek v. State, Department of Revenue" on Justia Law

The Supreme Court affirmed Defendant’s conviction for deliberate homicide, holding that the prosecutor did not commit misconduct during closing argument that prejudiced Defendant’s right to a fair trial and warranted plain error review.A jury convicted Defendant of deliberate homicide. On appeal, Defendant argued that the prosecutor committed misconduct during closing argument. Because Defendant did not object to the statements, he sought plain error review. The Supreme Court affirmed, holding that Defendant did not demonstrate that failure to review the asserted errors would result in a miscarriage of justice, raise a question about the fundamental fairness of the proceedings, or compromise the integrity of the judicial process. View "State v. Lau" on Justia Law

The justice court did not err in concluding that Defendant waived his right to a jury trial when he failed to appear at his jury confirmation hearing.Defendant was found guilty by the justice court of driving while under the influence of alcohol and obstructing a peace officer. On appeal, Defendant argued that the justice court erred in determining that Defendant waived his right to a jury trial when he failed to appear at the jury confirmation hearing. The Supreme Court affirmed, holding that, under the circumstances, the justice court did not err in determining that Defendant waived his right to a jury trial by failing to attend his jury confirmation hearing. View "State v. Sherlock" on Justia Law

The Supreme Court affirmed Defendant’s sentence for three separate cases involving partner or family member assault against three different women to a combined twenty years, with eight suspended. The district court included conditions in all three cases that restricted contact between Defendant and his victims. On appeal, Defendant argued that the condition prohibiting contact between him and his second victim was an unreasonable sentencing condition and an unconstitutional restriction on his common-law marriage. The Supreme Court held (1) the contested condition was not an unreasonable sentencing condition; and (2) Defendant’s general objection to the restricted contact conditions was insufficient to preserve his argument that the conditions unconstitutionally infringe upon his marriage, privacy, and due process rights. View "State v. Parkhill" on Justia Law

The Supreme Court affirmed Defendant’s sentence for three separate cases involving partner or family member assault against three different women to a combined twenty years, with eight suspended. The district court included conditions in all three cases that restricted contact between Defendant and his victims. On appeal, Defendant argued that the condition prohibiting contact between him and his second victim was an unreasonable sentencing condition and an unconstitutional restriction on his common-law marriage. The Supreme Court held (1) the contested condition was not an unreasonable sentencing condition; and (2) Defendant’s general objection to the restricted contact conditions was insufficient to preserve his argument that the conditions unconstitutionally infringe upon his marriage, privacy, and due process rights. View "State v. Parkhill" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment to the Wolf Point School District Board of Trustees (Board) on Plaintiff’s claim that the Board unlawfully terminated her employment in violation of the open meeting law, Mont. Code Ann. 2-3-203, and Mont. Const. art. II, 9.Plaintiff appeared before the Board for a hearing regarding the termination of her employment. The Board closed the meeting to the public and then re-opened the meeting to the public, at which time a trustee made a motion, seconded by another, for the Board to terminate Plaintiff’s employment. The meeting was then closed again to everyone except the Board and the superintendent to allow the Board to discuss unspecified litigation strategy at an “executive session” with the Board’s lawyer. When Plaintiff was allowed back into the room the Board voted to terminate Plaintiff’s contract. The Supreme Court reversed the district court's grant of summary judgment to the Board, holding that the district court (1) erred in granting summary judgment that the Board lawfully closed the hearing portion of the meeting based on third-party privacy rights; and (2) erred in granting summary judgment that the Board lawfully excluded Plaintiff from its “executive session” under the litigation strategy exception of section 2-3-203(4). View "Raap v. Board of Trustees, Wolf Point School District" on Justia Law

The Supreme Court affirmed Defendant’s conviction of aggravated assault and reversed his conviction for violating a no-contact order. The Court held (1) the State did not present sufficient evidence for the jury to find Defendant guilty of violating a no-contact order; and (2) the prosecutor’s comment during rebuttal closing argument that the jury’s “job” was to ensure the alleged victim’s safety was improper, and the nature of the remark implicated Defendant’s right to a fair trial, but this isolated incident of alleged misconduct did not result in a miscarriage of justice or compromise the integrity of Defendant’s trial. View "State v. Ritesman" on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment to the City of Billings (City) and the Montana Municipal Interlocal Authority (MMIA) (collectively, Defendants) in this “Petition for Release of Documents” seeking documents related to a civil judgment MMIA paid on behalf of the City. Defendants released to Plaintiff all non-privileged documents and provided privilege logs describing those documents withheld on the ground of attorney-client or attorney-work-product privilege. In his petition, Plaintiff asked for the release of “everything related to” the civil judgment. The district court granted summary judgment in favor of Defendants and dismissed the petition. The Supreme Court affirmed, holding that the privileged documents were not subject to disclosure under the Montana Constitution. View "Nelson v. City of Billings" on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment to the City of Billings (City) and the Montana Municipal Interlocal Authority (MMIA) (collectively, Defendants) in this “Petition for Release of Documents” seeking documents related to a civil judgment MMIA paid on behalf of the City. Defendants released to Plaintiff all non-privileged documents and provided privilege logs describing those documents withheld on the ground of attorney-client or attorney-work-product privilege. In his petition, Plaintiff asked for the release of “everything related to” the civil judgment. The district court granted summary judgment in favor of Defendants and dismissed the petition. The Supreme Court affirmed, holding that the privileged documents were not subject to disclosure under the Montana Constitution. View "Nelson v. City of Billings" on Justia Law