Justia Montana Supreme Court Opinion Summaries

Anthony Cordero, a student at Montana State University (MSU) during the Spring 2020 semester, sued MSU for prorated reimbursement of his tuition and fees after the university transitioned to online learning due to the COVID-19 pandemic. Cordero claimed that MSU breached an express contract to provide in-person education and services. He also asserted claims for breach of implied contract, unjust enrichment, due process violation, violation of the takings clause, and inverse condemnation.The First Judicial District Court of Lewis and Clark County dismissed four of Cordero’s six claims, including the implied contract and unjust enrichment claims, under M. R. Civ. P. 12(b)(6). The court granted summary judgment in favor of MSU on the remaining claims, including the express contract claim, and denied Cordero’s motion to certify the case as a class action. The court found that Cordero did not identify a specific, bargained-for promise by MSU to provide in-person education and that he had no compensable property interest in the tuition and fees paid.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decisions. The court held that there was an express contract between Cordero and MSU, but it did not include a specific promise to provide in-person education. The court found that MSU had the right to change its regulations and policies, including transitioning to online learning during emergencies. The court also affirmed the dismissal of the implied contract and unjust enrichment claims, noting that an implied contract cannot exist when an express contract is present. The court concluded that MSU did not breach its contractual duties regarding tuition and fees, as it maintained campus facilities and services to the extent possible during the pandemic. View "Cordero v. Montana State University" on Justia Law

The case involves a dispute between Judge Kerry L. Burman, the Glendive City Judge, and Mayor Deb Dion of Glendive, Montana. Judge Burman petitioned for a writ of mandamus to reinstate Mary York to her position as Clerk of Glendive City Court after Mayor Dion terminated York's employment. The termination occurred following a disagreement over the justification for York's attendance at a training conference. York was terminated without notice and escorted out of the court, leaving unfinished work and causing operational disruptions.The District Court initially ordered York's interim reinstatement pending further review. Judge Burman argued that Mayor Dion's actions violated state statute, the court's holding in Carlson v. City of Bozeman, and the constitutional doctrine of separation of powers. Respondents contended that Mayor Dion had the statutory authority to terminate York, who was still in her probationary period, and that the court's operations were not significantly impaired.The Supreme Court of the State of Montana reviewed the case. The court determined that the matter was more appropriately characterized as an application for a writ of prohibition rather than mandamus. The court found that Mayor Dion's actions disrupted the court's operations and violated § 3-1-111, MCA, which grants courts the authority to control their ministerial officers. The court held that the executive's authority to hire or fire employees must be exercised in a manner that does not impair the court's ability to conduct its business.The Supreme Court of Montana granted the petition for a writ of prohibition, arresting Mayor Dion's action of terminating York's employment. The court emphasized the need for coordination between branches of government to avoid such disruptions. View "Burman v. City of Glendive" on Justia Law

The case revolves around Candice Lea Davis, who was arrested for driving under the influence (DUI) after her vehicle was found high-centered on a rock berm. Davis had red and watery eyes, and the officer detected the smell of alcohol from her vehicle. She admitted to having a drink after her shift at work. Due to adverse weather conditions, the officer decided to conduct standardized field sobriety tests (SFSTs) at the Sheriff’s Office. Davis was handcuffed for transportation but was informed that she was not under arrest. After performing poorly on the SFSTs and a breath test at the Sheriff’s Office, Davis was arrested for DUI.Davis was convicted on all counts in Justice Court and appealed to the District Court for a trial de novo. She filed a motion to suppress, arguing that she was subjected to a custodial interrogation without being advised of her Miranda rights and that all evidence obtained after she was handcuffed should be suppressed. The State argued that the officer had particularized suspicion that Davis was driving under the influence. The District Court denied Davis's motion to suppress, reasoning that the officer had particularized suspicion to extend the stop at each step of his investigation.The Supreme Court of the State of Montana affirmed the District Court's decision. The court concluded that there was probable cause to believe Davis had committed the offense of DUI when she was placed in handcuffs and taken to the Sheriff’s Office for testing. The court also found that Davis's Miranda rights were not violated as she was not subjected to a custodial interrogation. The court held that the results of the SFSTs and breath test did not require a Miranda warning as they were not self-incriminating statements that must be suppressed in the absence of a Miranda waiver. View "State v. Davis" on Justia Law

The case revolves around Joseph Brian McElroy, who was charged with criminal possession of dangerous drugs with intent to distribute, a felony. The charge stemmed from a traffic stop initiated by Trooper Adams for speeding. During the stop, Trooper Adams noticed the smell of marijuana from the vehicle and observed signs of "hard travel." After verifying the driver's information and concluding that the driver was not under the influence, Trooper Adams questioned the occupants about the smell of marijuana. When they denied consent to search the vehicle, Trooper Adams deployed a canine for a sniff test, which led to the discovery of drugs and other items. McElroy filed a motion to suppress the evidence, arguing that the traffic stop was unlawfully extended without sufficient particularized suspicion.The District Court denied McElroy's motion to suppress the evidence. The court found that Trooper Adams had sufficient particularized suspicion to conduct the canine sniff based on the smell of marijuana, signs of hard travel, the occupants' nervousness, and their somewhat differing backstories. McElroy then entered a plea agreement, reserving the right to appeal the denial of his motion to suppress.The Supreme Court of the State of Montana reversed the District Court's decision. The court found that Trooper Adams did not have sufficient particularized suspicion to expand the traffic stop into a drug possession investigation. The court held that factors such as signs of hard travel, traveling from a known drug center in a third-party vehicle, and nervous demeanor, even when considered together, do not constitute particularized suspicion. The court also noted that the smell of marijuana itself does not constitute particularized suspicion sufficient to conclude there could be drugs in the vehicle. Therefore, the court concluded that Trooper Adams's further questioning about the marijuana smell and subsequent use of the canine sniff were unlawful. The court reversed the District Court's order denying McElroy's motion to suppress evidence and the resulting judgment of conviction and sentence. View "State v. McElroy" on Justia Law

The case revolves around Neil Lanchantin, who was charged with felony DUI and four misdemeanor offenses after being pursued and arrested by a Montana Highway Patrol Trooper on private property. The property, where Lanchantin was residing with his girlfriend, was marked with a "No Trespassing" sign. Lanchantin appealed the First Judicial District Court's order denying his motion to suppress evidence obtained when law enforcement officers entered the private property without a warrant.The District Court denied Lanchantin's motion to suppress on the basis that he did not have a reasonable expectation of privacy at the location of the stop. Lanchantin pled guilty to the DUI charge but reserved his right to appeal the District Court’s order. The State argued that Lanchantin had no privacy interest in the property because he did not live there, and that the "No Trespassing" signs were inadequate to convey an expectation of privacy because they were tacked to trees along the side of the road.The Supreme Court of the State of Montana reversed the District Court's decision, holding that Lanchantin had a reasonable expectation of privacy in the driveway of the property where he was residing with his girlfriend. The court found that the "No Trespassing" signs were sufficient to manifest an actual expectation of privacy that society recognizes as reasonable. The court concluded that law enforcement cannot enter onto private property without a warrant, even in the case of a misdemeanant fleeing, unless there are exigent circumstances. The case was remanded for further proceedings consistent with the court's opinion. View "State v. Lanchantin" on Justia Law

John David Panasuk was pulled over by Officer Riediger and Lieutenant Frank Martell for towing a trailer without trailer plates. After Panasuk was unable to initially provide his license, registration, and proof of insurance, Riediger asked him to exit his vehicle. The other occupants, Camilla TalksDifferent and Dustin Hickman, were also asked to exit. Riediger and Martell knew TalksDifferent as a drug user, but they did not know Panasuk or Hickman. When Hickman produced a North Dakota driver’s license, Riediger contacted the Williams County Task Force in North Dakota and was told Hickman had a history of being a drug dealer and user. Riediger also recalled a previous incident where Panasuk was suspected of selling methamphetamine. TalksDifferent gave consent to search her purse, where Riediger found two syringes. She also told Riediger there was methamphetamine in Panasuk’s vehicle. Riediger seized the vehicle and applied for a search warrant. Law enforcement recovered 6.4 grams of methamphetamine from the vehicle’s center console after searching the vehicle. Panasuk was charged with criminal possession of dangerous drugs and drug paraphernalia.The District Court denied Panasuk’s motion to suppress the evidence, noting Panasuk’s previous incident and that TalksDifferent had said there was methamphetamine in the vehicle. The court found that law enforcement had sufficient particularized suspicion to expand the scope of a traffic stop to a drug investigation.The Supreme Court of the State of Montana reversed the District Court's decision. The Supreme Court found that the initial detention was unconstitutionally extended beyond what was necessary to effectuate the initial purpose of the stop. The court concluded that there were no articulable facts, other than prior suspected criminal histories, which were offered as justification to expand the search into a drug investigation. The court held that knowledge of a person’s prior criminal involvement is alone insufficient to give rise to the requisite reasonable suspicion. The court remanded the matter for further proceedings consistent with its opinion. View "State v. Panasuk" on Justia Law

The defendant, William Jerome Carnes, was arrested on suspicion of driving under the influence of alcohol or drugs. He was charged with felony DUI for a fourth or subsequent offense, misdemeanor resisting arrest, and misdemeanor driving without a valid liability insurance policy in effect. Carnes failed to appear for his final pretrial conference, leading to an arrest warrant being issued. He was later arrested in Nevada for fleeing the scene of an accident and was sentenced to 24 to 72 months in the Nevada Department of Corrections.Carnes filed a pro se motion for a speedy trial or dismissal for lack of speedy trial and timely prosecution, citing the Sixth Amendment to the United States Constitution and Nevada Revised Statutes. The State argued that Carnes did not follow procedure as contemplated by statute to make a request for final disposition. The District Court agreed with the State and denied Carnes’s motion. Carnes then filed a motion to dismiss the case for the State’s failure to comply with the Interstate Agreement on Detainers, which was also denied by the District Court.In the Supreme Court of the State of Montana, Carnes appealed the order denying his motion to dismiss and the subsequent judgment on his plea of guilty to an amended charge of criminal endangerment pursuant to a plea agreement with the State. The court concluded that Carnes failed to preserve his right to appeal the District Court’s denial of his motion to dismiss. The court held that a defendant who voluntarily and knowingly pleads guilty to an offense waives all non-jurisdictional defects and defenses, including claims of constitutional rights violations which occurred prior to the plea. The court found that Carnes’s plea agreement contained no language reserving the right to appeal after his guilty plea and he did not comply with the statutory requirements to reserve the right to appellate review of the adverse pretrial ruling. Therefore, the judgment of the District Court was affirmed. View "State v. Carnes" on Justia Law

The case revolves around the defendant, Luke Strommen, who was charged with Sexual Intercourse Without Consent (SIWC) and Sexual Abuse of Children. The charges stemmed from allegations made by two women, one of whom claimed that she had an ongoing sexual relationship with Strommen when she was a minor. The other woman alleged that Strommen possessed digital images of her engaged in sexual activity when she was 17. Strommen pleaded not guilty to both charges.In the lower courts, the State of Montana sought to present the testimony of a sexual assault behavioral psychologist, Dr. Sheri Vanino, remotely via two-way video conferencing due to her unavailability to travel to Montana for the trial. The defense objected, asserting that personal in-court cross-examination was essential. The District Court granted the State's motion, allowing Dr. Vanino to testify remotely. The trial resulted in Strommen being found guilty of SIWC and sentenced to a 40-year prison term.In the Supreme Court of the State of Montana, Strommen appealed his conviction, arguing that the District Court erroneously allowed the State to present adverse expert testimony remotely via two-way video conferencing at trial. The Supreme Court agreed with Strommen, holding that the allowance of Dr. Vanino's remote testimony violated Strommen's fundamental right to personal face-to-face confrontation of adverse prosecution witnesses in the courtroom at trial, as guaranteed by the Sixth Amendment and Mont. Const. art. II, § 24. The court reversed Strommen's conviction and remanded the case for a new trial. View "State v. Strommen" on Justia Law

A group of plaintiffs, including former members of the Montana Board of Regents, faculty organizations, student groups, and individual students, challenged the constitutionality of three bills passed by the Montana Legislature in 2021. The bills in question were HB 349, which regulated student organizations and speech on campus; HB 112, known as the "Save Women's Sports Act," which required sports teams to be designated as male, female, or coed based on biological sex; and § 2 of SB 319, which revised campaign finance laws and regulated the funding of certain student organizations. The plaintiffs argued that these bills infringed on the constitutional authority of the Board of Regents to supervise, coordinate, manage, and control the Montana University System.The District Court of the Eighteenth Judicial District, Gallatin County, granted the plaintiffs' motion for summary judgment, declaring HB 349, HB 112, and § 2 of SB 319 unconstitutional. The court also denied the plaintiffs' request for attorney fees. Both parties appealed this order.The Supreme Court of the State of Montana affirmed the District Court's decision. The court found that the plaintiffs had standing to bring their claims and that the challenged bills were unconstitutional. The court also upheld the District Court's denial of the plaintiffs' request for attorney fees, as the justices could not reach a majority opinion on this issue. View "Barrett v. State" on Justia Law

The case revolves around Kyle Severson, who was convicted for mitigated deliberate homicide after shooting Tyler Hayden. Severson, his girlfriend, her sister, and his daughter were at a convenience store when Hayden and Dalton Watson arrived. Hayden approached Severson's car, and Severson shot him, claiming he feared Hayden would harm him or his daughter. Severson was charged with deliberate homicide and later found guilty of mitigated deliberate homicide, resulting in a forty-year prison sentence.Severson appealed his conviction, arguing that the District Court erred in denying his motion to dismiss based on the State's failure to disclose favorable evidence and that the cumulative effect of errors in the District Court denied him a fair trial. The undisclosed evidence included law enforcement investigative reports of a burglary at Severson's home and the contents of Watson's cell phone.The Supreme Court of the State of Montana concluded that the cumulative effect of errors in the proceedings denied Severson his constitutional rights to a fair trial and due process. The court found that the prosecutor's misconduct and the State's failure to disclose certain evidence had a direct bearing on the credibility of the witnesses at trial. The court reversed Severson's conviction and remanded the case for a new trial. View "State v. Severson" on Justia Law