Justia Montana Supreme Court Opinion Summaries

Plaintiff Arthur Rooney appealed a district court's order in favor of Defendant City of Cut Bank in his wrongful termination suit. Plaintiff appealed the court's decision that his termination did not violate Montana's Wrongful Discharge From Employment Act (WDEA). The City cross-appealed the District Court's earlier interlocutory order denying the City's motion to dismiss the WDEA claim. The Supreme Court reversed an interlocutory ruling, and did not reach the issues raised by Plaintiff. The Court affirmed the District Court's judgment in favor of the City on this alternative ground. The Supreme Court concluded Plaintiff was afforded "full and fair adjudication of his claims in the proceedings before the Police Commission." When the City moved for relief from the District Court's order ruling that the WDEA claim was distinct from the appeal of the Police Commission decision, it was correct that issue preclusion applied. View "Rooney v. City of Cut Bank" on Justia Law

Defendant Scott Adams was charged in three separate proceedings in Ravalli County: (1) felony operating a motor vehicle with an alcohol concentration of 0.08 or more, fourth or subsequent offense, and a related misdemeanor; (2) forgery and two counts of misdemeanor theft; and (3) operating a motor vehicle with an alcohol concentration of 0.08 or more, fourth or subsequent offense, and several other offenses. Defendant posted bail following his arrest for the first driving under the influence charge, but bail was revoked following the filing of the second. The District Court then set a higher bail amount for his release. Unable to post bail a second time, Defendant remained incarcerated until a combined sentencing hearing in all three proceedings was conducted; Defendant ultimately served 66 days. Defendant appealed each of the three cases, and the Supreme Court consolidated them for this opinion. On appeal, Defendant argued multiple errors in the district court's decisions, ranging from miscalculation of his sentence and credit for time served. The State conceded that the District Court should not have ordered the revocation sentences to run consecutively to and requested that this provision be vacated. Upon the State's concession, the Supreme Court vacated the provision ordering the revocation sentences to run consecutively to one of the DUI sentences and remanded the case for correction. Otherwise, the Court affirmed the district court in all other respects. View "Montana v. Adams" on Justia Law

Plaintiff-Appellant John Dilley appealed the grant of summary judgment in favor of Defendant-Appellee City of Missoula. The district court concluded the City acted within its legal authority when it purchased the Missoula Civic Stadium with tax increment financing (TIF) funds designated for urban renewal. The stadium was originally planned and developed by Play Ball Missoula, Inc. (Play Ball), a volunteer, non-profit corporation organized for the purpose of bringing a minor league baseball team to Missoula. In 2000, Play Ball and the City entered a development agreement that permitted Play Ball to finance and construct a stadium on blighted City property and later convey the facility to the City. Plaintiff, acting pro se, filed suit prior to the City's acquisition of the stadium, alleging the planned purchase using TIF funds was an "illegal payoff of private enterprise debt." On appeal, Plaintiff argued that the district court erroneously failed to specify which provision under Title 7, Chapter 15, Part 42 of the Montana Code that permitted the "payoff." He also argued that the City could not make such an expenditure of TIF funds simply because the practice was not prohibited by statute. Finding that the City's use of TIF money to acquire the stadium was a proper exercise of its urban renewal posers, the Supreme Court affirmed the grant of summary judgment in the City's favor. View "Dilley v. City of Missoula" on Justia Law

R.T. was born in 2009; his mother was killed in a car accident a year later. R.T.'s biological father was a minor at the time of the mother's death, and was living in a halfway house. R.T.'s maternal grandfather petitioned for guardianship/conservatorship of R.T. A year after the guardianship/conservatorship was granted, R.T.'s maternal grandmother (then living in Hawai'i) petitioned to be substituted as R.T.'s guardian/conservator, claiming it was not in R.T.'s best interest to remain in the grandfather's care because he was exposed to second-hand cigarette and marijuana smoke within the grandfather's home. She further alleged that R.T.'s developmental needs were not being met because the child was always left with babysitters. A hearing was held on the grandmother's petition, and the district court eventually granted the grandmother's petition. The grandfather appealed, arguing that R.T.'s father's parental rights were not terminated and therefore the district court ruled in error. Upon review, the Supreme Court found no error in the district court's decision and found the record supported the court's conclusion. View "In re R.T. a Minor" on Justia Law

The United States District Court for the District of Montana, Helena Division certified the following question to this Court: "Is obesity that is not the symptom of a physiological condition a 'physical or mental impairment' as it is used in Montana Code Annotated 49-2-101(19)(a)?" Respondent Eric Feit filed an administrative complaint with the Montana Department of Labor and Industry (Department) alleging that Burlington Northern Santa Fe Railway Company (BNSF) illegally discriminated against him because of perceived disability. A hearing officer for the Department entered summary disposition in favor of Respondent, concluding that "BNSF engaged in and is liable for a discriminatory refusal to hire Feit because it regarded him as disabled" and awarded damages for lost wages and benefits, prejudgment interest, and emotional distress. BNSF filed an unsuccessful appeal with the Montana Human Rights Commission, which was then presented to the U.S. District Court. Upon review, the Montana Supreme Court accepted the certified question and answered it "yes." View "BNSF Railway Co. v. Feit" on Justia Law

Respondent-Appellant Chad Cringle appealed a district court order that remanded his case to the Montana Human Rights Commission for further proceedings in his discrimination complaint against Petitioner-Appellee BNSF Railway Company (BNSF). The issue on appeal was whether BNSF demonstrated sufficient grounds to excuse its noncompliance with a fourteen-day filing deadline. In 2008, Respondent filed a complaint with the Montana Department of Labor and Industry charging that BNSF had illegally discriminated against him in employment. Following proceedings on the issues of damages and affirmative relief, the hearing officer issued a final decision in Respondent's favor. That same day, the hearing officer issued notice of his decision by mail to the parties. BNSF received the decision the next day. A legal secretary discovered the decision under papers on her desk nineteen days after it was received. By that time, the decision had become final and "not appealable." BNSF filed a notice of appeal, asking for an extension of time in which to file its notice of appeal. Respondent objected to the request. The Commission denied BNSF's appeal. BNSF sought judicial review; The Commission and Respondent filed separate motions to dismiss BNSF's petition. BNSF then appealed the district court's dismissal of its petition, arguing that the district court erred in interpreting the fourteen-day filing deadline as "jurisdictional" and asked the Supreme Court to hold that the Commission had authority to extend the deadline to file the appeal. The case came before the Supreme Court a second time, the last issue to decide was whether BNSF had shown good cause for its untimely filing. Upon review, the Court concluded BNSF failed to justify relief from the deadline. View "BNSF Railway Co. v. Cringle" on Justia Law

The Medical Marijuana Growers Association, Inc., Courier 1, Courier 2, Caregiver 1, Caregiver 2, and Caregiver 3 (collectively referred to as Plaintiffs) appealed an Order and Rationale on Defendant’s Motion for Summary Judgment (Order), entered by the Eleventh Judicial District Court of Flathead County, Montana. The Order determined that caregivers, as providers of medical marijuana to qualifying patients under Montana’s 2009 Medical Marijuana Act, were not permitted to engage in marijuana transactions with or provide cultivation services to other caregivers or their agents or contractors. Upon review, the Supreme Court found the plain language of the statute clear and unambiguous: "A caregiver is authorized to provide marijuana to qualifying patients only. The 2009 MMA does not provide for the transfer of marijuana or paraphernalia from caregiver to caregiver or among their agents, nor is there a provision allowing for a caregiver to cultivate marijuana for other caregivers or for their agents or contractors." Therefore, the Court affirmed the determination of the District Court that the 2009 MMA does not permit the exchange of marijuana among caregivers, nor does it permit a caregiver to cultivate or manufacture marijuana for another caregiver. View "Medical Marijuana Growers Association, Inc. v. Corrigan" on Justia Law

Pro se Defendant Ronald Petersen appealed a district court order that denied his petition for post-conviction relief and his motion to suppress his confession. In January 2009, Defendant pled guilty to Deliberate Homicide in the shooting death of Clyde Wilson. After initially pleading not guilty, Defendant executed an Acknowledgment of Rights and Plea Agreement wherein he agreed to plead guilty to the charge of Deliberate Homicide in connection with Wilson's death, and the State agreed to recommend a sentence of 100 years with no time suspended. Defendant changed his mind on the plea agreement: he claimed that he was manipulated and pressured into pleading guilty. In addition, Defendant filed a Motion to Suppress Confession claiming that his confession was coerced. Upon review, the Supreme Court found that Defendant's claim that he should be allowed to withdraw his guilty plea because the District Court rejected the plea agreement, was already decided against him in his direct appeal to the Supreme Court. The doctrine of res judicata barred relitigation of that issue when it was adequately raised on direct appeal. Moreover, the Court found that Defendant waived the right to raise his remaining claims when he pled guilty. Accordingly the Court held that all of Defendant's claims raised on appeal were procedurally barred, and affirmed the district court's denial of his petition for relief. View "Petersen v. Montana" on Justia Law

Defendant Thomas Evans appealed the revocation of his suspended sentence. In 2003, Defendant pled guilty to issuing bad checks for which he was sentenced to a five-year commitment to the Department of Corrections. Defendant was given credit for nineteen days served pending final disposition. The sentence was suspended pursuant to conditions, and was to run consecutive to a prior Missioula County sentence, also for issuing bad checks. One of the conditions of his suspended sentence was that he “remain law-abiding.” Late 2010, Missoula law enforcement responded to a report that Defendant had assaulted his former girlfriend. The felony assault charge was eventually dismissed, but Defendant retained a misdemeanor PFMA count. The district court denied his motion to dismiss and revoked Defendant's suspended sentence. Defendant appealed and raised several issues on appeal: (1) the District Court lacked jurisdiction to conduct the revocation proceedings; (2) Defendant was denied due process; (3) Defendant challenged whether the State established grounds for revocation by a preponderance of the evidence; and (4) Defendant alleged that the District Court erred in failing to award him credit for time served in jail prior to the revocation of his suspended sentence. Upon review, the Supreme Court concluded that the district court indeed miscalculated Defendant's credit for time served. The Court remanded the case so that the lower court could give Defendant additional credit for time served in the amount of ninety-five days for a total of 158 days. The District Court was affirmed in all other respects. View "Montana v. Evans" on Justia Law

Glacier Kitchens, Inc., CR Weaver Trust, and the Estate of Grace Weaver (collectively "Defendants") appealed the denial of their motion to set aside the default judgments issued against them in district court. Weaver filed a complaint against Plaintiff Mountain West Bank (MWB) alleging breach of contract, unfair trade practices, and a violation of the implied covenant of good faith and fair dealing. MWB filed its answer and counterclaim for judicial foreclosure. MWB attempted to serve the Defendants at the residence of Weaver by personally serving Weaver’s daughter Elizabeth Weaver (Elizabeth). Elizabeth bore no relationship to the Defendants, other than she is Weaver’s daughter. Weaver filed a pro se answer to MWB’s counterclaim as it related to him. The Defendants failed to file an answer or otherwise appear. As a result, MWB applied for entries of default against them. Weaver filed a pro se motion to set aside the judgments against Defendants. In his motion, Weaver noted that Elizabeth was not legally qualified to accept service on behalf of the Defendants. MWB objected and argued that Weaver had failed to explain why Elizabeth was not authorized to accept service on behalf of the Defendants. MWB additionally contended that Weaver, as a non-attorney, could not appear on behalf of the Defendants. The Supreme Court dismissed Weaver's appeal without prejudice due to the fact that as a pro se appellant, Weaver was unable to bring an appeal on behalf of the Defendants. Defendants through counsel made a motion to set aside the default judgments arguing MWB's alleged faulty service. The Defendants' motion to set aside the default judgments was deemed denied pursuant to M. R. Civ. P. 60(c) (2009) when the District Court failed to rule on them within 60 days. It is from that denial that the Defendants appealed. Upon review, the Supreme Court concluded that the district court erred when it failed to set aside the default judgments issued against Defendants due to the problem with service. Accordingly, the Court reversed the district court and remanded the case for further proceedings. View "Mtn. West v. Glacier Kitchens, Inc." on Justia Law