Justia Montana Supreme Court Opinion Summaries

Sidney and Julian Helvik, who have lived on their family ranch since 1947, sold a portion of their ranch to Wesley and Karen Tuscano in 2018. In 2020, the Helviks agreed to sell the remainder of the ranch to the Tuscanos under an agreement that included a promissory note and provisions for the Tuscanos to assist the elderly Helviks with end-of-life issues. The Helviks signed a quitclaim deed, but the Tuscanos later had them sign a gift deed, which transferred the ranch without consideration. The Tuscanos never made any payments under the agreement and used the gift deed to obtain a mortgage on the ranch.The Helviks filed a complaint in the District Court of the Sixth Judicial District, Sweet Grass County, seeking to void the agreement and the gift deed, alleging undue influence and fraud. The Tuscanos counterclaimed and filed a third-party complaint against Jacqueline Conner, alleging tortious interference and abuse of process. The District Court granted summary judgment in favor of Conner on the tortious interference claim and excluded evidence of an Adult Protective Services investigation and an oral agreement to transfer land.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court's decision to rescind the agreement based on its equitable powers, noting the unique fiduciary duty in grantor-support agreements. The court found no abuse of discretion in excluding evidence of the APS investigation and the oral agreement. The court also held that the Tuscanos waived their argument regarding jury instructions on undue influence by not objecting at trial. The summary judgment in favor of Conner was upheld due to the lack of evidence of damages. The court declined to award attorney fees to Conner under M. R. App. P. 19(5). The District Court's orders and judgments were affirmed. View "Helvik v. Tuscano" on Justia Law

Kratzer Construction entered into a subcontract with Hardy Construction Co. to perform work on a building addition for Ekalaka Public Schools. Kratzer completed the work and submitted pay applications, including one for $92,856.45, which Hardy partially disputed due to unapproved change orders. Hardy offered to pay $81,153 upon Kratzer signing a release, but Kratzer refused, demanding the full amount plus interest. Hardy later offered the same amount without requiring a release, but Kratzer still declined, insisting on interest.The Sixteenth Judicial District Court granted summary judgment to Kratzer, ruling that Hardy owed $81,153 plus 18% interest from January 6, 2022, and attorney fees, as Kratzer was deemed the prevailing party. Hardy appealed, arguing that Kratzer failed to meet a condition precedent in the subcontract requiring submission of releases from his subcontractors before final payment.The Supreme Court of Montana reviewed the case and concluded that the subcontract's provisions were clear and unambiguous. The court determined that Kratzer's failure to submit the required releases constituted a breach of the subcontract, and Hardy was entitled to withhold payment. The court found that Hardy's offers to settle did not constitute a waiver of the condition precedent or a novation of the contract.The Supreme Court reversed the District Court's summary judgment in favor of Kratzer, including the awards for interest and attorney fees. The court remanded the case for entry of judgment in favor of Hardy, requiring Hardy to pay Kratzer $81,153 for services rendered under the subcontract, less reasonable attorney fees and costs incurred by Hardy. View "Kratzer Construction v. Hardy Construction" on Justia Law

Michael Reilly approached William G. Harris III, a developmentally disabled individual, to purchase his home for $30,000, significantly below its appraised value. Harris, unable to understand the value of money, signed the contract. Reilly attempted to finalize the sale but was informed by the Sheltered Workshop, where Harris was a client, of Harris's disability and was denied further contact with him. Harris passed away in December 2021, and Reilly sued Harris's Estate for specific performance of the contract. The Estate counterclaimed, alleging negligence, violations of the Montana Consumer Protection Act (CPA), and sought punitive damages.The Second Judicial District Court, Butte-Silver Bow County, dismissed Reilly's complaint without imposing sanctions and denied the Estate's request for treble damages and attorney fees. The jury awarded the Estate $28,900 in compensatory damages and $45,000 in punitive damages. Reilly moved to dismiss his complaint just before the trial, which the District Court granted, but the Estate objected, seeking sanctions for the late dismissal. The District Court did not rule on the objection. The jury found Reilly exploited Harris and violated the CPA, awarding damages accordingly. The District Court later denied the Estate's request for treble damages and attorney fees, citing the substantial jury award as sufficient.The Supreme Court of the State of Montana reviewed the case. It held that the District Court abused its discretion by dismissing Reilly's complaint without imposing sanctions, given the late timing and the Estate's incurred costs. However, it affirmed the District Court's denial of treble damages and attorney fees under the CPA, agreeing that the jury's award was substantial. The Supreme Court affirmed the compensatory and punitive damages awarded to the Estate and remanded the case to the District Court to award the Estate its full costs and attorney fees incurred before Reilly's motion to dismiss. View "Harris Estate v. Reilly" on Justia Law

Former students of the University of Montana filed a class action lawsuit against the university, alleging mishandling of student loan reimbursement payments. They claimed that the university's contract with Higher One Holdings, Inc. subjected them to excessive bank fees and unlawfully disclosed their personal information without consent. The university had contracted with Higher One from 2010 to 2015 to process student loan reimbursements, which involved issuing debit cards and charging various fees.The District Court of the Fourth Judicial District in Missoula County certified three classes of plaintiffs but was later partially reversed by the Montana Supreme Court, which upheld the certification of two classes and reversed the third. The case proceeded to a jury trial, where the jury found in favor of the university, concluding that it did not breach its fiduciary duty, violate privacy rights, or unjustly enrich itself.The Supreme Court of the State of Montana reviewed the case on appeal. The students raised several issues, including the admissibility of evidence regarding their banking practices, the testimony of the university's expert witness, the university's closing arguments, the admission of a fee comparison chart, and the refusal of a burden-shifting jury instruction. The court found that the District Court did not abuse its discretion in its evidentiary rulings, including allowing the university to present evidence about students' banking practices and admitting the fee comparison chart. The court also held that the expert witness's testimony was permissible and that the university's closing arguments did not prejudice the students' right to a fair trial.Ultimately, the Supreme Court of Montana affirmed the District Court's judgment in favor of the University of Montana, upholding the jury's verdict. View "Knudsen v. U. of M." on Justia Law

Neely, acting as his own general contractor, hired Grosvold to perform excavation work on his property under an oral contract. Grosvold worked from April to October 2021, but their relationship deteriorated, and Neely refused to pay for an invoice amounting to $55,858. Neely sent Grosvold a notice of alleged defects in the work, which Grosvold disputed. Grosvold then filed a complaint for breach of contract and prejudgment interest, while Neely counterclaimed for breach of contract, negligence, and construction defect.The District Court of the Third Judicial District in Anaconda-Deer Lodge County tried the case before a jury. The court refused to instruct the jury on Neely’s construction defect and negligence claims, reasoning that the evidence did not substantiate the work was done to a residence and that the case was strictly a breach of contract matter. The jury found Neely had breached the contract and awarded Grosvold $60,512.60 in damages. The court denied Grosvold’s request for prejudgment interest, finding the damages were not certain until the jury’s determination.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court’s decision not to instruct the jury on the construction defect claim, holding that the residential construction defect statute did not create an independent cause of action beyond breach of contract or tort. The court also affirmed the refusal to instruct the jury on negligence, finding that Neely’s substantial rights were not affected as the breach of contract instructions adequately covered the disputed subject matter. Finally, the court upheld the denial of prejudgment interest, concluding the amount of recovery was not capable of being made certain until the jury’s verdict. View "Grosvold v. Neely" on Justia Law

Richard Edward Paul died intestate on October 3, 2022, leaving behind four daughters: Richann L. Ray, Dawn M. Paul Charron, Shelbi L. Paul, and Danita J. Paul. Richann was appointed as the Personal Representative of the Estate with the consent of her sisters. The Estate's significant asset was a cabin in Lincoln, Montana. The heirs could not agree on the disposition of the cabin, leading to conflict. Shelbi filed a motion for a temporary restraining order, alleging that Richann intended to sell the cabin contrary to their parents' wishes. The District Court denied the motion and ordered mediation for any disputed issues.The heirs continued to discuss the cabin's disposition, and Shelbi filed a motion to enforce a settlement agreement based on email communications, which the District Court denied, finding no valid settlement agreement. The heirs proceeded to mediation, resulting in a General Release and Mediated Settlement Agreement, which outlined a procedure for selling the cabin to one or more heirs within 30 days of an appraisal. The cabin was appraised at $234,000, but none of the heirs submitted a bid within the 30-day period. Richann listed the cabin for sale and later filed a motion to approve its sale for $106,100, considering the estimated repair costs. Shelbi opposed the motion, arguing the cabin was not fairly marketed.The Montana Eighth Judicial District Court approved the sale, finding the Agreement resolved all issues and the sale price was reasonable and in the best interest of the Estate. Shelbi filed motions to reconsider, which the District Court denied. Shelbi appealed the order approving the sale.The Montana Supreme Court affirmed the District Court's decision, concluding that the Agreement did not address the situation where no heir qualified to purchase the cabin within the specified time. The Court found that Richann, as Personal Representative, had the statutory authority to sell the cabin and that the sale was reasonable and in the best interest of the Estate. View "In re Estate of Paul" on Justia Law

Katelyn Hove was hospitalized in 2018 for pregnancy complications, and the Billings Clinic billed Blue Cross Blue Shield (BCBS) of Montana for her services. BCBS of Montana indicated that BCBS of Texas was her insurance provider. BCBS of Texas paid part of the bill, leaving a balance that Hove did not pay. The clinic assigned the unpaid debt to CB1, a debt-collection agency, which then sued the Hoves for breach of contract, breach of obligation, and unjust enrichment. The Hoves named BCBS of Montana as a third-party defendant. CB1 moved for summary judgment, supported by affidavits from the clinic. Hove responded with a written declaration disputing the charges, including an EOB from BCBS of Texas and an email from the Montana Commissioner of Securities and Insurance.The Thirteenth Judicial District Court, Yellowstone County, granted summary judgment in favor of CB1, reasoning that Hove's declaration and attached EOB were unverified and inadmissible. The court entered a final monetary judgment against the Hoves. The Hoves filed a motion to amend the judgment, attaching a sworn affidavit with the same information as the declaration. The District Court denied the motion, stating that the declaration and its attachments were inadmissible hearsay and that the declaration did not meet the statutory criteria under § 1-6-105, MCA.The Supreme Court of the State of Montana reviewed the case and found that a declaration under § 1-6-105, MCA, is equivalent to an affidavit. The court determined that Hove's declaration, which stated she never spent time in the ICU despite being billed for it, raised a genuine issue of material fact. The court reversed the District Court's summary judgment and remanded the case for trial on the merits. View "CB1 v. Hove" on Justia Law

Jill Brenden appealed an order from the Eighteenth Judicial District Court, Gallatin County, which denied her claims against the estate of her late husband, Robert Brenden. Jill sought reimbursement for expenses and objected to the distribution and valuation of certain property in the estate. Barbara Jensen, Robert's sister and the appellee, sought attorney fees. Jill and Robert had a long-term relationship, cohabitated, and married in 2010. They purchased a home together in 2006 and later built another home on a property Robert inherited. Robert was diagnosed with cancer, which went into remission but later returned. Before his death, Robert designated Barbara as the Payable on Death (POD) beneficiary of his bank account.The District Court found that Jill converted funds from Robert's account after his death, despite her claim that Robert instructed her to transfer the funds before he died. The court admitted bank records as business records, which showed the transfers occurred after Robert's death. Jill continued to access the account and transferred funds to herself without notifying the estate. Barbara intervened in the probate action, filing a third-party complaint against Jill for wrongful conversion and deceit. Jill counterclaimed, alleging unjust enrichment and seeking a constructive trust over the proceeds from the sale of their jointly owned home.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not abuse its discretion in admitting the bank records as business records. The court affirmed the District Court's finding that Jill converted the funds in Robert's account, as Barbara became the rightful owner upon Robert's death. However, the court found that Jill was entitled to her share of the proceeds from the sale of their jointly owned home, held in a resulting trust. The court denied Barbara's request for attorney fees and remanded the case for further proceedings consistent with its opinion. View "In re Estate of Brenden" on Justia Law

Bluebird Property Rentals, LLC, a Montana limited liability company, and its sole member, Alaina Garcia, received a $450,000 loan from World Business Lenders, LLC (WBL) and its subsidiaries in December 2020. The loan, secured by real property in Gallatin County, had an annual percentage rate of approximately 85% and required weekly payments. Bluebird signed several agreements, including a Business Promissory Note and Security Agreement, which listed Axos Bank as the lender, although Bluebird had no prior dealings with Axos. After falling behind on payments, Bluebird sold the collateral property in a distress sale and paid off the loan in October 2022, having paid a total of $945,990.39.Bluebird sued WBL, alleging that WBL engaged in a "rent-a-bank" scheme to evade Montana's usury laws, claiming that Axos Bank was merely a front and that WBL was the true lender. Bluebird sought a declaration that Montana law applied and sought double the interest paid above the maximum allowable rate under Montana law. WBL filed a motion to dismiss and compel arbitration based on the agreements' arbitration and choice-of-law provisions.The Eighteenth Judicial District Court denied WBL's motion, ruling that Montana law must be applied to determine the enforceability of the arbitration and choice-of-law provisions. The court treated WBL's motion as a Rule 12(b)(1) motion to dismiss for lack of subject matter jurisdiction and found that the validity of the arbitration clause was for the court to decide, not an arbitrator.The Supreme Court of the State of Montana affirmed the District Court's decision, holding that the general rule that courts determine arbitrability was not overcome by the facts of this case. The court found no clear and unmistakable evidence that the parties agreed to arbitrate arbitrability, despite WBL's arguments regarding the incorporation of AAA rules. The court did not address the merits of the enforceability of the arbitration agreement or the choice-of-law provision. View "Bluebird v. World Business Lenders" on Justia Law

Laura Marie Obert, a former Broadwater County Commissioner, was investigated by the Montana Department of Justice Division of Criminal Investigation (DCI) in 2015 for allegedly receiving unlawful overtime pay and potential ethics violations. In 2016, Obert entered a deferred prosecution agreement with the Assistant Attorney General, agreeing to repay the excess wages and abstain from voting on matters where she had a conflict of interest. In 2019, based on new allegations of violating the agreement, Obert was charged with felony theft and misdemeanor official misconduct. The district court dismissed these charges in 2021, finding Obert had complied with the agreement and there was insufficient evidence for the misconduct charge.Obert then sued the State of Montana and Broadwater County Attorney Cory Swanson, alleging breach of contract, bad faith, due process violations, and malicious prosecution. The First Judicial District Court dismissed her claims, leading to this appeal.The Montana Supreme Court reviewed the case and made several determinations. It reversed the lower court's dismissal of Obert's breach of contract and good faith and fair dealing claims, holding that these claims were not time-barred and did not accrue until the criminal charges were dismissed. However, the court affirmed the dismissal of Obert's bad faith claim, finding no special relationship existed between Obert and the State that would support such a claim. The court also upheld the dismissal of the malicious prosecution claim, ruling that Swanson was protected by prosecutorial immunity as he acted within his statutory duties. Lastly, the court affirmed the dismissal of the due process claim, concluding that Obert's procedural due process rights were not violated as the State followed proper procedures in charging her and the district court provided an appropriate forum to address the alleged breach of the agreement. View "Obert v State" on Justia Law