Justia Montana Supreme Court Opinion Summaries

The North Central Montana Regional Water Authority (the Authority) was created in 2000 through an interlocal agreement among several municipalities and county water and sewer districts. The Town of Kevin, a small municipality with fewer than 175 residents, did not sign the original agreement but signed several later documents attempting to join the Authority. The Town later sought to sever ties with the Authority, which resisted these attempts. On May 29, 2020, the Town sued the Authority, seeking a declaratory judgment under the Uniform Declaratory Judgment Act (UDJA) that it was not, and never had been, a member of the Authority, and also sought attorney fees.The Twelfth Judicial District Court held a bench trial and issued an order on November 10, 2022, declaring that the Town was not a member of the Authority and granting other relief. Subsequently, the Town filed a motion for attorney fees under the UDJA. On March 30, 2023, the District Court found that equitable factors supported awarding attorney fees to the Town, noting the significant disparity in resources between the Town and the Authority. The Authority appealed this order.The Supreme Court of the State of Montana reviewed the case. The court affirmed the District Court's decision, holding that the UDJA provides a legal basis for awarding attorney fees between governmental entities when appropriate. The court found that the parties were not similarly situated, as the Town had significantly fewer resources compared to the Authority. The court also applied the "tangible parameters test" and concluded that the Authority possessed what the Town sought, it was necessary for the Town to seek a declaration, and the declaratory relief was necessary to change the status quo. Therefore, the District Court did not abuse its discretion in awarding attorney fees to the Town. The Supreme Court affirmed the award of attorney fees to the Town. View "Town of Kevin v. North Central Montana Regional Water Authority" on Justia Law

This case involves a dispute between the City of Great Falls and the Board of Commissioners of Cascade County, Montana, over the interpretation of a 1975 interlocal agreement that established a consolidated City-County Health Board. The disagreement arose after the Montana Legislature enacted new laws in 2021 that changed the governance of local health boards. The County argued that the new laws required the County Commission to be the governing body of the Health Board, while the City maintained that the 1975 agreement allowed the City mayor to be a full voting member of the Health Board.The District Court of the Eighth Judicial District ruled in favor of the City, finding that the 1975 agreement allowed the City mayor to be a full voting member of the Health Board and that the Health Board was the "local governing body" referenced in the new laws. The County appealed this decision to the Supreme Court of the State of Montana.The Supreme Court affirmed the District Court's decision. It held that the District Court did not adjudicate a non-justiciable political question and correctly interpreted the 1975 agreement and the new laws. The Supreme Court found that the 1975 agreement allowed the City mayor to be a full voting member of the Health Board and that the Health Board was the "local governing body" referenced in the new laws. The Court also held that the new laws did not moot the issues at stake in the case. View "City of Great Falls v. Cascade County Commissioners" on Justia Law

The case involves a dispute between Missoula County and the Montana Department of Corrections (DOC) over the reimbursement rate for housing DOC inmates in county detention centers. The County and the DOC had entered into a contract in 2015, setting a reimbursement rate of $88.73 per day for each inmate. However, in 2015, the Montana Legislature capped the reimbursement rate at $69 per day. The County filed a lawsuit in 2020, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and unjust enrichment.The District Court granted summary judgment to the DOC, concluding that the County's contract claims were time-barred by a one-year statute of limitations. It also found that the County's tort claim for breach of the covenant of good faith was not supported by a special relationship and that the County could not recover under a theory of unjust enrichment.The Supreme Court of Montana affirmed the District Court's decision. It held that the one-year statute of limitations applied to the County's contract claims, rejecting the County's argument that an eight-year limitation period should apply. The court also agreed with the lower court that the County's tort claim for breach of the covenant of good faith was not supported by a special relationship. Finally, the court concluded that the County could not recover under a theory of unjust enrichment, as the County had not demonstrated that the DOC had reaped an inequitable gain. View "Missoula County v. Department of Corrections" on Justia Law

In a dispute arising from a failed subdivision in Missoula County, Montana, a group of property purchasers, led by Gilbert and Judith Johnston, claimed that Flying S Title and Escrow, Inc., breached a purported contract to provide title insurance for the properties they bought. The properties were originally platted as lots, but the purchasers believed that they would eventually be reconfigured into larger parcels. However, the necessary infrastructure was not installed and the amended plat was never recorded, so the parcels never came into existence. The purchasers claimed that pro forma documents provided by Flying S constituted a contract to insure the parcels. The Supreme Court of Montana disagreed, ruling that the pro forma documents did not constitute a contract, but were merely an offer to issue a title insurance policy for the parcels, subject to the terms stated in the documents. The court noted that a contract for title insurance could not exist under the pro forma documents because the parcels, and the title thereto, never existed. Furthermore, the court found that Flying S had not been unjustly enriched by the purchasers' premium payments because it had provided, as agreed, title insurance for the transaction completed by the purchasers to buy the lots. Therefore, the court affirmed the lower court's decision in favor of Flying S Title and Escrow, Inc. View "Johnston v. Flying S Title & Escrow, Inc." on Justia Law

In this case, the Supreme Court of the State of Montana addressed a dispute over a settlement agreement regarding the sale of a house and the subsequent release of construction-related claims. Daniel Perl and Sandra Perl (collectively, "the Perls"), who are the plaintiffs and appellants, entered into discussions with Christopher Grant and other related parties (collectively, "the Grants"), who are the defendants and appellees. The Perls had purchased a home from the Grants and later became dissatisfied with the construction quality. After negotiations, the parties, through text messages, appeared to reach an agreement wherein the Grants would buy back the property for $2.8 million, and the Perls would release all claims related to the house's construction. However, the Perls later objected to several terms in the formal documents prepared by the Grants' attorney and disputed the existence of an enforceable settlement agreement.The lower court, the Eleventh Judicial District Court, Flathead County, granted the Grants' motion for summary judgment and denied the Perls' cross-motion for partial summary judgment. The lower court held that there was indeed an enforceable settlement agreement.The Supreme Court of the State of Montana affirmed the lower court's decision. The Supreme Court found that the parties' text messages satisfied the statute of frauds and constituted an enforceable settlement agreement. The court pointed out that the text messages contained all the essential elements of a contract, including the parties, the subject matter, a reasonably certain description of the property, the purchase price, and mutual assent. The court also found that the Perls' objections to non-material terms in the formal documents did not invalidate the settlement agreement. Therefore, the Supreme Court affirmed the lower court's decision to grant the Grants' motion for summary judgment and deny the Perls' cross-motion for partial summary judgment. View "Perl v. Grant" on Justia Law

In this case, the Supreme Court of the State of Montana had to decide if the Thirteenth Judicial District Court erred by disallowing a stipulated agreement for entry of a consent judgment between American Express National Bank (Amex) and Jocelyn Born (Born), and subsequently dismissing the action with prejudice.Born had accumulated a debt of $20,754.69 on her American Express credit card that she failed to repay, despite Amex’s demands for repayment. The parties had entered into a stipulation and consent agreement where Born agreed to the entry of judgment for the amount of her debt, plus costs. After some payments by Born, the amount owed had reduced to $19,368.19. The District Court initially entered a consent judgment for the reduced amount but later the same day vacated the judgment and dismissed the litigation with prejudice.Amex appealed this decision arguing that the District Court misunderstood the nature of the stipulation and consent agreement and treated it as a "cognovit judgment" - a judgment entered in advance of legal action in case of default, rather than a "judgment on consent" - an agreed judgment entered after action is commenced.The Supreme Court of the State of Montana agreed with Amex's argument, finding that the stipulation was a valid consent judgment and constituted a contract between the parties. The court held that the District Court erred in vacating the judgment and abused its discretion by denying Amex's motion for relief. The court reversed the order of dismissal and remanded the matter for entry of a consent judgment as contemplated by the parties' stipulation. View "American Express v. Born" on Justia Law

In the State of Montana v. Sky M. Little Coyote, the Supreme Court of Montana dealt with an appeal by Little Coyote, who had been incarcerated and was appealing the revocation of his suspended sentence. Little Coyote argued that his time served had been incorrectly calculated and that, when correctly accounted for, his sentence had already expired before the State filed its revocation petition. The State argued that Little Coyote was bound by an agreement he had entered into regarding the time served.The Supreme Court reversed the lower court's decision and remanded the case for dismissal of the State's Petition for Revocation. The court found that Little Coyote's time served had indeed been inaccurately calculated. It ruled that the parties involved had been operating under a mutual mistake regarding the time Little Coyote had served. The court held that, when correctly calculated and credited, Little Coyote's sentence had expired nearly three months before the State filed its revocation petition. Thus, the disposition imposed on Little Coyote was deemed illegal as the lower court had lacked the authority to revoke or impose a disposition after the expiration of his sentence. View "State v. Little Coyote" on Justia Law

In the case before the Supreme Court of the State of Montana, the plaintiff, Kevin Barber, appealed against his former employer, Bradford Aquatic Group, LLC, alleging wrongful termination. Bradford Aquatic Group, a North Carolina-based company, had employed Barber as a Regional Business Development Manager for its Rocky Mountain region, which includes Montana. The employment contract between Barber and the company included a choice-of-law and forum selection clause, specifying that any disputes arising from the agreement would be governed by North Carolina law and adjudicated in North Carolina courts.Barber, a resident of Montana, argued that Montana law should apply to his claims of wrongful discharge, breach of contract, and bad faith, and that the suit should be heard in Montana. The district court dismissed Barber's claims due to improper venue, based on the choice-of-law and forum selection clauses in the employment agreement.Upon review, the Supreme Court of the State of Montana affirmed the district court's decision. The court found that the choice-of-law provision in the employment agreement was valid and that North Carolina law should apply to Barber's claims. The court also upheld the validity of the forum selection clause, concluding that it is enforceable under North Carolina law. Therefore, the court determined that the dispute should be adjudicated in North Carolina, not Montana. View "Barber v. Bradford Aquatic" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgments of the district court enforcing the parties' mediated memorandum of understanding (MOU) regarding a subdivision dispute and then implementing it in the form of a more formal final settlement agreement proposed by Developers for approval by the Town of Fort Peck, Montana, holding that the district court erroneously granted Developers judgment as a matter of law.The district court ultimately concluded that the mediated MOU was an independently valid and enforceable contract in accordance with its written terms and as approved by the Town Council at its closed meeting, thus granting Developers' motion to enforce and implement the mediated MOU. The Supreme Court reversed in part, holding that the district court erred in granting Developers judgment as a matter of law that the Town Council took action to approve the parties' mediated MOU at its closed meeting and that a genuine issue of material fact remained as to whether a majority a quorum of the Town Council satisfied the agreed condition precedent to contract formation and enforceability of the MOU. View "Hanson v. Town of Fort Peck" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgments of the district court adjudicating a parental interest and accompanying parenting plan regarding Father's minor child in favor of his non-parent ex-wife (Surrogate), holding that the district court erroneously made a child custody parenting plan determination involving a non-parent without the predicate parental interest implied as a condition precedent to imposition of a best interests-based parenting plan.Specifically, the Supreme Court held that the district court (1) correctly concluded that the preclusive terms of a gestational carrier agreement did not preclude Surrogate from later acquiring or establishing a parental interest and right to the extent independently authorized under Montana law; (2) did not err in finding and concluding that Father voluntarily signed the premarital agreement and that it ws thus a validly formed and enforceable contract; (3) did not erroneously reject Father’s assertion that the parent-child relationship provision was unenforceable as equitably unconscionable; and (4) erroneously adjudicated a non parent "parental interest" in favor of Surrogate without the required predicated finding of fact specified by Mont. Code Ann. 40-4-228(2)(a). View "Sayler v. Yan Sun" on Justia Law